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Licence

Environmental Protection Act 1986, Part V

Licensee: Chevron Australia Pty Ltd Licence: L8479/2010/2

Registered office: Chevron Australia Pty Ltd 250 St Georges Terrace PERTH WA 6000

ACN: 086 197 757

Premises address: Gorgon Gas Development Bridging Wastewater Treatment Plant Within the coordinates:

339.221.921 E 7700 046.895 N 339 247.633 E 7700 066.770 N 339 268.266 E 769 9986.931 N 339 295.335 E 7700 005.055 N

Wastewater disposal well 1: 332 731.2 E, 7 700 842.5 N Wastewater disposal well 2: 332 824.0 E, 7,700 644.7 N BARROW ISLAND WA 6712

As depicted in Schedule 1 Issue date: Thursday, 21 August 2014 Commencement date: Friday, 22 August 2014 Expiry date: Wednesday, 21 August 2019 Prescribed premises category

Schedule 1 of the Environmental Protection Regulations 1987 Category

number Category description

Category production or design capacity

Approved Premises production or design capacity

54 Sewage facility: premises –

(a) on which sewage is treated (excluding septic tanks); or

(b) from which treated sewage is discharged onto land or into waters.

100 cubic metres or more per day

1385 cubic metres per day

Conditions

This Licence is subject to the conditions set out in the attached pages.

Date signed: 4 March 2016 ...

Jonathan Bailes

Manager Licencing (Process Industries) Officer delegated under section 20

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Contents

Introduction 2

Licence conditions 5

1 General 5

2 Emissions 6

3 Monitoring 7

4 Information 8

Schedule 1: Maps 10

Schedule 2: Reporting & notification forms 13

Introduction

This Introduction is not part of the Licence conditions.

DER’s industry licensing role

The Department of Environment Regulation (DER) is a government department for the state of Western Australia in the portfolio of the Minister for Environment. The DER’s purpose is to advise on and implement strategies for a healthy environment for the benefit of all current and future Western Australians.

The DER has responsibilities under Part V of the Environmental Protection Act 1986 (the Act) for the licensing of prescribed premises. Through this process the DER works with the business owners, community, consultants, industry and other representatives to prevent, control and abate pollution and environmental harm to conserve and protect the environment. The DER also monitors and audits compliance with works approvals and licence conditions, takes enforcement action as appropriate and develops and implements licensing and industry regulation policy.

Licence requirements

This Licence is issued under Part V of the Act. Conditions contained within the Licence relate to the prevention, reduction or control of emissions and discharges to the environment and to the monitoring and reporting of them.

Where other statutory instruments impose obligations on the Premises/Licensee the intention is not to replicate them in the licence conditions. You should therefore ensure that you are aware of all your statutory obligations under the Act and any other statutory instrument. Legislation can be accessed through the State Law Publisher website using the following link:

http://www.slp.wa.gov.au/legislation/statutes.nsf/default.html

For your Premises relevant statutory instruments include but are not limited to obligations under the:

Environmental Protection (Unauthorised Discharges) Regulations 2004 – these Regulations make it an offence to discharge certain materials such as contaminated stormwater into the environment other than in the circumstances set out in the Regulations.

Environmental Protection (Controlled Waste) Regulations 2004 - these Regulations place obligations on you if you produce, accept, transport or dispose of controlled waste.

Environmental Protection (Noise) Regulations 1997 – these Regulations require noise emissions from the Premises to comply with the assigned noise levels set out in the Regulations.

You must comply with your licence. Non-compliance with your licence is an offence and strict penalties exist for those who do not comply.

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Licence holders are also reminded of the requirements of section 53 of the Act which places restrictions on making certain changes to prescribed premises unless the changes are in accordance with a works approval, licence, closure notice or environmental protection notice.

Licence fees

If you have a licence that is issued for more than one year, you are required to pay an annual licence fee prior to the anniversary date of issue of your licence. Non payment of annual licence fees will result in your licence ceasing to have effect meaning that it will no longer be valid and you will need to apply for a new licence for your Premises.

Ministerial conditions

If your Premises has been assessed under Part IV of the Act you may have had conditions imposed by the Minister for Environment. You are required to comply with any conditions imposed by the Minister.

Premises description and Licence summary

The Gorgon Gas Development Bridging Wastewater Treatment Plant (BWWTP) was assessed as a prescribed premises category 54 as per Schedule 1 of the Environmental Protection

Regulations 1987. The following activities are carried out on site:

Category 54: Sewage facility: premises –

(a) on which sewage is treated (excluding septic tanks); or (b) from which treated sewage is discharged onto land or waters.

The BWWTP services the construction camp for the Gorgon Gas Development (Gorgon) by treating sewage and disposing of treated effluent to wastewater disposal wells via a temporary wastewater injection plant.

Chevron Australia Pty Ltd (Chevron) also has the ability to reuse the treated effluent for construction, however, is currently liaising with the Department of Health for approval.

In May 2009, Chevron was issued a works approval to enable construction of an additional wastewater treatment train beside the two existing trains at the BWWTP. This expansion resulted in a 50% increase in the plant’s treatment capacity from 875m3/day to 1312.5m3/day.

A licence amendment application was subsequently processed in November 2012 to allow operation of the new train under the existing licence, following DER receiving the commissioning report. The quality of wastewater has remained the same. However, the licence has been updated to reflect the increase in capacity and to incorporate the deep well injection points into which treated effluent is injected to the Flacourt Formation.

This Licence is the result of an amendment sought by the Licensee to allow the disposal of treated effluent to the Permanent Wastewater Disposal wells via the Liquid Waste Facility. The Permanent Wastewater Disposal and Liquid Waste Facility are licensed separately under Licence L8894/2015/1.

The licences and works approvals issued for the Premises since 18/08/2011 are:

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Instrument log

Instrument Issued Description

W4635/2010/1 22/07/2010 Construction of the WWTP.

W5152/2012/1 10/05/2012 Construction of an additional wastewater treatment train beside the two existing trains at the BWWTP. This expansion resulted in a 50% increase in the plant’s treatment capacity from 875m3/day to 1312.5m3/day.

L8479/2010/1 18/08/2011 New Licence for operation.

L8479/2010/1 6/12/2012 Licence amended to include an additional wastewater treatment train beside the two existing trains at the BWWTP.

This expansion resulted in a 50% increase in the plant’s treatment capacity from 875m3/day to 1312.5m3/day.

L8479/2010/2 21/08/2014 Licence reissued and converted to the new format.

L8479/2010/2 04/03/2016 Amendment to allow disposal of treated effluent to the Permanent Wastewater Disposal wells in the Licence.

Severance

It is the intent of these Licence conditions that they shall operate so that, if a condition or a part of a condition is beyond the power of this Licence to impose, or is otherwise ultra vires or invalid, that condition or part of a condition shall be severed and the remainder of these conditions shall nevertheless be valid to the extent that they are within the power of this Licence to impose and are not otherwise ultra vires or invalid.

END OF INTRODUCTION

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Licence conditions

1 General

1.1 Interpretation

1.1.1 In the Licence, definitions from the Environmental Protection Act 1986 apply unless the contrary intention appears.

1.1.2 For the purposes of this Licence, unless the contrary intention appears:

‘Act’ means the Environmental Protection Act 1986;

‘annual period’ means the inclusive period from 1 July until 30 June in the following year;

‘AS/NZS 5667.1’ means the Australian Standard AS/NZS 5667.1 Water Quality – Sampling – Guidance of the Design of sampling programs, sampling techniques and the preservation and handling of samples;

‘AS/NZS 5667.10’ means the Australian Standard AS/NZS 5667.10 Water Quality – Sampling – Guidance on sampling of waste waters;

‘averaging period’ means the time over which a limit or target is measured or a monitoring result is obtained;

‘CEO’ means Chief Executive Officer of the Department of Environment Regulation;

‘CEO’ for the purpose of correspondence means:

Chief Executive Officer

The Department administering the Environmental Protection Act 1986 Locked Bag 33

CLOISTERS SQUARE WA 6850 Email: [email protected];

‘controlled waste’ has the definition in Environmental Protection (Controlled Waste) Regulations 2004;

‘Licence’ means this Licence numbered L8479/2010/2 and issued under the Act;

‘Licensee’ means the person or organisation named as Licensee on page 1 of the Licence;

‘NATA’ means the National Association of Testing Authorities, Australia;

‘NATA accredited’ means in relation to the analysis of a sample that the laboratory is NATA accredited for the specified analysis at the time of the analysis;

‘NTU’ means Nephelometric Turbidity Units;

‘Premises’ means the area defined in the Premises Map in Schedule 1 and listed as the Premises address on page 1 of the Licence;

‘quarterly’ means the 4 inclusive periods from 1 July to 30 September, 1 October to 31 December and in the following year, 1 January to 31 March, 1 April to 30 June;

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‘Schedule 2’ means Schedule 2 of this Licence unless otherwise stated; and

‘spot sample’ means a discrete sample representative at the time and place at which the sample is taken.

1.1.3 Any reference to an Australian or other standard in the Licence means the relevant parts of the standard in force from time to time during the term of this Licence.

1.1.4 Any reference to a guideline or code of practice in the Licence means the version of that guideline or code of practice in force from time to time, and shall include any amendments or replacements to that guideline or code of practice made during the term of this Licence.

1.2 Premises operation

1.2.1 The Licensee shall only allow waste to be accepted on to the Premises if:

(a) it is of a type listed in Table 1.2.1;

(b) the quantity accepted is below any limit listed in Table 1.2.1; and (c) it meets any specification listed in Table 1.2.1.

Table 1.2.1: Waste acceptance

Waste Quantity Limit Specification1 Sewage and

wastewater and other minor volumes

transported by truck as an infrequent contingency

1385 cubic metres per day

Accepted from the Gorgon Project and discharged via emission points L1 and L2 and/or disposed of to the Permanent Wastewater Disposal wells (Z-WI1 and Z-WI2) via the Liquid Waste Facility as shown in the maps in Schedule 1.

Note 1: Additional requirements for the acceptance of controlled waste are set out in the Environmental Protection (Controlled Waste) Regulations 2004.

2 Emissions

2.1 General

2.1.1 The Licensee shall record and investigate the exceedance of any descriptive or numerical limit in this section.

2.2 Emissions to land

2.2.1 The Licensee shall ensure that where waste is emitted to land from the emission points in Table 2.2.1 and identified on the map of emission points in Schedule 1 it is done so in accordance with the conditions of this Licence.

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Table 2.2.1: Emissions to land Emission point reference and location on map of emission points

Emission point Description Source including abatement L1

E336856, N7699528

Standpipe for construction reuse

Discharge treated effluent to land within the Barrow Island lease and for the purpose of associated Gorgon Gas Development

construction activities.

Bridging Wastewater Treatment Plant L2

E332731, N7700843 and E332824, N7700645

Discharge to wastewater disposal wells

Discharge to

wastewater disposal wells via treated wastewater injection points (WDW1 and WDW2)

2.2.2 The Licensee shall limit emissions to land at or below the levels specified listed in Table 2.2.2.

Table 2.2.2: Emission limits to land Emission point

reference

Parameter Limit

(including units)

Averaging period

L1

pH 6.5 – 8.5 pH units

Spot sample

Turbidity 5 NTU (95%tile)

Total residual chlorine 0.2 – 2 mg/L

3 Monitoring

3.1 General monitoring

3.1.1 The Licensee shall ensure that:

(a) all water samples are collected and preserved in accordance with AS/NZS 5667.1, with the exception of holding times where these are not achievable;

(b) all wastewater sampling is conducted in accordance with AS/NZS 5667.10; and (c) all laboratory samples are submitted to and tested by a laboratory with current

NATA accreditation for the parameters being measured unless indicated otherwise in the relevant table.

3.1.2 The Licensee shall ensure that quarterly monitoring is undertaken at least 45 days apart.

3.1.3 The Licensee shall ensure that all monitoring equipment used on the Premises to comply with the conditions of this Licence is calibrated in accordance with the manufacturer’s specifications or any relevant and effective internal management system.

3.1.4 The Licensee shall, where the requirements for calibration cannot be practicably met, or a discrepancy exists in the interpretation of the requirements, bring these issues to the attention of the CEO accompanied with a report comprising details of any modifications to the methods.

3.2 Monitoring of emissions to land

3.2.1 The Licensee shall undertake the monitoring in Table 3.2.1 according to the specifications in that table.

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Note 1: In-field non-NATA accredited analysis permitted.

3.3 Monitoring of inputs and outputs

3.3.1 The Licensee shall undertake the monitoring in Table 3.3.1 according to the specifications in that table.

Table 3.3.1: Monitoring of inputs and outputs Input/Output Monitoring

point reference

Parameter Units Averaging period

Frequency

Sewage - Inlet Flow Inflow meter Volumetric flow rate (cumulative)

m3/day Daily Continuous

Treated wastewater pumped to land for the purpose of associated Gorgon Gas

Development

construction activities.

Outflow meter where practicable or truck volumes

Volumetric flow rate (cumulative) where practical or truck counts

m3/day Daily Continuous

Treated wastewater pumped to wastewater disposal wells)

Outflow meter

Volumetric flow rate (cumulative)

m3/day Daily Continuous

4 Information

4.1 Records

4.1.1 All information and records required by the Licence shall:

(a) be legible;

(b) if amended, be amended in such a way that the original and subsequent amendments remain legible or are capable of retrieval;

(c) except for records listed in 4.1.1(d) be retained for at least 6 years from the date the records were made or until the expiry of the Licence or any subsequent licence; and

(d) for those following records, be retained until the expiry of the Licence and any subsequent Licence:

(i) off-site environmental effects; or

(ii) matters which affect the condition of the land or waters.

4.1.2 The Licensee shall complete an Annual Audit Compliance Report indicating the extent to which the Licensee has complied with the conditions of the Licence, and any previous licence issued under Part V of the Act for the Premises for the previous annual period.

Table 3.2.1: Monitoring of emissions to land Monitoring point reference and

location on map of monitoring locations

Parameter Units Frequency

Monitoring Point E339279, N7699996 (L1 - reuse only)

pH1 pH units

Daily

Turbidity1 NTU

Total residual chlorine1 mg/L Biochemical oxygen demand mg/L

Quarterly Total suspended solids mg/L

Total nitrogen mg/L

Total phosphorus mg/L

E. coli cfu/100mL

Anionic surfactants mg/L

Oil and grease 10 mg/L

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

4.2 Reporting

4.2.1 The Licensee shall submit to the CEO an Annual Environmental Report within 120 calendar days after the end of the annual period. The report shall contain the information listed in Table 4.2.1 in the format or form specified in that table.

Table 4.2.1: Annual Environmental Report Condition or table

(if relevant)

Parameter Format or form1

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

None specified

Table 2.2.2 Limit exceedances None specified

Table 3.2.1 pH

Turbidity

Total residual chlorine Biochemical oxygen demand Total suspended solids Total nitrogen

Total phosphorus E. coli

Anionic surfactants Oil and grease

None specified

3.3.1 Inputs and outputs None specified

4.1.3 Compliance Annual Audit

Compliance Report (AACR)

4.1.4 Complaints summary None specified

Note 1: Forms are in Schedule 2

4.3 Notification

4.3.1 The Licensee shall ensure that the parameters listed in Table 4.3.1 are notified to the CEO in accordance with the notification requirements of the table.

Table 4.3.1: Notification requirements Condition

or table (if relevant)

Parameter Notification requirement1 Format

or form2 2.1.1 Breach of any limit specified in the

Licence

Part A: As soon as practicable but no later than 5pm of the next working day

Part B: As soon as practicable

N1

3.1.4 Calibration report As soon as practicable. None

specified Note 1: No notification requirement in the Licence shall negate the requirement to comply with s72 of the

Act.

Note 2: Forms are in Schedule 2

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Schedule 1: Maps

Premises map

The Premises is shown in the map below. The red line depicts the Premises boundary.

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Map of emission points

The locations of the emission points defined in Table 2.2.1 are shown below.

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Map of monitoring locations

The locations of the monitoring points defined in Table 3.2.1 are shown below.

Output to L1, L2 and Liquid Waste Facility

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Schedule 2: Reporting & notification forms

These forms are provided for the proponent to report monitoring and other data required by the Licence. They can be requested in an electronic format.

ANNUAL AUDIT COMPLIANCE REPORT PROFORMA SECTION A

LICENCE DETAILS

Licence Number: Licence File Number:

Company Name:

Trading as:

ABN:

Reporting period:

___________________ to ___________________

STATEMENT OF COMPLIANCE WITH LICENCE CONDITIONS

1. Were all conditions of the Licence complied with within the reporting period? (please tick the appropriate box)

Yes

□ Please proceed to Section C

No

□ Please proceed to Section B

Each page must be initialled by the person(s) who signs Section C of this Annual Audit Compliance Report (AACR).

Initial:

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SECTION B

DETAILS OF NON-COMPLIANCE WITH LICENCE CONDITION.

Please use a separate page for each Licence condition that was not complied with.

a) Licence condition not complied with:

b) Date(s) when the non compliance occurred, if applicable:

c) Was this non compliance reported to DER?:

Yes

Reported to DER verbally Date ___________

Reported to DER in writing Date ___________

No

d) Has DER taken, or finalised any action in relation to the non compliance?:

e) Summary of particulars of the non compliance, and what was the environmental impact:

f) If relevant, the precise location where the non compliance occurred (attach map or diagram):

g) Cause of non compliance:

h) Action taken, or that will be taken to mitigate any adverse effects of the non compliance:

i) Action taken or that will be taken to prevent recurrence of the non compliance:

Each page must be initialled by the person(s) who signs Section C of this AACR Initial:

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SECTION C

SIGNATURE AND CERTIFICATION

This Annual Audit Compliance Report (AACR) must only be signed by a person(s) with legal authority to sign it. The ways in which the AACR must be signed and certified, and the people who may sign the statement, are set out below.

Please tick the box next to the category that describes how this AACR is being signed. If you are uncertain about who is entitled to sign or which category to tick, please contact the licensing officer for your premises.

If the licence holder is The Annual Audit Compliance Report must be signed and certified:

An individual

by the individual licence holder, or

by a person approved in writing by the Chief Executive Officer of the Department of Environment Regulation to sign on the licensee's behalf.

A firm or other unincorporated company

by the principal executive officer of the licensee; or

by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

A corporation

by affixing the common seal of the licensee in accordance with the Corporations Act 2001; or

by two directors of the licensee; or

by a director and a company secretary of the licensee, or

if the licensee is a proprietary company that has a sole director who is also the sole company secretary – by that director, or

by the principal executive officer of the licensee; or

by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

A public authority (other than a local government)

by the principal executive officer of the licensee; or

by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

a local government □

by the chief executive officer of the licensee; or by affixing the seal of the local government.

It is an offence under section 112 of the Environmental Protection Act 1986 for a person to give information on this form that to their knowledge is false or misleading in a material particular. There is a maximum penalty of $50,000 for an individual or body corporate.

I/We declare that the information in this annual audit compliance report is correct and not false or misleading in a material particular.

SIGNATURE: ________________________

NAME:

(printed) _____________________________

POSITION: __________________________

DATE: ______/_______/________________

SIGNATURE: ________________________

NAME:

(printed) _____________________________

POSITION: __________________________

DATE: ______/_______/________________

SEAL (if signing under seal)

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Licence: L8479/2010/2 Licensee: Chevron Australia Pty Ltd

Form: N1 Date of breach:

Notification of detection of the breach of a limit

These pages outline the information that the operator must provide. Units of measurement used in information supplied under Part A and B requirements shall be appropriate to the circumstances of the emission. Where appropriate, a comparison should be made of actual emissions and authorised emission limits.

Part A

Licence Number Name of operator Location of Premises

Time and date of the detection

Notification requirements for the breach of a limit Emission point reference/ source

Parameter(s) Limit

Measured value

Date and time of monitoring Measures taken, or intended to be taken, to stop the emission

Part B

Any more accurate information on the matters for notification under Part A.

Measures taken, or intended to be taken, to prevent a recurrence of the incident.

Measures taken, or intended to be taken, to rectify, limit or prevent any pollution of the environment which has been or may be caused by the emission.

The dates of any previous N1 notifications for the Premises in the preceding 24 months.

Name Post

Signature on behalf of Chevron Australia Pty Ltd Date

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Decision Document

Environmental Protection Act 1986, Part V

Licensee:

Chevron Australia Pty Ltd Licence: L8479/2010/2

Registered office: Chevron Australia Pty Ltd 250 St Georges Terrace PERTH WA 6000

ACN: 086 197 757

Premises address: Gorgon Gas Development Bridging Wastewater Treatment Plant Within the coordinates:

339.221.921 mE 7700 046.895 mN 339 247.633 mE 7700 066.770 mN 339 268.266 mE 769 9986.931 mN 339 295.335 mE 7700 005.055 mN

Wastewater disposal well 1: 332 731.2E, 7 700 842.5N Wastewater disposal well 2: 332 824.0E, 7,700 644.7N BARROW ISLAND WA 6712

Issue date: Thursday, 21 August 2014 Commencement date: Friday, 22 August 2014 Expiry date: Wednesday, 21 August 2019

Decision

Based on the assessment detailed in this document the Department of Environment Regulation (DER) has decided to issue an amended licence. DER considers that in reaching this decision, it has taken into account all relevant considerations.

Decision Document prepared by: Fiona Roser Licensing Officer

Decision Document authorised by: Jonathan Bailes Delegated Officer

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Contents

1 Purpose of this Document 2

2 Administrative summary 3

3 Executive summary of proposal and assessment 4

4 Decision table 5

5 Advertisement and consultation table 10

6 Risk Assessment 10

Appendix A 11

1 Purpose of this Document

This decision document explains how DER has assessed and determined the application and provides a record of DER’s decision-making process and how relevant factors have been taken into account. Stakeholders should note that this document is limited to DER’s assessment and decision making under Part V of the Environmental Protection Act 1986. Other approvals may be required for the proposal, and it is the proponent’s responsibility to ensure they have all relevant approvals for their Premises.

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2 Administrative summary

Administrative details

Application type

Works Approval ☐

New Licence ☐

Licence amendment ☒

Works Approval amendment ☐

Activities that cause the premises to become prescribed premises

Category number(s) Assessed design capacity

54 1,835m3/day

Application verified Application fee paid

Date: N/A Date: N/A Works Approval has been complied with

Compliance Certificate received

Yes ☐ No ☐

N/A ☒

Yes ☐ No ☐

N/A ☒

Commercial-in-confidence claim Yes ☐ No ☒ Commercial-in-confidence claim outcome N/A.

Is the proposal a Major Resource Project? Yes ☐ No ☐ Was the proposal referred to the Environmental

Protection Authority (EPA) under Part IV of the Environmental Protection Act 1986?

Yes ☒ No ☐

Referral decision No:

Managed under Part V ☐ Assessed under Part IV ☒

Is the proposal subject to Ministerial Conditions?

Yes ☒ No ☐ Part of Gorgon LNG Project

Ministerial statement No: 800 (previously 748)

EPA Report No: 1323 (previously 1221)

Does the proposal involve a discharge of waste into a designated area (as defined in section 57 of the Environmental Protection Act 1986)?

Yes ☐ No ☒

Department of Water consulted Yes ☐ No ☒ Is the Premises within an Environmental Protection Policy (EPP) Area Yes ☐ No ☒

Is the Premises subject to any EPP requirements? Yes ☐ No ☒

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3 Executive summary of proposal and assessment

The Gorgon Gas Development Bridging Wastewater Treatment Plant (BWWTP) services the construction camp for the Gorgon Gas Development (Gorgon) by treating sewage and disposing of treated effluent to wastewater disposal wells via a temporary wastewater injection plant (TWIP).

The TWIP consists of two injection points that discharge treated effluent into the Flacourt Formation, located approximately 1,000m below ground. Chevron Australia Pty Ltd (Chevron) also has approval under this Licence to reuse the treated effluent for construction.

Chevron also operates two Permanent Wastewater Disposal (PWD) wells, which receive wastes associated with the commissioning and operation of the Gas Treatment Plant (GTP) via the Liquid Waste Facility. The Liquid Waste Facility consists of two 1,300m3 Disposal Water Tanks where various water streams associated with the GTP, such as produced formation water and process wastes, are combined prior to disposal to PWD wells. The PWD wells are located 630m south of the GTP site and discharge to the same formation, the Flacourt Formation, as the TWIP.

Chevron has applied to amend the Licence to allow the use of the PWD wells for the disposal of treated effluent from the BWWTP. The TWIP will be used as the primary disposal point initially.

However, the PWD wells will be increasingly utilised as the Gorgon project develops. Transfer to the PWD wells will be via a pipeline connecting to the Disposal Water Tanks. The Liquid Waste Facility and PWD wells are licensed separately under Licence L8894/2015/1.

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4 Decision table

All applications are assessed in line with the Environmental Protection Act 1986, the Environmental Protection Regulations 1987 and DER’s Operational Procedure on Assessing Emissions and Discharges from Prescribed Premises. Where other references have been used in making the decision they are detailed in the decision document.

DECISION TABLE

Works Approval / Licence section

Condition number W = Works Approval L= Licence

Justification (including risk description & decision methodology where relevant) Reference documents

General conditions

L1.2.1 – L1.2.4 DER Guidance Statement: Setting conditions stipulates that licences may be granted subject to conditions that are valid, enforceable and risk-based. ‘General conditions’

(i.e. conditions 1.2.1 – 1.2.5) are not considered to be consistent with the Guidance Statement: Setting Conditions as they are not sufficiently clear or certain. Accordingly, these conditions have been removed from the Licence.

Unauthorised discharges of environmentally hazardous materials are subject to the provisions of the Environmental Protection (Unauthorised Discharges) Regulations 2004. The general provisions of the Environmental Protection Act 1986 relating to causing pollution and environmental harm also apply.

DER Guidance Statement: Setting Conditions

Environmental Protection Act 1986

Environmental Protection (Unauthorised Discharges) Regulations 2004 Premises

operation

L1.2.1 Disposal of liquid waste via deep-well injection is undertaken in accordance with the Solid and Liquid Waste Management Plan developed under Ministerial Statement 800.

The objectives of the Solid and Liquid Waste Management Plan are to ensure that discharges from any WWTP or reverse osmosis plant, and other process waters are disposed of via deep well injection unless otherwise authorised.

Condition 1.2.1 has been amended to allow the disposal of treated effluent to the PWD wells via the Liquid Waste Facility. The environmental risks associated with disposal of various liquid wastes, including treated effluent, via the PWD wells, were assessed

Application supporting documentation MS800

Solid and Liquid Waste Management Plan

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DECISION TABLE

Works Approval / Licence section

Condition number W = Works Approval L= Licence

Justification (including risk description & decision methodology where relevant) Reference documents

Emissions general

L2.1.1 Reference of descriptive and numeric targets has been removed in accordance with Departmental reform as published on the DER’s website under “Administrative changes implemented within the Department of Environment Regulation”.

DER public website at:

www.der.wa.gov.au Emissions to

land including monitoring

L2.2.1 L3.2.1

Emission Risk Assessment – Normal Operations Emission Description

Emission: Treated sewage disposed of via deep injection well to the Flacourt Formation via the TWIP.

Impact: Potential impacts from deep well injection include reduced quality of the surface aquifer which supports significant subterranean fauna and fluctuations in the water table due to the injection of liquid wastes. The shallow surface formations and the water table identified as subterranean fauna habitat are geologically isolated from the deeper Flacourt Formation. Factors that could cause impact to the characteristics of the shallow aquifer and the stygofauna present during deep well injection include:

 Fracturing of the receiving formations and overlying confining units resulting in penetration of liquid waste into the near-surface aquifer; and

 Injection into a receiving environment that is not isolated from the shallower aquifers by adequate confining layers.

Controls: Monitoring and inspections to ensure well integrity is maintained. Periodic monitoring of the superficial aquifer is carried out in accordance with the Terrestrial and Subterranean Monitoring Program developed in under condition 8 of MS800, to identify if the surface aquifer is being impacted by injection activities.

Risk Assessment Consequence: Minor Likelihood: Rare Risk Rating: Low

Application supporting documentation Guidance Statement:

Setting Conditions MS800

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DECISION TABLE

Works Approval / Licence section

Condition number W = Works Approval L= Licence

Justification (including risk description & decision methodology where relevant) Reference documents

Regulatory Controls

Disposal of wastewater down well is in accordance with the Solid and Liquid Waste Management Plan developed under condition 30 of MS800. Water quality monitoring requirements for disposal down well have been removed from the licence due to the low environmental risk.

Residual Risk Consequence: Minor Likelihood: Rare Risk Rating: Low

In accordance with administrative changes implemented within the Department of Environment Regulation published on DER’s website, conditions that contain targets or trigger levels will not be applied or continued in licences or works approvals.

Accordingly, condition 2.2.3 (previously 2.5.3) has been removed from the Licence.

The targets previously stated in the licence are replicated in Appendix A so that DER can benchmark the performance of the treatment plant on submission of the Annual Environmental Report and data. With the exception of updates outlined below, monitoring requirements in the Licence remain unchanged and results of monitoring required to be submitted in the Annual Environmental Report.

Conditions 3.2.1 (previously 3.5.1) has been amended to allow in-field non-NATA accredited sampling of pH, turbidity and total residual chlorine which are all monitored using online monitoring equipment. It is noted that monitoring of treated effluent occurs from a single location (E337386, N7696691) prior to disposal to either emission point L1 or L2. Furthermore, although monitoring occurs on a continuous basis, data is only recorded daily for regulatory purposes as agreed with the Department of Health.

Tables 2.2.2 and 3.2.1 (previously 3.5.1) have been amended to reflect this.

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DECISION TABLE

Works Approval / Licence section

Condition number W = Works Approval L= Licence

Justification (including risk description & decision methodology where relevant) Reference documents

Fugitive emissions

L2.6.1 – L6.2.2 The previous licence contained conditions 2.6.1 and 2.6.2 relating to light emissions.

Light glow generated from artificial light sources on or near nesting beaches can result in disorientation, exhaustion and disturbance of marine turtle nesting patterns. Design and operational control of lighting can minimise light glow. The design of lighting at the premises was assessed under the works approvals (W4635/2010/1 and

W5152/2012/1). Monitoring to determine impacts on marine turtles from light glow is conducted in accordance with the Long-Term Marine Turtle Management Plan, which is a requirement of condition 16-1 of Ministerial Statement 800. Light emissions can be sufficiently regulated under Part IV of the Environmental Protection Act 1986 and, therefore, conditions 2.6.1 and 2.6.2 have been removed from the Licence

General provisions of the Environmental Protection Act 1986

Guidance Statement:

Setting Conditions MS800

Monitoring general

L3.1.1

L3.1.3 and L3.1.4

Condition 3.1.1 has been amended to allow in-field non-NATA accredited sampling of pH, turbidity and total residual chlorine which are all monitored using online monitoring equipment.

Conditions 3.1.3 and 3.1.4 have been included in the Licence to ensure that monitoring equipment is calibrated in accordance with the manufacturer’s specifications or, where manufacturer specifications are not sufficient, any internal management system.

Where calibration requirements cannot be met, the Licensee is required to notify DER.

N/A

Monitoring of inputs and outputs

L3.3.1 Condition 3.3.1 requires the Licensee to record the volume of effluent disposed of via deep well injection. The condition has been updated to include the PWD wells.

N/A

Information L4.2.1 L4.3.1

DER Guidance Statement: Setting Conditions stipulates that licences may be granted subject to conditions that are valid, enforceable and risk-based. Condition 4.1.2 is not considered to be consistent with the guidance statement as the requirements for compliance are not sufficiently clear or certain. Accordingly, this condition has been removed from the Licence.

Condition 4.2.1 (previously 5.2.1) has been amended to include reporting of monitoring of inputs and outputs in the Annual Environmental Report (this was previously omitted in error).

Guidance Statement:

Setting Conditions

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DECISION TABLE

Works Approval / Licence section

Condition number W = Works Approval L= Licence

Justification (including risk description & decision methodology where relevant) Reference documents

Condition 4.3.1 (previously 5.3.1) has been amended to ensure that DER is notified if calibration requirements under condition 3.1.3 cannot be met.

Licence Duration

N/A The Licence is due to expire on 21 August 2019. No amendments have been made to the licence duration.

N/A

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5 Advertisement and consultation table

Date Event Comments received/Notes How comments were taken into consideration

22/1/2016 Proponent sent a copy of draft instrument

1. Requested that Licence updated to more clearly identify emission points.

2. Monitoring at L1 for pH, turbidity &

total residual chlorine occurs continuously but only recorded on a daily basis for regulatory purposes as agreed with Department of Health.

3. Requested the removal of quarterly water quality sampling at L2 (discharge to injection wells) on the basis that environmental risk associated with deep well injection is low due to lack of sensitive environmental receptors within the receiving formation. A key

management mechanism is ensuring water quality is within targets for maintaining well operability/integrity.

4. The Licensee indicated that ability to determine volumes of

wastewater directed to the TWP vs.

the PDW wells is limited and requested removal of the

requirement to monitor/record this.

1. Disposal of wastewater to the permanent disposal wells via the Liquid Waste Facility is allowed under condition 1.2.1. These wells are not stipulated in the Licence as emission points as they are specified under Licence L8894/2015/1. Condition 2.2.2 and maps in Schedule 1 have been updated to identify clearly two emission points; reuse (L1) and deep well disposal via TWIP (L2).

2. Conditions 2.2.2 and 3.2.1 updated accordingly.

3. Quarterly sampling at L2 for the purpose of determining the quality of wastewater disposed of downwell removed.

Monitoring requirements remain on the Licence at emission point L1.

4. Condition 3.3.1 updated accordingly. Flow meters are available at the TWIP and PWD wells to determine the total volume of waste discharged downwell.

6 Risk Assessment

Note: This matrix is taken from the DER Corporate Policy Statement No. 07 - Operational Risk Management

Table 1: Emissions Risk Matrix

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Appendix A

BWWTP performance specifications Emission point

reference

Parameter Specification

(including units) L1 - Reuse on land Biochemical oxygen demand <20 mg/L

Total suspended solids <30 mg/L

Total nitrogen <20 mg/L

Total phosphorus <6 mg/L

E. coli <10 cfu/100mL

Anionic surfactants <5 mg/L

Oil and grease <10 mg/L

L2 - Disposal via deep well injection

Biochemical oxygen demand <30 mg/L

Total suspended solids <40 mg/L

Total nitrogen <50 mg/L

Total phosphorus <12 mg/L

E.coli <106 cfu/100mL

Anionic surfactants <5 mg/L

Oil and grease <10 mg/L

References

Related documents

Table 20: Operational controls WWWTP chlorinator unit and associated infrastructure  Undertake regular inspections and schedule maintenance of system processes as required to