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APACHE ENERGY LTD (ABN 39 009 301 964) 100 ST GEORGES TERRACE / PERTH / WA / 6000 TEL (08) 6218 7100 / FAX (08) 6218 7200

Coniston/Novara Field Development Project (EPBC 2011/5995) Annual Compliance Report 2014-2015

12 May 2015

APACHE ENERGY LTD (ABN 39 009 301 964) 100 ST GEORGES TERRACE / PERTH / WA / 6000 TEL (08) 6218 7100 / FAX (08) 6218 7200

REVISION HISTORY

Revision Date Amendment

A 07/05/2015 Draft version for Internal Review

0 12/05/2015 Final version to be published on Apache website and issued to Department of Environment

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Coniston/Novara Field Development Project (EPBC 2011/5995) Annual Compliance Report 2014-2015

CONTENTS

1. INTRODUCTION ............................................................................................................................... 1

1.1 Overview ....................................................................................................................................... 1

1.2 Terms, Definitions and Abbreviations ............................................................................................. 1

2. DECLARATION OF ACCURACY ........................................................................................................... 3

3. APPROVED ACTION.......................................................................................................................... 4

3.1 Regulatory Context ........................................................................................................................ 4

3.2 Description of Activities ................................................................................................................. 4

3.2.1 Project Overview ................................................................................................................................... 4

3.2.2 Activities Undertaken during the 2014-2015 Reporting Period ............................................................ 9

4. COMPLIANCE ASSESSMENT ............................................................................................................ 11

4.1 Compliance Evaluation................................................................................................................. 11

4.1.1 Environmental Audits and Inspections ................................................................................................ 11

4.1.2 Environmental Audits Conducted by Regulators ................................................................................ 12

4.1.3 Environmental Performance Reports .................................................................................................. 13

4.2 Compliance Designations ............................................................................................................. 14

4.3 Compliance Summary .................................................................................................................. 14

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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 Condition 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 14 February 2013. This is the second annual compliance report for EPBC 2011/5995, and covers the period 14 February 2014 to 13 February 2015 (referred to herein as the ‘2014-2015 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 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 Commonwealth

DC Drill Centre

Department Department of the Environment

DER Daily Environment Reports

DoE Department of the Environment

EPBC Environment Protection and Biodiversity Conservation

DSEWPaC Department of Sustainability, Environment, Water, Population and Communities (now the Department of the Environment)

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

FPSO Floating Production Storage Offtake Vessel

Guidelines Environment Annual Compliance Report Guidelines, Department of the Environment, 2014

HSE Health, Safety and Environment

ICT Incident Command Team

IMT Incident Management Team

MODU Mobile Offshore Drilling Unit

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Abbreviation Description

NEBA Net Environmental Benefits Analysis

NOPSEMA National Offshore Petroleum Safety and Environmental Management Authority

PER Public Environmental Report

PLEM Pipe Line End Manifold

OPGGS(E) Regulations Commonwealth Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009

OSCP Oil Spill Contingency Plan

OSMP Operational and Scientific Monitoring Program

SMPEP Shipboard Marine Pollution Prevention Emergency Plan

SOPEP Shipboard Oil Pollution Emergency Plans

I'd, "^e

DECLARATION OF ACCURACY

In accordance with the department's Guidelines, Apache as the approval holder makes the followingdeclaration.

Declaration of Accuracy

In making this declaration, I am aware that sections 490 and 491 of the Environment Protection gridBiodiversity Conservotion Act1999 (Cth) (EPBC Act) make it an offence in certain circumstances toknowingIy provide false or misleading information or documents. The offence is punish able on convictionby imprisonment or a fine, or both. I declare that all the information and documentation supporting thiscompliance report is true and correct in every particular. I am authorised to bind the approval holder to thisdeclaration and that I have no knowledge of that authorisation being revoked at the time of making thisdeclaration.

Signed

Full name

Position

Organisation

Date

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' ^\,^"^,. s. ^Mi Hopkinson

I 2.15/1. s

Regional HSE Manager - Australia

Apache Energy Ltd (ABN 39 009301964)

Coniston/Novara Field Development ProjectjEPBC 2011/5995j Annual Compliance Report 2014-2015

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3. APPROVED ACTION

3.1 Regulatory Context

Apache Energy Ltd (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 2038.

Table 3-1 Details of Approved Action under EPBC 2011/5995

EPBC number 2011/5995

project name Coniston/Novara Field Development Project, Western Australia

Approval holder Apache Energy Ltd

ABN 39 009 301 964

Approved Action 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].

Date of commencement of the Project

14 February 2013

Reporting Period for this Annual Compliance Report

14 February 2014 to 13 February 2015

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 Apache-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.

However, this annual report is concerned with compliance with EPBC 2011/5995 only.

3.2 Description of Activities

3.2.1 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).

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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 Apache-operated Van Gogh field development. The Project will use the FPSO associated with Van Gogh, the Ningaloo Vision (Figure 3-3). This Apache-operated project, a joint venture between Apache and INPEX, commenced in late 2011 and is due for completion in 2015. Further project information is available on Apache’s website: http://www.apachecorp.com/Operations/Australia/Coniston_Development_Project/index.aspx

http://www.apachecorp.com/Operations/Australia/Coniston_Development_Project/index.aspx

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Figure 3-1 Coniston/Novara Field Development Project Location Map

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Figure 3-2 Coniston/Novara Field Development Project and Ningaloo Vision FPSO, showing 500 m

exclusion zone at each drill centre location

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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)

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3.2.2 Activities Undertaken during the 2014-2015 Reporting Period

Pre-lay anchors were installed on 19 and 24 September 2013 by the vessel Skandi Atlantic, and the semi-submersible mobile offshore drilling unit (MODU) arrived on location on 24 December 2013.

During the 2014-2015 reporting period, drilling was performed by a semi-submersible MODU named the Atwood Falcon, operated by Atwood Oceanics.

To date, there has been no activity associated with the Novara field.

No project activities have occurred since 15 January 2015.

Project activities conducted during the 2014-2015 reporting period can be summarised as follows:

• Coniston 10H Well

o Drilled the intermediate section and ran and cemented casing.

o Drilled two production laterals and ran lower completions.

o Ran the upper completion and suspended the well ready for production.


o Attempted to run the upper completion, but encountered technical difficulties with some wellhead equipment. Suspended the well for re-entry at a later date.








o Drilled three production laterals and ran lower completions.


o Recovered the BOP.

o Recovered anchors and handed Atwood Falcon over to next operator.




o Completed drilling the third production lateral and prepared to run lower completion on that lateral.

o Completed operations on the well after running the upper completion.

o Recovered the blowout preventer (BOP) for scheduled maintenance.


o Ran and tested the BOP.


o Drilled three production laterals and ran lower completions.

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Installation activities conducted during the reporting period were undertaken by the offshore construction vessel Skandi Acergy owned by DOF Subsea and chartered to Subsea 7. Activities undertaken by Skandi Acergy included:

• the recovery and replacement of Van Gogh flowlines;

• the tie in of the Gas Production Manifold; and

• associated pre-commissioning activities.

Support vessels utilised during the 2014-2015 reporting period were involved in the project for short periods (less than 3 months). These vessels were:

• UOS Endeavour, Sea Frost and Go Sirius (Contractor – Go Marine)

• SL Mallard (Contractor – Smit Lamnalco)

• Maersk Server (Contractor – Maersk Supply) and

• Jetwave Maddison (Contractor – Jetwave Marine Services).

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4. COMPLIANCE ASSESSMENT

4.1 Compliance Evaluation

Apache has based its assessment of compliance with EPBC 2011/5995 on environmental audits and performance reports conducted or prepared during the 2014-2015 reporting period. These sources of information are discussed in the following sub-sections.

4.1.1 Environmental Audits and Inspections

Internal audits and inspections are a key component of Apache’s compliance assurance program for EPBC 2011/5995.

During the 2014-2015 reporting period a number of environmental audits and inspections were undertaken by Apache in accordance with Apache’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.

The audits / inspections conducted by Apache aim to identify non-conformances against audit criteria, which are typically based on the relevant Environment Plan and other environmental standards and requirements maintained by Apache. Environment Plan Summaries for the Coniston/Novara Field Development Project are publicly available via NOPSEMA: http://www.nopsema.gov.au/environmental-management/ep-submissions-and-summaries/search/

The pre-mobilisation inspection of one of the vessels, the SL Mallard, found that the oil spill exercise schedule required updating and that not all crew had received an environmental induction. Apache required that these issues were rectified prior to mobilisation; therefore, they do not represent non-compliances against EPBC 2011/5995.

None of the other environmental inspections or in-field audits identified non-compliances with EPBC 2011/5995 conditions of approval.

Table 4-1 provides an overview of the environmental audits and inspections conducted of relevance to EPBC 2011/5995 during the 2014-2015 reporting period.

Table 4-1 Environmental Audits and Inspections Conducted during the 2014-2015 reporting period relevant to activities conducted under EPBC 2011/5995

Date Facility / Vessel

Audit / Inspection Type

Audit / Inspection Criteria

18/02/2014 Skandi Acergy Pre-Mobilisation Inspection

Coniston/Novara Construction and Installation Environment Plan

19/02/2014 Smit Lamnalco Mallard

Pre-Mobilisation Inspection

Coniston/Novara Construction and Installation Environment Plan Apache’s Environmental Requirements for Offshore Marine Vessels

20-21/03/2014

Skandi Acergy In-field audit Coniston/Novara Construction and Installation Environment Plan Apache’s Environmental Requirements for Offshore Marine Vessels

28/03/2014 Maersk Server In-field audit Apache’s Environmental Management Standards for MODU Support Vessels

http://www.nopsema.gov.au/environmental-management/ep-submissions-and-summaries/search/

http://www.nopsema.gov.au/environmental-management/ep-submissions-and-summaries/search/

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Date Facility / Vessel

Audit / Inspection Type

Audit / Inspection Criteria

23/05/2014 Jetwave Maddison

Pre-Mobilisation Inspection

Balnaves Development Environment Plan Apache’s Environmental Management Standards for MODU Support Vessels

17/07/2014 Go Sirius Desktop Pre-Mobilisation Assessment

Coniston/Novara Construction and Installation Environment Plan

02-04/07/2014

Atwood Falcon

In-field audit Coniston/Novara Phase II Drilling Environment Plan Commonwealth Waters

04/12/2014 UOS Endeavour

In-field audit Apache’s Environmental Management Standards for MODU Support Vessels

06/12/2014 Sea Frost

In-field audit Apache’s Environmental Management Standards for MODU Support Vessels

4.1.2 Environmental Audits Conducted by Regulators

NOPSEMA conducted an inspection against the Coniston/Novara Phase II Drilling Environment Plan between 29 and 31 October 2014.

NOPSEMA’s inspection findings relevant to EPBC 2011/5995 were as follows:

1. Training and competency of offshore oil spill responders

Finding: The OSCP states that “Apache key personnel are adequately trained, understand and are capable of fulfilling their assigned role in the OSR”. While the designated on-scene commander demonstrated an understanding of the position’s roles and responsibilities, no documented evidence of specific training other than Coniston/Novara leadership induction were sighted. Inspectors also found that while personnel signed off that they had received the Atwood Falcon environmental induction, there was no evidence that personnel were required to undertake a written assessment at the conclusion of the slide presentation to assess competency or that personals understanding was formally assessed as stated in the EP.

Recommendations: Ensure measures are in place to ensure personnel with key roles in OSR have appropriate competency and training.

The offshore induction process to be reviewed to reflect the requirements contained within the EP.

Apache Response / Action:

In accordance with Apache's Incident Command and Management Manual, On-scene Commanders (such as Drilling Supervisors) are now required to complete the AMOSC-delivered Oil Spill Response Familiarisation Training. Apache intends to commence the training in Q1 2015.

Apache will introduce a reporting metric to ensure inductions are completed as required.

Implications for EPBC 2011/5995:

The recommendations made by NOPSEMA represented opportunities for improvement to Apache’s existing OSR training program, and did not represent a non-compliance with EPBC 2011/5995 approval conditions.

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2. Physical Equipment Tracker buoys

Finding: Documentation sighted with tracker buoys states that batteries must be replaced every 24 months. No evidence was sighted that tracker buoys maintenance requirements were managed through preventative maintenance type system to ensure they are appropriately maintained.

Recommendation: Tracker Buoys be included in a preventative maintenance system.

Apache Response / Action:

Tracker buoys are deployed annually to test the deployment and retrieval process, and functionality of the buoys (including batteries) and satellite tracking software. Maintenance is completed during or after the test as necessary. Testing requirements are stipulated in Apache's Oil Spill Response Exercise and Training Schedule, which is valid until 2016. The annual tracker buoy test for the Atwood Falcon at the Coniston/Novara location was performed on 21 October 2014. Therefore, Apache's current tracker buoy testing and maintenance program for contracted rigs is considered adequate. Therefore, no further action was proposed.

Implications for EPBC 2011/5995:

No implication for compliance status of EPBC 2011/5995.

Apache provided its response to NOPSEMA on 8 January 2015 and NOPSEMA deemed the inspection to be closed on 3 February 2015, although NOPSEMA noted that its recommendations may be followed-up further if it elects to undertake an additional inspection for this activity in the future.

4.1.3 Environmental Performance Reports

In accordance with accepted Environment Plans for the Coniston/Novara Field Development Project, Apache has committed to providing routine environmental performance reports to NOPSEMA. Table 4-2 lists the environmental performance reports prepared by Apache that are relevant to the 2014-2015 reporting period for EPBC 2011/5995.

Table 4-2 Coniston/Novara Field Development Project Environmental Performance Reports for the 2014-2015 reporting period

Date of report Report title Period covered

26/09/14 Annual Environmental Performance Report for Coniston/Novara Phase II Drilling

19 September 2013 to 10 July 2014

17/10/14 Environmental Performance Report: Coniston/Novara Construction and Installation Environment Plan - Phase 2

27 December 2013 to 20 July 2014

The performance reports did not identify any non-conformances relevant to EPBC 2011/5995 during the 2014-2015 reporting period.

These reports assess environmental performance based on the following sources of evidence, where relevant:

• Environmental audits and inspections, including pre-mobilisation inspections and – for support vessels – International Marine Contractors Association (IMCA) Common Marine inspection Document (CMID) inspections;

• Daily, Weekly and/or Monthly environmental reports and checklists prepared by the MODU and support vessels;

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• Environmental incident reports;

• Other drilling operations documentation (e.g. daily operations reports, persons on-board (POB) lists, end-of-well reports etc.);

• Interviews conducted with Apache personnel and contractors.

4.2 Compliance Designations

In accordance with the department’s Guidelines, Table 4-3 describes the compliance designations used in this report.

Table 4-3 Compliance Designations

Compliant ‘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.

Non-compliant 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.

Not applicable 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 2014-2015 reporting period. For example a condition which applies to an activity that has not yet commenced.

4.3 Compliance Summary

Apache’s compliance with EPBC 2011/5995 for the 2014-2015 reporting period can be summarised as follows:

• Compliant: 7 conditions

• Non-compliant: 2 conditions

• Not Applicable: 5 conditions

Table 4-4 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 2014-2015 reporting period, and provides commentary on evidence and corrective and preventative actions.

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Table 4-4 Compliance Summary for EPBC 2011/5995 Coniston/Novara Field Development Project for the 2014-2015 reporting period

Condition Number

Condition 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.

Not applicable The commencement date for the approved action was 14 February 2013. Therefore, Condition 1 did not apply during the 2014-2015 reporting period.

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.

Non-compliant Environmental records relating to activities undertaken for Coniston/Novara Field Development Project are maintained on Apache’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.

On 3 December 2014, the department wrote to Apache alleging that Condition 2 had been contravened, as follows:

a) In correspondence with the department in August 2014, Apache incorrectly stated that its annual compliance report for EPBC 2011/5995 had been published in May 2014 (ref. Condition 3).

b) Apache’s annual compliance report 2013-2014 did not reflect the contravention of Condition 3.

c) Apache did not detect the contravention of Condition 8, which

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Condition Number


Evidence/Comments

occurred on 17 September 2013, until 25 August 2014. This contravention was subsequently reported in the annual compliance report 2013-2014.

Therefore, Apache has reported that it did not fully comply with Condition 2 during the 2014-2015 reporting period.

On 23 February 2015 the department directed Apache to undertake an independent environment audit in response to these contraventions. Detailed corrective and preventative actions are to be determined following the outcomes of this audit.

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.

Non-compliant The approved action commenced on 14 February 2013; therefore, annual compliance reports for EPBC 2011/5995 must be published by 14 May each year.

Apache published its annual compliance report for EPBC 2011/5995 for 2013-2014 on 25 September 2014 (available at: http://www.apachecorp.com/Sustainability/Environment/Public_notices/index.aspx), which was more than 4 months after the due date. Also refer to comments provided under Condition 2.

Therefore, Apache has reported that it did not fully comply with Condition 3 during the 2014-2015 reporting period.

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.

Not applicable Activities during the 2014-2015 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 2014-2015 reporting period.

http://www.apachecorp.com/Sustainability/Environment/Public_notices/index.aspx


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Condition Number


Evidence/Comments

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 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.

Not applicable No requests were made to Apache by the Minister to revise the plans or programs specified in conditions of EPBC 2011/5995 during the 2014-2015 reporting period.

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 14 February 2013. Therefore, this condition no longer applies.

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Condition Number


Evidence/Comments

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 No plans or programs referred to in EPBC 2011/5995 were developed or revised during the 2014-2015 reporting period.

The following plans and programs were published in 2013 and were available on Apache’s website throughout the 2014-2015 reporting period:

• Coniston-Novara Phase 1 Drilling Oil Spill Contingency Plan including Operational and Scientific Monitoring Program (Revision 3, dated 30/01/2013).

o Approved by DSEWPaC on 31 January 2013. o Published on the Apache website on 28 March 2013

(Note: On 28 February 2013 DSEWPaC extended the timeframe for publication of the Phase 1 Drilling OSCP until 31 March 2013 without breach of conditions of approval.)

• Coniston-Novara Installation and Construction Oil Spill Contingency Plan including Operational and Scientific Monitoring Program (Revision 2, dated 6 March 2013).

o Approved by DSEWPaC on 12 March 2013. o Published on the Apache website on 10 April 2013.

• 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 2013. o Published on the Apache website on 12 October 2013.

• 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 (outside the 2014-2015 reporting period).

o To be published within one month of approval.

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Condition Number


Evidence/Comments

Published plans and programs can be found at: http://www.apachecorp.com/Sustainability/Environment/Public_notices/index.aspx

Note: Redactions were made to the OSCPs/OSMPs before publishing to address Apache’s 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 (Condition 14); however, this plan is not required until 12 months before commencement of the decommissioning phase.

Therefore, Apache considers that it was in compliance with Condition 7 during the 2014-2015 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 Apache within the Exmouth Gulf during the period 15 September to 31 October 2014.

Evidence of compliance is available in the form of Daily Vessel Reports, which are provided by all vessels on contract to Apache and indicate vessel activities and positions. Only two of the vessels listed in Section 3.2.2 were on contract to Apache during the period 15 September to 31 October 2014, i.e. UOS Endeavour and Sea Frost. Throughout this period both vessels were running out of Dampier and performed standby and supply activities for Atwood Falcon, and the locations provided in Daily Vessel Reports indicated that neither of the vessels entered the Exmouth Gulf.

As reported in Apache’s annual compliance report for the period 2013-2014 (September 2014), Condition 8 was contravened on 17 September 2013. Enforcement of this requirement is through the relevant Environment Plan accepted by NOPSEMA. In addition, Apache’s Marine



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Condition Number


Evidence/Comments

Superintendent is responsible for communicating to all vessels contracted to Apache that entry to the Exmouth Gulf is prohibited during the period 15 September to 31 October, regardless of whether the vessels are contracted to support Coniston/Novara Field Development Project activities.


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.

Compliant The Environment Plans accepted by NOPSEMA provide for marine fauna / vessel interaction management controls and address the requirements of Part 8 of the EPBC Regulation.

For example, for the Coniston/Novara Installation activities Apache included the following management controls in Section 4.1 of the Coniston/Novara Environment Plan (Section 6.3 of Coniston/Novara Drilling EP):

Fauna Observation Kits

All vessels have fauna observation kits (including as a minimum binoculars and fauna observation recording sheets) on board, which are checked/ inspected during vessel pre-mobilisation inspection and in-field audits undertaken by Apache.

All cetacean and whale shark sightings are recorded on the Apache Marine Fauna Sighting Datasheet with data submitted to Department of Environment.

Apache provides hard copies (as well as electronic) of the Marine Fauna Sighting Datasheets to the vessels, the datasheets which are completed on the vessel are emailed to Apache and all sightings are registered on Apache’s Marine Fauna Sighting database. Approximately every 6 months the information is emailed to [email protected]. Sightings are recorded on the Daily Environment Report (required for all

mailto:[email protected]

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Condition Number


Evidence/Comments

vessels) provided to Apache.

Apache also provides a marine fauna identification poster to the vessels, copies of which are put up around the vessel to aid identification.

Crew Training

The vessel crew is provided with basic information on procedures to manage interactions between vessels and marine fauna in the vessel environment induction. A short assessment is undertaken for all crew at the end of these inductions.

The Leadership induction is provided to the Vessel Leadership Team (Vessel Master), who also undertake the crew induction.

Vessel Operation

The interaction of all vessels with cetaceans and whale sharks will be consistent with Part 8 of the EPBC Regulations 2000, which for these activities includes the following:

o A vessel will not travel at greater than 6 knots within 300 m (caution zone) of a cetacean (or whale shark) known to be in the area;

o A vessel will not approach closer than 100 m of a cetacean (or whale shark) known to be in the area; and

o If a dolphin approaches the vessel or comes within 100 m the vessel master must not change the course or speed of the vessel suddenly.

Apache provides a “Quick Reference Guide” of the environment commitments (included in all EPs that are on the vessel), which includes the key requirements for interactions with marine fauna as per Part 8 of the EPBC Regulations.

The Vessel Leadership Team is also provided with references, such as

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Condition Number


Evidence/Comments

Australian National Guidelines for Whale and Dolphin Watching 2005.

Aircraft

Helicopters are the only aircraft used by the Coniston/Novara Field Development Project. The contractor for helicopters is Bristows Group, which has flight procedures and a Cetacean Policy that are consistent with Part 8 of the EPBC Regulations.

Apache reports conformance with these management controls to NOPSEMA in compliance reports prepared for each Environment Plan, upon completion of the activity.


10 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:

Compliant As discussed under Condition 7, the Coniston/Novara Field Development Project OSCPs/OSMPs developed in accordance with EPBC 2001/5995 can be found on Apache’s website: http://www.apachecorp.com/Sustainability/Environment/Public_notices/index.aspx

As detailed under Condition 7, each of the OSCPs (incorporating OSMPs) for drilling and construction/installation activities under EPBC 2011/5995 have been approved by the department prior to the 2014-2015 reporting period. The department’s approval is based on a review by officers of the department that finds that the OSCP/OSMP meets the requirements of conditions 10 and 11 of the EPBC 2011/5995.

For example, the Coniston-Novara Phase II Drilling OSCP/OSMP addresses the EPBC approval conditions for OSCPs as follows:

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;



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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;

Condition ref.

Key Sections in Coniston-Novara Phase II Drilling OSCP/OSMP addressing EPBC 2011/5995

10 a) 10 b)

4 – 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 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

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 18.10 – Reporting

10 h) 17 – Response Preparedness- Contingency Planning and Exercises

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 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 Conditions 10 and 11, and repairing environmental damage arising from potential spills, as determined from the results of the Operational and Scientific Monitoring Program;

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

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h) A demonstrated procedure for testing, maintenance and review of the OSCP.

With regard to implementation of the approved OSCP/OSMP, key activities include:

• Testing and drills: The OSCP commits Apache to routine testing on vessels and facilities (e.g. recorded in Daily Environment Reports (DER) and vessel logs) and major spill exercises to test communication and notification links between the facilities (MODU), Apache Incident Command team (ICT), service providers and others (including AMOSC and NOPSEMA).

• Personnel training and competency is managed and recorded using Apache’s training database, induction attendance and assessment sheets and DERs (e.g. spill drills).

• Oil spill response resources and equipment availability is included in routine environmental inspections environmental audits on vessels and facilities, including availability and maintenance of oil spill response equipment. This includes confirmation that spill kits are located near high risk areas and that scupper plugs were available to prevent unplanned liquid discharges from the decks. In addition, all vessels are required to maintain either a current Shipboard Oil Pollution Emergency Plans (SOPEP) or Shipboard Marine Pollution Prevention Emergency Plan (SMPEP).

• Appropriate contracts and agreements with key Service Providers are maintained.

In accordance with the requirements described in the OSCPs, exercises, tests and audits are designed to test preparedness for the following spill scenarios:

• Test #1: Tier 1 - rig or vessel releases (e.g. diesel spill): Regular oil spill response drills are conducted on vessels and facilities in accordance with an Incident Response Exercise Schedule, with records maintained in vessel logs and daily environmental reports. For example, the Skandi Acergy undertook oil spill

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.

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.

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exercises on 26 February 2014, 29 March 2014 and 1 June 2014. • Test #2: Tier 2 - vessel collision and Tier 3 - loss of well control

(e.g. diesel spill, topsides equipment failure) – Communication test: During the 2014-2015 reporting period an audit of the OSCP was completed 25 February 2014.

• Test #3: Tier 3 - loss of well control (e.g. tank rupture) – Desk top exercises are conducted for Tier 3 scenario. A Coniston-Novara Loss of Well Control Exercise was conducted on 19 August 2014.


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 With regard to OSMP requirements as noted under Condition 10, each of the OSCPs (incorporating OSMPs) for drilling and construction/installation activities under EPBC 2011/5995 have been approved by the department prior to the 2014-2015 reporting period. The department’s approval is based on a review by officers of the department that finds that the OSCP/OSMP meets the requirements of conditions 10 and 11 of the EPBC 2011/5995.

For example, the Coniston-Novara Phase II Drilling OSCP/OSMP address the EPBC approval conditions for OSMPs as follows:

Condition ref.

Key Sections in Coniston-Novara Phase II Drilling OSCP/OSMP addressing EPBC 2011/5995

11 a) 11 b)

14 – Operational and Scientific Monitoring Plan

11 c) 17.7 – Insurances for incident response and coverage of costs

11 d) 11 e)

14.2 – Scientific monitoring

11 f) 19.4 – Document review

Also see Condition 10 for further details of OSCP/OSMP.

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;

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;

c) Details of the insurance arrangements that have

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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.

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

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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 Condition 11;

b) any environmental management and remediation and/or equivalent determined necessary by the results of the OSMP.

Compliant No spills occurred during the 2014-2015 reporting period that required operational and scientific monitoring to be undertaken.

During the 2014-2015 reporting period, Apache’s insurance policies provided $1 billion for activities and damages related to sudden and accidental pollution coverage, plus another $660 million for General Liabilities (which also includes sudden and accidental pollution). The insurance covers each project, however the insurance value is apportioned on a per year basis at $120 million. These insurance policies provide coverage of costs arising from response (including type I and type II monitoring), clean-up, oiled wildlife and restoration activities.

These insurances are payable upon Apache being found liable for pollution within a court of law and are payable on released expenses. In addition, where costs will not be covered by insurances Apache commits to paying all costs associated with the remediation equivalent value where remediation cannot or will not be undertaken.


13 The development must be designed and constructed to allow for the complete removal of all structures and components above the seafloor during the decommissioning phase.

Compliant 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 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

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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.


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 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.

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.

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.

Therefore, Condition 14 did not apply during the 2014-2015 reporting period.

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