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Victorian Desalination Project

TDJV D&C EMP

Attachment I

Commissioning Environmental Sub-plan (CESP)

DOCUMENT NUMBER

TDV 0 EV SB 0021.I 03


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Table of Contents

Definitions and Acronyms ............................................................................................... 6

1 Purpose and application .......................................................................................................... 9

1.1 Purpose ........................................................................................................................... 9

1.2 Application ..................................................................................................................... 10

1.2.1 Commissioning Stages ......................................................................................... 10

1.3 References..................................................................................................................... 11

2 Project Overview .................................................................................................................... 12

2.1 VDP Project Scope......................................................................................................... 12

2.1.1 Area 1 - Marine Intake and Outlet Structures ........................................................ 14

2.1.2 Area 2, 3 and 4 - Desalination Plant and Facilities ................................................ 14

2.2 Environmental Objectives and Targets ........................................................................... 15

3 Commissioning Overview ...................................................................................................... 15

3.1 Commissioning Scope .................................................................................................... 15

3.2 Commissioning Components .......................................................................................... 16

3.3 Legal Obligations ........................................................................................................... 17

3.4 Environmental Context and Significant Environmental Aspects ....................................... 18

4 Commissioning Delivery Approach ...................................................................................... 23

4.1 Project Delivery Mode and Contractual Requirements .................................................... 23

Project Phases ............................................................................................................... 23

4.3 Commissioning Phasing and Handover to O&M Phase ................................................... 24

4.4 Project Management Documentation .............................................................................. 26

4.5 Commissioning Documentation ...................................................................................... 26

4.6 Operational Management Control ................................................................................... 27

4.6.1 Commissioning Work Area Packs ......................................................................... 27

4.6.2 Commissioning Work Packs ................................................................................. 28

4.6.3 Work Method Statements & Procedures ............................................................... 29

4.6.4 Job Safety Environmental Analysis ....................................................................... 29

4.6.5 Inspection Test Plans (ITPs) ................................................................................. 30

5 Commissioning Organisational Structure and Resourcing ................................................. 30

5.1 Leadership and Individual Responsibility ........................................................................ 30

5.2 Commissioning Organisational Structure ........................................................................ 31

5.3 TDJV Roles and Responsibilities .................................................................................... 32

5.4 AquaSure Roles and Responsibilities ............................................................................. 34

5.5 Independent Reviewer and Environmental Auditor .......................................................... 34

6 Commissioning Environmental Management Documentation ............................................. 35

6.1 Overview ........................................................................................................................ 35

6.2 Documentation ............................................................................................................... 36

6.2.1 Attachment I.1 – Risk Register.............................................................................. 36


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6.2.2 Attachment I.2 – Commissioning Management Strategies ..................................... 37

6.2.3 Attachment I.3 – Monitoring, Inspection, Reporting and Auditing Schedule............ 37

6.2.4 Attachment I.4 – Commissioning Monitoring Program, interfacing with the

Baseline Marine Monitoring Program (BMMP) ...................................................... 37

6.2.5 Attachment I.5 – Monthly Environmental Checklist ................................................ 37

6.3 Authorisation and Distribution ......................................................................................... 37

6.4 Control of Environmental Documents.............................................................................. 38

6.5 Reference Documents .................................................................................................... 39

6.6 Master Documents ......................................................................................................... 39

7 Competency Training and Awareness .................................................................................. 40

7.1 Project Personnel ........................................................................................................... 40

7.2 Subcontractors and Consultants ..................................................................................... 40

7.3 Training .......................................................................................................................... 40

7.4 Maintaining Qualifications/Skills and Records ................................................................. 40

7.5 Commissioning Induction................................................................................................ 41

7.5.1 Project Induction ................................................................................................... 41

7.5.2 Commissioning Work Package Induction .............................................................. 41

7.5.3 Visitor Induction .................................................................................................... 41

8 Communications .................................................................................................................... 42

8.1 AquaSure Communications ............................................................................................ 42

8.2 Internal Communications ................................................................................................ 42

8.3 Enquiries and Complaints Management.......................................................................... 42

9 Incident and Emergency Preparedness and Response ....................................................... 43

10 Checking ................................................................................................................................ 44

10.1 Monitoring and Measurement ......................................................................................... 44

10.1.1 Environmental Monitoring ..................................................................................... 44

10.1.2 Environmental Inspections .................................................................................... 45

10.2 Evaluation of Compliance ............................................................................................... 45

10.3 Non-conformity, Corrective and Preventative Actions ...................................................... 45

10.4 Control of Records ......................................................................................................... 46

10.5 Audits ............................................................................................................................ 47

10.5.1 AquaSure ............................................................................................................. 47

10.5.2 TDJV .................................................................................................................... 47

10.5.3 External ................................................................................................................ 47

11 Review, Reporting and Improvement .................................................................................... 48

11.1 Reporting Environmental Performance ........................................................................... 48

11.2 Management Review ...................................................................................................... 48

Attachment I.1: Environmental Risk Register .......................................................................... 49

Attachment I.2: Commissioning Management Strategies: ...................................................... 50


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Attachment I.3: Monitoring, Inspection, Reporting and Auditing Schedule ........................... 51

Attachment I.4: Commissioning Monitoring Program, interfacing with the Baseline

Marine Monitoring Program (BMMP) and Operational Marine Monitoring Program

(OMMP) ......................................................................................................................... 52

Attachment I.5: Monthly Environmental Checklist .................................................................. 53


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Definitions and Acronyms

AEMP Area Environmental Management Plan

AQS AquaSure

AquaSure The proponent for the Victorian Desalination Project, TDJV’s client

Area 1 Marine intake and outlet structures

Area 2 Desalination plant and facilities

Area 3 / 4 Utilities comprising:

• Transfer pipeline from the desalination plant to Melbourne’s water supply system at Pakenham

• Power supply comprising high voltage alternating current (HVAC) underground cable network transmission and power supply from the desalination plant to Cranbourne.

BMMP Baseline Marine Monitoring Program

CCAP TDJV Commissioning and Commercial Acceptance Plan

CER Commissioning Environmental Representative

CESP Commissioning Environmental Sub-plan

CIP AquaSure Community Involvement Plan

Client Capital Projects Division of Department of Sustainability and Environment, AquaSure’s client

Close-out When the balance of D&C activities, remaining after Commercial Acceptance, have been completed in accordance with the Project Deed

Close-out works While construction will be largely complete, some construction items will require to be completed after the plant has started delivering desalinated water. These items are the close-out works

Commercial acceptance

The stage when most of the D&C activities are complete and the desalinated water supply system is able to be safely operated

Commissioning Commissioning is the program of activities to test and run-in the plant so that it can become fully operational

CMS Commissioning Management Strategy

CWAP Commisioning Work Area Pack - used to collate the CWPs into individual commissioning systems.

CWP Commissioning Work Pack – a discrete element of work used in the detailed planning, execution, verification and generation of Project records.

Contractor The AquaSure appointed D&C Contractor (Thiess Degrémont Joint Venture) and the O&M Contractor (Degrémont Thiess Services Joint Venture)

D&C Design and Construction

D&C Contractor Thiess Degrémont Joint Venture

D&C Management Team

Project Director, Area Project Directors, Commercial Director, Design Director, Stakeholder and Completions Director, D&C Environmental Manager, Planning and Program Director, Human Resource Director, Construction Managers and their teams


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DC-CIP Design and Construct Community Involvement Plan

DCP Design and Construction Plan

Defects liability period

This is the period after the completion of the works during which the D&C Contractor is responsible for any defects. The period is specified in clause 24.6 of the Deed and is generally 24 months.

DPCD Department of Planning and Community Development

DSE Department of Sustainability and Environment

DSEWPC Department of Sustainability, Environment, Water, Population and Communities

DTS Distributed temperature sensing

DTSJV The AquaSure appointed O&M Contractor, Degrémont Thiess Services Joint Venture

DMPF Dual Media Pressure Filter

DWSS Desalinated Water Supply System, including the marine intake/outlet facilities, the desalination plant and water transfer pipeline.

EES Environment Effects Statement

Electricity Supplier AGL

EMP Environmental Management Plan. Refers to the D&C EMP and/or AEMP as relevant in the context of the document

EMR Environmental Management Representative

EMS Environmental Management System

EPA Environment Protection Authority

EPA Section 30A Commissioning Approval

Means by which the EPA may authorise emergency storage, use, discharge etc. of waste under the Environment Protection Act 1970. In the case of VDP this relates to permitting commissioning activities and associated discharges to the outlet (i.e. prior to establishment of a licenced mixing zone) – refer to Section 30A(1)(a) and 30A(1A)(c) of the EPA Act.

EPBC Environment Protection and Biodiversity Conservation

Gigalitres (GL) Billion litres

HVAC High Voltage Alternating Current

InCite A web-based document management system managed by Nexus Point Solutions adopted for use on the Project.

ISO 14001 AS/NZS ISO 14001:2004 Environmental Management systems – Requirements with guidance for use

JSEA Job Safety and Environmental Analysis

MIRA Schedule Monitoring, Inspection, Reporting and Audit Schedule

O&M Operations and Maintenance

O&M Contractor Degrémont Thiess Services Joint Venture

OMMP Operational Marine Monitoring Program

PPEF Project Planning and Execution Framework - provides the structure, including a checklist for preparing Commissioning Work Packs (CWPs).


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Potabilisation Close-Out – is broadly when the balance of D&C activities, remaining after Commercial Acceptance, have been completed in accordance with the Project Deed

PR Performance Requirement

Preliminary Commercial Acceptance (PCA)

When the Desalinated Water Supply System is able to be safely and legally operated to deliver at least 50 GL of desalinated water per year

Process Commissioning

Commissioning of the water treatment process machinery and systems. Automatic running and optimisation (fine tuning) of all related systems during operation with design fluids and chemicals.

Project Victorian Desalination Project

Project Deed (the Deed)

Contractual arrangement between the State and AquaSure Pty Ltd for the delivery of desalinated water from the Project to Victoria's water supply system

PS&PR Project Scope and Performance Requirements set out in Annexure 3 to the Project Deed

Reference document

Reference Documents includes the documents referred to in Appendix S2 (Reference Documents) to the PS&PR (Annexure 3 to the Project Deed)

Reliability Test Finalisation

(RT Finalisation) – is broadly when all reliability testing of the Desalinated Water Supply System is completed in accordance with the Project Deed.

Reverse Osmosis (RO)

Two stages of reverse osmosis, where seawater is pushed through ultra-fine membranes under high pressure. Fresh water will pass through, leaving sea water concentrate behind.

SCADA Supervisory control and data acquisition

Screen and Pump Station

An initial screening that removes fine particles including sand and sediment

SEP Site Environmental Plan

SEWPAC Department of Sustainability, Environment, Water, Population and Communities

*Formally DEWHA (Department of Environment, Water, Heritage and the Arts)

State The Minister for Water of the State of Victoria for and on behalf of the Crown in the Right of the State of Victoria

TDMS Thiess Degrémont Management System

TDJV The AquaSure appointed D&C Contractor, Thiess Degrémont Joint Venture.

VDP Victorian Desalination Project

WAB Work Activity Briefing

WMS Work Method Statement


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1 Purpose and application

1.1 Purpose

The purpose of this Commissioning Environmental Sub-plan (CESP) is to achieve compliance with the

environmental Performance Requirements (PRs) of the Victorian Desalination Project (the Project) and with

other applicable environmental legislation for the commissioning phase of the Project. The CESP defines

what is included within the commissioning phase of the Project and establishes the environmental

management controls to be implemented, including contingency measures.

This CESP describes Thiess Degrémont Joint Venture’s (TDJV) system for minimising and managing

environmental risks associated with Project commissioning activities. The CESP has been prepared in

accordance with AquaSure’s Environmental Management System (EMS) Manual, the TDJV Environmental

Management Plan (EMP) and with reference to AS/NZS ISO 14001:2004. The key purposes of the CESP

are to:

• comply with the contractual Project Deed including the Project Scope and Project Requirements

(PS&PR) for the identified commissioning activities

• implement the AquaSure, Thiess and Degrémont environmental policies

• deliver the prescribed environmental outcomes for relevant commissioning activities

• supplement the system for legislative and contractual compliance

• establish mitigation and management measures to achieve the environmental requirements of the

Project during the commissioning phase. This involves the risks the Project poses to the

environment specifically during the commissioning activities associated with the Project.

• Incorporate Project commissioning processes to minimise the potential impacts of the Project

commissioning activities to the environment and community

• effectively manage potential impacts to the environment and community during the commissioning

of the Project through Commissioning Work Packs (CWPs)

• develop, implement and monitor management measures

• establish the environmental commissioning management requirements for subsidiary

environmental management documentation.

This CESP identifies and addresses:

• the environmental risks associated with commissioning

• how the Project will meet the PRs as set out in

• the D&C EMP

• the requirements of Appendix S8 Commissioning Tests to Annexure 3 PS&PR of the

Project Deed for commissioning to comply with the Environmental Requirements.


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1.2 Application

This CESP is Attachment I of the TDJV D&C EMP (TDV-0-EV-PL-0010-05) and applies to TDJV, its

consultants and subcontractors in the commissioning of the Project. All personnel must comply with the

requirements of this CESP.

Commissioning is the program of activities to test and run-in the plant so that it can become fully

operational. For the purposes of the CESP this consists of all commissioning activities from the initial

intake of seawater through to RT Finalisation. It does not include any Cleaning and Construction

Verification activities, as these are addressed through the Design and Construction Area Environmental

Management Plan (D&C EMP), and the Plant and General Area (P&GA) and Utilities EMPs. The

commissioning of the underground high voltage power supply is not included within this CESP, as this is

addressed in the Utilities D&C EMP. The broader commissioning of the Project is described in more detail

in Section 1.2.1.

All commissioning activities will be supported by documentation and all data will be recorded for training

and documentation to transfer to the O&M Team. All required documentation related to commissioning can

be found in the relevant Commissioning Work Pack (CWP – described in more detail in Section 4.6.2).

This includes but is not limited to:

• Manufacturer and Supplier O&M manuals and QA/QC reports

• Discipline Inspection and Test Reports (ITR)

• Factory Acceptance Test (FAT) reports

• Drawings and Functional Descriptions

1.2.1 Commissioning Stages

The commissioning processes, including cleaning and construction verification activities, typically includes

the three following stages (applicable to all areas of the Project), generally in order:

1) Pre-Commissioning Dry:

• Design and construction inspections against specifications and drawings.

• Media and element loadings (if applicable)

• Testing and adjusting individual pieces of equipment and instrumentation and their

• interface with the SCADA System

2) Pre-Commissioning Wet:

• Pipes, tanks and vessels flushing.

• Manual start-up and testing of each component and individual sub-system with fluid.

3) Process Commissioning:

• Automatic running and optimisation (fine tuning) of all related systems during operation

• with design fluids and chemicals.


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NOTE: This CESP addresses all Process Commissioning activities which commence following the

initial intake of seawater and continue through to RT Finalisation. The Pre-Commissioning stages

(wet and dry) are addressed through the D&C EMP, the D&C P&GA EMP and the D&C Utilities EMP.

1.3 References

The following documents have informed the development of this CESP:

• Project Deed between AquaSure and the State

• D&C Contract between AquaSure and TDJV

• AquaSure EMS Manual

• TDJV D&C EMP

• TDJV Commissioning and Commercial Acceptance Plan

• Environmental management requirements of Thiess and Degrémont

• Department of Sustainability and Environment 2008. Victorian Desalination Project – Environment

Effects Statement (including EPA Works Approval Application)

• Mitchell K et al. 4 December 2008. Report of the Inquiry to the Minister for Planning - Victorian

• Minister for Planning. January 2009. Victorian Desalination Project – Assessment under

• Environment Effects Act 1978

• AS/NZS ISO 14001:2004. Environmental Management Systems – Requirements with guidance for

use.

• 30A Commissioning Approval Application.


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2 Project Overview

2.1 VDP Project Scope

The VDP will be capable of supplying up to 150 gigalitres (GL) of water a year - a third of Melbourne's

annual water needs - with capability to expand to 200 GL a year in the future. As part of the D&C scope,

TDJV is delivering the commissioning phase of the Project.

The processing plant of the Project is located near Wonthaggi in the Bass Coast region south east of

Melbourne. The Project involves the components shown in Table 2-1.

Table 2-1: Project components and delivery

Area Key Components

Area 1 - Marine intake and outlet structures (Excludes land-based construction activities associated with the tunnels and marine structures)

Marine intake and outlet structures (risers and precast structures)

Area 2 - Desalination plant and facilities (Includes land-based construction activities associated with the tunnels and marine structures. Includes the general shared land-based facilities for the plant and marine structures construction)

• Box cut for tunnel boring machines (TBMs)

• Lined intake and outlet tunnels

• Seawater intake pumps and screens

• Pre-treatment plant and buildings

• Reverse osmosis plant and buildings

• Treated water storage

• Electrical substation

• Ancillary buildings e.g. chemicals storage

• Landscaping and rehabilitation

Area 3/4 - Utilities comprising:

• Transfer pipeline from the desalination plant to Melbourne’s water supply system at Pakenham

• Power supply comprising high voltage alternating current (HVAC) underground cable network transmission and power supply from the desalination plant to Cranbourne

• Ancillary fibre-optic cable

• 84 km pipeline to link to Melbourne Water’s Cardinia-Percedale main in Berwick

• Booster pump station approximately 74.5km north of the desalination plant near the intersection of Pound Road and McCormacks Road

• 87 km HVAC underground cable to Cranbourne Terminal Station (same corridor as the transfer pipeline, except for the final 8km at the Cranbourne end)

• Intermediate stations at the Booster Pump Station and a mid-point site at or near the intersection of Rayner Hoff Drive and the Bass Highway

• Fibre-optic cable in separate trench along pipeline alignment


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Figure 1 shows the regional context of the components of the Project.

Figure 1 - Regional View of VDP


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2.1.1 Area 1 - Marine Intake and Outlet Structures

The desalination plant requires that structures are constructed in the ocean to deliver seawater to the plant

and return the concentrated saline brine stream to the ocean. Refer to Figure 2 for approximate location of

the intake and outlet structures. The activities managed by this area exclude land-based construction

activities associated with the tunnels and marine structures. It includes the land-based logistics to support

the marine construction activities.

2.1.2 Area 2, 3 and 4 - Desalination Plant and Facilities

The general location of the desalination plant in proximity to the Powlett River and foreshore is shown in

Figure 2. The desalination plant will draw saline water from Bass Strait and treat it to potable standards

using reverse osmosis (RO) technology. The plant has a 200 Gigalitres (GL) per year ultimate capacity to

meet the State’s water supply targets but the plant itself is only being constructed to 150 GL per year

capacity. Figure 2 shows the alignment of the utilities.

Figure 2 - General Location of Victorian Desalination Plant and Marine Structures


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2.2 Environmental Objectives and Targets

The overarching environmental objectives of the Project are to:

• comply with the environmental standards established for the Project through design and

appropriate risk management

• optimise energy efficiency through project design and offset any impact through the purchase of

renewable energy credits for 100% of the electricity used at the Desalination Plant and Transfer

Pipeline

• protect the beneficial uses of the coastal and marine environment.

The PRs specified in the Project Scope and Performance Requirements (PS&PRs) have been set as more

detailed Project objectives and targets for the Project, particularly Appendix S3 Environmental

Requirements to Annexure 3 of the PS&PRs.

3 Commissioning Overview

3.1 Commissioning Scope

• Commissioning is the program of activities to test and run-in the plant so that it can become

operational. For the purposes of the CESP this consists of all commissioning activities from the

initial intake of seawater through to RT Finalisation. This involves the sequential and cumulative

commissioning of the following elements of the Desalinated Water Supply System (DWSS), as

shown in Table 3-1. From Preliminary Commercial Acceptance (PCA), the Operations and

Maintenance (O&M) EMP will be the controlling document with appropriate parts of the D&C EMP

documentation (including the CESP) embedded within. A detailed table of the commissioning

process and sequencing is included in Appendix A of the Section 30A Commissioning Approval

Application (TDV-0-EV-PL-0500).

Table 3-1: Commissioning Components

Component Description Liquid Discharge Solid Waste

Marine Tunnels and Sea Water Lift Pump Station Commissioning

Intake and discharge of seawater through the Seawater Lift Pump

Sea water (possibly with neutralised chemicals if shock chlorination occurs at this stage). pH increase due to leaching from concrete.

None

Pre-Treatment Commissioning

Pre-treatment including filtration through the Screen and Pump Station, and Dual Media Pressure Filter

pH buffered, filtered sea water (including neutralised chemicals)

Organic screen rejects

Ferric sludge

Reverse Osmosis and Potabilisation Commissioning

The reverse osmosis desalination of water and the potabilisation of desalinated water and the use of the Plant Substation

pH buffered, filtered sea water (including neutralised chemicals)

Lime sludge


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Component Description Liquid Discharge Solid Waste

Desalinated Water Production Commissioning (Overall Systems Commissioning)

The production of desalinated water, and discharging of brine. This includes:

• using the treated water storages,

• transfer pump station

• transfer pipeline

Brine (including neutralised chemicals)

Lime sludge

Ferric Sludge

Organic screen rejects

For 150 GL/yr capacity, the process involves three parallel streams, each of 50GL capacity. One stream

will be progressively commissioned to produce desalinated water, with the commissioning of the remaining

streams occurring in parallel after successful completion of the commissioning of the first stream. The

commissioning of the underground high voltage power supply is not included within this CESP, as this is

addressed in the Utilities D&C EMP. Cleaning and Construction Verification activities are addressed

through the D&C Area EMPs, as part of the construction activities.

The requirements for the generation, handling and disposal of waste from commissioning are the subject of

a separate authorisation from the EPA. This is outlined in Section 3.3 below.

3.2 Commissioning Components

The CESP consists of all commissioning activities from the initial intake of seawater through to Overall

Systems Commissioning (see Figure 3). This involves the cumulative commissioning of the following

components:

• Marine Tunnels and Sea Water Lift Pump Station Commissioning

• Pre-Treatment Commissioning

• Reverse Osmosis and Potabilisation Commissioning

• Overall Systems Commissioning

The location of these components is shown in Figure 3. Stream 1 will be commissioned initially. Stream 2

and Stream 3 will be commissioned subsequent to Overall Systems Commissioning. Each of the four

commissioning components have their own Commissioning Management Strategy, included in Attachment

I.2 to this CESP and described in more detail in Section 6.2.2 below. During the commissioning of Stream

1, it is likely that the Commissioning Management Strategies will be operational sequentially and not

concurrently. During the commissioning of Stream 2 and Stream 3, several Commissioning Management

Strategies may be operational in parallel. Appendix I.2 provides detail on the triggering and close out of the

Commissioning Management Strategies.


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Figure 3 – Commissioning Components

3.3 Legal Obligations

The Environmental Legislation Register (Attachment E of the D&C EMP) identifies all Commonwealth and

State legislation relevant to the Project.

The Project Deed sets out that Project works require a number of approvals, licences and permits to allow

the works to be constructed, commissioned and put into operation.

Additional EPA commissioning approvals will be required specifically for the commissioning of the Project

and will be in the form of an EPA Section 30A Commissioning Approval under the Environment Protection

Act 1970 (hereon referred to as EPA Commissioning Approval).

EPA Commissioning Approvals will permit the EPA to authorize storage and discharge of waste to enable

the commissioning of the Project. Applications for EPA Commissioning Approvals must be made to the

EPA in writing and will be valid for a period of 120 days.

The D&C Environmental Manager is responsible for managing the commissioning approvals process and

ensuring all the required approvals from Statutory Authorities are obtained.

Project personnel, in particular the senior management team, are responsible for liaising with the

Stakeholder and Completions Director, Commissioning Director, Commissioning Environmental

Representative, Environmental Manager and Area Environmental Managers in timely planning of activities

that require approval prior to commencement. To ensure permits, licences and approvals are obtained

through the most streamlined route, TDJV will engage with the relevant regulatory agencies prior to and

throughout the relevant approvals process to gain an understanding of their requirements.

TDJV will submit new or revised licences, permits or approvals to the AquaSure EMR, who in turn will

forwarded these to the State. Issues relating to problems with compliance with statutory approvals will be

notified promptly to AquaSure, in addition to the reporting requirements in Section 10.1 of the D&C EMP.

Stream 1

Stream 2

Stream 3

Marine Tunnels and Sea Water Lift Pump Station

Pre-treatment

Reverse Osmosis and Potabalisation

Overall Systems

Stream 1

Stream 2

Stream 3


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3.4 Environmental Context and Significant Environmental Aspects

A detailed risk assessment of the four commissioning activities (i.e., Marine Tunnels and Sea Water Lift

Pump Station, Pre-treatment, Reverse Osmosis and Potabilisation and Overall Systems) has been applied

to this CESP. This is set out in Attachment I.1, along with risks associated with abnormal events or

emergencies. The Commissioning Management Strategies for each component (see CESP Attachment I.2)

describe the existing conditions, environmental risk and management controls for each environmental

aspect.

The commissioning risk assessment considers all relevant environmental aspects. Table 3-2 provides a

summary of the significant environmental aspects related to the commissioning of the Project and the

potential hazards and impacts.

Table 3-2: Significant environmental aspects

Overall

Activity

Significant Environmental Aspect Potential Hazards and Impacts

Marine Tunnels and Sea Water Lift Pump Station Commissioning

Start up and commissioning of Sea Water Lift Pump and bypass water to outlet.

• Leaks from pumps impacting to marine flora and fauna

• Increased turbidity due to material in the tunnels impacting marine flora and fauna

• Underwater noise from pumps causing discomfort to recreational users / marine fauna

Pre-Treatment Commissioning

Transport & unloading of pre-treatment and sludge chemicals. (Ferric Sulphate, Sulphuric Acid, Coagulant Aid, Sodium Bisulphide, Sodium Hypochlorite).

• Chemical spills resulting in localised contamination of soils or groundwater/surface water systems affecting surface water and groundwater systems downstream of the plant site

• Overdosing resulting in off-spec discharge and impact to marine flora and fauna

Use of pre-treatment and sludge chemicals. (Ferric Sulphate, Sulphuric Acid, Coagulant Aid, Sodium Bisulphide, Sodium Hypochlorite).

• Overdosing resulting in off-spec discharge and impact to marine flora and fauna.

Commissioning of the Sludge System.

• Wetter sludge produced and disposal of waste to the incorrect offsite facility.

• Generation of odour and impact on neighbourhood amenity.

Disposal of sludge waste. • Inappropriate offsite management/disposal resulting in Impact to land or water at location of disposal; pollution; neighbourhood amenity.

Commissioning of the DMPF system.

• Overdosing resulting off-spec discharge and impacts to marine flora and fauna.

• Failure of inline monitoring system resulting in off-spec discharge and impacts to marine flora and fauna.


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Overall

Activity


Potential injection of dilute sodium hypochlorite for biofilm control of SWLP, DMPF, Cartridge filter systems prior to feed to RO.

• Overdosing or poor neutralisation resulting in off-spec discharge and impact on marine flora and fauna.

Biofilm control of systems prior to feed to RO.

• Overdosing or poor neutralisation resulting in off-spec discharge and impact on marine flora and fauna.

Reserve Osmosis and Potabilisation Commissioning

Commissioning of RO Chemicals and potabilisation chemical systems, including sodium hypochlorite, sodium bisulphite, antiscalant, carbon dioxide, FSA, Lime.

• Spills or leaks of chemicals resulting in contamination of soils and/or groundwater/surface water and associated ecosystems

• Spills during truck loading/unloading resulting in contamination of soils and/or groundwater/surface water and associated ecosystems

• Overdosing resulting in off-spec discharge and impacts to marine flora and fauna

Flushing of RO piping from Cartridge Filter to RO 1st & 2nd Pass (Disposal of water to Outfall from RO Building Pipe Flushing).

• Construction debris remaining in tunnel causing discoluration and/or turbidty resulting in impacts to marine environment.

• Overflowing of pits in RO building resulting in contamination of surface water runoff.

Commissioning of 1st & 2nd pass RO system without retention of permeate.

• Overdosing of caustic soda to 2nd pass feed resulting in off-spec discharge and impacts to marine flora and fauna.

RO commissioning and Potabilisation

Process Commissioning, without retention of permeate.

• Potential discharge of potabilisation chemicals resulting in off-spec discharge and impacts to marine flora and fauna.

• Failure of inline monitoring system resulting in off-spec discharge and impacts to marine flora and fauna.

Overall Systems Commissioning

Reliability Test

Retention of permeate and discharge of brine.

• Brine discharge causing impact to marine flora and fauna

• Low flows resulting in poor dilution and impacts to marine flora and fauna

Commissioning of Stabilisation Pond.

• Discharge of insufficiently neutralised chemicals to the outlet resulting impacts to marine flora and fauna.

Commissioning of the VDP - multiple streams & retention of permeate.

• Brine discharge causing impact to marine flora and fauna

Pipeline Commissioning. • Discharge of chlorinated and/or turbid water resulting in impact to Cardinia Reservoir

• Leakages resulting in uncontrolled discharge and impact to surface water ecosystems


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Overall

Activity


RO membranes

Clean in Place (during operation, after approx 6-12 months from commissioning).

• Disposal of neutralised effluent from Cleaning in Place / flushing of membranes resulting in impact to marine flora and fauna.

Management and monitoring of the potential hazards and impacts listed in Table 3-2, together with those

associated with other environmental issues/receptors is done so through a combination of the existing D&C

Environmental Management Plan (and associated Area EMPs) and specific controls developed as part of

this CESP. This relationship is outlined below in Table 3-3, grouped by environmental issue/receptor.

Table 3-3: Management and Monitoring summary of environmental hazards and impacts

Existing EMPs CESP

Environmental

issue/receptor

M

G

M

T

M

O

N

I

T

Reference Documents M

G

M

T

M

O

N

I

T

Reference Documents

Archaeology � � Continue to be managed and monitored through the D&C PGA EMP and its associated Archaeological and Cultural Heritage Sub Plan (Attachment I1).

Hazardous materials � � Storage and handling of hazardous materials is managed and monitored through the D&C PGA EMP and its associated Hazardous Materials Sub Plan (Attachment I2).

� � Management and monitoring of hazardous materials is addressed in this CESP.

Newly created habitat (site rehabilitation)

� � Managed and monitored through the D&C Utilities and PGA EMPs.

Air quality � � Conformance with the State Environment Protection Policy (Air Quality) is managed and monitored through the D&C PGA EMP and its associated Air Quality Sub Plan (Attachment I4).

� � Monitoring and assessment managed and monitored through this CESP and associated Commissioning Procedure for Odour Assessment (COMM-52).

Flora and fauna � � Management and monitoring of terrestrial flora and fauna is addressed through the D&C PGA EMP and its associated Flora and Fauna Sub Plan (Attachment I5).

� � The impact on aquatic flora and fauna due to the discharge of off-specification water is managed and monitored through this CESP.

Resource efficiency � � Managed and monitored through the Resource Efficiency Sub Plans of the Area EMPs.

� � Management and monitoring of energy, water and wastes directly associated with commissioning is addressed through this CESP.

Soil management � � Managed and monitored through the D&C PGA EMP.


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Existing EMPs CESP

Environmental

issue/receptor

M

G

M

T

M

O

N

I

T

Reference Documents M

G

M

T

M

O

N

I

T

Reference Documents

Noise � � Conformance with construction-related noise requirements is managed and monitored through the D&C PGA EMP and its associated Noise and Vibration Sub Plan (Attachment I8).

� � Any additional noise management and monitoring requirements during commissioning are addressed through this CESP and associated Environmental Noise Assessment (COMM-51).

Water quality and erosion management

� � Freshwater quality and erosion management and monitoring is addressed through the D&C PGA EMP and its associated Water Quality and Erosion Management Sub Plan (Attachment I9).

� � Marine water quality and surface water quality related specifically to commissioning is managed and monitored through this CESP.

Waterways and wetlands

� � Managed and monitored through the D&C PGA EMP and its associated Waterways and Wetlands Sub Plan (Attachment I10).

� � The impact on waterways and wetlands due to the venting of water from the pipeline is managed and monitored through this CESP.

Acid sulfate soils � � Managed and monitored through the D&C PGA EMP and its associated Acid Sulphate Soils Sub Plan (Attachment I11).

Marine flora and fauna

� � Managed and monitored through the D&C Marine Area EMP, its associated Marine Flora and Fauna Sub Plan (Attachment I4) and the BMMP.

� � Managed and monitored through the Environmental Monitoring and Control procedure. Discharge will be monitored and responded to through this CESP, the BMMP and 30A Comissioning Approval.

Coastal processes and activities

� � Managed and monitored through the D&C Marine Area EMP, its associated Coastal Processes and Activities Sub Plan (Attachment I1) and the BMMP.

� � Managed and monitored through BMMP.

Marine pest and pathogen

� � Managed and monitored through the D&C Marine Area EMP, its associated Marine Pest and Pathogen Management Sub Plan (Attachment I6) and the BMMP.

� � Managed and monitored through the BMMP.

Underwater noise Sub-plan

� � Managed and monitored through the D&C Marine Area EMP, its associated Underwater Noise Sub Plan (Attachment I7)

� � Managed through the CESP and associated Environmental Noise Assessment (COMM-51).


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// TDV-0-EV-SB-0021.I-03

4 Commissioning Delivery Approach

4.1 Project Delivery Mode and Contractual Requirements

The State has contracted AquaSure to deliver the Project. As such, from 1 September 2009, the official

status of Project proponent has been transferred from the State to AquaSure. The environmental

requirements are set out in the Project Deed between AquaSure and the State. Clause 58.3 of the Project

Deed permits AquaSure to subcontract its obligations to the D&C Contractor.

AquaSure has contracted TDJV to design, construct and commission the Project as its D&C Contractor.

The relevant environmental requirements in the Project Deed have been transferred to TDJV via the D&C

Contract between AquaSure and TDJV, although it should be noted that AquaSure is still required to meet

all legislative requirements and has an obligation to ensure appropriate environmental management is

implemented.

TDJV has contractual responsibilities and obligations with a number of organisations to facilitate delivery of

the Project.

4.2 Project Phases

The D&C component of the Project has the following phases:

• Design and pre-construction

• Construction

• Commissioning

• Close-out

• Defects liability

Key features implemented during the Design and pre-construction, and Construction phases of the D&C

component include, but are not limited to:

• Bunding of chemical storage areas

• Construction testing and verification

• Pre-Commissioning cleaning, verification and calibration.

TDJV’s approach to environmental management during the Commissioning Phase is set out below:

• The Commissioning and Commercial Acceptance Plan has been developed which establishes a

high level framework for environmental management during commissioning activities.

• Environmental risks associated with commissioning equipment failure and design and construction

errors are identified and managed.

• Specific environmental risks associated with commissioning are identified and addressed.

• Changeover of environmental roles, responsibilities and accountabilities from the D&C Contractor

to the O&M Contractor is managed effectively.


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In addition to the D&C EMP and this CESP, the following TDJV management plans are relevant:

• Commissioning and Commercial Acceptance Plan

• Overall Commissioning Sub-Plan

4.3 Commissioning Phasing and Handover to O&M Phase

The phasing of the CESP in relation to the D&C and O&M phases of the Project is shown in Figure 4. The

O&M Phase commences at Preliminary Commercial Acceptance (PCA) and overlaps with the D&C Phase

until the D&C Phase concludes at RT Finalisation.

Following PCA, the O&M EMP will be the controlling document and any outstanding D&C EMP

requirements will be transferred to the O&M EMP including this CESP. The D&C Project Phase continues

after the O&M EMP has been initiated at PCA and will comprise relevant D&C Activities including

commissioning.


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// TDV-0-EV-SB-0021.I-03

Figure 4 - Project Phase Environmental Management

D&C Project Phase

Performance Test Reports Submission

and Approval

O & M Project Phase

Design and Construction

Commissioning Tests

Performance Tests

Reliability Test Reports Submission

and Approval

Production Test Reliability Test

D&C Environmental Management Plan Area Environmental Management Plans

Commercial Acceptance

Preliminary Commercial

Acceptance

Works

Completion

O&M Environmental Management Plan Area Environmental Management Plans

D&C Commissioning Environmental Subplan

Reliability Test Finalisation

Environmental Management System

O&M Commissioning Environmental Subplan


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// TDV-0-EV-SB-0021.I-03

TRAFFIC MANAGEMENT

MANAGEMENT PLAN STRUCTURE

D&C MANAGEMENT PLAN

RO PLANT IMPLEMENTATION

PLANS

TUNNEL IMPLEMENTATION

PLANS

MARINE IMPLEMENTATION

PLANS

POWER IMPLEMENTATION

PLANS

PIPELINE IMPLEMENTATION

PLANS

O&M • COMMUNITY

INVOLVEMENT PLAN

• WATER QUALITY RISK MANAGEMENT PLAN

• INCIDENT MANAGEMENT PLAN

• HANDOVER PLAN

• KPI PERFORMANCE MONITORING PLAN

• CRITICAL INFRASTRUCTURE

PROTECTION PLAN

AQUASURE PROJECT MANAGEMENT PLAN

PIPELINE & POWER CONSTRUCTION MANAGEMENT

PLAN

TDJV STEERING COMMITTEE

O&M MANAGEMENT PLAN

• IR STRATEGY • PEOPLE MANAGEMENT

PLAN

• OH&S MANAGEMENT PLAN

COMMERCIAL & FINANCE

ENGINEERING

APPROVALS

PEOPLE & SAFETY

• ENVIRONMENTAL MANAGEMENT PLAN

• COMMUNITY

INVOLVEMENT PLAN • CRISIS MANAGEMENT

PLAN

• COMMERCIAL & FINANCE MANAGEMENT PLAN

• RISK MANAGEMENT

PLAN • ICT MANAGEMENT PLAN

• DESIGN PLAN

AQUASURE

TD

PROJECT CONTROLS

• PROJECT CONTROLS PLAN

• PROJECT PLANNING &

SCHEDULING PLAN• DOCUMENT & RECORDS

MANAGEMENT PLAN

WONTHAGGI AREA CONSTRUCTION MANAGEMENT

PLAN

21 JUNE 2010

DTS

STRATEGY & SUPPORT

• QUALITY PLAN• PROCUREMENT

MANAGEMENT PLAN

• COMMISSIONING & COMMERCIAL ACCEPT.

MANAGEMENT PLAN• COMPLETION PLAN

PROTECTION PLAN

4.4 Project Management Documentation

The relationship between the D&C Project Management Plan, the D&C EMP and the other Project plans is

shown in Figure 5. This CESP is a Sub-plan to the D&C EMP.

Figure 5 - Project management plan structure

4.5 Commissioning Documentation

The Commissioning and Commercial Acceptance Plan (CCAP):

• Details all contractual requirements and obligations with respect to Commissioning and

Commercial Acceptance

• Provides the management plan structure within which all requirements and obligations will be

satisfied

• Assigns responsibility for each requirement and obligation.

The CCAP identifies environmental requirements including to:

• Update the D&C EMP for commissioning, including developing a Commissioning Environmental

Sub-plan;

• Obtain approvals to manage waste streams during commissioning

• ENVIRONMENTAL MANAGEMENT PLAN


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// TDV-0-EV-SB-0021.I-03

• develop an O&M EMP

• obtain approvals and licences to manage waste streams during the O&M Phase

Commissioning Envionmental Monitoring and control Procedure (CEMCP):

• Documents below the level of the EMP Sub Plans, such as Work Packs, Work Area Packs,

Temporary Work Packages and Environmental Procedures, are used to inform Sub Plans and

Environmental controls, and undergo the review process outlined in the D&C EMP.

• For Commissioning works environmental controls are incorporated into the CEMCP.

• The CEMCP is reviewed by the AquaSure EMR and Approved by the TDJV Environmental

Manager.

4.6 Operational Management Control

The operational management controls addressed in this section are:

• Commissioning Work Area Packs (CWAPs)

• Commissioning Work Packs (CWPs)

• Work Method Statements and Procedures

• Job Safety Environmental Analysis (JSEA)

• Inspection Test Plans (ITPs)

4.6.1 Commissioning Work Area Packs

Commissioning Work Area Packs (CWAPs) are used to collate the CWPs into individual commissioning

systems. The CWAPs provide a commissioning system area overview for each of the main system phases

of commissioning i.e. Seawater Lift Pump commissioning, DMPF Commissioning, RO Commissioning etc.

The CWAPs:

• Provide an area overview of subsystem for commissioning

• Provide an overall environment impact assessment and risk mitigation

• Provide the risk control measures and / or feed into respective commissioning procedures to

ensure risk is controlled

• Provide overall monitoring of environmental compliance

• Provide overall reporting of monitoring variables


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// TDV-0-EV-SB-0021.I-03

4.6.2 Commissioning Work Packs

The Project Planning and Execution Framework (PPEF) provides the structure, including a checklist for

preparing Commissioning Work Packs (CWPs). The CWPs create manageable scopes of work and

generate the Project records required for Commissioning and to assure AquaSure, the IR&EA and the

State that TDJV has met its obligations under the D&C Contract.

A CWP is comprised of a number of components, including:

• Work method statement & Procedures

• Job safety environmental analysis

The CWPs are used to collate the various work process documents which define the sequential method of

production or control and detail the criteria for management of risk (including environmental risks),

constructability and workmanship, equipment to be used, verification activities and related

authorities/responsibilities. The CWPs include consideration of the relevant environmental risks, including

links to the CESP, as well as additional controls in the Work Method Statements and Procedures as

required.

Typically a number of CWPs will be allocated to various Project engineers who will be expected, with their

manager’s guidance, to plan, organise, monitor and cost forecast the activities with an assigned supervisor,

both being co-located in the same office. Where the works are executed under a subcontract, the

subcontract will include requirements to create and maintain CWPs and hand over completed records.

A register of CWPs is maintained in accordance with the Documents and Records Management Plan.

CWPs that are relevant to this CESP are shown in Table 4-1 below.

Table 4-1: Commissioning Work Packs Relevant to CESP

CWP

Number CWP Title

CWP

Number

CWP Title

COMM 001 Seawater Lift Pump Station COMM 024 Antiscalant

COMM 002 Drum Screens COMM 025 Caustic Soda

COMM 003 DMPF feed pumps COMM 026 Carbon Dioxide

COMM 004 DMPF Stream 1 COMM 028 Centrifuges Feed Polymer

COMM 005 DMPF Stream 2 COMM 030 Fluorosilicic Acid

COMM 006 DMPF Stream 3 COMM 031 RO CIP Chemicals

COMM 010 Reverse Osmosis Stream 1 COMM 035 Sludge Treatment

COMM 011 Reverse Osmosis Stream 2 COMM 037 2nd Pass Permeate Service Water

COMM 012 Reverse Osmosis Stream 3 COMM 038 Potable Water

COMM 013 1st Pass Permeate Service Water COMM 039 Chemical Sumps

COMM 014 Lime Preparation & Dosing COMM 042 Transfer Pump Station

COMM 015 Membrane Testing Skids COMM 043 Transfer Pipeline - One Way Tank KP10.3


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CWP

Number CWP Title

CWP

Number

CWP Title

COMM 016 Treated Water Tanks COMM 044 Transfer Pipeline - One Way Tank KP29.1

COMM 017 Sodium Hypochlorite - Pre-Treatment

COMM 045 Transfer Pipeline - PRVs at CP1

COMM 018 Sodium Hypochlorite - Potabilisation

COMM 046 Transfer Pipeline - Delivery Points

COMM 019 Sulphuric Acid COMM 047 Booster Pump Station

COMM 020 Ferric Sulphate - Sludge Treatment

COMM 051 Noise Validation

COMM 021 Ferric Sulphate - Pre-Treatment COMM 052 Odour Validation

COMM 022 Coagulant Aid - Pre-Treatment COMM 053 Diffuser Validation

COMM 023 Sodium Bisulphite TDV-2-EV-PRD-0006

Environmental Monitoring Procedure

4.6.3 Work Method Statements & Procedures

A work method statement (WMS) is a high level, activity-specific risk assessment and step by step planning

tool contained within each CWP. A WMS details the steps involved in a particular commissioning activity

along with their respective risk control measures. The WMS will identify key environmental risks for

commissioning activities and ensure appropriate controls and mitigation measures – taken from the CESP -

are implemented to ensure that Project objectives, targets and obligations are achieved. Procedures are a

more detailed task specific work instruction that is contained within each CWP and used to control specific

activities. Environmental controls are incorporated into specific procedures as part of the CWP

development as outlined by the Project Planning and Execution Framework (PPEF).

Commissioning work method statements and procedures (where applicable) will be prepared for all

commissioning activities. They are prepared by the Site Engineer in conjunction with the Site Supervisor,

Foreman and environment team. WMS’s require Comissioning Completion Manager (or delegate) review

for extreme and high-risk (pre-control) Environmental aspects as per the Risk Register prior to works

commencing. It is the responsibility of the Environmental Manager (or delegate) to review proposed

mitigation measures to reduce the extreme and high risks to an acceptable level.

WMSs and procedures will reference relevant controls from the CESP or incorporate additional activity

specific controls.

4.6.4 Job Safety Environmental Analysis

A Job Safety Environmental Analysis (JSEA) is a medium level, activity-specific risk assessment and

planning tool which will be prepared by the Site Supervisor or Site Foreman with input from Engineers and

the environment team. JSEAs will identify the specific environmental management measures – taken from

the CESP, or developed and implemented for the specific commissioning activity being undertaken.

JSEAs require Environmental Manager (or delegate) approval for extreme and high-risk (pre-control)

aspects prior to commissioning works commencing. It is the responsibility of the Environmental Manager

(or delegate) to review proposed mitigation measures in order to reduce extreme and high risks to an

acceptable level.


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JSEAs will be developed in accordance with the requirements set out in the Occupational Health and

Safety Management Plan.

4.6.5 Inspection Test Plans (ITPs)

ITPs are an operational control which are specific for each Commissioning Work Pack. For further

information on ITPs refer to specific CWPs. ITPs detail all activities that will be conducted when performing

the commissioning activities for a System / Subsystem as described in the relevant commissioning

procedure. The ITP will demonstrate that the commissioinig activity is performed as per the Procedure. The

ITP is the document which highlights activities that would require either witness or hold points for internal or

external parties.

5 Commissioning Organisational Structure and Resourcing

5.1 Leadership and Individual Responsibility

Management at all levels and supervisory personnel will lead by example and set the highest standards for

environmental management.

Environmental responsibility, promotion of environmental awareness and the encouragement of ownership

are key approaches for environmental management implementation of this Project. These approaches will

bolster the prevention and, where required, the prompt correction of any nonconforming conditions or

behaviours leading to continual improvement at every opportunity.

The provision of competent and qualified environmental personnel throughout the duration of the Project

including during commissioning is critical to ensure that the PRs are achieved.

The TDJV Project Director has ultimate responsibility for ensuring that all the necessary activities are

undertaken to comply with regulatory and contractual requirements and mitigate identified environmental

risks through implementation of strategies and plans.

The Stakeholder and Completions Director is responsible to ensure the commissioning team

documentation, including environmental aspects, meets the requirements of the D&C contract.


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Environment Team

Area Environment Managers

Specialist Environmental

Consultants and Subcontractors

Plant Commissioning Manager

Commissioning Director

TDJV Environment Manager

Stakeholder and Completions Director

Project Director

Commissioning Environmental Representative

Commissioning Completion Manager

Commissioning Team

Area Lead Overall Systems

Commissioning Team

Area Lead RO and potabilisation

Commissioning Team

Area Lead Pre-treatment

Commissioning Team

Area Lead Seawater Lift Pump and

Marine Tunnels

5.2 Commissioning Organisational Structure

The Commissioning Organisation Structure is shown in Figure 6.

Figure 6 - Commissioning Orgnisation Structure


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5.3 TDJV Roles and Responsibilities

TDJV roles and responsibilities are given below in Table 5-1.

Table 5-1 Roles and Responsiblities

Title Role and Responsibility

Project Director • Establish, develop and lead the TDJV team to drive the performance of design, construction and commissioning to meet PRs, including environmental, and key stakeholder relationships.

Stakeholder and Completions Director

• Lead the environment team in the implementation of their environmental management plans and the Commissioning and Commercial Acceptance Plan.

• Develop and sustain relationships with key external stakeholders to facilitate efficiencies in the various review and approval processes.

Commissioning Director

• Lead the commissioning teams and drive the Project delivery performance to meet requirements.

• Ensure effective integration and collaboration with other teams.

• Ensure alignment and leadership of to optimise overall coordination and delivery outcomes on the Project.

Commissioning Manager

• Participate and lead development and implementation of work method statements, JSEA and related commissioning management tools to ensure environmental risks are correctly managed in accordance with best practices.

Commissioning Completion Manager

• Assist the Environmental Manager perform their duties, including identifying, administering and supporting the obtaining of environmental and planning approvals required for the Project in accordance with legislative requirements.

• Achieve and document commissioning completion for non process related activities in order to satisfy the requirements of the CCAP and the Commissioning Sub-Plan (including this Commissioning Environmental Sub-Plan).

• Liaise with the environment team to identify the detailed requirements for Commissioning Completion.

• Obtain all necessary third party approvals relevant to commissioning.

• Help develop the relevant documents required to communicate these requirements to the relevant teams on the Project.

• Manage all aspects of completions required for Commissioning that are not directly linked to process activities (3rd parties, construction handover of areas, environment).

• Manage all Environmental aspects linked to Commissioning as defined in the CESP.

• Implement the CESP.

• Assist CER and AEM with implementation of the EIRP where Commissioning Incidents are involved.

Commissioning Area Leads

• Lead and participate in commissioning team to successfully commission a section of the plant in accordance with the plans and programme, including develop commissioning documentation, plans, procedures, ITP, Work Method Statements.

• Participate and coordinate commissioning tasks.

• Document commissioning results and reporting on commissioning activities and progress.

Commissioning Environmental Representative

• Identify, administer and support obtaining commissioning environmental and planning approvals required for the Project in accordance with legislative requirements and assist the Commissioning Director to:

• Proactively and positively work with the regulators and authorities with regard to environmental standards compliance and impact targets.

• Work with Commissioning Team and Environmental Manager to obtain approvals consistent


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with Project delivery requirements.

• Coordinate the implementation of the CESP, including evaluation, reporting and auditing of compliance.

• Coordinate the transition (along with the Environmental Manager and O&M Environmental Manager) from the CESP to the O&M EMP.

• Create systems and manage all processes and resources to ensure best practice documentation.

• Assist the Area Environmental Managers to respond to environmental incidents and review the EIRPs, procedures and tools following incidents, near-hits and complaints.

Environmental Manager

• Identify, administer and support obtaining environmental and planning approvals required for the Project in accordance with legislative requirements and assist the Stakeholder and Completions Director to:

• Proactively and positively work with the regulators and authorities with regard to environmental standards compliance and impact targets.

• Work with design, construction and subcontractor teams to obtain approvals consistent with Project delivery requirements.

• Coordinate the implementation of the D&C EMP, including evaluation and reporting of compliance.

• Support the Stakeholder and Completions Director.

• Work with the Commissioning Completions Manager and Commissioning Environmental Representative to ensure the CESP is maintained and implemented.

• Monitor environmental compliance and coordinate with the Area Environmental Managers and Commissioning Environmental Representative.

Area Environmental Managers

• Assist in the implementation of the CESP along with the Environmental Manager and Commissioning Environmental Representative. When required, they will assist the Commissioning Director to:

• Assist the Commissioning Environmental Representative in managing the relationship between the Project, the regulators and authorities relating to environmental standards compliance and impact targets.

• Lead the provision of advice to the Commissioning Environmental Representative in areas of environmental risk management and delivery.

• Manage environmental incidents and review the EIRPs, procedures and tools following incidents, near-hits and complaints.

Environment Team

• Conduct surveillance of works, confirming systems are being implemented, and stop work immediately if observed likely damage to environment.

• Inform Project managers, engineers and site supervisors, the relevant TDJV Area Environmental Manager and the Comissioning Environmental Representative of corrective actions.

• Support the CER.

Commissioning Team

• Participate in development and implementation of work method statements, JSEA and related commissioning management tools to ensure environmental risks are correctly managed in accordance with best practices.

• Inform Commissioning Manager and Commissioning Environmental Representative of any departures from procedure.

Specialist Environmental Consultants and Subcontractors

• Marine biological monitoring.

• Water quality monitoring program - sampling and analysis.

• Air quality monitoring program.

• Noise and vibration monitoring.


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• Others as required during the course of commissioning.

All Staff, employees and contractors

• Comply with environmental procedures and risk mitigation measures.

• Conduct regular environmental inspections in accordance with job responsibilities.

• If a likelihood of damage occurring to the environment as a result of Project activities, notify their supervisor, and take appropriate corrective action including ceasing work activities, procedures or similar corrective actions.

• Ensure communication external to the Project regarding incidents occurs through the designated channels. Share learning and contribute to Project’s knowledge.

5.4 AquaSure Roles and Responsibilities

The AquaSure EMS Manual describes the roles and responsibilities of AquaSure staff including the

AquaSure Environmental Management Representative (EMR).

5.5 Independent Reviewer and Environmental Auditor

The Project Deed requires the engagement of the Independent Reviewer and Environmental Auditor

(IR&EA). The IR&EA is a joint appointment of the State and AquaSure under Clause 8 of the Project Deed.

The key function of the IR&EA with respect to environmental matters relevant to D&C was to verify that the

design documentation for each design package complied with the requirements of the State Project

Document. If the design package does comply, the IR&EA issues a certificate in the form set out in the

Certificate Schedule. The Environmental Management Framework (EMS and subordinate EMPs) are State

Project Documents and therefore the IR&EA is required to confirm that the EMS and EMP comply with the

requirements of the Project Deed including the environmental performance requirements. As part of the

audit and surveillance program, the IR&EA is also required to assess compliance of construction works

with the D&C EMP. During commissioning, the IR&EA will undertake audits on commissioning activities,

the EMS Manual, EMP documentation and the Environmental Requirements. The IR&EA will issue

Environmental Audit Reports to the State and AquaSure.


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6 Commissioning Environmental Management Documentation

6.1 Overview

The CESP relates to the D&C EMP as set out in below. Details on the attachments for this CESP and

where to find them are set out in Table 6-1 and Section 6.2.

Figure 7 - CESP Document Structure

Commissioning Environmental Monitoring and Control Procedure (TDV-2-EV-PRD-0006-00)

Environmental Noise Assessment (COMM 051). Commissioning Procedure for Odour Assessment (COMM 052). Tracer Testing (Difuser Validation) and Direct Toxicity Assessment (COMM 053). Commissioning Phase Sludge Sampling and Classification procedure (PR-TDV-EN-2-N-000-0001). Transfer Pipeline Hydrostatic Test and Commissioning Phase Environmental Discharge Procedure

(PLV-3-EN-PR-0003-00).

OMMP

D&C EMP

Plant & General Area

EMP

Marine EMP Utilities EMP

Attachments and Sub-

Plans


Plans


Plans

Attachment I.1 Risk Register

Attachment I.2 Commissioning

Management Strategies

Attachment I.3 Monitoring, Inspection, Reporting and Auditing

Attachment I.4 Commissioning Monitoring Program, interfacing with the

BMMP and OMMP

Attachment I.5 Monthly Environmental Checklist

Attachment I.2.2 Pre-Treatment Commissioning Management Strategy

Attachment I.2.1 Marine Tunnels and Sea Water Lift Pump Station Commissioning Management Strategy

Attachment I.2.3 Reverse Osmosis and Potabalisation Commissioning Management Strategy

Attachment I.2.4 Overall Systems Commissioning Management Strategy

O&M EMP

Attachments

Attachments

BMMP

D&C Commissioning

Environmental Sub-Plan

Attachment I.2.5 Commissioning Control Measures Table


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Table 6-1: Register for Environmental Commissioning

Item Where information can be found

Compliance Ready Reference D&C EMP Attachment A

List of technical reports and documents D&C EMP Attachment D

Environmental Legislation Register D&C EMP Attachment E

Environmental licences, permits and approvals register D&C EMP Attachment F

Environmental Obligations Register D&C EMP Attachment G

Environmental Training Matrix D&C EMP Attachment H

Enquiries and Complaints Process D&C EMP Attachment J

Commissioning Environmental Risk Register CESP Attachment I.1

Commissioning Components CESP Section 3.2 and Attachment I.2

Environmental Incident Response Plan D&C PGA EMP Attchment K; and D&C Utilities EMP Attachment K

Commissioning Monitoring, Inspection, Reporting and Auditing Schedule

CESP Attachment I.3

Commissioning Monitoring Program, interfacing with the Baseline Marine Monitoring Program (BMMP)

CESP Attachment I.4

Commissioning Monthly Environmental Checklist CESP Attachment I.5

6.2 Documentation

The content of each attachment of the CESP is as follows:

6.2.1 Attachment I.1 – Risk Register

The purpose of the commissioning environmental risk assessment is to identify the environmental risks

related to activities undertaken during the commissioning of the Project.

The risk analysis methodology specified in the AquaSure EMS has been used to conduct the

environmental risk assessment. The methodology applied is consistent with that described in the D&C Risk

Management Plan with the following variation. The environmental risk consequence level definitions on the

final page of the environmental risk analysis contain more detail than the D&C Risk Management Plan to

enable appropriate classification of environmental risks.

Risks are classified as ‘extreme’, ‘high’, ‘medium’ or ‘low’ in the Environmental Risk Register and require

documented controls. The Risk Register also captures residual risks. These will be implemented through

Commissioning Management Strategies (Attachment I.2) and Work Area Packages (Section 4.5.1).


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6.2.2 Attachment I.2 – Commissioning Management Strategies

For the purpose of this CESP, commissioning involves the sequential and cumulative commissioning of

several elements of the Desalinated Water Supply System, as set out in Figure 3 (Section 3.2

Commissioning Components). A Commissioning Management Strategy for each of these elements is

included within this Sub-plan. Each of these Commissioning Management Strategies is a procedural and

practical document that clearly sets out the strategy for the commissioning of each component, including

the environmental risks that are unique to the commissioning process and the measures to control these

risks. Contingency risks and associated contingency control measures are also addressed within CESP

Attachment I.2. The relevant contingency risks are similar to those outlined in the D&C PGA Risk Register,

however contingency risks that are unique to Design and Construction are not covered within this CESP

and will continue to be managed through the D&C EMP.

6.2.3 Attachment I.3 – Monitoring, Inspection, Reporting and Auditing Schedule

Environmental monitoring will be conducted in accordance with the Monitoring, Inspection, Reporting and

Audit Schedule (MIRA Schedule). More information on monitoring and reporting is included in Section 10.

6.2.4 Attachment I.4 – Commissioning Monitoring Program, interfacing with the Baseline

Marine Monitoring Program (BMMP)

The Commissioning Monitoring Program includes the following monitoring programs:

• Baseline Marine Monitoring Program (BMMP) - This program comprises two components:

• Coastal Processes Monitoring: impact monitoring commences at intake of seawater.

Intake of seawater commences with the Marine Tunnels and Sea Water Lift Pump Station

• Marine Ecosystems Monitoring: Impact monitoring commences with intake of seawater

(inshore components) and discharge of brine (offshore components). Brine is first

discharged during Overall Systems Commissioning.

• Section 8 of the Section 30A Commissioning Approval Application which includes In-Plant Water

Quality Monitoring and Diffuser Performance Monitoring.

• Section 9 of the Section 30A Commissioning Approval Application which includes the following

Tests and Assessments: Tracer Testing and Diffuser Validation, Direct Toxicity Assessment,

Waste Characterisation, Odour Assessment and a site wide Noise Assessment.

6.2.5 Attachment I.5 – Monthly Environmental Checklist

Inspection requirements are set out in the MIRA Schedule (Attachment I.3). Any actions required, or

measures determined not to be effective, will be identified on the Monthly Environmental Checklist, which

facilitates the auditing process.

6.3 Authorisation and Distribution

Without limiting TDJV’s obligation to notify any proposed revisions or amendments to the D&C EMP and

the Commissioning Sub-plan to AquaSure, the State and the IR&EA and TDJV overall responsibility for the

D&C EMP, revisions or amendments to this CESP are subject to the authorisation process set out in the

tables below.

Table 6-2: CESP authorisation


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Action Responsibility Initial

Issue

Major

Revision

Minor

Revision

Consultation with relevant government agencies

TDJV � � X

Consultation with AquaSure TDJV � � �

Approval Commissioning Director, TDJV � � �

Approval AquaSure EMR � � �

Consent The State � � �

Review and Assent Independent Reviewer and Environmental Auditor

� � �

Major revisions are required to be submitted to the Minister for Environment and Climate Change for

approval and to the State for consent. Major revisions to this CESP and its attachments will occur where

there is a significant change to environmental requirements, methodology and/or scope that change the

approach to the works.

Minor revisions are those that do not change the approach to the works or the environmental performance

standards in the CESP or attachments and may include changes which:

• Provide clarification or improvement to environmental management practices

• Add / modify activities and associated controls such that there is no increase in level of

environmental risks

• Add new obligations and associated controls e.g. for a new environmental permit.

All revisions to the CESP and/or attachments require State consent. Minor revisions will be undertaken as

per the following protocol:

Minor revisions protocol to CESP documentation

• Proposed minor changes will be tabulated by TDJV in a Changes Register and tabled at the

Environment Working Group (EWG) meeting for review and consideration. The EWG comprises

the State, IR&EA, TDJV and AquaSure.

• If the IR&EA consider the changes to be minor, the State will confirm this with DSE Biodiversity

and Ecosystem Services (DSE BES) and advise AquaSure of the DSE BES decision.

• If the changes are confirmed to be minor, TDJV are to amend the documentation in accordance

with the submitted Change Register and formally submit a complete revised version of the CESP

via AquaSure to the State (cc IR&EA).

• Upon State consent, new revisions will be uploaded to AquaSure’s web site and the Project’s

document management system (INCITE).

6.4 Control of Environmental Documents

The Commissioning Environmental Representative will ensure that environmental documents and records

nominated in the EMS Manual and specific to implementation of the CESP are maintained, archived and

controlled.


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CESP documentation will be controlled in accordance with the Documents and Records Management Plan.

The Commissioning Environmental Representative and Area Environmental Managers, together with the

document controllers, are responsible for ensuring that all controlled documents are:

• Developed, reviewed and approved prior to issue

• Issued for use

• Controlled

• Stored

• Removed from use when superseded or obsolete.

The minimum retention periods for all documents is as nominated in the AquaSure EMS Manual.

The Commissioning Environmental Representative is responsible for maintaining CESP documents as

current at the point of use.

6.5 Reference Documents

This CESP has been developed to comply with the Reference Documents. These are set out in Appendix

S2 to the PS&PR. More information on the Reference documents used in the preparation of this Sub-plan

is included in Section 6.2 of the D&C EMP.

6.6 Master Documents

The master of the CESP and associated attachments are stored as an electronic PDF file attached to the

record located within the Projects document management system (InCite) along with all related

management plans and associated documentation.

Where required, hard copies are to be derived from the signed electronic master and are deemed

‘uncontrolled’.

‘Masters’ that have been superseded are identified and located within the Controlled Documents File.

Documents are controlled in accordance with the Document and Records Management Plan.


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7 Competency Training and Awareness

7.1 Project Personnel

The People and Safety Director and Commissioning Director are to ensure that all commissioning

personnel are suitably qualified or experienced to undertake their work, using the requirements of the

Human Resources Management Plan. Commissioning personnel are selected on the basis of skills,

experience and cultural fit. Where a training need is identified, arrangements will be made for the

appropriate training and development in line with the individual’s needs.

Where necessary, assistance will be provided until the required competency level has been attained.

7.2 Subcontractors and Consultants

The competency of subcontractors and consultants to perform their environmental responsibilities will be

specified and assessed as part of the procurement process, in accordance with the Procurement

Management Plan.

Following appointment, where a subcontractor or consultant proves not competent to perform their

environmental responsibilities, the contract manager is responsible for taking remedial action which

includes:

• Communication and an agreed action plan with the subcontractor or consultant

• Training by TDJV of the relevant personnel

• Additional support to the subcontractor or consultant

• Taking remedies under the contract.

7.3 Training

Training for the Project commissioning is in accordance with the training procedures set out in Section 8.2

of the D & C EMP.

7.4 Maintaining Qualifications/Skills and Records

Records and means to maintain competencies, skills and qualifications will be in accordance with the

Human Resources Management Plan.

The following details must be included in environmental training records:

• Name of Project personnel attending the training

• Type of training attended

• Date of attendance

• Name of trainer

• Name of the organisation providing the training

• Refresher training requirements.

Copies of environmental training records will be maintained on the Project document management system.


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7.5 Commissioning Induction

7.5.1 Project Induction

All Project personnel, subcontractors, consultants and visitors will receive inductions into TDJV’s

environmental obligations prior to commencing on site. All environmental inductions will be conducted as

part of the Project induction. The Project induction courses will be reviewed on a six monthly basis or in the

event of a substantial change in environmental procedure, to ensure it reflects current working practice. All

Project and area environmental induction materials will be submitted to the AquaSure EMR for approval.

Records will be maintained of all inductions conducted, including:

• Names and signatures of personnel attending

• Date of attendance

• Name of trainer/facilitator.

7.5.2 Commissioning Work Package Induction

The environmental requirements of WMSs and JSEAs will be communicated to relevant Project and

subcontractor personnel via a pre-start meeting or work activity briefing (WAB), prior to that person

commencing work in accordance with the process procedure. Environmental matters are also

communicated through Desal Daily and toolbox talks.

7.5.3 Visitor Induction

All visitors going onto site must undergo a visitor’s induction. Consultants and subcontractors are

responsible for the actions and conduct of their visitors and must ensure that all visitors obey the site

environmental requirements.


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8 Communications

8.1 AquaSure Communications

TDJV will participate, as requested, in the following meetings facilitated by AquaSure:

• Fortnightly meeting with the AquaSure EMR

• Fortnightly Environmental Working Group meetings with the key stakeholders including the State

and AquaSure

In addition, TDJV will attend:

• Regular meetings of environmental agencies, convened by the State

• Regular meetings with key stakeholders including DSE and EPA.

8.2 Internal Communications

A program of internal communication networks, interfaces and regular meetings has been established

within the TDJV Project team as highlighted in the D&C Management Plan. The Stakeholder and

Completions Director, Environmental Manager, or delegate, will participate in communications and

interfaces where there are significant environmental issues during the commissioning process. The

AquaSure EMR, in accordance with the AquaSure EMS, will also participate where necessary.

Within the Project team, commissioning issues that may impact environmental considerations will be

conducted, as a minimum, by the following methods:

• InCite

• Weekly Project meetings

• Regular commissioning coordination meetings

• Regular environmental communications, such as, toolbox talks, pre-starts, daily commissioning

meetings, and work instructions.

The Environmental Manager will convene regular meetings of the environmental team during the

commissioning phase, including commissioning team members and the Area Environmental Managers.

The purpose of these meetings will be to:

• Review and set strategy for implementing CESP in an efficient and appropriate manner

• Provide a consistent approach to environmental management across the Project

• Facilitate two way feedback on issues and performance

• Coordinate between construction and commissioning activities.

8.3 Enquiries and Complaints Management

Enquiries and complaints will be handled in accordance with Attachment K of the D&C EMP.


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9 Incident and Emergency Preparedness and Response

Environmental incidents and emergency preparedness and response will be managed according to the

D&C PGA and D&C Utilities Environmental Incident Response Plans (EIRPs), based on the location where

the incident took place being either on the Plant site or along the Utilities corridor respectively. The EIRPs

integrate with the D&C Crisis Management Plan and as such covers environmental incidents only. The

EIRPs will be reviewed and, where applicable, updated. The D&C Crisis Management Plan and D&C PGA

and Utilities EIRPs provide a standard approach for the notification, recording, classification, investigation

and reporting of all work related incidents, including those involving sub-contractors, other persons working

on the TDJV site, ensuring safe and effective handling of incident situations. The EIRPs also provide

contact details and specific time frames for relevant authorities that may need to be notified in the event of

an environmental emergency.

The objectives of the D&C PGA and Utilities EIRPs are to:

• Define a procedure to manage environmental incident situations

• To ensure that the impact of an incident on the environment, TDJV, AquaSure and all stakeholders

is minimised

• To ensure that the continuity of operations is maintained through implementation of effective

environmental incident management procedures and response plans

• To ensure that appropriate internal reporting procedures are in place that include prompt

notification to AquaSure, the State, EPA, corporate management and other required agencies

• To ensure that communications protocols result in a coordinated public response, including any

public reporting obligations

• To ensure that results of all incidents are assessed, reported and corrective actions implemented.

As well as TDJV responsibilities, the EIRPs sets out the responsibilities of the AquaSure EMR to participate

in managing, responding to and investigating incidents.

The Commissioning and Completions Manager and Commissioning Environmental Representative

(supported by the Area Environmental Managers as required) have key roles to play in managing

commissioning environmental incidents and reviewing the EIRPs, procedures and tools following incidents,

near-hits and complaints.

The Commissioning Director through the Plant Commissioning Manager and the Area Environmental

Manager will be responsible for ensuring that the environmental emergency procedures are practised on a

regular basis during commissioning of the Project and is to provide the means for the Commissioning

Manager to ensure that the project team is trained and equipped to deal with a range of situations, to

include but not be limited to:

• Fuel spills (terrestrial and marine)

• Chemical spills (terrestrial and marine)

• Ground contamination

• Unplanned discharge of water to waterways/marine environment.


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10 Checking

10.1 Monitoring and Measurement

Environmental monitoring will be conducted in accordance with the MIRA Schedule (Attachment I.3). The

MIRA Schedule is a controlled document. Implementing the MIRA Schedule is the responsibility of the

persons nominated in the Schedule. As required in Appendix S3 of the PS&PR, the MIRA Schedule has

been developed in discussion with relevant government agencies.

Monitoring and measurement addresses:

• Baseline Marine Monitoring Program (BMMP)

• In-Plant Water Quality Monitoring

• Diffuser Performance Monitoring (refer to the Section 30A Commissioning Approval Application)

• Monitoring requirements to establish operational performance parameters including (refer to the

Section 30A Commissioning Approval Application):

• Tracer Test (Diffuser Validation)

• Direct Toxicity Assessment

• Waste Characterisation

• Air quality (odour)

• Noise

• Commissioning environmental compliance requirements.

A summary of the environmental components addressed within the MIRA schedule is shown in Table 3-3:

Management and Monitoring summary of environmental hazards and impacts.

10.1.1 Environmental Monitoring

The monitoring program is a centralised schedule of monitoring actions for the Project commissioning

based on obligations or controls nominated in Attachment I.3. Where required, specialist consultants will

be engaged to help establish internal monitoring systems and to train relevant personnel in the collection of

samples, use of scientific instrumentation and recording and analysis of data.

Monitoring will be conducted in accordance with relevant standards and guidelines for environmental

management identified in the EES, approvals and Reference Documents, such as Victorian Government

requirements, Australian Standards or, in the absence of an Australian Standard, industry acceptable

procedures. All analytical testing shall use National Association of Testing Authorities (NATA) approved

procedures where applicable.

Inspection, testing and calibration of monitoring equipment will be managed by TDJV in accordance with

the Quality Plan. Specialist monitoring consultants will be responsible for maintaining their monitoring

equipment in accordance with relevant standards. The minimum frequency and standard for monitoring is

that listed in applicable approvals, licences, and regulations. Monitoring results will be reviewed on a

regular basis (as soon as possible after results are received) depending on the data source to:


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• Evaluate performance relative to predicted impacts of the Project commissioning

• Evaluate performance and compliance with legal and other commitments

• Assess progress against targets for the EMPs.

Monitoring results exceeding the relevant standards/goals or performance criteria will be managed as per

the contingency protocol set out in the MIRA Schedule (Attachment I.3). Any monitoring results that exceed

the relevant performance criterion, as a result of the Project’s commissioning activities, will be managed in

accordance with the Procedure for Non-conformances as described in the Quality Plan. Corrective action

will be implemented, where needed, such as environmental Sub-plans or WMS modified, as appropriate

and as soon as possible after results are received.

AquaSure, the IR&EA and the State will be advised of any non-conformances from monitoring and the

results will be reported in the Monthly Environmental Report.

10.1.2 Environmental Inspections

Regular inspections will be conducted. Inspection requirements are set out in the MIRA Schedule attached

at Attachment I.3. Any actions required, or measures determined not to be effective, will be identified on the

inspection checklist and closed out on the Monthly Environmental Checklist (Attachment I.5).

10.2 Evaluation of Compliance

The Monthly Environmental Checklist included in Attachment I.5 will be used in order to monitor

compliance with commissioning environmental requirements.

10.3 Non-conformity, Corrective and Preventative Actions

A non-conformance is a failure to comply with environmental legislation or with the requirements of the

EMS Manual and/or EMP, which in turn contain Appendix S3 Environmental Requirements including the

PS&PRs. Non-conformances, will be managed in accordance with the Procedure for non-conformance as

described in the Quality Management Plan.

Non-conformances may be identified through a number of mechanisms including through IR&EA, EMR or

internal TDJV audits and complaints.

Once a non-conformance has been identified, corrective and/or preventive action will be initiated is

accordance with the MIRA schedule (CESP Attachment I.3). Also, any environmental management

improvement opportunities, identified as a result of incidents or emergencies, monitoring and

measurement, audit findings or other reviews, will be documented. These may also lead to corrective or

preventive actions. All employees have the authority to raise a non-conformance or preventative action

should they occur.

The tools and methods to be utilised for documenting, tracking, reporting and communicating non-

conformances are described in Table 10-1.

Table 10-1: Non-conformance Management Tool

Type of activities raising non-conformances Appropriate management tool

Inspection Inspection record

Incidents, procedural breaches, and high potential near hits

Incident report


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Type of activities raising non-conformances Appropriate management tool

Monitoring results Monitoring report

External and internal audits Audit report

Executive Management Team reviews Management review report

Environment Team reviews, EMP reviews Meeting minutes

Localised inspection observations (which are not incidents, procedural breaches, Near Hits)

Inspection Checklists tabled and reviewed at area-based HSE Progress meetings

Complaints (not found to be incidents) Complaints Register

Records may be kept in the Thiess HSE Reporting System Action Database. This database collects

environment, health and safety statistical and incident data for reporting and analysis purposes. The

database allows personnel to track actions through to close out.

All corrective actions from reviews, audits or incidents or new controls to be implemented shall be recorded

in the Project HSE Reporting System Action Database to ensure all actions have been assigned to the

responsible TDJV person(s) and actions have been tracked and closed out in the appropriate timeframe.

Implementation of corrective actions or controls shall adhere to the following timeframes as per the Thiess

HSE Reporting System Action Database:

• Extreme Priority Actions completed immediately

• High Priority Actions completed within 7 days

• Normal Priority Actions completed within 7 – 14 days

• Low Priority Actions completed within 14 – 21 days.

Priorities for response shall be determined based on the risk to the environment. As guidance, an extreme

priority action should be allocated to prevent immediate risk to the environment. Low priority actions should

be allocated to prevent long-term recurrence of the inappropriate situation.

The response to incidents will be managed in accordance with TDJV’s Crisis Management Plan and the

Commissioning Environmental Incident Response Plan.

The Commissioning Director, Commissioning Manager and Environmental Manager are accountable for

tracking closure of environmental non-conformances, inspection checklists, monitoring reports and incident

reports. Outstanding actions shall be reviewed weekly and reported monthly.

Where appropriate, work on non-conforming activities on-site may be stopped by the Stakeholder and

Completions Director, Environmental Manager, Commissiomning Environmental Representative, Area

Environmental Managers, Environment Officers, Project Directors or their nominees. This stoppage will

remain in force until corrective actions are implemented or authority is given to continue. Following a plant

shutdown event an Environmental Restart Permit, signed by the CER (or delegate), is required prior to the

recommencement of plant operation.

10.4 Control of Records

Records will be managed in accordance with the Documents and Records Management Plan as set out in

Section 8.4 of the D&C EMP.


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10.5 Audits

10.5.1 AquaSure

TDJV will facilitate audits by the AquaSure EMR.

The Commissioning Director, Commissioning Manager, Environmental Manager or Area Environmental

Managers will respond to audit reports of the CESP received from the AquaSure EMR within the time

specified by the EMR. TDJV will formulate a plan of action to follow-up the findings and recommendations

of the audit, including:

• Describing the planned corrective action/s for each finding

• Nominating a time frame to complete the corrective actions

• Nominating the responsible persons to carry out the corrective actions.:

• Implement remedial/corrective actions within the agreed timeframes

• Notify the EMR of close-out

• Provide evidence of completion where agreed.

The AquaSure EMR will review the close out of the audit findings.

10.5.2 TDJV

Internal environmental audits will be conducted in accordance with the MIRA Schedule (Attachment I.3)

and to the standards described in the ‘Environmental Audits’ procedure attached to the EMS Manual.

If the AquaSure EMR conducts an audit on an EMS component, that is also scheduled to be audited by

TDJV, the EMR’s audit may suffice as the TDJV audit, with the consent of the EMR. As a guide, the

AquaSure EMR and Environmental Manager will (separately or together) undertake the following types of

audits on a regular basis (minimum quarterly):

• D&C EMP - the scope of the audit will assess the level of implementation of the D&C EMP and the

CESP through document review and on-site assessment

• High Risk Activities- the scope of these audits will include an audit focussing on high risk

activities to ensure that environmental controls and procedures outlined in the D&C and AEMPs

are being implemented

Non-conformances will be recorded and managed as set out in Section 9.

10.5.3 External

The IR&EA or the State may audit any part of the Project or EMS Manual or other environmental

documentation with reasonable notice for the purposes of confirming compliance with Project

environmental PRs.

TDJV will facilitate audits by other parties, including the IR&EA and the State as set out in Section 9.5.3 of

the D&C EMP.


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11 Review, Reporting and Improvement

11.1 Reporting Environmental Performance

Reporting will be conducted in accordance with the MIRA Schedule included at Attachment I.3.

The Environmental Manager will provide a monthly report to the Stakeholder and Completions Director,

based on the template provided at Attachment I.5.

11.2 Management Review

The CESP must be reviewed and updated if at any time it:

• does not adequately address the matters it is intended to address

• is causing non-conformity or is otherwise necessary to comply with the Project Deed

• no longer represents current or appropriate practice

• is otherwise required by the Project Deed to be updated.

Management reviews will be conducted as set out in the D&C EMP Section 10.2.


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Attachment I.1: Environmental Risk Register


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Attachment I.2: Commissioning Management Strategies:

Attachment I.2.1: Seawater Lift Pump Commissioning

Attachment I.2.2: Pre-Treatment Commissioning

Attachment I.2.3: Reverse Osmosis and Potabilisation Commissioning

Attachment I.2.4: Overall Systems Commissioning

Attachment I.2.5: Control Measures Table


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Attachment I.3: Monitoring, Inspection, Reporting and Auditing

Schedule


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Attachment I.4: Commissioning Monitoring Program, interfacing

with the Baseline Marine Monitoring Program

(BMMP) and Operational Marine Monitoring

Program (OMMP)


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Attachment I.5: Monthly Environmental Checklist