Casino-5 Well Intervention and Workover: EP Summary

Casino-5 Well
Intervention and
Workover
EP Summary
CONTROLLED DOCUMENT
CHN-EN-EMP-0004
Casino-5 Well Intervention and Workover
EP Summary
Table of Contents
1.0 Introduction ............................................................................................................................... 6
1.1 Titleholder Nominated Liaison Person ........................................................................................ 6
2.0 Location of the Activity ............................................................................................................ 7

2.1 Location....................................................................................................................................... 7
2.2 Operational Area ......................................................................................................................... 7
2.3 Casino VIC/L24 Hydrocarbon System Overview ........................................................................ 7
3.0 Description of the Activity ....................................................................................................... 9

3.1 Timing of the Activity ................................................................................................................... 9
3.2 MODU Positioning and Rig Up ................................................................................................... 9
3.3 Well Intervention Activities .......................................................................................................... 9
3.4 Well Workover Activities ............................................................................................................ 10
3.5 Support Operations ................................................................................................................... 10
4.0 Description of the Environment ............................................................................................ 12

4.1 Regional Setting ........................................................................................................................ 12
4.2 Environment that May be Affected ............................................................................................ 13
4.3 Ecological and Social Receptors .............................................................................................. 14
4.4 Conservation Values within the EMBA ..................................................................................... 26
5.0 Environmental Impact and Risk Assessment Methodology .............................................. 27

5.1 Impact and Risk Evaluation ...................................................................................................... 28
5.2 Monitor and Review .................................................................................................................. 32
6.0 Risk and Impact Evaluation ................................................................................................... 33

6.1 Physical Interaction (Collision with Marine Fauna) ................................................................... 33
6.2 Physical Interaction (Other Marine Users) ................................................................................ 34
6.3 Light Emissions ......................................................................................................................... 34
6.4 Underwater Sound Emissions................................................................................................... 36
6.5 Physical Presence – Seabed Disturbance................................................................................ 37
6.6 Atmospheric Emissions............................................................................................................. 38
6.7 Planned Discharge – Cooling Water and Brine ........................................................................ 39
6.8 Planned Discharge - Treated Bilge ........................................................................................... 41
6.9 Planned Discharge - Sewage and Food Waste ........................................................................ 42
6.10 Planned Discharge - Ballast Water and Biofouling ................................................................... 43
6.11 Operational Discharges – Subsea ............................................................................................ 44
6.12 Operational Discharges – Surface ............................................................................................ 45
6.13 Accidental Release – Waste ..................................................................................................... 46
6.14 Accidental Release – Loss of Containment (Minor) ................................................................. 47
6.15 Accidental Release - LOC (Vessel Collision) ............................................................................ 48
6.16 Accidental Release - LOC (Loss of Well Control Event)........................................................... 54
7.0 Ongoing Monitoring of Environmental Performance .......................................................... 56

7.1 Cooper Energy’s Health Safety Environment and Community Management System (HSEC
MS)............................................................................................................................................ 56
7.2 Environmental Performance Monitoring & Reporting ............................................................... 56
7.3 Management of Change (MoC) ................................................................................................ 57
CHN-EN-EMP-0004 / UNCONTROLLED WHEN PRINTED Page 2 of 98

EP Summary
8.0 Emergency Response Arrangements ................................................................................... 59

8.1 Oil Spill Response Strategies ................................................................................................... 59
8.2 Risk Assessment of Oil Spill Response Strategies ................................................................... 61
8.3 Emergency (Oil Spill) Response Arrangements and Capability ............................................... 69
8.4 Operational and Scientific Monitoring Plan (OSMP) ................................................................. 74
9.0 Stakeholder Consultation ...................................................................................................... 75

9.1 Consultation Approach .............................................................................................................. 76
9.2 Ongoing Consultation ............................................................................................................... 77
10.0 References............................................................................................................................... 86
11.0 Acronyms and Units ............................................................................................................... 88

11.1 Acronyms .................................................................................................................................. 88
11.2 Units .......................................................................................................................................... 92
List of Figures
Figure 1-1 Location of Vic/L24 and VIC/L30 ........................................................................................... 6
Figure 2-1 Casino-5 Field Layout Drawing ............................................................................................. 7
Figure 4-1 Conceptual Model of the Geomorphology and Benthic Habitats of the Otway Shelf .......... 12
Figure 4-2 Seabed Habitats at Casino wells and along the Casino Pipeline route .............................. 13
Figure 4-3 Casino-5 Well Intervention and Workover - EMBA ............................................................. 14
Figure 5-1 AS/NZS ISO 31000 – Risk Management Methodology ....................................................... 27
Figure 5-2 ALARP Decision Support Framework.................................................................................. 30
List of Tables
Table 2-1 Casino-5 Well Coordinates (Surface Locations) (GDA94) ...................................................... 7
Table 2-2 Physical Characteristics of Netherby Condensate .................................................................. 8
Table 4-1 Presence of Ecological Receptors within the Operational Area and the EMBA ................... 15
Table 4-2 Presence of Social Receptors within the Operational Area and the EMBA .......................... 21
Table 4-3 Summary of conservation values and sensitivities within the EMBA .................................... 26
Table 5-1 Definition of Consequence .................................................................................................... 28
Table 5-2 Definition of Likelihood .......................................................................................................... 30
Table 5-3 Cooper Energy Qualitative Risk Matrix ................................................................................. 31
Table 5-4 Cooper Energy Acceptability Evaluation ............................................................................... 31
Table 6-1 Physical Interaction (Collision with Marine Fauna) EIA / ERA .............................................. 33
Table 6-2 Physical Interaction (Other Marine Users) EIA / ERA ........................................................... 34
Table 6-3 Light Emissions EIA / ERA .................................................................................................... 34
Table 6-4 Underwater Sound Emissions EIA / ERA .............................................................................. 36
Table 6-5 Physical Presence – Seabed Disturbance EIA / ERA ........................................................... 37
Table 6-6 Atmospheric Emissions EIA / ERA ........................................................................................ 38
Table 6-7 Planned Discharge – Cooling Water and Brine EIA / ERA ................................................... 39
Table 6-8 Planned Discharge - Treated Bilge EIA / ERA ...................................................................... 41
Table 6-9 Planned Discharge – Sewage and Food Waste EIA / ERA .................................................. 42
Table 6-10 Planned Discharge - Ballast Water EIA / ERA .................................................................... 43
Table 6-11 Operational Discharges – Subsea EIA / ERA ..................................................................... 44
Table 6-12 Operational Discharges – Surface EIA / ERA ..................................................................... 45
Table 6-13 Accidental Release – Waste EIA / ERA .............................................................................. 46
Table 6-14 Accidental Release – Loss of Containment (Minor) EIA / ERA ........................................... 47
Table 6-15 Accidental Release - LOC (Vessel Collision) EIA/ERA ....................................................... 48
Table 6-16 Accidental Release - LOC (Loss of Well Control Event) EIA / ERA .................................... 54
Table 8-1 Suitability of Response Options for MDO and CHN Condensates Spills.............................. 59

EP Summary
Table 8-2 Source Control EIA / ERA ..................................................................................................... 61

Table 8-3 Monitor and Evaluate EIA / ERA ........................................................................................... 63
Table 8-4 Protect and Deflect EIA / ERA............................................................................................... 65
Table 8-5 Shoreline assessment and clean-up EIA / ERA .................................................................... 66
Table 8-6 Oiled Wildlife Response EIA / ERA ....................................................................................... 68
Table 8-7 Preparation Controls for Response Capabilities ................................................................... 69
Table 8-8 OPEP Exercise Schedule (Victorian Operations) ................................................................. 72
Table 9-1: Stakeholders for the Casino-5 well workover activity.......................................................... 75
Table 9-2: Stakeholder Feedback and Cooper Assessment of Claims/Objections............................... 78

EP Summary
Document Control
Ownership of this document remains within the Cooper Energy Pty Ltd Drilling and Completions
department. Any updates, technical and /or errata, and the subsequent re-distribution of this
document remains the responsibility of its author.
Document Revision and Amendment
Rev Date Details Author Reviewer Approver
0 03/01/2018 For Submission R Hooke / P J Earnshaw

Raitt
1 22/01/2018 Updated to address NOPSEMA comments R Hooke / P J Earnshaw

Raitt
Distribution List
Copy No. Recipient
1 General Manager Operations – Cooper Energy
2 HSEC Coordinator – Cooper Energy
3 Drilling HSEC Coordinator – Cooper Energy
4 Incident Operations Centre – Cooper Energy
5 Well Construction Manager – Cooper Energy

EP Summary
1.0 Introduction
Cooper Energy Pty Ltd (Cooper Energy), as the titleholder, proposed to undertake well
intervention and workover activities at the Casino-5 well in Production Licence VIC/L24 (Figure
1-1).
This Environment Plan (EP) Summary has been prepared to meet Regulation 11(4) of the
Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009
(OPGGSER) and summarises the information provided in the Casino-5 Well Intervention and
Workover EP accepted by the National Offshore Petroleum Safety and Environmental
Management Authority (NOPSEMA).
Figure 1-1 Location of Vic/L24 and VIC/L30
1.1 Titleholder Nominated Liaison Person

VIC/L24 titleholder’s nominated liaison person is:
Iain MacDougall (General Manager Operations), Cooper Energy Limited
Address: Level 10, 60 Waymouth Street, Adelaide, SA, 5000
Phone: (08) 8100 4900
Email: [email protected]

EP Summary
2.0 Location of the Activity
2.1 Location
The Casino wells, which includes Casino-5, are located in Production Licence VIC/L24, in water
depths ranging from 60-70 m, approximately 30 km southwest of Port Campbell, Victoria
(Figure 1-1). The field layout is showing in Figure 2-1 below.
The coordinates for the Casino-5 well is provided in Table 2-1.
Table 2-1 Casino-5 Well Coordinates (Surface Locations) (GDA94)
Locations Longitude (E) Latitude (S) Water Depth (m)
Casino-5 142o 44’ 44.599” 38o 47’ 43.68” 70
2.2 Operational Area

The “operational area” for the activities is the area where well intervention and workover-related
activities will take place and will be managed under the EP. This operational area includes:
• A 500 m designated petroleum safety zone (PSZ) around the MODU to manage vessel
movements. Note, the MODU will be located within the existing PSZ for the Casino-2 wellhead.
• An area out to 2 km from the MODU within which anchoring activities will be undertaken.
The transit of the MODU and support vessels is outside the scope of this Plan. These activities
are managed under the Commonwealth Navigation Act 2012.
Figure 2-1 Casino-5 Field Layout Drawing
2.3 Casino VIC/L24 Hydrocarbon System Overview

The CHN fields comprise four operating subsea wells, flowlines and umbilicals.
The condensate of the CHN reservoirs is classified as a Group 1 (non-persistent) oil. There is
little variation in composition between the three reservoirs. On this basis, Netherby condensate
is representative of the three reservoirs. The condensate is highly evaporative when released

EP Summary
into the environment, with a zero percent estimated residual (persistent) component. Physical
characteristics of the Netherby condensate is provided in Table 2-2.
Table 2-2 Physical Characteristics of Netherby Condensate
Rm Netherby Condensate
API Gravity 51.2
Density@25oC g/ml 0.774
Dynamic Viscosity @ 25oC (cP) 0.14
Condensate Gas Ratio 0.6
Pour Point (oC) -54

Boiling Point Curve
Volatiles (<180oC) 84
Semi-volatile (180-265oC) 14
(% mass)
Low Volatility (265-380oC) 2
Residual (>380oC) -
Group I
2.3.1 Flow Rate

As outlined in the Well Operations Management Plan (CHN-DC-WMP-0001 Casino Henry
Netherby WOMP Rev 1) Cooper Energy has conducted reservoir simulation to identify the
maximum credible blow out rates for the field. The range of potential flows from wells ranges
considerably between the wells depending on the permeability, completion strategy and/or
reservoir pressure.
The maximum blowout rate for Casino-5 using industry recognised modelling software for the
existing 7" completion is 68 MMscfd; this drops to 42 MMscfd after the downsize 5-1/2"
completion tubing is installed.

EP Summary
3.0 Description of the Activity
3.1 Timing of the Activity

Activities covered under this plan are anticipated to commence in the first half of 2018.
Preparations for the MODU arrival including pre-lay of moorings and preparations for BOP
tethering system, may potentially occur 1-3 weeks prior, and are also described and assessed
within the EP.
The total expected duration for the Casino-5 workover is approximately 25 days, excluding
weather and operational delays. During this period any of the activities described in this EP
Summary may be undertaken, with normal operations conducted 24-hours a day.
3.2 MODU Positioning and Rig Up

Cooper Energy has engaged the Ocean Monarch semi-submersible MODU to undertake the
Casino-5 well intervention and workover.
The MODU will be towed to location where it is then moored prior to commencing activities.
Anchors may be placed on the seabed and tested by the support vessels prior to the MODU
arriving. Eight anchors will be required, with each having a footprint of approximately 30m2.
Each anchor is connected to large chain (84mm diameter) which runs along the seabed
towards the MODU for approximately 1500m; before rising towards the MODU. The final
mooring analysis will determine the anchor distance from the MODU and the chain on the
seabed.
3.2.1 Clump weight deployment
A BOP tethering system is also likely to be used to reduce wellhead cyclic stresses and
manage fatigue by arresting the motion of the BOP stack.
The tethering system comprises of up to 8 clump weights positioned around the BOP, which are
either pre-installed or installed on rig arrival, and connected to the outer frame of the BOP once
deployed to provide dampening of the BOP motion. Each clump weight has a footprint of
approximately 10m2.
3.3 Well Intervention Activities

Once the MODU has been positioned and secured, Cooper Energy plans to undertake well
intervention and workover activities at the Casino-5 well.
Well intervention activities planned for Casino-5 include:
• Isolation of the Casino-5 subsea tree from the subsea flowline. No fluids are discharged
to the environment during the process of isolation;
• Removal of marine growth and debris from subsea tree by jetting pressurised seawater
from a remotely operated vehicle (ROV), or scrubbing the cap. Small volumes of
chemicals and grit may be used to assist removal;
• Running and testing well control equipment (i.e. the blowout preventer (BOP)).
Operation of the BOP results in small volumes of control fluid (Transaqua HT) being
released to the environment (between 0.5L and 2.98L) when BOP valves are actuated.
Approximately 150 valve actuations are expected during the well activity for BOP testing
and verification purposes;
• Entry into the well using slickline / wireline to perform intervention activities. Small
volumes of gas (approximately 0.1 Mscf (3m3)) will be vented from pressure control
equipment (slickline lubricator) during slickline runs;

EP Summary
• Running and testing of a reservoir plug to isolate the well from the reservoir prior to well
workover activities. Once the reservoir plug is set, gas (approximately 48 Mscf
(1360m3)) within well tubing above the plug will be vented to atmosphere. During the gas
bleed off process, approximately 30m3 of brine will be pumped into the production tubing
from surface down to the reservoir plug. The brine above the reservoir plug is monitored
for well control verification;
• Cut tubing above the production packer and recover the upper completion string to the
MODU. This will result in the recovery of fluids, including brine, Mono-ethylene glycol
(MEG), corrosion inhibitor and biocide, aquifer fluids and reservoir gas to the MODU via
a bleed down package. An oil in water (OIW) separator will be used to reduce oil content
of the recovered fluids to <15ppm prior to the discharge. Components recovered with the
upper completion string will be returned to shore where they may either be subject to
diagnostics, inspection or disposal. There are no naturally occurring radioactive materials
(NORMS) expected in the tubing.
3.4 Well Workover Activities

With the reservoir isolated and upper completion string recovered to surface during the well
intervention activities described above, well workover activities can commence. Well Workover
activities will include:
• Remedial casing repair involving the use of wireline to run diagnostic tools and
components into the well. Casing will also be cut, resulting in the generation of metal
swarf which will be removed from the well either with magnets or viscous fluid pills that
will be discharged once circulated back to surface;
• Installation of new production casing;
• Wellbore clean-up to remove fluids (including brine, biocide, corrosion inhibitor) from
inside the production casing prior to running new upper completions. Clean-up fluids
used will include seawater, brine, viscous space, acid soaking and a surfactant;
• Installation of upper completion string;
• Circulating the well tubing to nitrogen. Nitrogen will be used to displace brine into the
annulus prior to removal of the reservoir plug and resumption of production.
Approximately 135bbls (21.5m3) brine is expected to be displaced out of the annulus and
discharged from the MODU;
• Well reinstatement; the reservoir plug will be recovered with slickline and lower crown
plug installed in the tubing hanger to suspend the well. Nitrogen will be bled off and
vented during slickline runs and testing of the lower crown plug.
Well testing or well flowback activities are not planned for the initial phase of Casino-5 workover
as the well will be cleaned up directly into the gathering network. Flowback is achieved by
opening the isolation valves to the pipeline with a ROV and then operating the well normally
under the control of Iona gas plant operators.
The well intervention and workover activities described above involve a variety of planned
emissions and discharges to the marine environment, such as completion fluids, control fluids,
brine and vented gas. These will be carefully controlled, and have been assessed in the Risk
and Impact Evaluation presented in Section 6.
3.5 Support Operations

The MODU will be supported by two or three anchor handling, tow and support (AHTS)
vessels. One vessel will remain on standby and in attendance to the MODU throughout the
workover program. Vessels will undertake the following support activities:

EP Summary
• Tow the MODU to/from the Casino-5 well location; and

• Supply provisions (food, fuel, bulk materials) and equipment to the MODU and remove
waste from the MODU to shore.
• The support vessels are part of the petroleum activity when:
• Within the MODU PSZ; and
• Whilst undertaking activities such as laying anchors for the MODU, within the 2km
Operational Area.
The transit of the MODU and support vessels is outside the scope of the EP. These activities
are managed under the Commonwealth Navigation Act 2012.
Project vessels (MODU and AHTS vessels) will undertake a variety of planned emissions and
discharges to the marine environment, such as cooling water and brine, treated bilge, sewage
and food waste, and ballast water. These will be carefully controlled, and have been assessed
in the Risk and Impact Evaluation presented in Section 6.
Personnel will access the Ocean Monarch by helicopter, which is expected to operate out of
Warrnambool airfield. Flights to the MODU are expected 5-7 days each week. Helicopters
utilised are expected to be Agusta Westland AW139 or similar type. Helicopter operations
within the operational area are limited to landing and take-off on the helideck of the MODU.
A ROV will be used during the activities. The ROV is deployed from the MODU/support vessel
and can be fitted with various tools and camera systems which can be used to capture imagery
of the environment and operations. The ROV will be used to assist in the running of the well
control equipment, operation of valves on subsea infrastructure, as well as visual and sonar
survey.

EP Summary
4.0 Description of the Environment
4.1 Regional Setting

The Casino-5 well is located within the South-east Marine Bioregion, on the Otway Shelf,
approximately 30 km southwest of Port Campbell, Victoria. The Otway environment includes
very steep to moderate offshore gradients, high wave energy and cold temperate waters
subject to upwelling events.
The Otway shelf is comprised of Miocene limestone beneath a thin veneer of younger
sediments (James et al., 2013). Based on assessment of sampled sediments, it was concluded
that the Otway continental margin is a swell-dominated, open, cool-water, carbonate platform. A
conceptual model was developed that divided the Otway continental margin into depth-related
zones, each with different typical habitat types (Figure 4-1). The Casino-5 well is located in
approximately 70 m water depth, at the transition between shallow and middle shelf zones
(Figure 4-1).
(Source: James et al., 2013)
Figure 4-1 Conceptual Model of the Geomorphology and Benthic Habitats of the Otway Shelf
Surveys along the Casino pipeline route between the HDD exit point (18 m depth) and
approximately 60 m water depth, indicated primarily open sand habitat with infauna
communities of bivalves, polychaetes and crustaceans, and with little or no epifauna present
(Figure 4-2) (Santos, 2004). A side-scan survey of the Otway gas pipeline (adjacent to the
Casino pipeline) undertaken by Woodside (2003) showed similar results with soft seabed
characterised by coarse sand and containing mega-ripples. It was reported that given the
nature of the highly mobile sand, there is likely to be an inherent temporal and spatial variability
of infauna and epibiota.

EP Summary
An area along the pipeline corridor at KP19.5 (i.e. beyond the operational area), was
characterised by a localised and isolated sponge reef habitat. The area had a diverse range of
epifauna, including sponges, hydrozoans, bryozoans and algae; as well as demersal fish
species. This sponge reef habitat also represents the only potential abalone and rock lobster
habitat along the pipeline route (Santos, 2004).
Sponges and epifauna may also occur, albeit in reduced density and diversity, intermittently
along the pipeline alignment between KP19.5 and the well sites. Kelp-dominated reef (known to
occur elsewhere in the region) do not appear to be a feature along the pipeline alignment as
covered by the acoustic survey (Santos, 2004).
Beyond 60 m water depth and out to the well sites (i.e. approximately 70 m water depth), the
seabed is characterised by outcrops of hard substrate with low relief and structural complexity,
separated by gullies of sand or gravel (Santos, 2004). Survey footage in the vicinity of the
Casino wells (e.g. locations 1 and 2 from the 2002 survey (see Figure 4-2)) show a sparse
cover of epifauna, typically dominated by sponges. The presence of some small fish species
were also recorded in the vicinity of the wells (Santos, 2004).
Therefore, based on the above survey information, it is expected that the benthic habitat
around the Casion-5 well site, and within the operational area, is typically soft sediment, with
some outcropping of hard substrate, and a sparse coverage of epifauna (e.g. sponges or
bryozoans).
Figure 4-2 Seabed Habitats at Casino wells and along the Casino Pipeline route
4.2 Environment that May be Affected

The Environment that May be Affected (EMBA) is based on the maximum credible hydrocarbon
spill event that might occur during petroleum activities. For the activities under this EP, the
EMBA is based on hydrocarbon exposures above the impact thresholds for the accidental
release of marine diesel oil from a vessel collision and the release of condensate from a loss of
well control event. Based on stochastic modelling results (APASA 2013; RPS-APASA 2017a),
the EMBA extends into waters off the western Victoria coast (Figure 4-3).

EP Summary
Figure 4-3 Casino-5 Well Intervention and Workover - EMBA
4.3 Ecological and Social Receptors

The following tables show the presence of ecological (Table 4-1) and social (Table 4-2)
receptors that may occur within the operational area and EMBA.
The Operational Area is 2km from the well location, as defined in Section 2.2, and the EMBA is
defined in Section 4.3 above. The tables below present information from the relevant EPBC
Protected Matters Searches, and from other literature and data available for the Otway region.
Examples of values and sensitivities associated with each of the ecological or social receptors
have been included in the tables. These values and sensitivities have been identified based on:
• Presence of listed threatened or migratory species, or threatened ecological
communities;
• Presence of BIAs;
• Presence of important behaviours (e.g. foraging, roosting or breeding) by fauna,
including those identified in the EPBC Protected Matter searches;
• Provides an important link to other receptors (e.g. nursery habitat, food source,
commercial species); or
• Provides an important human benefit (e.g. community engagement, economic benefit).

EP Summary
Table 4-1 Presence of Ecological Receptors within the Operational Area and the EMBA
Receptor Receptor Type Receptor Values and Operational Area EMBA

Group Description Sensitivities
Habitat Shoreline Rocky  Foraging habitat – Not present. ✓ The coastal environment in the Otway
(e.g. birds) region is a mixture of sandy beaches
and rocky coasts, including the well
 Nesting or known limestone and sandstone cliffs
Breeding habitat and rock formations of the Great Ocean
(e.g. birds, Road.
pinnipeds,
Sandy turtles) – ✓ Each of these shoreline types has the
 Haul-out sites potential to support different flora and
(e.g. pinnipeds) fauna assemblage due to the different
physical factors (e.g. waves, tides, light
etc.) influencing the habitat; for
example:
 Australian Fur-seals are known to
use rocky shores for haul-out
and/breeding;
Gravel/Cobble – ✓
 Birds species may use sandy, rocky
or cliff areas for roosting and
breeding sites; and
 Cliff and rocky coasts can provide a
hard substrate for sessile
invertebrate species (e.g. barnacles,
sponges etc.) to attach to.
Saltmarsh Saltmarsh  Nursery habitat – Not present. ✓ Saltmarshes are widespread along the
(e.g. Victorian coast, typically within
ecosystem
crustaceans, estuaries and coastal embayments. The
fish) ‘Subtropical and Temperate Coastal
Saltmarsh’ is listed as a vulnerable TEC
 Threatened – ✓ under the EPBC Act, and it’s known
Ecological distribution includes the southern and
Community eastern coasts of Australia. Known
areas of saltmarsh within the EMBA
include Merri River (Warrnambool, Port
CHN-DC-EMP-0001 / UNCONTROLLED WHEN PRINTED Page 15 of 98

EP Summary

Campbell creek, and Moyne River
estuary (Port Fairy).
Soft Sediment Unvegetated soft  Key habitat (e.g. ✓ Sediment is ubiquitous on the open ✓ Sediment is ubiquitous on the open
sediment benthic ocean floor. The Otway Shelf is ocean floor, throughout both intertidal
invertebrates)
substrates comprised of Miocene limestone and subtidal areas. The Otway Shelf is
beneath a thin veneer of sediments. comprised of Miocene limestone
The seabed within the operational area beneath a thin veneer of sediments.
is expected to be typically soft Shallow water (<20 m) water depth is
sediment, with some outcropping of typically open sand with intermittent
hard substrate, and a sparse coverage patch reefs with algae coverage.
of epifauna (e.g. sponges or Deeper water depths (>20 m) is
bryozoans). dominated by open sandy habitat with
sparse coverage of epifauna (e.g.
sponges or byrozoans). Small, isolated
patches of sponge reef may also occur.
Seagrass Seagrass  Nursery habitat – Not present. ✓ Seagrass generally grows in soft
meadows (e.g. sediments within intertidal and shallow
crustaceans,
subtidal waters where there is sufficient
fish)
light. Known seagrass areas include
 Food source
(e.g. dugong, offshore from Warrnambool, extending
turtles) east from Port Campbell (including
within the Twelve Apostles Marine
Park).

EP Summary

Algae Benthic  Food source – Not present. ✓ Benthic microalgae are ubiquitous in
microalgae (e.g. gastropods) aquatic areas where sunlight reaches
the sediment surface. Macroalgae
communities are generally found on
intertidal and shallow subtidal rocky
substrates. Intermittent patch reefs
Macroalgae  Nursery habitat – ✓ dominated by the brown alga, Ecklonia
(e.g. sp., with red algae and coralline algae
crustaceans, also present, have been recorded in
fish)
shallow (<20 m) water depths).
 Food source
(e.g. birds, fish) The ‘Giant Kelp Marine Forests of
South East Australia’ is listed as an
endangered TEC under the EPBC Act.
 Threatened – ✓
Ecological The ecological community is
Community characterised by a closed to semi-
closed surface or subsurface canopy of
Macrocystis pyrifera. This ecological
community predominantly occurs in
Tasmania; however small areas of
Giant Kelp have been identified within
the EMBA within the Merri Marine
Sanctuary.
Coral Hard and soft  Nursery habitat – Not present. ✓ Soft corals can be found at most depths
coral (e.g. throughout the continental shelf, slope
crustaceans,
communities and offslope regions, to well below the
fish)
limit of light penetration. Soft corals
 Breeding habitat
(e.g. fish) (e.g. sea fans, sea whips) may occur as

EP Summary

part of mixed reef environments in
waters along the Otway coast.
Marine Plankton Phytoplankton  Food Source ✓ Phytoplankton and zooplankton are ✓ Phytoplankton and zooplankton are
Fauna and zooplankton (e.g. whales, widespread throughout oceanic widespread throughout oceanic
turtles)
environments. No defined area of environments; however increased
upwelling occurs within the operational abundance and productivity can occur
area. in areas of upwelling (e.g. Bonney
Coast Upwelling).
Seabirds and  Listed Marine ✓ 30 seabird and shorebird species (or ✓ 77 seabird and shorebird species (or
Shorebirds Species species habitat) may occur within the species habitat) may occur within the
 Threatened ✓ operational area; with foraging ✓ EMBA; with breeding, foraging and
Species behaviours identified for some albatross roosting behaviours identified for many
 Migratory ✓ and tern species. The operational area ✓ species. The EMBA intersects foraging
Species intersects foraging BIAs for: Antipodean BIAs for: Antipodean Albatross,
 BIA – –
Albatross, Wandering Albatross, ✓ Wandering Albatross, Buller’s
Aggregation Buller’s Albatross, Shy Albatross, Albatross, Shy Albatross, Campbell
Campbell Albatross, Black-browed Albatross, Black-browed Albatross,
 BIA – Breeding – ✓
Albatross, and the Common Diving- Common Diving-Petrel, Short-tailed
 BIA – Foraging ✓ Petrel. ✓ Shearwater, and the Australasian
Gannet. There is also an aggregation
 Behaviour – – ✓
Breeding BIA for the Australasian Gannet at the
eastern end of the EMBA, at Point
 Behaviour – ✓ ✓
Danger and Lawrence Rocks (south of
Foraging
Portland). A breeding BIA for the
 Behaviour – – ✓ Common Diving-Petre also exists for
Roosting
Lady Julia Percy Island.

EP Summary

Marine Benthic and  Food Source ✓ A variety of invertebrate species may ✓ A variety of invertebrate species may
Invertebrates pelagic (e.g. whales, occur within the operational, including occur within the EMBA, including
turtles)
invertebrates sponges and bryozoans. Infauna may sponges, bryozoans and arthropods.
 Commercial ✓ also be present within the sediment ✓ Infauna studies along the Victorian
Value profile. coast showed high species diversity,
Given the lack of suitable habitat, that increased with water depth;
commercially important species (e.g. crustacean were the dominant taxa in
rock lobster, Giant Crab) are unlikely to each depth class.
occur in significant numbers within the Commercially important species (e.g.
operational area. abalone, rock lobster, and Giant Crab)
may occur within the EMBA.
Fish Fish  Threatened ✓ One threatened fish species (or species ✓ One threatened fish species (or species
Species habitat) may occur within the habitat) may occur within the
operational area, the Australian operational area, the Australian
Grayling. Note, this species is typically Grayling. Note, this species is typically
found in freshwater streams; however, found in freshwater streams; however,
 Commercial ✓ may spend part of its lifecycle in coastal ✓ may spend part of its lifecycle in coastal
Value waters. waters.
Commercial fish species may occur Commercial fish species may occur
within the operational area, including within the EMBA, including species of
species of wrasse (e.g. Bluethroat wrasse, flathead, and warehou,
Wrasse).
Sharks and Rays  Threatened ✓ Three shark species (or species habitat) ✓ Three shark species (or species habitat)
Species may occur within the operational area. may occur within the EMBA; with
 Migratory ✓ No important behaviours or BIAs have ✓ foraging behaviours identified for the
Species been identified. Great White Shark. There is also a
 BIA – Distribution ✓ ✓ foraging BIA at the eastern end of

EP Summary

 BIA – Foraging – ✓ EMBA (extending approximately

between Port Fairy and Portland), and a
 Behaviour – – ✓ wider distribution BIA present in the
Foraging
area.
Syngnathids  Listed Marine ✓ 27 syngnathid species (or species ✓ 29 syngnathid species (or species
Species habitat) may occur within the habitat) may occur within the EMBA. No
operational area. No important important behaviours of BIAs have been
behaviours of BIAs have been identified.
identified.
Marine Reptiles Turtles  Listed Marine ✓ Three marine turtle species (or species ✓ Three marine turtle species (or species
Species habitat) may occur within the habitat) may occur within the EMBA,
 Threatened ✓ operational area. No important ✓ with breeding behaviours identified for
Species behaviours of BIAs have been the Leatherback Turtle. No BIAs have
 Migratory ✓ identified. ✓ been identified within the vicinity.
Species
Breeding
Marine Mammals Pinnipeds  Listed Marine ✓ Two pinniped species (or species ✓ Two pinniped species (or species
Species habitat) may occur within the habitat) may occur within the EMBA;
 Behaviour – – operational area. No important ✓ with breeding behaviours identified for
Breeding behaviours of BIAs have been the Australian Fur-seal. One of the main
identified. breeding colonies for the Australian Fur-
seal is located on Lady Julia Percy
Island. No BIAs have been identified
within the vicinity.
Whales  Listed Marine ✓ ✓

Species

EP Summary

 Threatened ✓ 6 whale species (or species habitat) ✓ 7 whale species (or species habitat)
Species may occur within the operational area, may occur within the EMBA, with
 Migratory ✓ with foraging behaviours identified for ✓ foraging and breeding behaviours
Species some species. The EMBA intersects a identified for some species. The EMBA
 BIA – – distribution and forging BIA for the ✓ intersects a distribution and forging BIA
Aggregation Pygmy Blue Whale, and a distribution for the Pygmy Blue Whale, and an
 BIA – Foraging ✓ BIA for the Southern Right Whale. ✓ aggregation, distribution and migration
BIA for the Southern Right Whale.
 BIA – Migration – ✓
Breeding
 Behaviour – ✓ ✓
Foraging
Dolphins  Listed Marine ✓ 6 dolphin species (or species habitat) ✓ 7 dolphin species (or species habitat)
Species may occur within the operational area. may occur within the EMBA. No
 Migratory ✓ No important behaviours of BIAs have ✓ important behaviours of BIAs have been
Species been identified. identified.
Table 4-2 Presence of Social Receptors within the Operational Area and the EMBA

Natural Commonwealth Key Ecological  High productivity – Not present. ✓ One KEF, Bonney Coast Upwelling,
System Areas, Parks and Features  Aggregations of intersects with the eastern extent of the
Reserves marine life EMBA. The Bonney Coast Upwelling is
a seasonal upwelling feature, that
supports regionally high productivity

EP Summary

and species diversity, and is a known
Blue Whale foraging area.
The Shelf Rocky Reefs and Hard
Substrates KEF is not spatially defined,
however the EMBA falls within the
water depths (50–220 m) that this
feature may be present.
State Parks and Marine Protected  Various; e.g. – Not present. ✓ There are four State marine protected
Reserves Areas foraging or areas intersect with the EMBA:
breeding areas
 Merri Marine Sanctuary
 The Arches Marine Sanctuary
 Twelve Apostles Marine Park
 Marengo Reefs Marine Sanctuary
 Eagle Rock Marine Sanctuary
Terrestrial  Various; e.g. – Not present. ✓ A number of State terrestrial protected
Protected Areas shorelines areas have a coastal boundary that
intersects with the EMBA, including:
 Discovery Bay Coastal Park
 Lawrence Rocks Wildlife Reserve
 Lady Julia Percy Island Wildlife
Reserve
 Bay of Islands Coastal Park
 Port Campbell National Park
 Cape Otway National Park
Human Commercial Commonwealth-  Economic benefit ✓ While a number of Commonwealth- ✓ A number of Commonwealth-managed
System Fisheries managed managed fisheries have management fisheries have management areas that
areas that intersect with the operational intersect with the EMBA. Fishing

EP Summary

area, active fishing effort within this area intensity data suggests that the
is expected to be minimal given the lack Southern and Eastern Scalefish and
of suitable benthic habitat features Shark Fishery and the Southern Squid
within the operational area, and pre- Jig Fishery are the two with activity that
existing PSZ’s around the Casino wells. may occur within the EMBA.
State-managed  Economic benefit ✓ While a number of State-managed ✓ A number of State-managed fisheries

fisheries have management areas that have management areas that intersect
intersect with the operational area, with the EMBA. Fishing intensity data is
active fishing effort within this area is not available; however, it is possible
expected to be minimal given the lack of that the Giant Crab, Rock Lobster and
suitable benthic habitat features within Wrasse fisheries may be active within
the operational area, and pre-existing the EMBA.
PSZ’s around the Casino wells.
Recreational  Community ✓ Recreational fishing may occur within ✓ Most recreational fishing typically
Fisheries engagement the operational area, but activity is occurs in nearshore coastal waters, and
expected to be minimal given its within bays and estuaries; offshore
location >20 km offshore. (>5 km) fishing only accounts for
approximately 4% of recreational
fishing activity in Australia. The Otway
coastal waters have a moderate fishing
intensity (relative to other areas within
the South-East Marine Region).
Coastal  Community – Not present. ✓ The communities of Port Campbell,

Settlements engagement Peterborough, Warrnambool and Port
 Economic benefit Fairy are located along the coast of the
EMBA. The coastal communities
provide services to the recreational and

EP Summary

commercial fishing industries of south-
eastern Victoria.
Recreation and  Community ✓ Marine-based recreation and tourism ✓ The Australian coast provides a diverse
Tourism engagement may occur within the operational area, range of recreation and tourism
 Economic benefit but activity is expected to be minimal opportunities, including scuba diving,
given its location >20 km offshore. charter boat cruises, and surfing. The
Great Ocean Road is a popular tourism
attraction in eastern Victoria.
Industry Shipping  Community ✓ The south-eastern coast is one of ✓ The south-eastern coast is one of
engagement Australia’s busiest in terms of shipping Australia’s busiest in terms of shipping
 Economic benefit activity and volumes. The Casino-5 well activity and volumes. There are no
does not coincide with major shipping major ports within the EMBA, but minor
routes. ports do exist (e.g. Portland) that
support commercial and recreational
fishing industries.
Oil and Gas  Economic benefit ✓ Petroleum activity within the operational ✓ Petroleum infrastructure in Otway Basin
Exploration area includes other Cooper operated is well developed, with a network of
and/or assets. pipelines transporting hydrocarbons
Operations produced offshore to onshore facilities.
Current offshore production in the
Otway Basin includes the Minerva,
Thylacine, Geographe, Casino, Henry
(including Netherby) fields, and the
Halladale/Speculant gas project.
Heritage Maritime  Shipwrecks – Not present. ✓ Numerous shipwrecks have been

recorded in nearshore and coastal
Australian waters. The one in closest

EP Summary

proximity to Casion-5 is Falls of
Halladale, Schomberg and Newfield
(approximately 16 km to the northeast).
Cultural  Commonwealth – Not present. ✓ There is one National Heritage Place

Heritage Places within the EMBA:
 World Heritage
 Great Ocean Road and Scenic
Properties
Environs.
 National Heritage
Places
Indigenous  Indigenous use – Not present. ✓ The coastal area of south-east Australia
or connection was amongst the most densely
 Native Title populated regions of pre-colonial
Australia. Through cultural traditions,
Aboriginal people maintain their
connection to their ancestral lands and
waters. The Gadubanud (Ktabanut)
people have occupied the Otway
region, including the estuaries and
coastline for thousands of years.

EP Summary
4.4 Conservation Values within the EMBA

The following table provides details of the features present within the EMBA for those receptors
identified within Regulation 13(3) of the OPGGS(E) Regulations (Table 4-3). Note, no AMPs,
internationally (Ramsar) or nationally important wetlands, World Heritage Properties or
Commonwealth Heritage Places occur within the EMBA.
Table 4-3 Summary of conservation values and sensitivities within the EMBA
Receptor Type Value and Sensitivities Features present within the EMBA
Commonwealth Key Ecological Features  Bonney Coast Upwelling
Areas, Parks and
Reserves  Shelf Rocky Reefs and Hard Substrates
State Parks and Marine Protected Areas  Merri Marine Sanctuary

Reserves
 The Arches Marine Sanctuary
 Twelve Apostles Marine Park
 Marengo Reefs Marine Sanctuary
 Eagle Rock Marine Sanctuary
Terrestrial Protected Areas  Bay of Islands Coastal Park
 Great Otway National Park
 Lady Julia Percy Island Wildlife Reserve
 Lawrence Rocks Wildlife Reserve
 Port Campbell National Park
 Discovery Bay Coastal Park
Heritage National Heritage Places  Great Ocean Road and Scenic Environs
Seabirds and Threatened and/or  Numerous threatened (35) and migratory (52)
Shorebirds migratory species species or species habitat present (including various
albatross, petrel, plover, sandpiper, shearwater and
tern species)
Fish Threatened and/or  One threatened fish species or species habitat
migratory species present (Australian Grayling)
 One threatened (Great White Shark) and three
migratory (Great White Shark, Shortfin Mako Shark,
Porbeagle Shark) shark species or species habitat
present
Marine Reptiles Threatened and/or  Three threatened and migratory marine turtle
migratory species species or species habitat present (Loggerhead
Turtle, Green Turtle, Leatherback Turtle)
Marine Mammals Threatened and/or  Five threatened whale species or species habitat
migratory species present (Sie Whale, Blue Whale, Fin Whale,
Southern Right Whale, Humpback Whale); and ten
migratory whale species or species habitat present
 One migratory dolphin species or species habitat
present (Dusky Dolphin)
Saltmarsh Threatened Ecological  Subtropical and Temperate Coastal Saltmarsh
Community
Macroalgae Threatened Ecological  Giant Kelp Marine Forests of South East Australia
Community

EP Summary
5.0 Environmental Impact and Risk Assessment

Methodology
This section describes the environmental impact and risk assessment methodology employed
for activities to be undertaken as part of the Casino-5 well intervention and workover, adopting
Cooper Energy’s risk assessment framework and toolkit to evaluate the potential impacts and
risks.
For the Cooper Energy offshore activities, environmental aspects, impacts and risks have been
identified and assessed through the following steps:
• Establish the context for the assessment by defining the activity and associated
environmental aspects;
• Identifying the impact or risk associated with the environmental aspects;
• Identifying the ecological and social receptors with the potential to be exposed to the
hazard;
• Evaluate the potential impact or risk (consequence);
• Determine the ALARP decision context and identify control measures;
• Evaluate the likelihood of the impact or risk (consequence) occurring;
• Assigning residual risk rating (after control measures are implemented) utilizing the
Cooper Energy qualitative risk matrix. In accordance with the Cooper Energy
acceptance criteria, the impacts and risks continue to be reassessed until it is
demonstrated the impact or risk is reduced to a level which is as low as reasonably
practicable (ALARP) and is acceptable according to the Cooper Energy acceptance
criteria; and
• Evaluate the acceptability of the potential impact or risk.
Figure 5-1 provides the process adopted for managing impacts and risks associated with the
petroleum activity.
Figure 5-1 AS/NZS ISO 31000 – Risk Management Methodology

EP Summary
5.1 Impact and Risk Evaluation

5.1.1 Establish the context
After describing the petroleum activity, an assessment was carried out to identify potential
interactions between the petroleum activity and the receiving environment. The outcomes of
stakeholder consultation also contributed to aspect identification.
Based upon an understanding of the environmental interactions, relevant impacts or risks were
defined. Ecological and social receptors identified with the potential to be exposed to an aspect
and subsequent impacts or risks were then summarised enabling a systematic evaluation to be
undertaken.
5.1.2 Evaluate the potential impact (consequence)
After identifying the potential impacts or risks; consequences were determined based on:
• the spatial scale or extent of potential impact or risk of the environmental aspect within
the receiving environment;
• the nature of the receiving environment (within the spatial extent), including proximity to
sensitive receptors, relative importance, and sensitivity or resilience to change;
• the impact mechanisms (cause and effect) of the environmental aspect within the
receiving environment (e.g. persistence, toxicity, mobility, bioaccumulation potential);
• the duration and frequency of potential effects and time for recovery;
• the potential degree of change relative to the existing environment or to criteria of
acceptability.
Consequence definitions are provided in Table 5-1.
Table 5-1 Definition of Consequence
Descriptor Environment Regulatory, reputation, community and

media
5. Critical Severe long-term impact on highly-valued Critical impact on business reputation &/or
ecosystems, species populations or international media exposure.
habitats. High-level regulatory intervention.
Significant remedial/recovery work to Potential revocation of License/Permit.
land/water systems over decades (if
Operations ceased.
possible at all).
4. Major Extensive medium to long-term impact on Significant impact on business reputation

highly-valued ecosystems, species and/or national media exposure.
populations or habitats. Significant regulatory intervention.
Remedial, recovery work to land or water Operations ceased.
systems over years
(~5-10 years).
3. Moderate Localised medium-term impacts to species Moderate to small impact on business

or habitats of recognized conservation reputation.
value or to local ecosystem function. Potential for state media exposure.
Remedial, recovery work to land/water Significant breach of regulations, attracting
systems over months/year. regulatory intervention.

EP Summary
Descriptor Environment Regulatory, reputation, community and

media
2. Minor Localised short-term impacts to Some impact on business reputation and/or

species/habitats of recognised conservation industry media exposure.
value but not affecting local ecosystem Breach of regulations - event reportable to
functioning. authorities.
Remedial, recovery work to land, or water
systems over days/weeks.
No significant impacts to third parties.
1. Negligible Temporary localised impacts or disturbance Minimal impact on business reputation.

to plants/animals. Negligible media involvement.
Nil to negligible remedial/recovery works on No regulatory breaches or reporting.
land/water systems.
5.1.3 Determine the ALARP decision context and identify control measures
In alignment with NOPSEMA’s ALARP Guidance Note (N-04300-GN0166, Rev 6, June 2015),
Cooper Energy have adapted the approach developed by Oil and Gas UK (OGUK) (formerly
UKOOA; OGUK, 2014) for use in an environmental context to determine the assessment
technique required to demonstrate that potential impacts and risks are ALARP (Figure 5-2).
Specifically, the framework considers impact severity and several guiding factors:
• activity type
• risk and uncertainty
• stakeholder influence.
A Type A decision is made if the risk is relatively well understood, the potential impacts are low,
activities are well practised, and there are no conflicts with company values, no partner
interests and no significant media interests. However, if good practice is not sufficiently well-
defined, additional assessment may be required.
A Type B decision is made if there is greater uncertainty or complexity around the activity
and/or risk, the potential impact is moderate, and there are no conflict with company values,
although there may be some partner interest, some persons may object, and it may attract local
media attention. In this instance, established good practice is not considered sufficient and
further assessment is required to support the decision and ensure the risk is ALARP.
A Type C decision typically involves sufficient complexity, high potential impact, uncertainty, or
stakeholder influence to require a precautionary approach. In this case, relevant good practice
still must be met, additional assessment is required, and the precautionary approach applied for
those controls that only have a marginal cost benefit.

EP Summary
Figure 5-2 ALARP Decision Support Framework

(NOPSEMA Decision-making – Criterion 10A(c) Acceptable level. N-04750-GL1637, Rev 0, Nov 2016)
In accordance with the regulatory requirement to demonstrate that environmental impacts and
risks are ALARP, Cooper Energy has considered the above decision context in determining the
level of assessment required. This is applied to each aspect described in Section 6.0.
The assessment techniques considered include:
• good practice
• engineering risk assessment
• precautionary approach.
5.1.4 Evaluate the likelihood of the impact (consequence) occurring
The likelihood of a defined consequence occurring was determined, considering the control
measures that have been previously identified. Likelihood levels are determined according to
the Cooper Energy qualitative risk matrix (Table 5-3). Likelihood definitions are provided in
Table 5-2.
Table 5-2 Definition of Likelihood
Descriptor Description
A. Almost certain Common event, expected to occur in most circumstances within Cooper Energy
operations (i.e., several times a year).
B. Likely Event likely to occur once or more during a campaign, ongoing operations or
equipment design life.
C. Possible Infrequent event that may occur during a campaign, ongoing operations or
equipment design life.

EP Summary
Descriptor Description
D. Unlikely Unlikely event, but could occur at sometime within Cooper Energy operations (has
occurred previously in similar industry).
E. Remote Rare event. May occur in exceptional circumstances of Cooper Energy operations
(not heard of in recent similar industry history).
5.1.5 Assigning residual risk rating

Based upon the identified consequence and likelihood levels, Cooper Energy use the
qualitative risk matrix (Table 5-3) to rate the residual risk level.
Table 5-3 Cooper Energy Qualitative Risk Matrix
CONSEQUENCE
1.Negligible 2.Minor 3.Moderate 4.Major 5.Critical
Almost Certain M M H H H
Likely M M M H H
LIKELIHOOD
Possible L M M H H
Unlikely L L M M H
Remote L L L M M
5.1.6 Evaluate the acceptability of the potential impact and risk

Cooper Energy considers a range of factors when evaluating the acceptability of environmental
impacts or risks associated with its activities. This evaluation works at several levels, as
outlined in Table 5-4 and is based on NOPSEMA’s Guidance Notes for EP Content
Requirements (N04750-GN1344, Rev 3, April 2016) and guidance issued in Decision-making –
Criterion 10A(c) Acceptable Level (N-04750-GL1637, Rev 0, Nov 2016). The acceptability
evaluation for each aspect associated with this activity is undertaken in accordance with Table
5-4.
Table 5-4 Cooper Energy Acceptability Evaluation
Factor Criteria / Test
Cooper Energy Risk Process • Is the level of risk High? (if so, it is considered unacceptable)
Principles of Ecologically • Is there the potential to affect biological diversity and ecological
Sustainable Development integrity? (Consequence Level Major [4] and Critical [5])
(ESD) [See below]
• Do activities have the potential to result in serious or irreversible
environmental damage?
o If yes: Is there significant scientific uncertainty associated with
aspect?
o If yes: Has the precautionary principle been applied to the aspect?
Legislative and Other • Confirm that all good practice control measures have been identified for
Requirements the aspect including those identified in relevant EPBC listed species
recovery plans or approved conservation advices.
Internal Context • Confirm that all Cooper Energy HSEC MS Standards and Risk Control
Processes have been identified for this aspect
External Context • What objections and claims regarding this aspect have been made, and
how have they been considered / addressed?

EP Summary
ESD Principles are:

A. Decision making processes should effectively integrate both long term and short term
economic, environmental, social and equitable considerations
This principle is inherently met through the EP assessment process. This principal is not
considered separately for each acceptability evaluation
B. If there are threats of serious or irreversible environmental damage, lack of full scientific
certainty should not be used as a reason for postponing measures to prevent environmental
degradation.
An evaluation is completed to determine is the activity will result in serious or irreversible
environmental damage. Where the activity has the potential to result in serious or
irreversible environmental damage, an assessment is completed to determine if there is
significant uncertainty in the evaluation
C. The principle of inter-generational equity—that the present generation should ensure that
the health, diversity and productivity of the environment is maintained or enhanced for the
benefit of future generations.
Where the potential impacts and risk are determined to be serious or irreversible the
precautionary principle is implemented to ensure the environment is maintained for the
benefit of future generations
D. The conservation of biological diversity and ecological integrity should be a fundamental
consideration in decision making
An assessment is completed to determine if there is the potential to impact biological
diversity and ecological integrity
E. Improved valuation, pricing and incentive mechanisms should be promoted
Not relevant to this EP
5.2 Monitor and Review

Monitoring and review activities are incorporated into the impact and risk management process
to ensure that controls are effective and efficient in both design and operation. This is achieved
for the Casino-5 well intervention and workover activities through the environmental
performance outcomes, standards and measurement criteria that are described for each
environmental hazard. Additional aspects of monitoring and review include:
• Analysing and lessons learnt from events (including near-misses), changes, trends,
successes and failures;
• Detecting changes in the external and internal context (e.g. new conservation plans
issued); and
• Identifying emerging risks.

EP Summary
6.0 Risk and Impact Evaluation

This Section summarises the impacts and risks associated with the petroleum activity
appropriate to the nature and scale of each impact or risk, and provides the control measures
that are used to reduce the risks to ALARP and an acceptable level.
6.1 Physical Interaction (Collision with Marine Fauna)

Table 6-1 provides a summary of the environmental impact assessment (EIA) / environmental
risk assessment (ERA) for
Physical Interaction (Collision with Marine Fauna).
Table 6-1
Physical Interaction (Collision with Marine Fauna) EIA / ERA
Cause of Aspect The movement of vessels within the operational area and the physical presence of the
vessel has the potential to result in collision with marine fauna.
Summary of Interaction with fauna has the potential to result in:
impact(s)
 injury or death of marine fauna
Consequence Evaluation
Receptor(s) Description of Potential Environmental Impact
Megafauna Several marine mammals (whale, dolphin) and turtle species, including those listed as
either threatened and/or migratory under the EPBC Act have the potential to occur within
the operational area. The operational area is located within a foraging BIA for the Pygmy
Blue Whale, and a distribution BIA for the Southern Right Whale and Great White Shark.
Cetaceans are naturally inquisitive marine mammals that are often attracted to offshore
vessels and facilities. The reaction of whales to the approach of a vessel is quite
variable. Some species remain motionless when in the vicinity of a vessel, while others
are curious and often approach ships that have stopped or are slow moving, although
they generally do not approach, and sometimes avoid, faster-moving ships (Richardson et
al.1995).
Collisions between larger vessels with reduced manoeuvrability and large, slow-moving
cetaceans occur more frequently where high vessel traffic and cetacean habitat occurs
(Whale and Dolphin Conservation Society, 2006). Laist et al. (2001) identifies that larger
vessels with reduced manoeuvrability moving in excess of 10 knots may cause fatal or
severe injuries to cetaceans, with the most severe injuries caused by vessels travelling
faster than 14 knots. Vessels typically used to support workover activities do not have the
same limitations on manoeuvrability and would not be moving at these speeds when
conducting activities within the scope of this EP, inside the operational area.
The duration of fauna exposure to vessel strike is limited to the duration of this activity
which is expected to be approximately 25 days. If a fauna strike occurred and resulted in
death, it is not expected that it would have a detrimental effect on the overall population.
Consequently, the potential impacts and risks from fauna strike are considered to be
Minor (2) as this type of event may result in a localised short-term impact to species of
recognised conservation value but is not expected to affect the population or local
ecosystem function.
ALARP Decision A
Context

EP Summary
Summary of Control Measures
 Adherence to EPBC Regulations 2000 – Part 8 Division 8.1 interacting with cetaceans – The Australian
Guidelines for Whale and Dolphin Watching describes strategies to ensure whales and dolphins are not
harmed during offshore interactions with people.
 Vessel strike reporting
Likelihood Unlikely (D) Residual Risk Low
6.2 Physical Interaction (Other Marine Users)

Table 6-2 provides a summary of the EIA / ERA for Physical Interaction (Other Marine Users).
Table 6-2 Physical Interaction (Other Marine Users) EIA / ERA
Cause of Aspect The movement of vessels within the operational area, and the physical presence of the
MODU and vessels has the potential to result in interactions with other marine users.
Summary of Interaction with other marine users has the potential to result in:
impact(s)
 a disruption to commercial activities.
Commercial Several commercial fisheries have management areas that overlap the operational area
Fisheries associated with the EP; however, fishing activity in the area is low. The MODU will be
Other marine users located within an existing exclusion zone (the PSZ for Casino-2 wellhead).
Stakeholder engagement, along with annual fishing records, indicates that that the
proposed activities are not expected to result in an impact to commercial operations (via
loss of catches or damage to fishing equipment.)
The operational area is located to the northern extremity of commercial shipping routes.
The well intervention and workover activities for the EP is expected to take approximately
25 days. Consequently, any impacts would be Negligible (1), with little to no potential
impacts to, or concerns from, affected external stakeholders.
ALARP Decision A
Context
 Pre-start notifications
 Petroleum Safety Zone
Likelihood Remote (E) Residual Risk Low
6.3 Light Emissions

Table 6-3 provides a summary of the EIA / ERA for Light Emissions.

EP Summary
Table 6-3 Light Emissions EIA / ERA

Cause of Aspect The MODU and support vessels will generate light while in the operational area. Lighting
is used for marine safety to ensure clear identification of vessels to other marine users
and to allow activities to be undertaken safely 24 hours a day. Lighting will typically
consist of bright white (i.e., metal halide, halogen, fluorescent) lights, and are not
dissimilar to other offshore activities in the region, including fishing and shipping.
Summary of A change in ambient light levels may have the potential to result in:
impact(s)
 Attraction of light-sensitive species such as seabirds, squid and zooplankton in turn
affecting predator-prey dynamics; and
 Alteration of behaviour that may affect species during breeding periods (e.g.
shearwaters, turtle hatchlings).
Seabirds, squid and Localised light glow that may act as an attractant to light sensitive species
zooplankton High levels of marine lighting can attract and disorient seabird species resulting in species
behavioural changes (e.g. circling light sources leading to exhaustion or disrupted
foraging), injury or mortality near the light source (e.g. Marquenie et al. 2008; Weise et al.
2001). These studies indicate that migratory birds are attracted to lights on offshore
platforms when travelling within a radius of 5 km from the light source, but their migratory
paths are unaffected outside this zone (Shell, 2010).
Other marine life may also be attracted to the MODU or support vessels (e.g., fish, squid
and plankton) that can aggregate directly under downward facing lights. These are prey
species to many species of marine fauna and given the nature of the activity, any impacts
arising from light emissions will be localised and temporary.
Consequently, the potential impacts and risks from light emissions are considered to be
Negligible (1) as this type of event may result in temporary localised impacts or
disturbance to animals but is not expected to affect the population or local ecosystem
function.
Turtles, seabirds Alteration of behaviour from light-sensitive species during breeding periods
Turtles
Light pollution can be an issue along, or adjacent to, turtle nesting beaches where
emerging hatchlings orient to, and head towards, the low light of the horizon unless
distracted by other lights which disorient and affect their passage from the beach to the
sea (EA, 2003). Given the absence of known turtle nesting in Victoria, impacts to turtle
hatchlings are not expected.
Seabirds
Artificial light can cause significant impacts on burrow-nesting petrels and shearwaters.
The operational area is approximately 30 km from the closest shoreline. Given the
distance offshore, changes to ambient light levels in seabird breeding areas are not
expected to occur, thus impacts to breeding periods from light emissions are not
expected.
ALARP Decision A
Context

EP Summary
 Lighting will be limited to that required for safe work and navigation.
Likelihood Possible (C) Residual Risk Low

EP Summary
6.4 Underwater Sound Emissions

Table 6-4 provides a summary of the EIA / ERA for

EP Summary
Underwater Sound Emissions.

Table 6-4

EP Summary
Underwater Sound Emissions EIA / ERA

Cause of Aspect Underwater sound emissions will be generated from:
 Support operations (MODU/vessel operations)
 Support operations (helicopter operations)
Note, MODU sound will be from thrusters and power generation only. No drilling or
seismic activities will be undertaken under the EP.
Summary of The potential impacts of underwater sound emissions in the marine environment are:
impact(s)
 Localised and temporary fauna behavioural disturbance that affects migration or
social behaviours; and
 Auditory impairment, Permanent Threshold Shift (PTS).
Marine mammals Localised and Temporary Fauna Behavioural Disturbance
Fish and sharks Marine Mammals
Commercial Using the National Marine Fisheries Service (NMFS) guidance for sounds such as vessel
Fisheries noise, behavioural disturbance may occur within 4km of the MODU / vessel. The
operational area is located within a foraging BIA for the Pygmy Blue Whale, and a
distribution BIA for the Southern Right Whale; both species typically occur as individuals
or in small (2–3 individuals) groups. Therefore, within the open water environment of the
operational area, it is anticipated that cetacean numbers would be low, and so it is not
expected that exposure to these sound levels would result in a significant change to
foraging behaviours or natural movement that would result in further impact at either the
individual or local population levels. Consequently, the potential impacts and risks from
noise emissions are considered to be Minor (2).
Fish and sharks
Sound levels are expected to be below the Popper et al. (2014) threshold for injury in fish
with a high or medium hearing sensitivity.
For some fish, a strong ‘startle’ response has been observed at lower sound levels, with
fish shown to move away from the noise source. Using a conservative approach, Cooper
Energy has estimated that fish may exhibit a behavioural response to expected sound
levels within 3km of the sound source (well location). Any behavioural impacts would be
temporary. Consequently, the potential impacts and risks from noise emissions are
Negligible (1) as this type of event may result in temporary localised impact or
disturbance to animals.
Commercial fisheries
The EMBA is located within an important commercial fishing area. Localised and
temporary behaviour changes in fish have the potential to adversely affect commercial
fishing operations.
During stakeholder consultation, concern was raised by South East Trawl Fishing Industry
Associate (SETFIA) regarding the potential impact of seismic survey on marine
invertebrates and fish. Cooper Energy provided sufficient information to show that, as
seismic survey will not be undertaken, impacts from the activities are unlikely to result in
impacts to fish and will not affect commercial fishing.

EP Summary
As potential impacts and risks from noise emissions to fish and sharks is determined to
have a negligible consequence, impacts and risks to commercial fisheries from noise
emissions are also considered to be Negligible (1).
Marine mammals Auditory Impairment, Permanent Threshold Shift (PTS)
Fish and sharks As the sound levels generated by MODU/vessel operations associated with the activities
will be below the thresholds suggested by Southall et al., (2007) (cetaceans) and Popper
et al., (2014) (fish), no further assessment is required.
ALARP Decision A
Context
 Planned Maintenance Schedule

 Adherence to EPBC Regulations 2000 – Part 8 Division 8.1 interacting with cetaceans
Likelihood (species of recognised Unlikely (D) Residual Low
conservation value) Risk
Likelihood (fish) Possible (C)
Likelihood (Commercial Fisheries) Remote (E).
6.5 Physical Presence – Seabed Disturbance

Table 6-5 provides a summary of the EIA / ERA for Physical Presence – Seabed Disturbance.
Table 6-5 Physical Presence – Seabed Disturbance EIA / ERA
Cause of Aspect During the activity, the MODU will be anchored to the seabed to enable well intervention
and workover activities to be undertaken.
Summary of Seabed disturbance has the potential to impact on receptors through:
impact(s)
 Smothering and alteration of benthic habitats
 Localised and temporary increase in turbidity near the seabed
Benthic habitats Smothering and Alteration of benthic habitat

and fauna The benthic habitat within the operational area is characterised by soft sediment with the
occasional hard substrate outcrop, infauna communities, and sparse epibiotic
communities (typically sponges).
Any impact will be limited to the immediate vicinity of the well location, and thus the extent
of potential impact is localised.
The type of damage that could be sustained may include destruction of habitat. However,
due to the similarity of surrounding habitat, and lack of sensitive benthic habitats, it is
expected that recovery is likely. It is expected that any localised impacts from anchoring
would rapidly recolonise and recover following any disturbance, therefore the potential
impact has been determined as Negligible (1).
Localised and temporary increase in turbidity near the seabed
Benthic fauna may be disturbed through the temporary increase in turbidity near the
seafloor as a result of seabed disturbance during anchoring. The area of increased

EP Summary
turbidity is likely to be a very small area localized around the disturbance points where
anchors or weights sit on the seabed.
The location of the wells within a homogenous seabed area, and lack of sensitive benthic
features, means that turbidity resulting from the described activities is not expected to
result in any environmental impacts.
ALARP Decision A
Context
 Undertake mooring analysis

 Monitor mooring line tensions
Likelihood Unlikely (D). Residual Risk Low
6.6 Atmospheric Emissions

Table 6-6 provides a summary of the EIA / ERA for Atmospheric Emissions.
Table 6-6 Atmospheric Emissions EIA / ERA
Cause of Aspect The following activities have the potential to result in air emissions:
 Use of fuel (support vessels and MODU)
 Venting of gas and nitrogen from slickline operations
Venting would be undertaken intermittently over several days. Volumes released are
controlled such that only small amounts are released at any given time. Given the slow
release rates and volumes associated with this activity, it is not expected to generate
exposures significant enough to result in impacts to any identified environmental
receptors.
Summary of Generation of atmospheric emissions has the potential to result in:
impact(s)
 chronic effects to sensitive receptors from localised and temporary decrease in air
quality from diesel combustion;
 contribution to the global greenhouse gas (GHG) effect.
Seabirds Localised and temporary decrease in air quality from diesel combustion
Marine megafauna The use of fuel (specifically marine-grade diesel) to power engines, generators and
that surface for air mobile and fixed plant (e.g., ROV, back-deck crane, generator), will result in gaseous
(e.g. cetaceans and emissions of greenhouse gases (GHG).
marine turtles) The quantities of atmospheric emissions and related impacts will be similar to other
vessels and helicopters operating in the region. Emissions from engines, generators and
deck equipment may be toxic, odoriferous or aesthetically unpleasing, and will result in a
localised, temporary reduction in air quality.
Modelling of nitrogen dioxide (NO2) emissions from MODU power generation for an
offshore project (BP, 2013) indicates that, although emissions will result in a temporary
increase in ambient NO2 concentration, any exposure from these operations would be
expected to be below Australian Ambient Air Quality National Environmental Protection
(Air Quality) Measures (NEPM) standards.

EP Summary
Emissions will be small in quantity and will dissipate quickly into the surrounding
atmosphere, therefore any reduction in air quality will be localised and impacts would be
limited. No impacts are anticipated on a population scale, and consequence is therefore
considered to be Negligible (1).
Contribution to the global GHG effect
While these emissions add to the GHG load in the atmosphere, which adds to global
warming potential, they are relatively small on a global scale, and temporary, representing
an insignificant contribution to overall GHG emissions (DoEE, 2017).
Any exposure from these operations would be expected to be insignificant, therefore no
further evaluation of this aspect has been undertaken.
ALARP Decision A
Context
 Use reduced sulphur content fuel

 All vessels to comply with Marine Orders – Part 97: Marine Pollution Prevention – Air Pollution (appropriate to
vessel class)
 Adherence to MARPOL Annex VI (Prevention of Air Pollution from Ships) requirements
 Adherence to MARPOL Annex VI (Chapter III Regulation 16 and Appendix IV – Requirements for Control of
Emissions from Ships – Shipboard Incineration) requirements
 Control cold venting of gas
Likelihood Remote (E). Residual Risk Low
6.7 Planned Discharge – Cooling Water and Brine

Table 6-7 provides a summary of the EIA / ERA for Planned Discharge – Cooling Water and
Brine.
Table 6-7 Planned Discharge – Cooling Water and Brine EIA / ERA
Cause of Aspect Seawater is used as a heat exchange medium for cooling machinery engines on vessels.
Upon discharge, it will be warmer than the surrounding ambient water and may contain
low concentrations of residual biocide if used to control biofouling.
Concentrated brine is a waste stream created through the vessels desalination equipment
for potable water generation. Brine will also be used, and subsequently discharged,
during wellbore clean-up.
Summary of Planned discharge of cooling and brine waters has the potential to result in chronic effects
impact(s)
to fauna through:
 increased water temperature
 increased water salinity
 potential chemical toxicity in the water column.
Transient marine Increased Temperature

fauna, including Modelling of continuous wastewater discharges (including cooling water) found that
whales, sharks, fish, discharge water temperature decreases quickly as it mixes with the receiving waters
and reptiles (WEL, 2014).

EP Summary
Marine mammals and fish passing through the area will be able to actively avoid
entrainment in any heated plume (Langford, 1990), and reptiles and sharks would be
expected to behave similarly. Studies of organisms at 15, 20 and 25°C allowed them to
tolerate temperature increments of 8-9°C without damage (UNEP, 1983).
Given the open nature of the receiving environment, the short duration of the activity, and
the lack of sensitive environmental receptors, the impact of increased temperature is
expected to be Negligible (1).
Potential Chemical Toxicity
Scale inhibitors and biocide used in the heat exchange and desalination process to avoid
fouling of pipework are inherently safe at the low dosages used; they are usually
consumed in the inhibition process, so there is little or no residual chemical concentration
remaining upon discharge.
Larger pelagic species are mobile; at worst, it is expected that they would be subjected to
very low levels of chemicals for a very short time as they swim near the discharge plume.
As transient species, they are not expected to experience any chronic or acute effects.
Any impacts from chemical discharge will be localised and short-term. Given the open
nature of the receiving environment, the intermittent nature of the activity, and the lack of
sensitive environmental receptors, the impact of potential chemical toxicity is expected to
be Minor (2).
Pelagic Fish Increased salinity
Plankton Brine water will sink through the water column where it will be rapidly mixed with receiving
waters and dispersed by ocean currents. As such, any potential impacts are expected to
be limited to the source of the discharge where concentrations are highest.
Changes in salinity can affect the ecophysiology of marine organisms. Most marine
species are able to tolerate short-term ﬂuctuations in salinity in the order of 20% to 30%
(Walker and McComb, 1990). However, larval stages, which are crucial transition periods
for marine species, are known to be more susceptible to impacts of increased salinity
(Neuparth, Costa & Costa 2002). Pelagic species are mobile; it is expected that at worst,
they would be subjected to slightly elevated salinity levels (~10-15% higher than
seawater) for a very short period which they are expected to be able to tolerate. As such,
transient species are not expected to experience chronic or acute effects.
Given the open nature of the receiving environment, the short duration of the activity, and
the lack of sensitive environmental receptors, the impact of increased salinity is expected
to be Negligible (1).
ALARP Decision A
Context

 Development of and adherence to Chemical Assessment Process

EP Summary
6.8 Planned Discharge - Treated Bilge

Table 6-8 provides a summary of the EIA / ERA for

EP Summary
Planned Discharge - Treated Bilge.

Table 6-8

EP Summary
Planned Discharge - Treated Bilge EIA / ERA

Cause of Aspect Bilge water consists of water, oily fluids, lubricants, cleaning fluids, and other similar
wastes that have accumulated in the lowest part of the vessel / MODU typically from
closed deck drainage and machinery spaces.
Bilge water is treated onboard the vessel or MODU using the oil water separator (OWS)
to reduce any oily residue to below regulated level, before being discharged at surface.
Summary of A discharge of this material has the potential to result in chronic effects to plankton
impact(s)
through potential toxicity in the water column.
Fish embryo, OSPAR (2014) indicates that the predicted no effect concentration (PNEC) for marine
larvae, and other organisms exposed to dispersed oil is 70.5 ppb.
plankton A discharge of treated bilge is non-continuous and infrequent. Modelling by Shell (2009)
Species which rely indicates that upon discharge, hydrocarbon and other chemical concentrations are rapidly
on plankton as a diluted and expected to be below PNEC within a relatively short period of time. Given the
food source nature of this discharge, marine fauna most susceptible to toxic impacts are mainly limited
to less mobile fish embryo, larvae, and other plankton.
There is potential for short-term impacts to species that rely on plankton as a food source.
Any impact to prey species would be temporary as the duration of exposure would be
limited, and fish larvae and other plankton are expected to rapidly recover as they are
known to have high levels of natural mortality and a rapid replacement rate (UNEP,
1985).
Consequently, the potential impacts and risks from planned discharge of treated bilge are
considered to be localised and short-term, and have been rated as Minor (2).
ALARP Decision A
Context
 Bilge discharges from vessels comply with MARPOL Annex I bilge discharge requirements
 MARPOL-approved oil water separator

EP Summary
6.9 Planned Discharge - Sewage and Food Waste

Table 6-9 provides a summary of the EIA / ERA for Planned Discharge – Sewage and Food
Waste.
Table 6-9 Planned Discharge – Sewage and Food Waste EIA / ERA
Cause of Aspect The use of ablution, laundry and galley facilities by personnel will result in the surface
discharge of sewage and grey water. The generation of food waste from feeding
personnel will result in the discharge of food waste from the galley.
Summary of A discharge of food waste, sewage and greywater has the potential to result in impacts to
impact(s)
marine fauna from:
 Temporary and localised reduction in water quality (nutrients and biological oxygen
demand [BOD])
 Changing predator / prey dynamics from increased scavenging behaviours
Transient marine Temporary and localised reduction in water quality (nutrients and biological
oxygen demand [BOD])
fauna, including
whales, sharks, fish Monitoring of sewage discharges for another offshore project (WEL, 2014), determined
and reptiles that a 10 m3 sewage discharge (over the course of an activity) reduced to ~1% of its
original concentration within 50 m of the discharge location.
Studies into the effects of nutrient enrichment from offshore sewage discharges indicate
that the influence of nutrients in open marine areas is much less significant than that
experienced in enclosed areas (McIntyre and Johnson, 1975) and suggest that
zooplankton composition and distribution in areas associated with sewage dumping
grounds are not affected. In addition, regardless of receptor sensitivity to BOD, Black et
al. (1994) state that BOD of treated effluent is not expected to lead to oxygen depletion in
the receiving waters.
Due to the rapid rate of mixing and dispersion identified during modelling of sewage
releases (WEL, 2014), no receptors are expected to be impacted by this activity and
consequently this hazard has not been evaluated further.
Plankton Changing predator / prey dynamics from increased scavenging behaviours
Large pelagic fauna The overboard discharge of sewage and macerated food waste creates a localised and
(e.g. marine temporary food source for scavenging marine fauna or seabirds whose numbers may
mammals, fish and temporarily increase as a result, thus increasing the food source for predatory species.
seabirds) The rapid consumption of this food waste by scavenging fauna, and physical and
microbial breakdown, ensures that the impacts of food waste discharges are insignificant
and temporary, and receptors that may potentially be in the water column are not
impacted.
Plankton are not affected by sewage discharges, and thus impacts to food source and
any predator-prey dynamics is not expected to occur.
Consequently, the potential impacts and risks from the planned discharge of sewage and
greywater have been evaluated as Minor (2), given this type of event may result in
localised short-term impacts to a species of conservation value (seabirds) through
impacting their foraging habitat.
ALARP Decision A
Context

EP Summary
 MARPOL-approved sewage treatment plant (STP)

 Food waste macerated (MARPOL Annex V)
6.10 Planned Discharge - Ballast Water and Biofouling

Table 6-10 provides a summary of the EIA / ERA for Planned Discharge - Ballast Water.
Table 6-10 Planned Discharge - Ballast Water EIA / ERA
Cause of Aspect The operation of the MODU and vessels may result in the discharge of ballast water
within the operational area.
The operation of the MODU and vessels also have the potential to result in biofouling,
resulting in the same hazard. Consequently, both biofouling and ballast water discharge
are evaluated below.
Summary of Planned discharge of ballast water, or biofouling, has the potential to introduce a marine
impact(s)
pest (IMP).
Benthic Habitat IMP are likely to have little or no natural competition or predators, thus potentially
outcompeting native species for food or space, preying on native species, or changing the
nature of the environment. Marine pest species can also deplete fishing grounds and
aquaculture stock, with between 10% and 40% of Australia’s fishing industry being
potentially vulnerable to marine pest incursion. Marine pests can damage marine and
industrial infrastructure, such as encrusting jetties and marinas or blocking industrial
water intake pipes. By building up on vessel hulls, they can slow the vessels down and
increase fuel consumption.
The benthic habitat within the operational area is expected to comprise soft sediment with
the occasional hard substrate outcrop, infauna communities, and sparse epibiotic
communities (typically sponges). Areas of higher value or sensitivity are located further
afield (e.g. it is approximately 75 km to the closest AMP (Apollo)).
Once established, some pests can be difficult to eradicate (Hewitt et al., 2002) and
therefore there is the potential for a long-term or persistent change in habitat structure.
Successful colonisation in the recipient region would be difficult given the nature of the
benthic habitats near the operational area, and lack of light due to deep waters. If an IMP
was introduced, and if it did colonise an area, it is expected that any colony would remain
fragmented and isolated, and only within the vicinity of the wells. Therefore, there is the
potential for a localised, but irreversible, impact to habitat resulting in a Moderate (4)
consequence.

EP Summary
ALARP Decision B
Context
Additional control measures considered but not adopted:
 Only use vessels / MODUs that are currently operating in Commonwealth Waters to
reduce the potential for introducing IMPs.
This control measure is considered to have costs (limited vessel availability leading to
delays in schedule and incurring additional expenses) which outweigh the benefits.
 Maritime Arrivals Reporting System (MARS)

 Adherence to Australian Ballast Water Management Requirements (version 7; DAWR, 2017), including:
o Ballast Water Management Plan
o Report ballast water discharges
o Maintain a ballast water record system
 Anti-fouling certificate
 Biofouling management plan
 Biofouling record book
Likelihood Possible (C) Residual Risk Medium
6.11 Operational Discharges – Subsea

Table 6-11 provides a summary of the EIA / ERA for Operational Discharges – Subsea.
Table 6-11 Operational Discharges – Subsea EIA / ERA
Cause of Aspect Fluids planned to be discharged subsea include:
 Sulfamic Acid
 Gas
 Debris from tree cap removal
 Control Fluid
 Seawater-brine interface
 Brine
The release of brine and seawater-brine interface is assessed in Section 6.7.
Summary of A planned discharge of various fluids during well activities has the potential result in
impact(s)
chronic and acute impacts to marine fauna via localised and temporary decrease in water
quality.
Soft sediment, Chemical Discharge

infauna All chemicals used and discharged will be assessed using the Cooper Energy Offshore
communities, and Environmental Chemical Assessment Process which uses the CHARM OCNS ranking in
sparse epibiotic conjunction with toxicity, biodegradation and bioaccumulation data to determine potential
communities impacts to the environment and acceptability of planned discharges.
Transient marine Little to no impact is expected on benthic fauna at the release location given the low
fauna, including toxicity, low bioaccumulation and biodegradability characteristics of the proposed
whales, sharks, fish, chemical discharges, and the dispersion characteristics of the release. For seabed
and reptiles invertebrates present near the wellhead, it is possible that low-level concentrations of
chemical may be present on a short-term and episodic basis, however given the low

EP Summary
toxicity of the chemicals, the low frequency and short-term nature of the exposure,
Negligible (1) impacts are expected.
For mobile demersal and pelagic species which may be present at the wellheads during
the activity, given the localised and short-term nature of the discharge, the low toxicity
and low-frequency nature of the discharge and the species mobility which limits exposure,
the environmental impact is expected to have a Negligible (1) impact to these species.
Gas
The main concern regarding a gas (methane) release is the possibility that the action of
methane-consuming microbes (methanotrophic bacteria) could exhaust oxygen in the
water column.
As gas is positively buoyant, upon release it will rise through the water column causing
the small volume to rapidly disperse and dilute. Consequently, receptors exposed would
be limited to transient marine fauna. Based upon the expected volumes (in the order of
0.0001 m3), exposure to transient marine fauna is not expected to occur at concentrations
that could feasibly result in an impact. Thus, this release has not been discussed further.
ALARP Decision A
Context
6.12 Operational Discharges – Surface

Table 6-12 provides a summary of the EIA / ERA for Operational Discharges – Surface.
Table 6-12 Operational Discharges – Surface EIA / ERA
Cause of Aspect Fluids planned to be discharged at the surface include:
 Completion packer brine (CaCO3), Ethylene glycol (MEG), aquifer fluids and/or
reservoir gas.
The release of brine is assessed in Section 6.7.
Summary of A planned discharge of fluid during well intervention and workover activities has the
impact(s)
potential result in chronic and acute impacts to marine fauna via: potential toxicity.
Whales, sharks, fish All chemicals used and discharged will be assessed using Cooper Energy’s Offshore
and plankton Environmental Chemical Assessment Process which uses the CHARM OCNS ranking in
conjunction with toxicity, biodegradation and bioaccumulation data to determine potential
impacts to the environment and acceptability of planned discharges.
Based upon the offshore location of the activity with no identified obstructions and open
ocean currents, potential exposures are expected to be limited to the operational area.
Given the infrequent nature of the discharge, it is expected that any exposure will be
limited in duration with rapid dilution and dispersion experienced.
Impacts from toxicity are most likely to be limited to those organisms that would get
entrained in the plume (such as plankton and fish larvae). Consequently, the potential

EP Summary
impacts and risks from the operational discharges at the surface are considered to be
Negligible (1).
ALARP Decision A
Context
6.13 Accidental Release – Waste

Table 6-13 provides a summary of the EIA / ERA for Accidental Release – Waste.
Table 6-13 Accidental Release – Waste EIA / ERA
Cause of Aspect The handling and storage of materials and waste on board MODUs and vessels has the
potential for accidental over-boarding of hazardous/non-hazardous materials and waste.
Summary of The potential environmental impacts associated with the accidental release of waste are:
impact(s)
 Marine pollution (litter and a temporary and localised reduction in water quality);
 Injury and entanglement of marine fauna and seabirds; and
 Smothering or pollution of benthic habitats.
Plankton and Hazardous Materials and Waste

pelagic fish Hazardous materials and wastes released to the sea cause pollution and contamination,
Benthic Habitats with either direct or indirect effects on marine organisms. For example, chemical spills
can impact on marine life from plankton to pelagic fish communities, causing physiological
damage through ingestion or absorption through the skin. Impacts from an accidental
release would be limited to the immediate area surrounding the release, prior to the
dilution of the chemical with the surrounding seawater. In an open ocean environment
such as the operational area, it is expected that any minor release would be rapidly
diluted and dispersed, and thus temporary and localised.
Solid hazardous materials, such as paint cans containing paint residue, batteries and so
forth, would settle on the seabed if dropped overboard. Over time, this may result in the
leaching of hazardous materials to the seabed, which is likely to result in a small area of
substrate becoming toxic and unsuitable for colonisation by benthic fauna. Given the size
of materials release it is expected that only very localised impacts to benthic habitats
within the operational area would be affected and unlikely to contribute to a significant
loss of benthic habitat or species diversity.
Marine Fauna Non-hazardous Materials and Waste
Seabirds Discharged overboard, non-hazardous wastes can cause smothering of benthic habitats
as well as injury or death to marine fauna or seabirds through ingestion or entanglement
Benthic Habitats
(e.g., plastics caught around the necks of seals or ingested by seabirds and fish).
If dropped objects such as bins are not retrievable by ROV, these items may permanently
smother very small areas of seabed, resulting in the loss of benthic habitat. However, as
with most subsea infrastructure, the items themselves are likely to become colonised by

EP Summary
benthic fauna over time (e.g., sponges) and become a focal area for sea life, so the net
environmental impact is likely to be neutral. This would affect extremely localised areas
of seabed and would be unlikely to contribute to the loss of benthic habitat or species
diversity.
Given the restricted exposures and limited quantity of marine pollution expected from this
program, it is expected that any impacts from marine pollution may have a Minor (2)
impact resulting from a localised short-term impact to species/habitats of recognised
conservation value but not affecting local ecosystem functioning.
ALARP Decision A
Context
 Adherence to MARPOL Annex V, including:

o Garbage / waste management plan
o Garbage record book
 Waste management training / induction
6.14 Accidental Release – Loss of Containment (Minor)

Table 6-14 provides a summary of the EIA / ERA for Accidental Release – Loss of Containment
(Minor).
Table 6-14 Accidental Release – Loss of Containment (Minor) EIA / ERA
Cause of Aspect The operation of the MODU and support vessels includes handling, use and transfer of
hazardous materials, and consequently the following pathways were identified as
potentially leading to a loss of containment event:
 Use, handling and transfer of hazardous materials and chemicals on board
 Hydraulic line failure from equipment
 Transfer of hazardous materials and chemicals between the MODU and Vessel
(refuelling)
Summary of A minor loss of containment (LOC) has the potential result in chronic and acute impacts
impact(s)
to marine fauna via: potential toxicity
Marine Fauna A loss of 50 m3 of diesel or chemicals upon release would be expected to result in
Pelagic species changes to water quality in both surface waters and the pelagic environment. As
evaluated in Section 6.15, the potential impacts associated with a larger loss of diesel fuel
were determined to be Minor (2), thus impacts from these types of events are not
expected to be any larger (and thus have not been considered further).
ALARP Decision A
Context

EP Summary
 Bulk transfer process

 Hoses and connections
 Development and adherence to vessel SMPEP (or equivalent)
 Accidental release / waste management training / induction
6.15 Accidental Release - LOC (Vessel Collision)

Table 6-15 provides a summary of the EIA / ERA for Accidental Release - LOC (Vessel
Collision).
Table 6-15 Accidental Release - LOC (Vessel Collision) EIA/ERA
Cause of Aspect A loss of control event resulting in the release of marine diesel oil (MDO) has the potential
to be caused by a collision between a support vessel and third-party vessel, rupturing the
diesel storage tank.
Summary of The LOC (vessel collision) event has the potential to expose the environment to surface,
impact(s)
in-water and shoreline hydrocarbon, with the potential to directly or indirectly result in:
 Toxicity or physical oiling to marine habitats or fauna;
 Reduction in intrinsic value / visual aesthetics;
 Damage to commercial businesses.
Results of stochastic oil spill modelling for the subsea release of gas condensate have
predicted:
 Surface exposure above environmental impact thresholds were predicted within
18 km of the release location, and be present for 1-2 days after release;
 Surface exposure above the visible impact thresholds were predicted within 36 km of
the release location;
 In-water (entrained) exposure above environmental impact thresholds were scarce
and isolated, with a low probability of occurrence;
 No in-water (dissolved) exposure above environmental impact thresholds;
 Shoreline exposure above environmental impact thresholds were predicted with a low
(<10%) probability of occurrence.
Shoreline Shoreline hydrocarbon exposure has the potential to concentrate as it strands ashore,
resulting in follow-on impacts to marine fauna that may use the habitat. Habitat types
within the area of exposure include rocky, sandy and gravel shores. As MDO rapidly
weathers, is highly evaporative, and any oil that does percolate into penetrable substrate
will get reworked via tidal and wave action, accumulation on the shoreline surfaces is not
expected. As such, it is unlikely that toxicity, smothering or directed oiling to exposed
marine fauna will occur. Consequently, the potential impacts and risks to coastal habitats
from shoreline exposure are considered to be Minor (2) as they could be expected to
result in localised short-term impacts to species/habitats of recognised conservation value
but not affecting local ecosystem functioning.

EP Summary
Soft Sediment Shoreline hydrocarbon exposure has the potential to expose intertidal areas of soft
sediment to concentrations above the impact threshold. Given the characteristics of MDO
and is residues, which due to their viscosity are likely to evaporate or percolate into the
sand, it is not considered likely to accumulate on the surface. The constant wave action
and tidal movements will naturally wash and further degrade MDO residues which remain
in the inter-tidal area. Consequently, the potential impacts and risks to soft sediments in
the intertidal zone from shoreline hydrocarbon exposure are considered to be Minor (2)
as they could be expected to result in localised short-term impacts to species/habitats of
recognised conservation value but not affecting local ecosystem functioning
Coral In-water (entrained) hydrocarbon exposure has the potential to cause lethal or sublethal
(e.g. reduced growth rates, tissue decomposition etc) impacts to corals. However, the
area predicted to be exposed to in-water concentrations above the impact threshold is
patchy and has a low probability of occurrence. Given the lack of hard coral reef
formations, and the sporadic cover of soft corals in mixed reef communities, any potential
impacts will likely be limited to isolated corals. Consequently, the potential impacts to
corals from in-water hydrocarbon exposure are considered to be Minor (2), as they could
be expected to result in localised short-term impacts to species/habitats of recognised
conservation value, but not affecting local ecosystem functioning.
Macroalgae In-water (entrained) hydrocarbon exposure has the potential to cause physiological
changes (e.g. changes to enzyme systems, rates of photosynthesis etc) to macroalgae,
but are typically able to recover rapidly, even from heavy oiling. Macroalgae, including the
Giant Kelp TEC, may be present within reef and hard substrate areas within the area
predicted to be exposed; noting however, that the area predicted to be exposed to in-
water concentrations above the impact threshold is patchy and has a low probability of
occurrence. Consequently, the potential impacts to macroalgae from in-water
hydrocarbon exposure are considered to be Minor (2), as they could be expected to
result in localised short-term impacts to species/habitats of recognised conservation
value, but not affecting local ecosystem functioning
Seagrass In-water (entrained) hydrocarbon exposure has the potential to cause sub-lethal impacts
to seagrass. Seagrass may be present within the area predicted to be exposed; noting
however, that the area predicted to be exposed to in-water concentrations above the
impact threshold is patchy and has a low probability of occurrence. Consequently, the
potential impacts to seagrass from in-water hydrocarbon exposure are considered to be
Minor (2), as they could be expected to result in localised short-term impacts to
species/habitats of recognised conservation value, but not affecting local ecosystem
functioning
Plankton In-water (entrained) hydrocarbon exposure has the potential to result in toxic effects to
plankton; plankton risk exposure via ingestion, inhalation and dermal contact. The area
predicted to be exposed to in-water concentrations above the impact threshold is patchy
and has a low probability of occurrence; but does occur within the 0-10 m surface layer
where plankton are generally more abundant. Higher abundance of plankton may also
occur within the Bonney Coast Upwelling KEF. However, MDO weathers rapidly with the
entrained component naturally biodegrading. Once background water quality conditions
have re-established, the plankton community is expected to recover. Consequently, the
potential impacts to plankton from in-water hydrocarbon exposure are considered to be
Minor (2), as they could be expected to cause short-term and localised impacts, but not
affecting local ecosystem functioning.

EP Summary
Marine In-water (entrained) hydrocarbon exposure has the potential to result in acute and chronic
Invertebrates effects to marine invertebrates. No exposure to benthic invertebrates was predicted from
oil spill modelling; however pelagic species may be exposed as temporary patches of
entrained MDO may be present within 0-10m depth layers. Consequently, the potential
impacts and risks to marine invertebrates from in-water hydrocarbon exposure are
considered to be Minor (2), as they could be expected to result in localised short-term
impacts to species/habitats of recognised conservation value but not affecting local
ecosystem functioning.
Shoreline hydrocarbon exposure has the potential to expose intertidal areas to
concentrations above the impact threshold. Given the characteristics of MDO and is
residues, which due to their viscosity are likely to evaporate or percolate into the sand, it
is not considered likely to accumulate on the surface. Where oil does penetrate into the
sediment profile, smothering of exposed infauna may occur, reducing reproductive
capacity or causing death. However, tidal washing rapidly degrades MDO residues, and
reworks the upper sediment profile. Consequently, the potential impacts and risks to
marine invertebrates in the intertidal zone from shoreline hydrocarbon exposure are
considered to be Minor (2) as they could be expected to result in localised short-term
Seabirds and Surface hydrocarbon exposure has the potential to expose birds that come into contact
Shorebirds with the water surface, causing acute or chronic toxicity. There are foraging BIAs for
some species of petrel, shearwater and albatross that occur within the area predicted to
exposed. However, the extent of area predicted to be exposed to surface concentrations
>10 mg/m2 is localised (<18 km) and temporary (1-2 days); therefore, contact with
considered unlikely. Consequently, the potential impacts and risks to seabirds and
shorebirds from surface exposure are considered to be Minor (2), as they could be
expected to result in localised short-term impacts to species/habitats of recognised
conservation value but not affecting local ecosystem functioning.
Shoreline hydrocarbon exposure has the potential to expose birds that come into contact
with the shoreline via direct impacts (i.e. contamination, or direct oiling) and indirectly via
reduction in available prey items. There are foraging BIAs for a number of species that
overlap the shoreline area potentially exposed; and a breeding BIA around Lady Julia
Percy Island. However, the probability of shoreline exposure above the impact threshold
(>100 g/m2) is low, typically <10%. Consequently, the potential impacts and risks to
seabirds and shorebirds from shoreline exposure are considered to be Minor (2) as they
could be expected to result in localised short-term impacts to species/habitats of
recognised conservation value but not affecting local ecosystem functioning.
Fish and Sharks In-water (entrained) hydrocarbon exposure has the potential to physically affect fish
exposed for an extended duration. No exposure to demersal species is likely, however
those pelagic species using the surface waters may be exposed as temporary patches of
entrained MDO were predicted within the 0-10m depth layers. Impacts on eggs and
larvae in the upper water column are not expected to be significant given the temporary
period of water quality impairment, and the limited areal extent of the spill. Consequently,
the potential impacts and risks to fish and sharks from in-water hydrocarbon exposure are
considered to be Minor (2), as they could be expected to result in localised short-term

EP Summary
Marine Turtles Surface hydrocarbon exposure has the potential to expose marine turtles that come into
contact with the water surface; ingested oil can harm internal organs and digestive
function, and oil on their bodies can cause skin irritation and affect breathing. No areas
identified as critical habitat or BIAs are present within the area predicted to be exposed;
therefore, presence in the area is expected to be minimal. Consequently, the potential
impacts and risks to marine turtles from surface exposure are considered to be
Negligible (1), as they could be expected to result in localised short-term impacts to
species/habitats of recognised conservation value but not affecting local ecosystem
functioning.
Shoreline hydrocarbon exposure has the potential to expose marine turtles nesting on
shorelines via direct contact with skin/body. There are no areas identified as critical
habitat, and no BIAs or known nesting locations within the area that may be exposed.
Vicinity. Consequently, the potential impacts and risks to marine turtles from shoreline
exposure are considered to be Negligible (1), as they could be expected to result in
localised short-term impacts to species/habitats of recognised conservation value but not
Pinnipeds Surface hydrocarbon exposure has the potential to expose pinnipeds that come into
contact with the water surface; oils can result in skin and eye irritations and disruption
thermal regulation for pinnipeds. No areas identified as critical habitat or BIAs are present
within the area predicted to be exposed; therefore, presence in the area is expected to be
minimal. Consequently, the potential impacts and risks to pinnipeds from surface
exposure are considered to be Negligible (1), as they could be expected to result in
In-water (entrained) hydrocarbon exposure has the potential to result in sub-lethal
impacts to pinnipeds via ingestion of the oil or oil-affected prey. However, given the
patchy and temporary exposure to in-water hydrocarbons above the impact level, this is
considered unlikely to occur.
Shoreline hydrocarbon exposure has the potential to expose pinnipeds using the
shoreline as haul-out or breeding sites, via direct contact with skin/body; oils can result in
skin and eye irritations and disruptions to thermal regulation. Given the rocky nature of
haul-out and breeding sites, any MDO is expected to rapidly weather through repeated
wave action against the rocks; therefore, exposure is expected to be of short duration.
Consequently, the potential impacts and risks to pinnipeds from exposure from an MDO
spill event are considered to be Minor (2) as they could be expected to result in localised
short-term impacts to species/habitats of recognised conservation value but not affecting
local ecosystem functioning.

EP Summary
Cetaceans Surface hydrocarbon exposure has the potential to expose cetaceans that come into
contact with the water surface; however, physical contact with MDO is unlikely to lead to
any long-term impacts. A foraging BIA for the Pygmy Blue Whale and aggregation and
migration BIA for the Southern Right Whale occurs within the area predicted to be
exposed. However, the extent of area predicted to be exposed to surface concentrations
>10 mg/m2 is localised (<18 km) and temporary (1-2 days); therefore, contact with
considered unlikely. Consequently, the potential impacts and risks to pinnipeds from
surface exposure are considered to be Negligible (1), as they could be expected to result
in localised short-term impacts to species/habitats of recognised conservation value but
not affecting local ecosystem functioning.
In-water (entrained) hydrocarbon exposure has the potential to result in toxicity effects
(e.g. via ingestion of the oil or oil-affected prey); however, this is typically associated with
’fresh’ hydrocarbon and the risk of impact declines with the MDO weathering. Given the
patchy and temporary exposure to in-water hydrocarbons above the impact level, these
toxicity effects are considered unlikely to occur. Consequently, the potential impacts and
risks to cetaceans from in-water exposure are considered to be Negligible (1), as they
could be expected to result in localised short-term impacts to species/habitats of
recognised conservation value but not affecting local ecosystem functioning.
Commonwealth In-water (entrained) hydrocarbon exposure may occur within the vicinity of the Bonney
Areas, Parks and Coast Upwelling KEF. While the oil will not affect the upwelling process itself, if the spill
Reserves occurs at the time of an upwelling event, it may result in krill being exposed to entrained
phase MDO. This may have subsequent effects further up the food chain (i.e. from
reduced prey); however, these impacts are expected to the localised and temporary. No
Australian Marine Parks are predicted to be exposed. Consequently, the potential impacts
and risks to Commonwealth Areas, Parks and Reserves from in-water hydrocarbon
exposure are considered to be Minor (2), as they could be expected to cause short-term
and localised impacts, but not affecting local ecosystem functioning.
State Parks and In-water (entrained) hydrocarbon exposure may occur within the vicinity of the Twelve
Reserves Apostles Marine Park and the Merrie Marine Sanctuary. Major conservation values for
these marine protected areas include breeding areas for seabirds and migration route for
whales. Any impact is expected to the localised and temporary, given the patchy
exposure of in-water hydrocarbons predicted. Consequently, the potential impacts and
risks to State Parks and Reserves from in-water hydrocarbon exposure are considered to
be Minor (2), as they could be expected to cause short-term and localised impacts, but
not affecting local ecosystem functioning.
Shoreline hydrocarbon exposure has the potential to expose a number of terrestrial
protected areas; noting that the probability of exposure is <10%. Oil ashore would
typically concentrate at or below high tide mark; the seaward boundary of most terrestrial
parks does not extend past this. Visible surface hydrocarbons have the potential to
reduce the visual amenity of the area for tourism, and discourage recreational activities.
Given the characteristics of MDO and is residues, which due to their viscosity are likely to
evaporate or percolate into the sand, it is not considered likely to accumulate on the
surface. Consequently, the potential impacts and risks to terrestrial protected areas from
shoreline exposure are considered to be Minor (2) as they could be expected to result in
affecting local ecosystem functioning

EP Summary
Commercial and In-water (entrained) hydrocarbon exposure may potentially result in the contamination or
Recreational acute impacts to fish species; nothing acute impacts are expected to eb limited to small
Fishing numbers of juvenile fish, larvae, and planktonic organisms, which are not expected to
affect population viability or recruitment. Actual or potential contamination of seafood can
impact seafood markets long after any actual risk to seafood from a spill has subsided
which can have economic impacts to the industry. However exposure is expected to
minimal given the predicted patchy in-water hydrocarbons above an impact threshold.
Consequently, the potential impacts and risks are considered to be Minor (2) as this type
of event may result in a localised short-term impact, with no significant impact to third-
parties.
Coastal Settlements Visible surface hydrocarbon exposure (e.g. a rainbow sheen) and shoreline hydrocarbon
exposure has the potential to reduce the visual amenity of nearshore areas around
coastal settlements. However, due to rapid weathering of the MDO, visible sheens on the
water surface are only predicted to occur for 1-2 days after release; and accumulate on
the surface at the shoreline is also considered unlikely due to the behaviour of the MDO.
Consequently, the potential impacts and risks to coastal settlements from surface and
shoreline hydrocarbon exposure are considered to be Minor (2) as this type of event may
result in a localised short-term impact, with no significant impact to third-parties.
Recreation and Visible surface hydrocarbon exposure (e.g. a rainbow sheen) and shoreline hydrocarbon
Tourism exposure has the potential to reduce the visual amenity of an area, and therefore impact
marine-based recreation and tourism activities. However, due to rapid weathering of the
MDO, visible sheens on the water surface are only predicted to occur for 1-2 days after
release; and accumulate on the surface at the shoreline is also considered unlikely due to
the behaviour of the MDO. Consequently, the potential impacts and risks to recreation
and tourism from surface and shoreline hydrocarbon exposure are considered to be
Minor (2) as this type of event may result in a localised short-term impact, with no
significant impact to third-parties.
In-water (entrained) hydrocarbon exposure may potentially impact recreation and tourism
industry indirectly via any related impacts to presence of marine fauna (e.g. whales),
particular habitats, and recreational fishing. Given the assessment for other receptors, the
potential impacts and risks to recreation and tourism from in-water hydrocarbon exposure
is considered to be Negligible (1).
Heritage Visible surface hydrocarbon exposure (e.g. a rainbow sheen) and shoreline hydrocarbon
exposure has the potential to reduce the visual amenity of an area, and therefore impact
areas of cultural heritage along the coast. However, due to rapid weathering of the MDO,
visible sheens on the water surface are only predicted to occur for 1-2 days after release;
and accumulate on the surface at the shoreline is also considered unlikely due to the
behaviour of the MDO. Consequently, the potential impacts and risks to heritage values
from surface and shoreline hydrocarbon exposure are considered to be Minor (2) as this
type of event may result in a localised short-term impact, with no significant impact to
third-parties.
ALARP Decision A
Context

EP Summary
 Adherence to AMSA Marine Order Part 3 (Seagoing Qualifications)

 Adherence to AMSA Marine Order Part 30 (Prevention of Collisions)
 Development and adherence to vessel SMPEP (or equivalent)
 Development and adherence to Cooper Energy’s OPEP and FSP
 Development and adherence to Cooper Energy’s OSMP
 Use of pre-start notifications including Notice to Mariners, as required under the Navigation Act 2014
6.16 Accidental Release - LOC (Loss of Well Control Event)

Table 6-16 provides a summary of the EIA / ERA for Accidental Release - LOC (Loss of Well
Control Event).
Table 6-16 Accidental Release - LOC (Loss of Well Control Event) EIA / ERA
Cause of Aspect A loss of well control (LOWC) event has the potential to be caused by the temporary
abandonment of the well during the removal of the subsea tree.
Summary of The LOWC event has the potential to expose the environment to surface and in-water
impact(s)
hydrocarbon, with the potential to directly or indirectly result in:
 Toxicity or physical oiling to marine habitats or fauna;
 Reduction in intrinsic value / visual aesthetics;
 Damage to commercial businesses.
Results of stochastic oil spill modelling for the subsea release of gas condensate have
predicted:
 No surface exposure above environmental impact thresholds;
 Visible surface exposures predominantly in the vicinity of the well, with scattered and
isolated exposures potentially occurring up to 120 km away;
 No in-water (entrained or dissolved) exposure above environmental impact
thresholds;
 No shoreline exposure.
Recreation and Visible surface hydrocarbon exposure (e.g. a rainbow sheen) has the potential to reduce
Tourism the visual amenity of an area, and therefore impact marine-based recreation and tourism
activities. The extent of visible surface sheens was predicted to occur predominantly
within the vicinity of the well, but may extend (<5% probability) up to 120 km east-
southeast; however, due to the rapid weathering of the condensate, visible surface
exposures were only predicted for 1-2 days after the release. Marine-based recreation
and tourism in the vicinity of the well is expected to be minimal given its location >20 km
offshore.
parties.

EP Summary
Heritage Visible surface hydrocarbon exposure (e.g. a rainbow sheen) has the potential to reduce
the visual amenity of an area, and therefore impact areas of cultural heritage along the
coast. Visible surface sheens within nearshore coastal waters were predicted to the
patchy and isolated. Therefore, any impact to coastal cultural heritage areas is expected
to be for a short-period and of small spatial extent.
parties.
ALARP Decision B
Context
 Adherence to the Cooper Energy Well Engineering Standards and Well Management System
 Adherence to the Cooper Energy WOMP
 Development and adherence to the Cooper Energy well program
 Development and adherence to the Cooper Energy OPEP and FSP
 Development and adherence to the Cooper Energy OSMP
Likelihood Unlikely (D) Residual Risk Medium

EP Summary
7.0 Ongoing Monitoring of Environmental Performance

Cooper Energy retains responsibility as the Titleholder ensuring that the Casino-5 well
intervention and workover activities are implemented in accordance with the performance
outcomes outlined in the EP.
The systems in place to ensure that environmental performance and the standards in the EP
are met are summarised in this section.
7.1 Cooper Energy’s Health Safety Environment and Community

Management System (HSEC MS)
Cooper Energy’s Health Safety Environment and Community Management System (HSEC MS)
is the corporate system which provides the framework for the delivery of Cooper Energy’s
values, policies, standards and practices related to health, safety, environment and community.
The HSEC MS applies to all:
• Workplaces, sites and activities operated by Cooper Energy and under Cooper Energy’s
management or control;
• Exploration, construction and development activities under Cooper Energy management
or control; and
• Cooper Energy employees, contractors and visitors on Cooper Energy sites, in offices
and on activities such as offshore inspections, construction and development projects.
All personnel are expected to be familiar with, trained in, and comply with, the requirements of
the HSEC MS.
7.2 Environmental Performance Monitoring & Reporting

7.2.1 Emissions and Discharges
For MODU / vessel-based activities Cooper Energy will collect and retain records of emissions
and discharges. These emissions and discharges include treated bilge, sewage, food scraps,
incinerator (waste), ballast water discharge, fuel use, chemical discharges, spills and accidental
waste discharges.
A summary of these results will be reported in the EP performance report submitted to
NOPSEMA.
7.2.2 Audit and Inspection
Environmental performance of the activities will be audited and reviewed in accordance with
Cooper Energy’s HSEC MS. These reviews are undertaken to ensure that:
• Environmental performance standards to achieve the environmental performance
outcomes are being implemented, reviewed and where necessary amended;
• Potential non-compliances and opportunities for continuous improvement are identified;
and
• All environmental monitoring requirements are being met.
The following arrangements review the environmental performance of the activity:
• Due-diligence pre-activity inspection/audit of the MODU / vessel will be carried out prior
to the work commencing (and after contract award) to verify that procedures and
equipment for managing routine discharges and emissions are in place to enable
compliance with the EP; and
• Campaign inspections of the MODU / vessel by the Cooper Energy Site Representative
to continually verify vessel activities are in compliance with the EP.

EP Summary
• Independent of vessel-based inspection/audit activities, Cooper Energy shall undertake a

compliance audit of the commitments contained in the EP and assess the effectiveness
of the implementation strategy.
Results from the environmental inspections and audits will be summarised in the annual EP
performance report submitted to NOPSEMA.
7.2.3 Management of Non-conformance
In response to any EP non-compliances, corrective actions will be issued in accordance with
the Cooper Energy Incident Management, Non-Conformity and Corrective Action Standard
Instruction.
Corrective actions will specify the remedial action required to fix the breach and prevent its
reoccurrence and is delegated to the person deemed most appropriate to fulfil the action. The
action is closed out only when verified by the appropriate Manager and signed off. This process
is maintained through the Cooper Energy corrective action tracking system.
Cooper Energy will carry forward any non-compliance items for consideration in future
operations and drilling and completion activities to assist with continuous improvement in
environmental management controls and performance outcomes.
7.3 Management of Change (MoC)

The Cooper Energy MoC Standard Instruction describes the requirements for dealing with
managing change.
Environmentally relevant changes include:
• New activities, assets, equipment, processes or procedures proposed to be undertaken
or implemented that have the potential to impact on the environment and have not been:
o Assessed for environmental impact previously, in accordance with the relevant
standard; and
o Authorised in the existing management plans, procedures, work instructions or
maintenance plans.
• Proposed changes to activities, assets, equipment, processes or procedures that have
the potential to impact on the environment or interface with the environmental receptor;
• Changes to the existing environment including (but not limited to) fisheries, tourism and
other commercial and recreational uses, and any changes to protective matter
requirements; and
• Changes to the requirements of an existing external approval (e.g. changes to conditions
of environmental licences).
For any MoC with identified environmental impacts or risks, an impact/risk assessment will be
undertaken to consider implications of the proposed change on the environmental impacts/risks
and the adopted control measures.
Additional controls identified as part of the MoC will be effective in reducing the environmental
impact and risk to a level which is ALARP and acceptable; and will meet the nominated EPOs
and EPSs set out in the accepted EP for the activity.
7.3.1 Revisions to the EP
If the proposed change introduces a significant new environmental impact or risk, results in a
significant increase to an existing risk, or through a cumulative effect of a series of changes
there is a significant increase in environmental impact or risk, this EP will be revised for re-
submission to NOPSEMA.
In addition, the titleholder is obligated to ensure that all specific activities, tasks or actions
required to complete the activity are provided for in the EP. Section 17(5) of the regulations

EP Summary
require that where there is a significant modification or new stage of the activity (that is, change
to the spatial or temporal extent of the activity) a proposed revision of the EP will be submitted
to NOPSEMA.

EP Summary
8.0 Emergency Response Arrangements

Cooper Energy manages emergencies from offshore Victoria activities in accordance with the
Cooper Emergency Management Plan (CEMP). Within that document the following
environmental incidents are recognised as emergencies together with the appropriate
notification requirements. Relevant environmental emergencies, as they apply to the impacts
and risks identified in this EP include the following:
• IMS introduction (notifiable to DELWP);
• Wildlife affected by an oil spill (notifiable to DELWP); and
• Marine pollution incidents (notifiable to Port of Portland, DEDJTR [Level 2] and AMSA).
Further emergency response arrangements as it relates to oil spill emergencies is detailed
below.
8.1 Oil Spill Response Strategies

There are 2 credible spill scenarios for this activity that have been assessed in the EP:
1. LOC - Vessel collision resulting in a ruptured tank and spill of MDO (MDO spill)
2. LOC - Loss of well control (LOWC)
By conducting an Operational and Net Benefit Assessment, Cooper Energy has identified the
following response strategies as being appropriate for a response to these events (Table 8-1).
These are discussed in the Sections 8.1.1 to 8.1.5, and their impacts evaluated in Section 8.2.
Table 8-1 Suitability of Response Options for MDO and CHN Condensates Spills
Adopted (✓ / X)
Response Option LOC – Vessel Collision (MDO) LOC – LOWC (Casion-5
Condensate spill)
Source Control ✓ ✓
Monitor & Evaluate ✓ ✓
Dispersant Application X X
Contain & Recover X X
Protect & Deflect ✓ X
Shoreline Clean-up Possible (certain areas where Possible (certain areas where
access is possible) access is possible)
Oiled wildlife Response (OWR) ✓ ✓
8.1.1 Spill Response: Source control

Source control arrangements for significant vessel spills resulting from fuel tank perforation
includes:
• closing water tight doors
• checking bulkheads;
• determining whether vessel separation will increase spillage;
• isolating penetrated tanks;
• tank lightering, etc.

EP Summary
Source control relies heavily upon the activation of the vessels SOPEP / SMPEP (or
equivalent).
Well-related source control activities may range from:
• ROV intervention utilising specialist ROV tooling; and/or
• Well capping and/or
• Relief well installation.
8.1.2 Spill Response: Monitor and Evaluate
Ongoing monitoring and evaluation of the oil spill is a key strategy and critical for maintaining
situational awareness and to complement and support the success of other response activities.
In some situations, monitoring and evaluation may be the primary response strategy. Monitor
and evaluate will apply to all marine spills.
It is the responsibility of the Control Agency to undertake operational monitoring during the spill
event to inform the operational response. Operational monitoring includes the following:
• Aerial observation;
• Vessel-based observation;
• Computer-based tools:
o Oil spill trajectory modelling;
o Vector analysis (manual calculation); and
o Automated Data Inquiry for Oil Spills (ADIOS) (a spill weathering model).
• Utilisation of satellite tracking drifter buoys.
8.1.3 Spill Response: Protect and Deflect
Shoreline protection includes use of a boom or sand berm to create a physical barrier to
separate hydrocarbons from sensitive resources, to deflect hydrocarbons to other areas for
recovery or towards an area where there will be reduced impact (compared to more sensitive
sites).
8.1.4 Spill Response: Shoreline Assessment and Clean-up
Shoreline clean-up consists of different manual and mechanical recovery techniques to remove
oil and contaminated debris from the shoreline to reduce ongoing environmental contamination
and impact. It may include the following techniques:
• Natural recovery – allowing the shoreline to self-clean (no intervention undertaken);
• Manual collection of oil and debris – the use of people power to collect oil from the
shoreline;
• Mechanical collection – use of machinery to collect and remove stranded oil and
contaminated material;
• Sorbents – use of sorbent padding to absorb oil;
• Vacuum recovery, flushing, washing – the use of high volumes of low-pressure water,
pumping and/or vacuuming to remove floating oil accumulated at the shoreline;
• Sediment reworking – move sediment to the surf to allow oil to be removed from the
sediment and move sand by heavy machinery;
• Vegetation cutting – removing oiled vegetation; and
• Cleaning agents – application of chemicals such as dispersants to remove oil.

EP Summary
Any shoreline operations will be undertaken in consultation with, and under the control of
DEDJTR EMD, the Control Agency for Victoria, and the appropriate land managers of the
shoreline affected.
8.1.5 Spill Response: Oiled Wildlife Response
Oiled wildlife response consists of a three-tiered approach involving:
• Primary: Situational understanding of the species/populations potentially affected
(ground-truth species presence and distribution by foot, boat or aerial observations);
• Secondary: Deterrence or displacement strategies (e.g., hazing by auditory bird scarers,
visual flags or balloons, barricade fences; or pre-emptive capture); and
• Tertiary: Recovery, field stabilisation, transport, veterinary examination, triage,
stabilisation, cleaning, rehabilitation, release.
In the event of a Level 2 or 3 hydrocarbon spill, the impacts on wildlife are determined by the
types of fauna present, the type of oil spilled and the extent of exposure.
8.2 Risk Assessment of Oil Spill Response Strategies

This section provides a risk assessment of the oil spill response options, based on two credible
spill scenarios:
3. LOC - Vessel collision resulting in a ruptured tank and spill of MDO (MDO spill)
4. LOC - Loss of well control (LOWC)
The information presented in this section has been used to inform the First Strike Plan (FSP)
and the Oil Pollution Emergency Plan (OPEP).
Further information regarding emergency response arrangements can be found in Section 8.3.
8.2.1 Source Control
A NEBA of source control activities against the potential for, in the instance of a LOWC event,
the increased impact/risk associated with vessel-based activities and relief well installation has
not been undertaken as it is recognised that source control is the most effective means of
mitigating oil spill impacts to the environment for large hydrocarbon releases.
The following source control options will be implemented in the event of a hydrocarbon release
to the environment.
Table 8-2 provides a summary of the EIA / ERA for Source Control.
Table 8-2 Source Control EIA / ERA
Description of Limit flow of hydrocarbons to environment
Response Strategy
Net Environmental Benefit Analysis (NEBA)
Suitability of Achieved by vessel SMPEP.

response for
Considered to be a viable option, with a net benefit
• LOC – Vessel
Collision (MDO)
Suitability of For wellhead issues:
response for
In accordance with the Offshore Victoria Source Control Plan (VIC-DC-ERP-0001). This
• LOC – LOWC
plan provides a response to release incidents from wellheads.
(Casino-5
condensate Considered to be a viable option, with a net benefit
spill)

EP Summary
Cause of Aspect Vessel-based source control options (ROV Intervention and capping deployment) are
vessel-based and the impacts and risks associated with those activities relate to:
 Vessel discharges and emissions (sound, air emissions, bilge, etc.);
 Vessel risks (discharges of deck drainage, IMS introduction, megafauna strikes,
equipment loss to the environment, etc.); and
 Seabed disturbance.
MODU-based source control activities have common impacts and risks from MODU
based workover activities described in Section 6.0, however also include the following:
 Drill muds and cuttings discharge impacts; and
 Cementing operations and cement residue discharges;
 Loss of well control risk (dry gas impact).
Summary of All known and potential impacts from vessel-based activities have been identified within
impact(s)
Section 6. Based upon the nature and scale of those described in Section 6, the risk
evaluation is considered appropriate and thus has not been duplicated here. The control
measures in Section 6 considered appropriate for vessel based source control activities
will apply to this activity. Thus, vessel based risks have not been discussed further.
A planned discharge of drill fluid, cuttings and cementing fluids and residue has the
potential result in chronic and acute impacts to marine fauna via:
 Potential toxicity.
A planned discharge of drill fluid, cuttings and cementing fluids and residue has the
potential to impact on receptors through:
 Smothering and alteration of benthic habitats
Benthic habitat Smothering and alteration of benthic habitats

Previous experience at the Minerva well site, which is in similar water depths to the
CHN wells, showed that the physical influence of drilling was initially restricted to
approximately 100m from the wellhead. Drill cuttings remained present 4 months after
drilling completion, but were absent after 11 months, most probably because of
sediment reworking due to natural hydrodynamic processes (Currie & Isaacs, 2005).
Currie and Isaacs (2005) also identified that changes in abundance of benthic
communities reduced within 100m of the wellhead, however in most cases these
changes became undetectable four months after drilling.
In high-energy environments such as Bass Strait little drilling mud and cuttings
accumulate on the sea floor and solids are redistributed by bottom currents soon after
deposition (Neff, 2010).
Consequently, any impacts would be Negligible (1).
Plankton Potential Toxicity

Pelagic fish Water-based muds (WBM) are proposed for any relief well activities on CHN assets.
Minor quantities of WBM adhere to cuttings discharged overboard and may form a
visible plume which extends from the rig dependent on current direction and speed and
background turbidity of the water. Residual mud on cuttings is reduced prior to
discharge in a cuttings treatment system. Visible plumes may also be evident when
muds are discharged at the end of a well section, however this discharge rapidly
disperses and dilutes in the Bass Strait marine environment. In Australia, the plume is
typically visible not more than 1 km from the discharge point (Hinwood et al, 1994). As

EP Summary
any relief wells will be located at least 30 km from shore, visual amenity impacts at
adjacent shorelines are not expected. Plume discharges will be temporary and localised
(negligible consequence).
WBM chemicals discharged to the sea have the potential to impact to marine life.
Cooper Energy utilises the UK Offshore Chemical Notification System (OCNS) standard
to assess the environmental performance of chemicals during the well planning phase
to ensure high environmental performance chemicals are selected which meet the
technical requirements for drilling. Additives assessed as low toxicity, biodegradable
and having no bioaccumulation potential are utilised. Accordingly, WBM discharges
have a low toxicity footprint in the environment. Given the localised nature of the
discharge, impacts to water quality and secondary impacts to marine fauna are
assessed as having a negligible consequence.
Cement used in the drilling program guarantees well integrity. Cement additives used in
the program are selected in accordance with the Cooper Energy chemical management
standards and have a CHARM rating of Gold or Silver, non-CHARM rating of “D” or “E”
or are classified as posing little to no risk to the environment (PLONOR).
During drilling operations, small volumes of excess cement per well section are
disposed to the marine environment. Given the low environmental hazard presented by
this discharge and the small volume, any impacts would be Negligible (1).
ALARP Decision A
Context

 Maintain source control response capability as described in the Source Control Plan
 Solids control equipment
8.2.2 Monitor and Evaluate

Ongoing monitoring and evaluation of the oil spill is a key strategy and critical for maintaining
situational awareness and to complement and support the success of other response activities.
Table 8-3 provides a summary of the EIA / ERA for monitoring and evaluation activities.
Table 8-3 Monitor and Evaluate EIA / ERA
Description of Direct observation – Aerial or marine; Vector Calculations; Oil Spill Trajectory Modelling;
Response Strategy
Satellite Tracking Buoys
To maintain situational awareness, all monitor and evaluate options suitable.

EP Summary
Suitability of MDO spreads rapidly to thin layers.

response for
Aerial surveillance is considered more effective than vessel to inform spill response and
• LOC – Vessel
identify if oil has contacted shoreline or wildlife. Vessel surveillance limited in
Collision (MDO)
effectiveness in determining spread of oil.
Manual calculation based upon weather conditions will be used at the time to provide
guidance to aerial observations.
Oil Spill trajectory modelling utilised to forecast impact areas.
Deployment of oil spill monitoring buoys at the time of vessel incident will assist in
understanding the local current regime during the spill event.
Suitability of Modelling identifies that for condensate spills over 84% of the liquid residue will
response for
evaporate over the first few hours of release, with a further 14% over the first day,
• LOC – LOWC leaving approximately 2% of the spill volume potentially observable at the sea surface
(Casino-5 (in calm weather conditions).
condensate
spill) For a continuous significant spill event (well blowout) hydrocarbons will be present at
the surface for the duration of the release.
To maintain situational awareness, all monitor and evaluate techniques will be
considered during condensate spill incidents to understand the possible impacts.
Cause of Aspect The following hazards associated with operational monitoring have the potential to
interfere with marine fauna:
 Additional vessel activity (over a greater area); and
 Aircraft use for aerial surveillance (fixed wing or helicopter).
Summary of The potential impacts of underwater sound emissions in the marine environment are:
impact(s)
 Localised and temporary fauna behavioural disturbance that significantly affects
migration or social behaviours; and
 Auditory impairment, Permanent Threshold Shift (PTS).
Marine mammals The potential impacts associated with aircraft and vessel activities have been evaluated
Marine reptiles in Section 6.4 of this EP Summary. Based upon the nature and scale of the activities,
the evaluation is considered appropriate for any aerial or marine surveillance
Fish
undertaken and thus has not been considered further.
Commercial fisheries
ALARP Decision A
Context
 See Section 6.4 of this EP Summary

 Cooper Energy maintains capability to implement operational monitoring in a Level 2 or 3 spill event.
 As requested by the relevant CA Cooper Energy implements operational monitoring to inform spill response
(Level 2 or 3 spill only).

EP Summary
8.2.3 Protect and Deflect

Shoreline protection includes use of a boom or sand berm to create a physical barrier to
separate hydrocarbons from sensitive resources, to deflect hydrocarbons to other areas for
recovery or towards an area where there will be reduced impact (compared to more sensitive
sites).
Table 8-4 presents the EIA / ERA for protect and deflect activities.
Table 8-4 Protect and Deflect EIA / ERA
Description of Booms and skimmers deployed to protect environmental sensitivities. Environmental
Response Strategy
conditions (e.g., current, waves) limit application
Suitability of MDO has persistent components and has the potential to reach shorelines. Protection
response for
and deflection may be effective in protecting open estuaries that have environmental
• LOC – Vessel sensitivities (aquatic vegetation, recreational users).
Collision (MDO)
Shoreline booming (i.e. sea booming) is not considered viable due to the high energy
environment of the Otway coast and the hazards of deploying and maintaining in such
an environment.
Suitability of Casino-5 condensates have no persistent hydrocarbon fractions and will weather
response for
rapidly within a few hours and spread into thin layers rapidly due to its viscosity.
• LOC – LOWC
Predictive modelling identifies that no sensitive estuary systems are threatened by
(Casino-5
condensate surface oiling.
spill) Accordingly, the application of shoreline protect and deflect is not considered a viable
response option.
Cause of Aspect The following hazards are associated with protection and deflection activities:
 Boom deployment and management (especially anchored boom); and
 Waste collection.
Summary of The known and potential impacts of booming activities are:
impact(s)
 Loss of seabed vegetation and impacts to associated fauna habitats while deploying
boom;
 Disturbance to estuarine habitats from boom anchors;
 Restricting access to the area for recreational activities.
Nearshore habitats Potential impacts of protect and deflect vary, depending on the method used and the
(such as seagrass) nearshore / shoreline habitat.
Shoreline habitats The consequence of these shoreline activities may potentially result in short-term and
(sandy beach localised incidental damage to or alteration of habitats and ecological communities, and
habitats). are ranked as Minor (2).
ALARP Decision A
Context

EP Summary
 Maintain protect and deflect capability as described in the Source Control Plan
 As requested by relevant CA, Cooper Energy implements or supplies resources for protect and deflect
operations (Level 2 or 3 spill), appropriate to the nature and scale of predicted shoreline impacts.
 Consultation In the event of a spill will ensure that relevant government agencies support the protect and
deflect strategy
 Utilising existing tracks and paths where possible
 Waste facilities are appropriately facilitated and managed
 Collected waste is disposed of in accordance with waste disposal requirements.
8.2.4 Shoreline Assessment and Clean-up

Shoreline clean-up consists of different manual and mechanical recovery techniques to remove
oil and contaminated debris from the shoreline to reduce ongoing environmental contamination
and impact.
Table 8-5 provides the EIA / ERA for shoreline assessment and clean-up.
Table 8-5 Shoreline assessment and clean-up EIA / ERA
Description of Where shoreline impact is predicted, shoreline clean-up assessment technique (SCAT)
Response Strategy
assessment is initiated. If SCAT and NEBA assess clean-up is of net benefit, initiate
clean-up.
Shoreline clean-up is a last response strategy due to the potential environmental
impact; heavy resource requirements; health and safety concerns to responders;
logistical complexities and waste management considerations
Suitability of Shoreline contact by MDO may occur at low levels from an MDO spill. Stochastic
response for
modelling indicates a there is only 13% probability of shoreline concentrations occurring
• LOC – Vessel greater than 25 g/m2, with loading above 100 g/m2 not expected to occur.
Collision (MDO)
Much of the shoreline affected by MDO residues is rock platform and backing cliffs
where shoreline clean-up is hazardous and due to the nature of the shoreline habitat
remediates rapidly. Access to these areas is limited along the Otway coastline.
MDO residue reaching accessible sand shorelines is likely to infiltrate sand where it will
be susceptible to remobilisation by wave action (reworking) until naturally degraded.
Due to the light nature of the product and its dispersion in the environment prior to
reaching shorelines it is possible that there would be insufficient quantities for manual
clean-up. MDO does not discolour shoreline as much as other hydrocarbon types.
Manual collection techniques likely to have limited effectiveness. Use of sediment
reworking is possible.
However, the potential for shoreline assessment and clean-up will be considered as
part of the NEBA in the event of a spill incident. Response strategy offers net benefit to
shoreline species which are sensitive to oil spill residues (e.g. birds).
Suitability of Although no shoreline residues are predicted from a LOWC event, this response
response for
technique has been selected as being possibly viable as it would be considered as part
• LOC – LOWC of any NEBA in the event of a spill incident.
(Casino-5
condensate
spill)

EP Summary
Cause of Aspect The following hazards are associated with shoreline clean-up activities and may
interfere with environmental sensitivities:
 Personnel and equipment access to beaches;
 Shoreline clean-up; and
 Waste collection and disposal.
Summary of The known and potential impacts of these activities are:
impact(s)
 Damage to or loss of vegetation;
 Disturbance to fauna habitat and fauna from noise, air and light emissions from
response activities;
 Disturbance to Aboriginal cultural heritage (e.g., shell middens);
 Temporary exclusion of the public from amenity beaches.
Shoreline fauna and The noise and general disturbance created by shoreline clean-up activities could
habitats potentially disturb the feeding, breeding, nesting or resting activities of resident and
Cultural heritage migratory fauna species that may be present (such as hooded plovers). Any erosion
caused by responder access to sandy beaches, or the removal of sand, may also bury
Recreation
nests. In isolated instances, this is unlikely to have impacts at the population level.
The movement of people, vehicles and equipment through backshore and dune areas
may disturb cultural heritage artefacts that occur at the surface or are buried.
Disturbance or damage to such sites will be minimised by fencing off such areas and
reporting its presence to the relevant state regulatory agency.
The vertical infiltration of oil into shoreline sediments caused by heavy machinery and
equipment can expose fauna to oil that would not otherwise have been exposed. This
exposes the base of the food-web to contamination that may bioaccumulate up through
the food chain. It also results in the need for the increased removal of contaminated
substrate, exacerbating risks such as beach erosion.
The very presence of stranded oil and clean-up operations will necessitate temporary
beach closures (likely to be weeks but depends on the degree of oiling and nature of
the shoreline). This means recreational activities (such as swimming, walking, fishing,
boating) in affected areas will be excluded until access is again granted by local
authorities. Given the prevalence of rocky shorelines in the region, this is unlikely to
represent a significant social or tourism drawback.
Consequently, the potential impacts and risks from these activities are considered to be
Minor (2).
ALARP Decision A
Context
 Maintain shoreline assessment and clean-up capability as described in the Source Control Plan
 Consultation In the event of a spill will ensure that relevant government agencies support the shoreline
assessment and clean-up strategy

EP Summary
8.2.5 Oiled Wildlife Response

In the event of a Level 2 or 3 hydrocarbon spill, the impacts on wildlife are determined by the
types of fauna present, the type of oil spilled and the extent of exposure.
Oiled wildlife response (OWR) consists of a three-tiered approach involving:
• Primary: Situational understanding of the species/populations potentially affected
(ground-truth species presence and distribution by foot, boat or aerial observations);
• Secondary: Deterrence or displacement strategies (e.g., hazing by auditory bird scarers,
visual flags or balloons, barricade fences; or pre-emptive capture); and
• Tertiary: Recovery, field stabilisation, transport, veterinary examination, triage,
stabilisation, cleaning, rehabilitation, release.
Table 8-6 provides the EIA / ERA for OWR activities.
Table 8-6 Oiled Wildlife Response EIA / ERA
Description of Consists of capture, cleaning and rehabilitation of oiled wildlife. May include hazing or
Response Strategy
pre-spill captive management.
In Victoria, this is managed by DELWP.
Suitability of Given limited size and rapid spreading of the MDO spill, large scale wildlife response is
response for
not expected. However, there is the potential that individual birds could become oiled
• LOC – Vessel near the spill.
Collision (MDO)
OWR is both a viable and prudent response option for this spill type.
Suitability of OWR may offer net benefits to both seabirds which come into contact and area affected
response for
by minor residues.
• LOC – LOWC
OWR is both a viable and prudent response option for this spill type.
(Casino-5
condensate
spill)
Cause of Aspect The hazards associated with OWR are:
 Hazing of target fauna may deter non-target species from their normal activities
(resting, feeding, breeding, etc.);
 Distress, injury or death of target fauna from inappropriate handling and treatment;
 Euthanasia of target individual animals that cannot be treated or have no chance of
rehabilitation.
Summary of The potential impacts of this activity are disturbance, injury or death of fauna.
impact(s)
Marine fauna Untrained resources capturing and handling native fauna may cause distress, injury and
death of the fauna. To prevent these impacts, only DELWP-trained oiled wildlife
responders will approach and handle fauna.
It is preferable to have oil-affected animals that have no prospect of surviving or being
successfully rehabilitated and released to the environment humanely euthanized than to
allow prolonged suffering. The removal of these individuals from the environment has

EP Summary
additional benefits in so far as they are not consumed by predators/scavengers,

avoiding secondary contamination of the food-web.
Hazing and exclusion of wildlife from known congregation, resting, feeding, breeding or
nesting areas may have a short- or long-term impact on the survival of that group if
cannot access preferred resources. These effects may be experienced by target and
non-target species. For example, shoreline booming or ditches dug to contain oil may
prevent penguins from reaching their burrows after they’ve excited the water and low
helicopter passes flown regularly over a beach to deter coastal birds from feeding in an
oil-affected area may also deter penguins from leaving their burrows to feed at sea,
which may impact on their health.
Due to the potential for localised short-term impacts to species/habitats of recognised
conservation value but not affecting local ecosystem functioning, the potential impacts
form this activity have been identified as Minor (2).
ALARP Decision A
Context
 Maintain OWR capability as described in the Source Control Plan

 Consultation In the event of a spill will ensure that relevant government agencies support the OWR strategy
 Wildlife is only approached or handled by DELWP-trained oiled wildlife responders.
8.3 Emergency (Oil Spill) Response Arrangements and Capability

The Cooper Energy implementation strategy for this activity includes an Emergency Response
Plan (ERP)/Oil Pollution Emergency Plan (OPEP), which include details of the arrangements
for testing the response arrangements contained within these plans.
Cooper Energy has in place a Cooper Emergency Management Plan (CEMP) and Offshore
Victoria OPEP (VIC-ER-EMP-0001) for Offshore Victorian assets that will be implemented as
part of emergency response escalation where hydrocarbons have been released offshore.
A Casino-5 well intervention and workover activity First Strike Plan (FSP) has been developed
to specifically address the risks of this activity and subsequent response strategy which links to
the accepted Offshore Victoria OPEP.
8.3.1 Oil Spill Response Capability
Cooper Energy ensures that adequate oil spill response capability is maintained by specifying
response preparation controls in the Environment Plan. For the response strategies described
in Section 8.1 the controls (both environmental performance and standards) are summarised in
Table 8-7.
Table 8-7 Preparation Controls for Response Capabilities
Response PREPARATION CONTROLS

Strategy
Environmental Environmental Performance Standards
Performance Outcomes
Source Control Well Response Resources

EP Summary

Strategy
Cooper Energy maintains Cooper Energy maintains the following agreements (or
capability to implement its contractor pre-qualifications) to maintain source control
Offshore VSCP (VIC-DC- capabilities:
EMP-0001)  Well Control Specialist (including capping stack
capability).
 ROV Contractors.
 Subsea Engineering Company.
 Well Engineering Contractor.
 APPEA Mutual Assistance Agreement
Cooper Energy conducts an annual source control
desktop exercise.
Monitor and Cooper Energy maintains Agreements

evaluate capability to implement Cooper Energy maintains the following agreements (or
operational monitoring in contractor pre-qualifications) to maintain operational
response capabilities:
a Level 2 or 3 spill event.
• AMOSC membership (Aerial Observers, RPS-
APASA Contract).
• AMSA MoU.
• Aviation support (pre-qualification assessment).
• Marine support services.
Oil Spill Tracking Buoys
MODU carries an oil spill tracking buoy and instructions
for deployment.
Protect and Cooper Energy maintains Agreements

deflect capability to implement a Cooper Energy maintains the following agreements (or
“protect and deflect” contractor pre-qualifications) to maintain operational
response capabilities:
response in a Level 2 or 3
spill event. • AMOSC membership (equipment, personnel,
CORE Group, Mutual Aid).
• AMSA MoU (equipment, personnel).
• Waste management contract.
Shoreline Cooper Energy maintains Agreements
Clean-up capability to implement Cooper Energy maintains the following agreements to
SCAT and shoreline maintain shoreline assessment/clean-up response
capabilities:
clean-up in a Level 2 or 3
spill event. • AMOSC membership (equipment, personnel,
CORE Group. Mutual aid).
• AMSA MoU (equipment, personnel).
• Scientific resource support agreement (GHD or
equivalent).
• Waste management contract
Oiled Wildlife Cooper Energy maintains Cooper Energy maintains the following agreements to
Response capability to support oiled maintain OWR response capabilities:
wildlife management in a • AMOSC membership (equipment, personnel).
Level 2 or 3 spill event. • Waste management contract.
• Vessel Contract.

EP Summary

Strategy
• Vessel of Opportunity listing
8.3.2 Testing Oil Spill Response Arrangements

In accordance with the Commonwealth OPGGS(E)R Regulation 14 (8C) and in accordance
with Cooper’s HSEC management system, the OPEP will be tested:
• Prior to the commencement of a drilling campaign;
• When there is a significant amendment to the OPEP;
• Not later than 12 months after the most recent test; and
• In accordance with the schedule outlined in Table 8-8.
Exercises will be documented and any corrective actions/recommendations arising from the
exercises will be managed in accordance with the Incident Management, Non-Conformity and
Corrective Action Standard Instruction (COE-MS-STI-0020) and stewarded to closure by the
Cooper Energy Drilling HSEC Advisor.
Where changes are required to the OPEP resulting from exercise outcomes, altered contractual
arrangements, corrective actions, routine information updates (i.e. contact details change), or
other items; the Cooper Energy General Manager Operations is responsible for ensuring
changes are assessed against Commonwealth OPGGS(E)R Regulation 17 revision criteria and
where necessary, the EP/OPEP submitted to NOPSEMA as a formal revision.
For changes which do not trigger a formal revision, internal revisions to the OPEP will be in
accordance with the Cooper Energy Management of Change Standard Instruction (COE-MS-
STI-0013) with any change justified.

EP Summary
Table 8-8 OPEP Exercise Schedule (Victorian Operations)
EXERCISE SCOPE OBJECTIVES PURPOSE FREQUENCY

NO:
1 Emergency  Test emergency contact  Maintain currency on contact Bi-annual

Contact information; information.
Verification
2 Level 2/3 Spill 1. Alert and call-out of response  Test communication systems Annual
Response teams to respective incident  Availability of personnel This will be tested on CHN infrastructure
(Desktop) control centres (ICC).  Ability to transmit information quickly
(Infrastructure) and accurately
 Confirm ICC suitability
2. Cooper Energy Emergency  Test Cooper Energy EMT knowledge
Management Team (EMT) to and capability
activate first-strike response  Ensure personnel are familiar with
roles
operation (desk-top only);
confirm external support  Ensure that support arrangements
meet required timeframes within
resources are available to OPEP.
respond; and develop and
implement an Incident Action
Plan (IAP) for the next
operational period
3. Test Cooper Energy crisis  Test communications systems

management arrangements  Test transmission of information
including activation of the  Evaluate CEMT support requirements
Cooper Energy crisis to EMT
management team (CEMT) to
support the Cooper Energy EMT
during a significant oil spill
event.

EP Summary
EXERCISE SCOPE OBJECTIVES PURPOSE FREQUENCY

NO:
SCENARIO-BASED TESTING IN ANNUAL EXERCISE (As relevant to Scenario)
1. For Cooper Energy  Confirm communication and

infrastructure scenarios (pipeline information transfer protocols
rupture) test Cooper Energy’s  Test alignment of Cooper Energy
NEBA and IAP processes with
interface with State response
DEDJTR;
arrangements
 Test interface processes.
2. For blowout scenario, test  Test communication protocols
interface between source control  Provision of adequate information
team and oil spill response team transfer
(scenario interjects only)
3 Level 2/3 Spill 1. Covered by Exercise 2, On IMR Inspection (if IMR activity occurs at a
Response Objective 1 & 2 frequency greater than one year)
(Desktop) (IMR
2. For vessel-based inspection,  Test notification protocols and
Vessel) information/ documentation transfer
maintenance and repair (IMR)
with State and Commonwealth
scenarios, test interface
Regulators
between the vessel SMPEP,
OPEP, NATPLAN and Victorian
Maritime Emergency (non-
search and Rescue) Plan.
4 Discussion 1. Ensure consistent, effective  Align Cooper Energy and State Every 2 years
Exercise approach to managing Regulator response management.
emergencies between Cooper
Energy and State authorities

EP Summary
8.4 Operational and Scientific Monitoring Plan (OSMP)

The Offshore Victoria Operational and Scientific Monitoring Program (OSMP) (VIC-ER-EMP-
0002) contains detail regarding the triggers for commencing operational and scientific
monitoring, who will conduct the monitoring and what will be monitored. This document
supports the Offshore Victoria OPEP by:
• Detailing operational monitoring (Type I) requirements to be implemented in a spill to
inform spill response activities; and
• Scientific monitoring (Type II) to quantify the nature of extent, severity and persistence of
environmental impacts from a spill event and inform on appropriate remediation
activities.

EP Summary
9.0 Stakeholder Consultation

Cooper has undertaken stakeholder engagement in preparation of the Casino-5 Well
Intervention and Workover Environment Plan.
Determining the stakeholders for the Casino activity involved the following:
• Reviewing existing stakeholders identified as relevant and contained within the Cooper
Energy stakeholder register (Otway and Gippsland Basins);
• Reviewing previous Casino Henry and Netherby (CHN) consultation records;
• Conversing with existing stakeholders to identify potential new stakeholders;
• Reviewing Commonwealth and State fisheries jurisdictions and fishing effort in the
region; and
• Determining the Titleholders of nearby exploration permits and production licences
through the National Offshore Petroleum Titles Administrator (NOPTA) website.
Cooper Energy has undertaken activities in the Otway Basin for an extended period as both
Cooper Energy and previously as Santos, and in this time, has consulted with stakeholders in
the region and established a good working relationship with them.
Stakeholders identified and contacted for this activity, grouped by the categories listed under
OPGGS(E)R Regulation 11A, are listed in Table 9-1.
Table 9-1: Stakeholders for the Casino-5 well workover activity
Department or agency of the Commonwealth to which the activities to be carried out under the EP may
be relevant
Australian Fisheries Management Authority (AFMA) Australian Hydrological Service (AHS)
Australian Border Control Australian Maritime Safety Authority (AMSA)
Department of Agriculture and Water Resources Department of Communications

(DAWR)
Department of Defence (DoD) Department of Environment and Energy (DoEE) - Marine

Protected Areas Branch
Department of Innovation, Industry and Science Geoscience Australia

(DIIS)
Marine Border Command National Native Title Tribunal (NNTT)
Each Department or agency of a State or the Northern Territory to which the activities to be carried out
under the EP may be relevant
DEDJTR – Earth Resources Regulation (ERR) DEDJTR – Victorian Fishery Authority

DEDJTR - Transport Victoria - Marine Pollution DELWP - Marine National Parks and Marine Parks
Team
DELWP -Victorian Coastal Council DELWP - Wildlife Emergencies and Biodiversity
Regulation
Transport Safety Victoria (Maritime Safety)
The Department of the responsible State Minister, or the responsible Northern Territory Minister
DEDJTR – Earth Resources Regulation (ERR)

EP Summary
A person or organisation whose functions, interests or activities may be affected by the activities to be
carried out under the EP
Fisheries:
Abalone Council Australia Abalone Victoria (Central Zone) (AVCZ)
Apollo Bay Fisherman’s Cooperative Commonwealth Fisheries Authority
Eastern Zone Abalone Industry Association Port Campbell Professional Fisherman’s Association
Port Franklin Fisherman’s Association Portland Professional Fisherman’s Association
San Remo Fishing Cooperative Seafood Industry Victoria (SIV)
South-east Fishing Trawl Industry Association Southern Rock Lobster Ltd

(SETFIA)
Southern Shark Industry Alliance Sustainable Shark Fishing Inc. (SSF)
Victorian Recreational Fishers Association (VRFish) Victorian Rock Lobster Association (VRLA)
Victorian Scallop Fisherman's Association Warrnambool Professional Fisherman’s Association
Western Abalone Divers Association (WADA)
Oil spill preparedness and response agencies:
Australian Marine Oil Spill Centre (AMOSC) DEDJTR – Marine Pollution Branch
Parks Victoria Department of Environment, Land, Water and Planning

(DELWP)
Nearby Petroleum Titleholders:
Lattice Energy Limited (Origin Energy Resources

Ltd)
Other entities:
Aboriginal Affairs Victoria Australian Oceanographic Services P/L
Native Title Services Victoria Southern Cross Cables
Victorian Fish and Food Marketing Association
Any other person or organisation that the Titleholder considers relevant
Community interests:
Port Campbell Boat Charters Scuba Divers Federation of Victoria (SDFV)
9.1 Consultation Approach

9.1.1 Initial Consultation
2018 Offshore Drilling Campaign Brochure
A 2018 Offshore Campaign Stakeholder Information Brochure outlining upcoming Cooper Energy
activities in the Otway and Gippsland Basins, including Casino-5 workover activities, was
disseminated to stakeholders in September 2017. The brochure provides information concerning
the location, timing and nature of the proposed activities, information on potential risks and

EP Summary
impacts, and provides contact details should stakeholders wish to seek further information or
have an objection.
Distribution of Survey Information via Fishing Associations
To ensure broader communications with new and existing commercial fishers; entities or
individuals holding commercial fishing licences have been informed of the activities via
government and private associations such as AFMA, SIV, VFA and SETFIA.
Cooper Energy Website
The 2018 Offshore Campaign Stakeholder Information Brochure has been made available on the
Cooper website (http://www.cooperenergy.com.au/) for all interested members of the public to
access. Information prepared for future project milestones will also be made available on the
website.
9.1.2 Summary of Stakeholder Consultation
Stakeholder engagement has involved a combination of email exchanges and phone
conversations.
A summary of stakeholder responses, Cooper Energy’s assessment of any objections or claims
and response or proposed response, are provided in Table 9-2. It should be noted that most of
responses are generic and relate equally to other activities that may occur as part of Cooper
Energy’s 2018 Offshore Campaign. Only two (2) responses (AMOSC and AMSA) refer directly
to the Casino activities.
9.2 Ongoing Consultation

Consultation with relevant stakeholders will be ongoing. Cooper Energy will comply with requests
by stakeholders for additional information or updates during the activity itself. In addition,
stakeholders will be notified of any changes to scope of the EP that may affect their interests or
activities at a minimum two (2) weeks in advance of an activity to be undertaken under that
change.
Prior to the workover activity commencing, Cooper Energy will provide relevant stakeholder’s
further information including:
• Confirmation on the timing and duration;
• Name and call sign of any associated vessels (if known);
• A description of the activities which are being undertaken;
• A request to provide feedback on the activities;
• The opportunity for face-to-face meetings; and
• Contact details of where any claims, objection or concerns may be directed.
As part of this process, Cooper Energy shall check that identified stakeholders are still relevant
and correct, and identify new stakeholders (via organisational bodies such as AFMA, AMSA, SIV,
SETFIA, lessons learnt etc.).
Cooper will follow-up with stakeholders providing notifications approximately five days prior to
activity commencement (or as requested by the individual stakeholder) and a demobilisation
notification within 10 days of completion of the activity (or at a period requested by stakeholder).
Activity notification may be a stand-alone notice or part of another Campaign Brochure (or
equivalent)

EP Summary
Table 9-2: Stakeholder Feedback and Cooper Assessment of Claims/Objections
Stakeholder Relevance to Information provided Summary of Response Assessment of Merits to Operators Response to each Claim /
Activity (Date, Method, Record, Adverse Claim / Objection Objection
Number)
Aboriginal Responsible for 19/9/2017– emailed Your message was received. Thank You. No assessment required Not applicable
Affairs Victoria the implementation 2018 Offshore
of the Aboriginal Campaign Stakeholder
Heritage Act 2006 Information brochure.
and the Aboriginal Thanked COE for the information and that
Lands Act 1970. it will be passed on to major projects senior Responded with thanks and offer of further
Determines RAPs. No assessment required
officer for consideration. If he determines a information if required.
cause for response he will get back to you.
Australian Management of 19/9/2017– emailed Replied with thanks Not Applicable Not Applicable
Fisheries Commonwealth 2018 Offshore Campaign
Management Commercial Stakeholder Information
Authority Fisheries from brochure.
3nm to 200nm Requested that all correspondence be via No claims or objection to be COE confirmed that the information was sent to
(EEZ) the generic [email protected] assessed. the appropriate fishing industry contacts as
address and it will then be disseminated to outlined in the link. requested confirmation then
relevant managers. All emails to only go via that any information about upcoming activities
generic petroleum email only be emailed to the ‘petroleum’ address and
address. not to individual fishery managers.
Australian Commonwealth 19/9/2017– emailed Requested to provide finalised information No claims or objections to be COE confirmed information would be provided
Hydrographic Agency 2018 Offshore Campaign at least three weeks prior to assessed. to AHS at least 3 weeks prior to activities
Services responsible for Stakeholder Information commencement of any commencing
Hydrographic brochure. works to allow for publication of notices to
Services such as mariners.
Notice to Mariners
Details of
infrastructure
placed on
Navigation Charts
Charting and
Information
Management

EP Summary
Number)
Australian Safety Regulator 19/9/2017– emailed 22/9/2017: Thanked COE for providing 22/9/2017: No claims or 23/9/2017: COE acknowledged increased traffic
Maritime Safety for Marine Safety 2018 Offshore information on PSZ, NtM and AUSCOAST objections to be assessed. in the areas and that the TSS slightly
Authority and Vessel-based Campaign Stakeholder warnings. COE acknowledge increased encroaches on BMG and Sole. COE
Oil Spill Response Information brochure. Provided updated data traffic plots for traffic in areas acknowledge the timeframes and requirements
in Commonwealth Otway and Gippsland basins. Identified for notification to AMSA in relation to the
Waters where greater traffic may be encountered. Auscoast warnings and NtM as well as any
Noted that vessels entering and exiting the petroleum safety zones.
Impacts on Traffic Separation Scheme (TSS) slightly This information will be carried through into EP
Shipping Routes & encroach on BMG and Sole. and future correspondence requirements.
Navigation Requested JRCC be contacted 24-48
Warnings hours before activity commences with
Marine Pollution vessel details etc to promulgate
Controller in AUSCOAST warning.
Commonwealth Requested AHS be contacted at least 4
Waters for Vessels weeks prior to activities for NtM (vis hyrdo
email) and to update charts (via datacentre
email).
Department of Pipeline 19/9/2017– emailed 20/9/2017: No claims or No response required

Environment, Regulation, 2018 Offshore 20/9/2017: Replied with thanks objections to be assessed.
Land Water and Regulation and Campaign Stakeholder
Planning Approvals Information brochure.
(DELWP) 19/9/2017: Thanked COE for the update.
Energy,
Environment and Requested confirmation that the 'single
19/9/2017: COE confirmed that the parties
point of contact' is for general 19/9/2017: COE
Climate Change involved in reporting etc. will not change but If
communications rather than statutory acknowledge confusion
Group any changes do occur, DELWP will be notified
reporting obligations, and that legal regarding point of contact and
immediately and amend and resubmit
arrangements for the transfer of Victorian provided clarity as requested
documentation as required.
land based pipelines will continue as is and
the current contacts will not be affected

EP Summary
Number)
AMOSC Oil Spill Response 19/9/2017– emailed Responded stating that OPEP is being finalised
20/9/2017: Cooper
Organisation 2018 Offshore 19/9/2017: AMOSC does not distribute and will be forwarded to AMOSC for review in
apologized for not removing
Campaign Stakeholder member information amongst the the near future.
Review and the sentence regarding
Information brochure. membership group. We will however, be
comment on distribution from the covering OPEP was supplied to AMOSC for review.
Cooper Energy Cooper Energy very interested in receiving a draft copy of email. Comments were received and incorporated as
Offshore Victorian maintains an Associate the OPEP to confirm with Cooper appropriate.
Oil Pollution Membership with AMOSC’s resources and processes and
comment on the same. No issue with comments
Emergency Plan AMOSC
provided
(OPEP) reviewer
Department of Commonwealth Offshore Campaign

19/9/2017: COE will no longer send information
the Environment Department Stakeholder Information 19/9/2017 - Generic response:
to DOE offshore petroleum email address.
and Energy formally brochure. Requested all information be via COE acknowledge the advice
No response necessary as it’s a generic
overseeing NOPSEMA. Provided links to further from DOE.
response email from DOE.
offshore petroleum guidance material.
Remove from stakeholder register.
activities.
DEDJTR Department of 19/9/2017– emailed

4/10/2017: Response to BMG notice. 4/10/2017: COE acknowledged request and will
Victorian Fishery Economic 2018 Offshore
Requested all info be sent to nominated update database
Authority (VFA) Development, Campaign Stakeholder
officer. 9/10/2017: COE reverted back to VFA to request
Jobs, Transport Information brochure.
whether ALL correspondence now goes to
and Resources
no assessment required nominated officer and whether they were using
Peak State
new email addresses.
Fisheries body 10/10/2017: VFA confirmed that all
correspondence to now go via nominated 10/102017: COE will ensure all correspondence
Regulator offshore officer and that all VFA emails are now VFA goes to nominated officer and that the VFA
to 3mn Victorian and not ecodev. emails will be used.
coastal Waters
Geoscience 19/9/2017– emailed
Australia 2018 Offshore 19/9/2017: Out of office reply, but noting
no assessment required No response required
Campaign Stakeholder officer has access to emails
Information brochure.

EP Summary
Number)
Australian Oil and Gas 19/9/2017– emailed 22/9/2017: No assessment

22/9/2017: Representative outlined their
Oceanographic Fishery Liaison 2018 Offshore required.
experience in O&G, fishing, energy 22/9/2017: COE acknowledged representative
Services Pty Ltd Campaign Stakeholder COE acknowledge
transmission and provision of services and but stated that the COE liaison would be out of
Information brochure. representatives experience
requested opportunity to talk that day. the country until the 12th and requested that the
and welcome the opportunity
discussion be delayed.
to work with him.
23/9/2017: Agreed talks can wait.
Representative spoke with COE 23/9/2017: COE agreed that use of fishing
23/9/2017: no adverse claim
management and service boat owners vessels where possible has merit as builds good
or objection to assess. COE
regarding their vessels being used for relations. Confirmed will be in touch on return.
acknowledge possible use of
future support activities.
fishing vessels
Department of 19/9/2017– emailed 20/9/2017: Auto reply outlining

Agriculture and 2018 Offshore requirements for vessels entering
Water Campaign Stakeholder Australian waters to enter info in the the
Resources - Information brochure. MARS system including:
MNCC • Pre-Arrival Report (PAR) – 96 and 12
hours prior to arrival in Australia.
• Ballast Water Report (BWR) – no later
than 12 hours prior to arrival in Australia if
20/9/2017: No response required as automated
the
reply.
vessel is fitted with ballast tanks. Ballast No assessment required
Information provided shall be included in
water must be managed in accordance
subsequent EPs as necessary
with the Australian Ballast Water
Requirements.
• Non First Point of Entry Application (NFP)
submitted no less than 10 working days
prior to
arrival in Australia (if applicable).
Changes in health of crew to be reported
Links to information provided

EP Summary
Number)
National Native 19/9/2017– emailed 20/9/2017. email from representative

5/10/2017: COE acknowledged that no
Title Tribunal 2018 Offshore stating that there were no registered claims
registered native title claims or determined
Campaign Stakeholder over the area of proposed activities.
native title claims appear to overlap the
Information brochure. However stated that for pipelines that
proposed offshore areas and that where a new
crossed the coast that it may impacts on
pipeline crosses the coast and becomes
interests of two groups. Stated:
onshore that native title holders may be
The proposed activities will take place
impacted. Confirmed that relevant parties will be
within the Representative Aboriginal Torres No assessment required contacted as required. Acknowledged that the
Strait Islander Body Area of the Native Title
Area unlikely to be affected by Native Title Services Victoria Ltd have not been
Services Victoria Ltd. You may wish to, if
offshore activities at Casino contacted and requested NNTT confirm the
you have not already consult with that
contact details for the group. COE also
body.
acknowledge that the Tribunal cannot comment
It is not appropriate for the Tribunal to
any further on the activities. NTSV sent flyer on
comment further.
9/10/17.
5/10/2017 - NNTT confirmed contact
5/10/17 - COE thanked NNTT for the assistance
details for NTSV and also provided a link to
and that the maps would be reviewed.
geospatial maps outlining RATSIB areas
Parks Victoria Marine Park 19/9/2017– emailed
2018 Offshore
19/9/2017: automated response email No assessment required No response required
Campaign Stakeholder
Information brochure.

EP Summary
Number)
South-East Peak Industry 19/9/2017– emailed 28/9/2017: COE acknowledged the email stating
Trawl Fishing Group for Trawl 2018 Offshore that an official response was being drafted.
Industry Fishermen in the Campaign Stakeholder Requested confirmation of meeting date for the
Association SE Region Information brochure. Mon or Tues
Interests: 30/9/2017: Meeting invite sent
Activity
Notifications 5/10/2017: Official response addressing claims
No response received in relation to and objections emailed. COE acknowledged:
Increased impacts
emailed brochure importance of FIS and potential impacts of
that may affect
upcoming FIS seismic, but that our activities are not seismic
26/9/2017: Generic email sent to all O&G and that any noise emissions would be similar to
Assessment of claims and
stakeholders outlining the upcoming Fish those currently generated by existing O&G
objections is required as the
Survey and request to not undertake any operations or transiting vessels in the region.
activity will be within the 6
activities between Feb and mid-Sept 2018 Provided supporting information on likely
months prior to the FIS and in
and then again between Feb and mid-Sept produced sound levels of the activities and that
close proximity. Initial notice
2018. Noted that an earlier request was the noise from the vessels is greater than from
only asked that seismic not be
sent out asking that no seismic be drilling itself. Based on studies it is likely
undertaken. COE are not
undertaken but that SETFIA has received 2 received levels will be less than 120dB within
undertaking seismic activities.
notices re non-seismic activities only 2-4 km from the activity, while seismic may
Cooper have assessed that
the offshore activities will not only reach such levels 35 km away. As such, the
28/9/2017: Confirmed may be available activities cannot be compared to each other as
negatively impact the FIS.
stated in the SETFIA letter. It is anticipated that
9/10/2017: SETFIA stated the outcome the drilling program will be completed before the
was not what they were after. They will FIS commences in August and pipelay activities
decide whether to proceed with the FIS will commence in nearshore waters adjacent to
shot(s) in question for that survey, but the Orbost Gas Plant between September and
suspect not. November 2018, and so likely not impact the
FIS.
9/10/2017: Meeting confirmed for Tuesday 17th

to discuss the issues raised
11/10/2017: COE replied with thanks and that
the issues would be discussed in the meeting on
the 17th.

EP Summary
Number)
Seafood Peak Industry 19/9/2017– emailed Email was already also sent to
Industry Victoria Body for Victorian 2018 Offshore 19/9/2017: Out of office reply. Alternate alternative email address and No action required
seafood and Campaign Stakeholder email address provided. so not further action is
fisheries Information brochure. required.
19/9/2017: COE responded stating first EP to be

submitted within 1 month. Reminded SIV that
19/9/2017: Representative responded consultation is ongoing and understood that they
requesting when feedback is required as need time to discuss the approach with their
they would like to discuss this and sit down members.
No assessment required
and work through an appropriate approach
to consulting with the fishing industry of 9/10/2017: Follow up email sent to see if SIV
Victoria. had any response or required a meeting
11/10/2017: Meeting organised for Monday 16th
September.
Southern Cross 19/9/2017– emailed 19/9/2017: Thank you for the information
Cable Network 2018 Offshore and notice, we will share this with our No assessment required
20/9/2017: COE sent thanks and offer for more
Campaign Stakeholder members in the Submarine Cable Unlikely to be affected by info if required.
Information brochure. community and advise you of any issues or activities at Casino
concerns.
Southern Shark Peak Group for 19/9/2017– emailed
Industry Alliance Gummy Shark 2018 Offshore
20/9/2017: Auto reply No assessment required No action required
fishing southern Campaign Stakeholder
Australia Information brochure.
Marine Border Integrated 2017.10.10 – emailed

Control defence/customs 2018 Offshore 10/10/2017: MBC confirmed that they are
organisation which Campaign Stakeholder the catch all for oil and gas industry and No action required
No assessment required
provides security Information brochure. will forward all information to the relevant 11/10/2017: COE replied with thanks
for offshore marine parties within MBC
areas

EP Summary
Number)
Department of Submarine Cables 19/9/2017– emailed 10/10/2017: The department had no

Communications Team 2018 Offshore comments on the proposals noting that No action required
and the Arts Campaign Stakeholder there are three submarine cables across
Information brochure. Bass Strait connecting Victoria and 11/10/2017: COE replied with thanks and
Submarine No assessment required questioned whether the department still wanted
Tasmania, but they do not appear to be in
Cables Team the vicinity of the activity areas to receive updates since their assets were not in
the vicinity

EP Summary
10.0 References
APASA. 2013. Quantitative Hydrocarbon Spill Modelling for the Patricia Baleen Asset.
Prepared for Santos Ltd.
Black, K.P., Brand, G.W., Grynberg, H., Gwyther, D., Hammond, L.S., Mourtikas, S.,
Richardson, B.J. and Wardrop, J.A. 1994. Production facilities. In: Environmental implications of
offshore oil and gas development in Australia – the findings of an independent scientific review.
Swan, J.M., Neff, J.M. and Young, P.C. (eds) Australian Petroleum Exploration Association.
Sydney. pp 209–407
BP. 2013. Shah Deniz 2 Project. Environmental & Socio-Economic Impact Assessment. BP
Development Pty Ltd.
DAWR, 2017. Australian Ballast Water Requirements. Department of Agriculture and Water
Resources, version 7.
http://www.agriculture.gov.au/SiteCollectionDocuments/biosecurity/avm/vessels/ballast/australia
n-ballast-water-management-requirements.pdf [Accessed November 2017]
DoEE, 2017. Conservation Values atlas. Search for HDD activity area Undertaken on the 6th of
January 201 at http://www.environment.gov.au/webgis-framework/apps/ncva/ncva.jsf
Environment Australia (EA). 2003. Recovery Plan for Marine Turtles in Australia, Prepared by
the Marine Species Section Approvals and Wildlife Division, Environment Australian. Available
online at: http://www.environment.gov.au/coasts/publications/turtle-recovery/pubs/marine-
turtles.pdf [Accessed 21 February 2017]
Hewitt, C.L., Martin, R.B., Sliwa, C., McEnnulty, F.R., Murphy, N.E., Jones, T. and Cooper, S.
(eds). 2002. National introduced marine pest information system. Available online
http://www.marinepests.gov.au/Pages/default.aspx Accessed 04 May 2017
Laist, D.W., Knowlton, A.R., Mead, J.G., Collet, A.S., & Podesta, M. 2001. Collisions between
Ships and Whales. Marine Mammal Science, Vol. 17, Issue 1, pp 35-75.
Langford, T.E.L. 1990. Ecological effects of thermal discharges, xi, 468p. Elsevier.
Marquenie, J., Donners, M., Poot, H., Steckel, W. and de Wit, B. (2008). Adapting the spectral
composition of artificial lighting to safeguard the environment. Petroleum and Chemical Industry
Conference Europe -Electrical and Instrumentation Applications, pp 1-6.
McIntyre, A.D. and Johnson, R. 1975. Effects of nutrient enrichment from sewage in the sea. In:
ALH Gameson, ed. Discharge of sewage from sea outfalls. New York, Pergamon Press.
pp. 131–141
Neuparth, T., Costa, F. O., & Costa, M. H. (2002). Effects of temperature and salinity on life
history of the marine amphipod Gammarus locusta. Implications for ecotoxicological testing.
Ecotoxicology, 11, 61–73.
OGUK. 2014. Guidance on Risk Related Decision Making. Available online at:
http://oilandgasuk.co.uk/product/guidance-on-risk-related-decision-making-issue-2-july-2014/
[Accessed 7 January 2017]
OSPAR. 2014. Establishment of a list of Predicted No Effect Concentrations (PNECs) for
naturally occurring substances in produced water. OSPAR Commission. OSPAR Agreement:
2014–05
Popper, A. N., Hawkins, A. D., Fay, R. R., Mann, D., Bartol, S., Carlson, T., Coombs, S., Ellison,
W. T., Gentry, R., Halvorsen, M. B., Løkkeborg, S., Rogers, P., Southall, B. L., Zeddies, D., and
Tavolga, W. N. (2014). “Sound Exposure Guidelines for Fishes and Sea Turtles: A Technical
Report,” ASA S3/SC1.4 TR-2014 prepared by ANSI Accredited Standards Committee
Richardson, W. J., Greene, C. R., Maime, C. I. and Thomson, D. H. 1995. Marine
Mammals and Noise. Academic Press, San Diego, California.

EP Summary
RPS-APASA. 2017. BMG Well Abandonment Program, Gippsland Basin – Quantitative Oil Spill
Modelling Study. Prepared for Cooper Energy. RPS Australia West Pty Ltd.
Santos. 2004. Casino Gas Field Development Environment Report. Prepared by Enesar
Consulting Pty Ltd, for Santos Ltd.
Shell. 2010. Prelude Floating LNG Project EIS Supplement-Response to Submissions
Southall, B.L., Bowles, A.E., Ellison, W.T., Finneran, J.J., Gentry, R.L., Greene Jr C.R., Kastak,
D., Ketten, D.R., Miller, J.H., Nachtigall, P.E., Richardson, W.J., Thomas, J.A and Tyack, P.L.
2007. Marine Mammal Noise Exposure Criteria: Initial Scientific Recommendations. Aquatic
Mammals. 33 (4):411–414.
United Nations Environment Programme, (UNEP). 1985. GESAMP: Thermal discharges in the
marine environment. UNEP Regional Seas Reports and Studies No. 45.
Walker, D.I. and McComb, A.J. 1990. Salinity response of the seagrass Amphibolis antarctica
(Labill.) Sonder et Aschers: an experimental validation of field results. Aquat Bot. 36:359–366.
WEL (Woodside Energy Ltd.) 2014. Browse FLNG Development, Draft Environmental Impact
Statement. EPBC 2013/7079. November 2014. Woodside Energy, Perth WA.
Whale and Dolphin Conservation Society (WDCS), 2003 - Oceans of Noise. [Online].
Available from: http://ww.wdcs.org/stop/pollution/index.php
Wiese, F. K., Montevecci, W. A., Davoren, G. K., Huettmann, F., Diamond, A. W. and Linke, J.
2001. Seabirds at risk around off shore oil platforms in the northwest Atlantic. Marine Pollution
Bulletin. 42:1285-1290.
Woodside. 2003. Otway Gas Project Environmental Impact Statement/Environment Effects
Statement (EIS/EES). Prepared by Woodside Energy Ltd.

EP Summary
11.0 Acronyms and Units
11.1 Acronyms
Acronym Description
ADIOS Automated Data Inquiry for Oil Spills
AFMA Australian Fisheries Management Authority
AHS Australasian Hydrographic Society
AHTS Anchor Handling, Tow and Support
ALARP As Low As Reasonably Practical
AMOSC Australian Marine Oil Spill Centre
AMP Australian Marine Park
AMSA Australian Maritime Safety Authority
API American Petroleum Institute
APPEA Australian Petroleum Producer & Exploration Association
APPEA Australian Petroleum Production and Exploration Association
AQIS Australian Quarantine and Inspection Service
AVCZ Central Zone Abalone Association
BAOAC Bonn Agreement Oil Appearance Code
BIA Biologically Important Areas
BOD Biological Oxygen Demand
BOM Bureau of Meteorology
BOP Blowout Preventer
CAMBA Agreement between the Government of Australia and the Government of the People’s
Republic of China for the Protection of Migratory Birds and their Environment
CBTA Competency Based Training Assessment
CFSR Climate Forecast System Reanalysis
CHN Casino Henry and Netherby
CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora
CoEP Code of Environmental Practice
DAFF Department of Agriculture, Fisheries and Forestry
DAWR Department of Agriculture, Water and Resources
DEDJTR Department of Economic Development, Jobs, Transport and Resources
DELWP Department of Environment, Land, Water and Planning
DIIS Department of Innovation, Industry and Science

EP Summary
Acronym Description
DoD Department of Defence
DoE Department of Environment
DSV Diving support vessel
EHU electro-hydraulic umbilical
EIA Environmental Impact Assessment
EMBA Environment that May Be Affected
EMP Emergency Management Plan
EMS Environmental Management System
EMT Emergency Management Team
EP Environment Plan
EPA Environment Protection Authority
EPBC Environmental Protection and Biodiversity Conservation
EPO Environmental Performance Outcomes
EPS Environmental Performance Standards
ERP Emergency Response Plan
ERR Earth Resources Regulation
ESD Ecologically Sustainable Development
FFG Flora and Fauna Guarantee
FSP First Strike Plan
FSP First Strike Plan
GEMS Diamond’s Global Excellence Management System
GHG Global Greenhouse Gas
HSEC Health, Safety, Environmental and Community
HSEC-MS Health, Safety, Environmental and Community Management System Management

System
HSEQ Health, Safety, Environmental and Quality
HXT Subsea Horizontal Tree
IADC International Association of Drilling Contractors
IAP Incident Action Plan
IC Incident Controller
ICC Incident Control Centres
IGP Iona Gas Plant
IMPs Invasive Marine Pests

EP Summary
Acronym Description
IMR Inspection, maintenance and repair
IOGP International Association of Oil and Gas Producers
IOPP International Oil Pollution Prevention
ISM International Safety Management
ISO International Organisation for Standardisation
IWCF International Well Control Forum
IWOCS Installation Workover and Control System
JAMBA Agreement between the Government of Australia and the Government of Japan for the
Protection of Migratory Birds and Birds in Danger of Extinction and their Environment
JHA Job Hazard Assessments
JRCC Joint Rescue Coordination Centre
JSA Job Safety Analysis
KEF Key Ecological Features
LOC Loss of Containment
LOWC Loss of Well Control
MAA Mutual Assistance Agreement
MARPOL International Convention for the Prevention of Pollution from Ships
MARS Maritime Arrivals Reporting System
MBC Maritime Border Command
MC Measurement Criteria
MDO Marine Diesel Oil
MEG Mono Ethylene Glycol
MFO Marine Fauna Observation
MNES Matters of National Environmental Significance
MO Marine Orders
MoC Management of Change
MODU Mobile Offshore Drilling Unit
MoU Memorandum of Understanding
NCEP National Centre for Environmental Prediction
NEPM National Environmental Protection (Air Quality) Measures
NES National Ecological Significance
NMFS National Marine Fisheries Service
NOPSEMA National Offshore Petroleum Safety and Environmental Management Authority

EP Summary
Acronym Description
NOPTA National Offshore Petroleum Titles Administrator
NORMS Naturally Occurring Radioactive Materials
NP National Park
OCNS Offshore Chemical Notification System
ODME Oil Detection Monitoring Equipment
OEM Original Equipment Manufacturer
OIM Offshore Installations Manager
OPEP Oil Pollution Emergency Plan
OPGGS Offshore Petroleum and Greenhouse Gas Storage
OPGGS(E)R) Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009
OPRC International Convention on Oil Pollution Preparedness, Response and Cooperation
OSMP Operational and Scientific Monitoring Program
OSRL Oil Spill Response Limited
OSTM Oil Spill Trajectory Modelling
OWR Oiled wildlife Response
OWS Oily Water Separator
PLONOR Posing Little Or No Risk to the environment
PMS Planned Maintenance System
PNEC Predicted No Effect Concentration
POB Persons on Board
POWBONS Pollution of Waters by Oil and Noxious Substances Act
PPE Personal Protective Equipment
PSZ Petroleum Safety Zone
PTS Permanent Threshold Shift
PTW Permit to Work
RAMSAR Convention on Wetlands of International Importance especially as Waterfowl Habitat
RCP Risk Control Practices
RMS Root Mean Squared
RO Reverse Osmosis
ROV Remotely Operated Vehicle/S
SCAT Shoreline Clean-Up Assessment Technique
SDFV Scuba Divers Federation of Victoria

EP Summary
Acronym Description
SEMS Diamond’s Safety and Environmental Management System
SETFIA South-east Fishing Trawl Industry Association
SIMAP Spill Impact Mapping Analysis Program
SIV Seafood Industry Victoria
SMPEP Shipboard Marine Pollution Emergency Plan
SOPEP Shipboard Oil Pollution Emergency Plan
SPL Sound Pressure Level
SSF Sustainable Shark Fishing Inc.
SSTs Subsea Trees
SSTT Sub-Sea Test Tree
STP Sewage Treatment Plan
TEC Threatened Ecological Communities
TPCs Third Party Contractors
TRSSV Tubing Retrievable Subsurface Safety Valve
UAV Unmanned Aerial Vehicles
VADA Victorian Abalone Divers Association
VRFish Victorian Recreational Fishers Association
VRLA Victorian Rock Lobster Association
VSCP Offshore Victoria Source Control Plan
WADA Western Abalone Divers Association
WBM Water Based Muds
11.2 Units
Unit Description
‘ Minutes
“ Seconds
µg/m3 Micrograms per Cubic Metre
cP Centipoise
dB Decibel
hrs Hours
kg/m3 Kilograms per Cubic Meter

EP Summary
Unit Description
kHz Kilohertz
km Kilometres
km2 Kilometres Squared
L Litres
m metres
m.s.-1 Metres Per Second
m2 Metres Squared
m3 Metres Cubed
m3/h Metres Cubed per Hour

o Degrees
oC Degrees Celsius
ppb Parts per Billion
ppm Parts Per Million
μPa Micro Pascals

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Casino-5 Well

2.0 Location of the Activity ............................................................................................................ 7

3.0 Description of the Activity ....................................................................................................... 9

4.0 Description of the Environment ............................................................................................ 12

5.0 Environmental Impact and Risk Assessment Methodology .............................................. 27

6.0 Risk and Impact Evaluation ................................................................................................... 33

7.0 Ongoing Monitoring of Environmental Performance .......................................................... 56

CHN-EN-EMP-0004 / UNCONTROLLED WHEN PRINTED Page 2 of 98

8.0 Emergency Response Arrangements ................................................................................... 59

9.0 Stakeholder Consultation ...................................................................................................... 75

11.0 Acronyms and Units ............................................................................................................... 88

CHN-EN-EMP-0004 / UNCONTROLLED WHEN PRINTED Page 3 of 98

Table 8-2 Source Control EIA / ERA ..................................................................................................... 61

CHN-EN-EMP-0004 / UNCONTROLLED WHEN PRINTED Page 4 of 98

Rev Date Details Author Reviewer Approver

0 03/01/2018 For Submission R Hooke / P J Earnshaw

1 22/01/2018 Updated to address NOPSEMA comments R Hooke / P J Earnshaw

Copy No. Recipient

1 General Manager Operations – Cooper Energy

2 HSEC Coordinator – Cooper Energy

3 Drilling HSEC Coordinator – Cooper Energy

4 Incident Operations Centre – Cooper Energy

5 Well Construction Manager – Cooper Energy

CHN-EN-EMP-0004 / UNCONTROLLED WHEN PRINTED Page 5 of 98

Figure 1-1 Location of Vic/L24 and VIC/L30

1.1 Titleholder Nominated Liaison Person

CHN-EN-EMP-0004 / UNCONTROLLED WHEN PRINTED Page 6 of 98

2.0 Location of the Activity

Locations Longitude (E) Latitude (S) Water Depth (m)

Casino-5 142o 44’ 44.599” 38o 47’ 43.68” 70

2.2 Operational Area

Figure 2-1 Casino-5 Field Layout Drawing

2.3 Casino VIC/L24 Hydrocarbon System Overview

CHN-EN-EMP-0004 / UNCONTROLLED WHEN PRINTED Page 7 of 98

API Gravity 51.2

Density@25oC g/ml 0.774

Dynamic Viscosity @ 25oC (cP) 0.14

Condensate Gas Ratio 0.6

Pour Point (oC) -54

Low Volatility (265-380oC) 2

2.3.1 Flow Rate

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3.0 Description of the Activity

3.1 Timing of the Activity

3.2 MODU Positioning and Rig Up

3.3 Well Intervention Activities

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3.4 Well Workover Activities

3.5 Support Operations

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• Tow the MODU to/from the Casino-5 well location; and

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4.0 Description of the Environment

4.1 Regional Setting

(Source: James et al., 2013)

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4.2 Environment that May be Affected

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Figure 4-3 Casino-5 Well Intervention and Workover - EMBA

4.3 Ecological and Social Receptors

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Receptor Receptor Type Receptor Values and Operational Area EMBA