Coniston/Novara Field Development Project (EPBC 2011/5995) Annual Compliance Report REVISION HISTORY

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2 REVISION HISTORY Revision Author / Editor Amendment A Jim Christianopoulos Draft version for internal review 0 Jim Christianopoulos Comments incorporated issued for review CO-00-RG of 31

3 CONTENTS 1. Introduction Overview Change in Titleholder Terms, Definitions and Abbreviations Declaration of Accuracy Approved Action Regulatory Context Description of Activities Project Overview Activities Undertaken during the Reporting Period Compliance Assessment Compliance Evaluation Environmental Audits and Inspections Environmental Audits Conducted by Regulators Environmental Audits Conducted by Independent Auditor Compliance Designations Compliance Summary Non Compliance CO-00-RG of 31

4 1. INTRODUCTION 1.1 Overview This report addresses compliance with each of the conditions of the Coniston/Novara Field Development Project, Western Australia approval EPBC 2011/5995. Specifically, this report has been prepared to meet the requirements of 3 of EPBC 2011/5995: Within three months of every 12 month anniversary of the commencement of the action, the person taking the action must publish a report on their website addressing compliance with each of the conditions of this approval, including implementation of any management plans as specified in the conditions. Documentary evidence providing proof of the date of publication and non-compliance with any of the conditions of this approval must be provided to the department at the same time as the compliance report is published. The approved action commenced on 3 February 2013 (Novara) & 14 February 2013 (Coniston). This is the third annual compliance report for EPBC 2011/5995, and covers the period 3 February 2015 to 3 February 2016 (referred to herein as the reporting period ). The report has been prepared in accordance with the Department of the Environment Annual Compliance Report Guidelines, 2014 (referred to herein as the Guidelines). 1.2 Change in Titleholder On 5 June 2015, a consortium comprising Brookfield Asset Management and Macquarie Capital acquired Apache Energy s Western Australian oil and gas assets by purchasing Apache Energy s corporate group. With effect from 23 June 2015, the name of the entity formerly known as Apache Energy Limited ABN changed to Quadrant Energy Limited (Quadrant Energy). The ABN remained the same. Other entities in the former Apache Energy group have also been renamed, retaining the ABN, for example Apache PVG Pty Ltd is now Quadrant PVG Pty Ltd. Quadrant and its affiliates will assume responsibility for all commitments and obligations pursuant to the Coniston/Novara Field Development Project, Western Australia approval EPBC 2011/ Terms, Definitions and Abbreviations The terms, definitions and abbreviations used in this report are listed below. Table 1-1 Terms, Definitions and Abbreviations Abbreviation Description Cth DC Department DER DoE DoF EPBC Commonwealth Drill Centre Department of the Environment Daily Environment Reports Department of the Environment Western Australian Department of Fisheries Environment Protection and Biodiversity Conservation CO-00-RG of 31

5 Abbreviation Description EPBC Act Environment Protection and Biodiversity Conservation Act 1999 EP DSEWPaC FPSO Guidelines HSE ICT IMT IMS MODU NEBA NOPSEMA NV NV EP PER PLEM OPGGS(E) Regulations OSCP OSMP OSV OSRC OSR SMPEP SOPEP Environmental Plan Department of Sustainability, Environment, Water, Population and Communities (now the Department of the Environment) Floating Production Storage Offtake Vessel Environment Annual Compliance Report Guidelines, Department of the Environment, 2014 Health, Safety and Environment Incident Command Team Incident Management Team Introduced Marine Species Mobile Offshore Drilling Unit Net Environmental Benefits Analysis National Offshore Petroleum Safety and Environmental Management Authority Ningaloo Vision NOPSEMA Approved Environmental Plan - Ningaloo Vision Operations Environmental Plan WA-35-L Van Gogh/Coniston/Novara Fields TV-00-RI Public Environmental Report Pipe Line End Manifold Commonwealth Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009 Oil Spill Contingency Plan Operational and Scientific Monitoring Program Offshore Support Vessel Oil Spill Response Capability Oil Spill Response Shipboard Marine Pollution Prevention Emergency Plan Shipboard Oil Pollution Emergency Plans CO-00-RG of 31

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7 3. APPROVED ACTION 3.1 Regulatory Context Apache Energy limited (Apache) submitted a referral under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) to the then Commonwealth Department of Sustainability, Environment, Water, Population and Communities (DSEWPaC) on 13 June 2011 to develop the Coniston/Novara fields within the Exmouth sub-basin of the North West Shelf (EPBC 2011/5995). The proposal was determined by DSEWPaC to be a controlled action on 15 July 2011, which was to be assessed on the basis of preliminary documentation and further information provided by Apache. The proposed action was approved on 15 October 2012 under sections 130(1) and 133 of the EPBC Act, subject to conditions attached to the approval EPBC 2011/5995. The approval has effect until 1 January EPBC number 2011/5995 project name Approval holder Table 3-1 Details of Approved Action under EPBC 2011/5995 ABN Approved Action Date of commencement of the Project Reporting Period for this Annual Compliance Report Coniston/Novara Field Development Project, Western Australia Quadrant Energy Limited (Formerly Apache Energy Ltd.) To develop seven subsea production wells and related infrastructure in the Exmouth Sub-basin on the North West Shelf in water depths of approximately 400 metres, approximately 28 kilometres north of the Ningaloo Coast, with a production life of approximately 20 years; as described in the referral received by the department on 16 June 2011 [See EPBC Act referral 2011/5995]. 3 February 2013 (Novara) 14 February 2013 (Coniston) 3 February 2015 to 3 February 2016 The environmental performance of the Coniston/Novara Field Development Project is also regulated by the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) in accordance with the Commonwealth Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009 (OPGGS (E) Regulations). In addition, the Coniston/Novara fields will tie-back to subsea infrastructure already in place for the Quadrant Energy-operated Van Gogh field development (and Ningaloo Vision Floating Production and Storage Operations (FPSO)), which also is subject to EPBC 2007/3213 for the Van Gogh Oil Field Operation and regulated by NOPSEMA under the OPGGS(E) Regulations. This annual report is concerned with compliance with EPBC 2011/5995 only. CO-00-RG of 31

8 3.2 Description of Activities Project Overview The project is located in the Exmouth Basin offshore North West Australia (Figure 3-1). The Coniston and Novara fields are located approximately 8 km north of the Ningaloo Vision FPSO (Figure 3-2). The Coniston/Novara Field Development Project is a new subsea oil field development located in the Exmouth Basin offshore North West Australia. The Project involves development of the Coniston and Novara oilfields via a tie-back to subsea infrastructure already in place for the Quadrant Energy-operated Van Gogh field development. The Project will use the FPSO associated with Van Gogh, the Ningaloo Vision (Figure 3-3). This Quadrant Energy-operated project, a joint venture between Quadrant Energy and INPEX, commenced in late Further project information is available on Quadrant Energy s website: CO-00-RG of 31

9 Figure 3-1 Coniston/Novara Field Development Project Location Map CO-00-RG of 31

10 Figure 3-2 Coniston/Novara Field Development Project and Ningaloo Vision FPSO, showing each drill centre location CO-00-RG of 31

11 Figure 3-3 Schematic of the Coniston/Novara Field Development Project (including DC3 and DC4) and existing infrastructure of the Van Gogh Operation (including Ningaloo Vision FPSO, DC1 and DC2) CO-00-RG of 29

12 3.2.2 Activities Undertaken during the Reporting Period Activities completed during the reporting period is summarised as follows. Date Activity 01 October 2014 Ningaloo Vision FPSO (NV FPSO) off station in Singapore for refitting works including swivel upgrades, replacement of boiler tubes and steel in cargo compartments Reporting Period March 2015 Whilst the NV FPSO was in dry dock in Singapore an Introduced Marine Species (IMS) Inspection was conducted. The IMS inspector declared that the FPSO posed a low risk of introducing any IMS of concern to Australia. 14 March 2015 NV FPSO departs Singapore (within 7 days of leaving dry dock, as per DoF guidance). 18 March 12 April 2015 Vessel Rem Etive (Contractor - Fugro TSM) assists NV FPSO with hook up and inspections. 21 March 2015 NV FPSO arrived in the Van Gogh field. 23 March 2015 The NV FPSO structurally connected to the DTM buoy on station in Van Gogh field. April 2015 May 2015 Integrity tests on the Van Gogh gas injection well were carried during April, prior to the field start-up. Integrity testing of all Van Gogh and Coniston production wells were carried out during April- May April 2015 First oil retrieved from Van Gogh wells since NV FPSO return to the field following refitting. 11 May 2015 First oil retrieved from the Coniston wells. 23 March February crude offtakes were completed. In addition to the hook up activities described above, where the Vessel Rem Etive was utilised the following additional offshore support vessels (OSV s) were utilised by Quadrant Energy to support production operations during the reporting period: SL Mallard (Contractor Smit Lamnalco) Mermaid Supporter (Contractor - Mermaid Marine) Mermaid Investigator (Contractor - Mermaid Marine) Mermaid Voyager (Contractor - Mermaid Marine) Go Capella (Contractor Go Marine) Fine time (Contractor - Jetwave Marine) Maddison (Contractor - Jetwave Marine) Escape (Contractor - Jetwave Marine) The SL Mallard was the most utilised OSV during the reporting period. CO-00-RG of 29

13 4. COMPLIANCE ASSESSMENT 4.1 Compliance Evaluation Quadrant Energy has based its assessment of compliance with EPBC 2011/5995 on the outcomes of internal and external environmental audits and performance reports that were conducted or prepared during the reporting period. These sources of information are discussed in the following sub-sections Environmental Audits and Inspections Internal audits and inspections are a key component of Quadrant Energy s compliance assurance program for EPBC 2011/5995. During the reporting period a number of environmental audits and inspections were undertaken by Quadrant Energy in accordance with Quadrant Energy s Environmental Auditing and Inspection Procedure. The audit / inspection process typically involves desktop review of documentation and records, interviews with relevant personnel and field observations. In addition several oil spill response capability exercises/inspections were conducted during the reporting period including Quadrant Energy participation in the industry wide Exercise Westwind designed to practise an integrated multi-sectoral response to a Level 3 maritime environmental emergency. The audits / inspections conducted by Quadrant Energy aim to identify non-conformances against audit criteria, which are typically based on the relevant Environment Plan (EP) and other environmental standards and requirements maintained by Quadrant Energy. The environmental inspections or in-field audits did not identify non-compliances with EPBC 2011/5995 conditions of approval, other than those already identified and notified to DoE in previous performance reports. Table 4-1 provides an overview of the environmental audits and inspections conducted of relevance to EPBC 2011/5995 during the reporting period. The referral conditions are incorporated as measurement criteria in the accepted EP. Table 4-1 Environmental Audits and Inspections Conducted during the reporting period relevant to activities conducted under EPBC 2011/5995 Date Facility / Vessel Audit / Inspection Type Q NV FPSO Pre-Sail Away/Field Entry Checks June September November 2015 NV FPSO NV FPSO NV FPSO 2015 Q2 HSE Audit 2015 Q3 HSE Audit 2015 Q4 HSE Audit Audit / Inspection Criteria Ningaloo Vision Operations Environmental Plan WA- 35-L Van Gogh/Coniston/Novara Fields TV-00-RI Ningaloo Vision Operations Environmental Plan WA- 35-L Van Gogh/Coniston/Novara Fields TV-00-RI Ningaloo Vision Operations Environmental Plan WA- 35-L Van Gogh/Coniston/Novara Fields TV-00-RI Ningaloo Vision Operations Environmental Plan WA- 35-L Van Gogh/Coniston/Novara Fields (TV-00-RI ) CO-00-RG of 29

14 Date Facility / Vessel Audit / Inspection Type Audit / Inspection Criteria Ongoing Offshore Support Vessels Daily, weekly and monthly checklists Ningaloo Vision Operations Environmental Plan WA- 35-L Van Gogh/Coniston/Novara Fields (TV-00-RI ) Environmental Management Standards for Operations Support Vessels (EA-91-ZI-10002) Ongoing Offshore Support Vessels Inductions and declarations from vessel operators Ningaloo Vision Operations Environmental Plan WA- 35-L Van Gogh/Coniston/Novara Fields TV-00-RI Environmental Management Standards for Operations Support Vessels (EA-91-ZI-10002) Ongoing Offtake Tankers Offtake tankers questionnaires Ningaloo Vision Operations Environmental Plan WA- 35-L Van Gogh/Coniston/Novara Fields (TV-00-RI ) Berthing and Terminal Handbook (TV-22-IG-00067) Ongoing NV FPSO & QE ICT & IMT Exercise OSRC by the of deployment/ins pection of OSR equipment and personnel Ningaloo Vision Operations Oil Spill Contingency Plan (Van Gogh and Coniston Novara fields) TV-00-RI and applicable plans/procedures Environmental Audits Conducted by Regulators NOPSEMA conducted an inspection against the Ningaloo Vision Operations Environmental Plan WA-35-L Van Gogh/Coniston/Novara Fields (TV-00-RI-00003) from January NOPSEMA s inspection findings relevant to EPBC 2011/5995 were as follows: 1. Arrangements for cleaning support vessels at sea or in Exmouth port. Finding: The OSCP (page 60-61) states that All vessels returning to port that are involved in oil spill response and have been exposed to oiled water must be washed prior to reentering the port area. To do this, Containment booms are to be set-up around the vessel in open water close to where the spill is located (immediately after they have exited the operational area). Oil must be high-pressure water washed from the hull. Sorbent boom is to be used to recover the oil from within the containment boom. A conceptual illustration (Figure 7-1, page. 61) shows how this might be done in theory. Inspectors found, however, that Quadrant had not yet examined the practicalities or developed plans, logistics or training to undertake these operations. Likewise, the OSCP describes in-port segregation/ cleaning/ skimming operations in and around the Exmouth Supply Wharf during oil spill response for which no evidence of supporting plans could be provided during the inspection. For both the at-sea and the in-port operations, it is likely that a great number of safety, process, and logistical challenges would have to be overcome before these could be expected to operate effectively. CO-00-RG of 29

15 Recommendation: Quadrant Energy Response / Action: Develop plans and ensure logistics and training requirements are adequate to undertake the cleaning of support vessels as detailed in the accepted EP. Quadrant will schedule an oil spill response vessel clean down exercise as a specific line item in the approved QE 2017 OSR Exercise Plan. Implications for EPBC 2011/5995: The recommendations made by NOPSEMA represented opportunities for improvement to Quadrant Energy s existing OSR training program, and did not represent a non-compliance with EPBC 2011/5995 approval conditions. 2. Environmental Audits Finding: A commitment on Page of the EP states: Audits are undertaken by Apache Environment Department personnel or their delegate and follow the requirements detailed in the Apache Environmental Auditing and Inspection Procedure (EA-91-IG-003). Audits ensure environmental performance outcomes are being implemented. Documents were collected in the inspection which confirmed that Quadrant have undertaken regular quarterly audits of environmental performance. The Ningaloo Vision HSE Audit Q (Document 25) and the Ningaloo Vision HSE Audit Q (Document 26) detail the outcomes of the audits that have been undertaken. These audit documents are based on the Ningaloo Vision Compliance Register 2015 (Document 89) which details the performance outcomes, standards and measurement criteria from the EP which are tested for compliance and the evidence collected to demonstrate compliance is met. From a review of the evidence collected in the compliance register and the outcomes of the audit, Inspectors observed that information collected by Quadrant during audits demonstrated compliance with the performance standards, but not all performance outcomes as required by the commitment in the EP. For example: A performance outcome in the EP states Support vessels comply with EPBC Regulations 2000 Part 8 Division 8.1 during routine operations in the Operational Area and there are a number of associated performance standards relating to maintenance of vessel engines, crew induction requirements for marine fauna interactions and helicopter and marine fauna interactions. While evidence was collected that confirms compliance with the performance standards, there was no evidence collected during audits conducted in 2015 which demonstrate compliance with the performance outcome above. Recommendation: Quadrant Response / Action: Ensure that audits undertaken to determine compliance with the EP test compliance with performance outcomes, as well as performance standards. NV FPSO EP Compliance Register will be modified to include Performance Outcomes as individual line items. Implications for EPBC 2011/5995: No implication for compliance status of EPBC 2011/5995. CO-00-RG of 29

16 Quadrant Energy provided its response to NOPSEMA on 22 April Environmental Audits Conducted by Independent Auditor Quadrant Energy was instructed by the Department on 23 February 2015 to undertake an independent environmental audit against compliance with each of the conditions of the Coniston/Novara Field Development Project, Western Australia approval EPBC 2011/5995. The audit was conducted by URS Australia Pty. Ltd. (URS). The audit was conducted according to the audit criteria and methodology table developed by URS for the purposes of this audit and approved by the Department of Environment (the department) on 14 June The report was submitted to the Department on 31 July Further information was requested of the independent auditor and supplied to the Department in February Compliance Designations In accordance with the department s Guidelines, Table 4-2 describes the compliance designations used in this report. Table 4-2 Compliance Designations Compliant Noncompliant Not applicable Compliance is achieved when all the requirements of a condition have been met, including the implementation of management plans or other measures required by those conditions. A designation of non-compliance should be given where the requirements of a condition or elements of a condition, including the implementation of management plans and other measures, have not been met. A designation of not applicable should be given where the requirements of a condition or elements of a condition fall outside of the scope of the reporting period. For example a condition which applies to an activity that has not yet commenced Compliance Summary Quadrant Energy s compliance with EPBC 2011/5995 for the reporting period can be summarised as follows: Compliant: 8 conditions Non-compliant: 1 condition Not Applicable: 5 conditions Table 4-3 contains the conditions of approval under EPBC 2011/5995 for the Coniston/Novara Field Development Project, indicates compliance status with regard to these conditions during the reporting period, and provides commentary on evidence and corrective and preventative actions Non Compliance Finding: Non-Compliance against 9. As determined by the independent audit (Section 4.1.3) Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) - There are inconsistencies in documents regarding the requirements for interactions with marine fauna; a number of documents do not allow for the fact that vessels must not approach within the caution zones when calves are present (i.e. 300m and 150m respectively for whales and dolphins) CO-00-RG of 29

17 Corrective Action: Quadrant Energy to revise applicable procedures to reflect the requirements of Part 8 of the EPBC Regulations specifically in the management of interactions with cetacean calves and to issue the revised procedure to Quadrant Energy vessel and aircraft contractors by August CO-00-RG of 29

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19 Table 4-3 Compliance Summary for EPBC 2011/5995 Coniston/Novara Field Development Project for the reporting period Number Compliance Status Evidence/Comments 1 Within 30 days after the commencement of the action, the person taking the action must advise the department in writing of the actual date of commencement. 2 The person taking the action must maintain accurate records, substantiating all activities associated with or relevant to the conditions of approval, including measures taken to implement the management plans, required by this approval, and make them available upon request to the department. Such records may be subject to audit by the department or an independent auditor in accordance with section 458 of the EPBC Act, or used to verify compliance with the conditions of approval. Summaries of audits will be posted on the department's website. The results of audits may also be publicised through the general media. Not Applicable Compliant The commencement date for the approved action was 03 February Therefore, 1 did not apply during the reporting period. On the basis of the above, Quadrant Energy considers that 4 was not applicable during the reporting year. Environmental records relating to activities undertaken for Coniston/Novara Field Development Project are maintained on Quadrant Energy s Document Management System. These include records relating to routine environmental monitoring activities conducted in accordance with relevant management plans, including the OSCP/OSMP required by EPBC 2011/5995 and Environment Plans required under OPGGS (E) Regulations. Environmental audits and inspections provide evidence of compliance with record keeping requirements, as well as implementation of environment plans and environmental performance more generally (Section 4.1). The corrective and preventative actions arising from these audits and inspections are managed using an online tracking system (Enablon), e.g. assignment of responsibilities, timeframes, status reporting and close-out records. The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determined a Compliant finding against this condition. On the basis of the above, Quadrant Energy considers that it was in compliance with 2 during the reporting year. CO-00-RG of 29

20 Number Compliance Status Evidence/Comments 3 Within three months of every 12 month anniversary of the commencement of the action, the person taking the action must publish a report on their website addressing compliance with each of the conditions of this approval, including implementation of any management plans as specified in the conditions. Documentary evidence providing proof of the date of publication and non-compliance with any of the conditions of this approval must be provided to the department at the same time as the compliance report is published. 4 If the person taking the action wishes to carry out any activity otherwise than in accordance with the plans or programs as specified in the conditions, the person taking the action must submit to the department for the Minister's written approval a revised version of that plan or program. The varied activity shall not commence until the Minister has approved the varied plan or program in writing. The Minister will not approve a varied plan or program unless the revised plan or program would result in an equivalent or improved environmental outcome over time. If the Minister approves the revised plan or program, that plan or program must be implemented in place of the plan or program originally approved. 5 If the Minister believes that it is necessary or convenient for the better protection of World Heritage properties (sections 12 & ISA), National Heritage places (sections 158 & 15C), Listed threatened species and Compliant Not Applicable Not Applicable The approved action commenced on 03 February 2013; therefore, annual compliance reports for EPBC 2011/5995 must be published by 03 May each year. Quadrant Energy published its annual compliance report for EPBC 2011/5995 for on 03 May 2016 (available at: On the basis of the above, Quadrant Energy considers that it was in compliance with 3 during the reporting year. Activities during the reporting period were carried out in accordance with the plans and programs as specified in the conditions of EPBC 2011/5995. No submissions to the department to vary the activity, plans or programs specified in EPBC 2011/5995 were made during the reporting period. On the basis of the above, Quadrant Energy considers that 4 was not applicable during the reporting year. No requests were made to Quadrant Energy by the Minister to revise the plans or programs specified in conditions of EPBC 2011/5995 during the reporting period. CO-00-RG of 29

21 Number Compliance Status Evidence/Comments communities (sections 1.8 & 1.8Aj, Listed migratory species (sections 20 & 20A) and/or Commonwealth marine areas (sections 23 & 24A), the Minister may request that the person taking the action make specified revisions to the plan or program specified in the conditions and submit the revised plan or program for the Minister's written approval. The person taking the action must comply with any such request. The revised approved plan or program must be implemented. On the basis of the above, Quadrant Energy considers that 5 was not applicable during the reporting year. 6 If, at any time after 5 years from the date of this approval, the person taking the action has not substantially commenced the action, then the person taking the action must not substantially commence the action without the written agreement of the Minister. Not Applicable The approved action substantially commenced on 03 February Therefore, this condition no longer applies. On the basis of the above, Quadrant Energy considers that 6 was not applicable during the reporting year. 7 Unless otherwise agreed to in writing by the Minister, the person taking the action must publish all plans or programs referred to in these conditions of approval on their website. Each plan or program must be published on the website within one month of being approved. Note: The Minister may agree in writing to exclude the requirement to publish information that is considered confidential. Compliant The following plans and programs were published in 2013 and were available on Quadrant Energy s website throughout the reporting period: Coniston Novara Phase II Drilling Oil Spill Contingency Plan including Operational and Scientific Monitoring Program (Revision 3, dated 06/09/2013). o Approved by DSEWPaC on 13 September o Published on the Apache website on 12 October Ningaloo Vision Operations Oil Spill Contingency Plan (Van Gogh and Coniston Novara fields) (Revision 3, dated 18 November 2014). o Approved by the department on 24 April 2015 o Published on the Quadrant Energy website on 20 May Applicable published plans and programs can be found at: CO-00-RG of 29

22 Number Compliance Status Evidence/Comments Note: Redactions were made to the OSCPs/OSMPs before publishing to address concerns relating to confidentiality and commercial sensitivity, in consultation and with the prior agreement of the department. The conditions of EPBC 2011/5995 also refer to a Decommissioning Plan ( 14); however, this plan is not required until 12 months before commencement of the decommissioning phase. No plans or programs referred to in EPBC 2011/5995 were developed or revised during the reporting period. The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determined a Compliant finding against this condition. On the basis of the above, Quadrant Energy considers that it was in compliance with 7 during the reporting year. 8 The Exmouth Gulf must not be used by support vessels during the period 15 September to 31 October. Compliant No activities were undertaken by support vessels whilst working on behalf of Quadrant Energy within the Exmouth Gulf during the period 03 February 2015 to 03 February Evidence of compliance is available in the form of Daily Vessel Reports, and which are provided by all vessels on contract to Quadrant Energy and indicate vessel activities and positions. In addition all operational vessels must comply with Quadrant Energy s Environmental Management Standards for Operational Vessels EA-91- ZI which details this requirement and is signed off in a declaration of compliance by the Vessel Master or Fleet Manager. Non compliances are required to be reported to Quadrant Energy. No non compliances were reported to Quadrant Energy during the reporting CO-00-RG of 29

23 Number Compliance Status Evidence/Comments period. The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determined a Compliant finding against this condition. On the basis of the above, Quadrant Energy considers that it was in compliance with 8 during the reporting year. 9 The person taking the action must implement cetacean and Whale shark (Rhincodon typus) interaction procedures for supply vessels and aircraft that are used to carry out the action, through all stages of the action from commencement. These procedures must be consistent with Part 8 of the Environment Protection and Biodiversity Conservation Regulations 2000 at a minimum, and must include provision of cetacean sightings reports to the department. Non- Compliant Although Quadrant Energy fulfils the requirement to implement procedures to manage cetacean and whale shark (Rhincodon typus) interaction for supply vessels and aircraft, the procedures implemented were not consistent with the requirements of Part 8 of the EPBC Regulations specifically only for the management of interaction with cetacean calves. All other aspects of the procedures and associated evidence e.g. training, reporting sightings etc. were consistent with the requirements of the EPBC Regulations There were no reported sightings of cetacean calves during the reporting period. The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determined a Non-Compliant finding against this condition. The non-compliance is described as follows. There are inconsistencies in documents regarding the requirements for interactions with marine fauna; a number of documents do not allow for the fact that vessels must not approach within the caution zones when calves are present (i.e. 300m and 150m respectively for whales and dolphins) On the basis of the above, Quadrant Energy considers that it was in non-compliance with 9 during the reporting year. CO-00-RG of 29

24 Number Compliance Status Evidence/Comments The non-compliance will be addressed in accordance with the details as provided in Section The person taking the action must develop and submit to the Minister for approval, an Oil Spill Contingency Plan (OSCP) that demonstrates the response preparedness of the person taking the action for any spills, including from offshore wells and infrastructure, pipelines, construction and operation vessels. This must include the capacity to respond to a spill and mitigate the environmental impacts on World and National heritage values, the Commonwealth marine area and species listed as threatened or migratory under the EPBC Act. The OSCP must include, but is not limited to: a) Identification of sensitive areas, species or habitats that may be impacted by a potential spill, as determined by site-specific modelling of worst case scenario spills; b) Specific response measures for those sensitive areas, species or habitats and prioritisation of those areas during a spill response, including a net environmental benefit analysis of the response options; c) A description of resources available for use in containing and minimising impacts in the event of a spill and arrangements for accessing them; d) A demonstrated capacity to respond to a spill at the site. Identification of the response measures that can feasibly, and will, be applied within the first 48 hours of Compliant As discussed under 7, the Coniston/Novara Field Development Project OSCPs/OSMPs developed in accordance with EPBC 2001/5995 can be found on Quadrant Energy s website: The approved OSCP are as follows: Coniston Novara Phase II Drilling Oil Spill Contingency Plan including Operational and Scientific Monitoring Program (CNDOSCP); and Ningaloo Vision Operations Oil Spill Contingency Plan (Van Gogh and Coniston Novara fields) (NVOOSCP) CNDOSCP (above) addresses 10 specifically as follows: ref. 10 a) 10 b) Key Sections in Coniston Novara Phase II Drilling OSCP/OSMP addressing EPBC 2011/ Assessments situational awareness, definition of tier, escalation, response options, NEBA 6 Monitoring and evaluate: surveillance, tracking buoys, (6.4) spill fate modelling 18.5 Predicted spill trajectory area, sensitivities and response priorities 10 c) 16 Spill Response Arrangements 10 d) Various response strategies are presented, including: 5 Source control: SOPEP, relief well and well intervention plans 6 Monitoring and evaluate: surveillance, tracking buoys, spill fate modelling CO-00-RG of 29

25 Number Compliance Status Evidence/Comments a spill occurring; e) Details of the insurance arrangements that have been made in respect of paying the costs associated with operational and scientific monitoring as outlined in the OSCP and Operational and Scientific Monitoring Program required under s 10 and 11, and repairing environmental damage arising from potential spills, as determined from the results of the Operational and Scientific Monitoring Program; 7 Containment and recovery 8 Dispersants 9 Protection and deflection 10 Shoreline clean up 11 Oiled wildlife response 12 Waste management 13 Operational and scientific monitoring 14 Forward planning operations plan 15 Spill response termination plan f) Training of staff in spill response measures and identifying roles and responsibilities of personnel during a spill response; g) Procedures for reporting spill incidents to the department; and h) A demonstrated procedure for testing, maintenance and review of the OSCP. 10 e) 17.7 Insurances for incident response and coverage of costs 10 f) 18.6 ICT and IMT Roles and Responsibilities Awareness and Training Requirements 18.7 Response field personnel roles and responsibilities awareness, exercises and training 10 g) 18 Approvals and Stakeholder Engagement, including Reporting The OSCP must be submitted at least three months prior to the commencement of the action, or as otherwise agreed to in writing by the Minister. The person taking the action must not commence the action until the OSCP is approved by the Minister. The approved OSCP must be implemented. 10 h) 17 Response Preparedness Contingency Planning and Exercises NVOOSCP (above) addresses 10 specifically as follows: ref. Key Sections in Ningaloo Vision Operations OSCP addressing EPBC 2011/5995 Note: If a legal requirement is held by the proponent that requires submission of a plan that meets the above requirements, that plan may be submitted for the purpose of this condition. 10 a) Section Predicted spill trajectory area, sensitivities and response priorities 10 b) Section 4.4 Assess applicable response options CO-00-RG of 29

26 Number Compliance Status Evidence/Comments 10 c), d) Section 5 Source Control Plans 6 Monitoring and Evaluate Plan 7 Containment and Recovery Plan 8 Dispersion Plan 9 Protection and Deflection Plan 10 Shoreline Clean-up Plan 11 Oiled Wildlife Response Plan 12 Waste Management Plan 13 Operational and Scientific Monitoring Plan 14 Forward Operations Plan 15 Response Arrangements 10 e) Section 16.6 Insurances for incident response and coverage of costs 10 f) Section 17.4 ICT and IMT Roles and Responsibilities Awareness and Training Requirements Section 17.5 Response field personnel roles and responsibilities awareness, exercises and training 10 g) Section 3 Notification and Reporting Plan 10 h) Section 17.4 ICT and IMT Roles and Responsibilities Awareness and Training Requirements Section 17.5 Response field personnel roles and responsibilities awareness, exercises and training Section 17.6 Recording of Tests and Exercises With regard to implementation of the approved OSCPs, the key activities are the maintenance of training and ongoing competency of spill response personnel and the exercising and testing of personnel and equipment. For the reporting period this has been done as follows: CO-00-RG of 29

27 Number Compliance Status Evidence/Comments Personnel training and competency has been managed and recorded using Quadrant Energy s training database. Level 1 (small scale) spill exercises have been conducted on the Ningaloo Vision FPSO during the reporting period as part of the Annual Drill Schedule. Larger Level 2/3 spill exercises involving the mobilisation and testing of external personnel and equipment and exercising of IMT/CMT roles have also been completed for the reporting period. These typically involve testing of arrangements relevant to a number of Quadrant Energy facility and activity OSCPs. The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determined a Compliant finding against this condition. On the basis of the above, Quadrant Energy considers that it was in compliance with 10 during the reporting year. 11 The person taking the action must develop and submit to the Minister for approval, an Operational and Scientific Monitoring Program that will be implemented in the event of a spill to determine the potential extent and ecosystem consequences of such a spill, including, but not limited to: Compliant As discussed under 7/10, the Coniston/Novara Field Development Project OSCPs/OSMPs developed in accordance with EPBC 2001/5995 can be found on Quadrant Energy s website: The approved OSCP are as follows: 1. Coniston Novara Phase II Drilling Oil Spill Contingency Plan including Operational and Scientific Monitoring Program (CNDOSCP); and 2. Ningaloo Vision Operations Oil Spill Contingency Plan (Van Gogh and Coniston Novara fields) (NVOOP) CNDOSCP (above) addresses 11 specifically as follows: CO-00-RG of 29

28 Number Compliance Status Evidence/Comments a) Triggers for the initiation and termination of the Operational and Scientific Monitoring Program, including, but not limited to, spill volume, composition, extent, duration and detection of impacts; ref. 11 a) 11 b) Key Sections in Coniston Novara Phase II Drilling OSCP/OSMP addressing EPBC 2011/ Operational and Scientific Monitoring Plan b) A description of the studies that will be undertaken to determine the operational response, potential extent of impacts, ecosystem consequences and potential environmental reparations required as a result of the spill; 11 c) 17.7 Insurances for incident response and coverage of costs. (see also 12 below) 11 d) 11 e) 14.2 Scientific monitoring 11 f) 19.4 Document review c) Details of the insurance arrangements that have been made in respect of the costs associated with operational and scientific monitoring and repairing any environmental damage arising from potential spills; d) Inclusion of sufficient baseline information on the biota and the environment that may be impacted by a potential spill, to enable an assessment of the impacts of such a spill. This must include sufficient information to determine the impact on the Whale shark population that feeds in the Ningaloo Marine World Heritage Area, including the reliance of this population of Whale sharks on coral spawning in the World Heritage Area as opposed to other food sources. e) A strategy to implement the scientific monitoring plan, including timelines for delivery of results and mechanisms for the timely peer review of studies; and f) Provision for periodic review of the program. NVOOSCP (above) addresses 11 specifically as follows: ref. 11 a) 11 b) Key Sections in Ningaloo Vision Operations OSCP addressing EPBC 2011/5995 Section 13.1 Operational Monitoring Plan Section Scientific Monitoring Plan 11 c) Section 16.6 Insurances for incident response and coverage of costs (see also 12 below) 11 d) 11 e) Section 13.2 Scientific Monitoring Plan 11 f) 19.4 Document review The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determines a Compliant finding against this condition. On the basis of the above, Quadrant Energy considers that it was in compliance with 10 during the reporting year. CO-00-RG of 29

29 Number Compliance Status Evidence/Comments The OSMP must be submitted at least three months prior to the commencement of the action, or as otherwise agreed in writing by the Minister. The person taking the action must not commence the action until the OSMP is approved by the Minister. The approved OSMP must be implemented. Note: If a legal requirement is held by the proponent that requires submission of a plan that meets the above requirements, that plan may be submitted for the purpose of this condition. 12 In the event of a spill, the person taking the action must pay all costs associated with: a) All operational and scientific monitoring undertaken in response to the spill, as outlined in the OSMP approved by the Minister under 11; b) any environmental management and remediation and/or equivalent determined necessary by the results of the OSMP. 13 The development must be designed and constructed to allow for the complete removal of all structures and components above the seafloor during the Compliant Compliant Quadrant Energy assesses each activity with a bottom up cost estimate for a complete worst case scenario oil spill response. The worst case scenario oil spill response (OSR) cost assessment includes the assessment of an operational and scientific monitoring program (OSMP) and any environmental management and remediation determined necessary by the results of the OSMP. The value of the OSR is insured on a case by case basis to the level of the total cost estimate. The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determines a Compliant finding against this condition. On the basis of the above, Quadrant Energy considers that it was in compliance with 12 during the reporting year. As reported in the previous annual compliance report, the features of the engineering design that allow for removal of structures and components during decommissioning are described in the CO-00-RG of 29

30 Number Compliance Status Evidence/Comments decommissioning phase. Coniston/Novara Construction and Installation Environment Plan. Installation and Retrieval Guidelines have also been developed for the subsea equipment. Key features of the design that will facilitate decommissioning include: The Drill Centre (DC) 3 Manifold, DC 4 pipeline end manifold and Gas Production Manifold (PLEM) structures are designed for single lift recovery at decommissioning. Flexible flowlines and umbilicals will be disconnected at the manifolds and Subsea Distribution Units (SDU) respectively and individually retrieved to surface. Gas lift jumpers, electro-hydraulic flying leads and rigid tie-in spools are all designed for individual recovery. The DC2 SDU and DC3 SDUs will be retrieved directly from the support frames on their respective mudmats and the mudmat base frames are provided with dedicated pad-eyes for lifting free from the seabed. The wells can be plugged and the casing cut internally below the mud line for Christmas Tree (XT) removal and abandonment. The Independent Environmental Audit - Coniston Novara Field Development - Audit of EPBC 2011/5995 s 30 July 2015 ( /R1801/M&C3964/0) also determines a Compliant finding against this condition. On the basis of the above, Quadrant Energy considers that it was in compliance with 12 during the reporting year. 14 The person taking the action must submit a Decommissioning Plan to the Minister for approval at least twelve months prior to commencement of the decommissioning phase. Appropriate consideration Not applicable The fields are expected to produce oil over a planned operating life of up to 10 years. At the end of the commercial lifetime, the field will be decommissioned, involving the removal of all infrastructure and materials above the seabed. CO-00-RG of 29

31 Number Compliance Status Evidence/Comments must be given to matters of national environmental significance as defined by the EPBC Act and the net environmental benefit analysis of pursuing the proposed plan. Therefore, 14 did not apply during the reporting period. Note: If a legal requirement held by the person taking the action requires submission of a plan that meets the above requirements, that plan may be submitted for the purpose of this condition. CO-00-RG of 29