Pipeline Licence 2 - Department of State...

2014 Annual Report

MOOMBA TO PORT BONYTHON LIQUIDS

PIPELINE

Pipeline Licence 2

Document Number S-34-102-AR-G-015

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1. Purpose ........................................................................................................................................... 5

2. Scope ............................................................................................................................................... 5

3. Technical Aspects ............................................................................................................................ 5

4. Operational and Maintenance Activities ........................................................................................ 7

4.1. Risk Management Review ............................................................................................................... 7

4.2. Training ........................................................................................................................................... 7

4.3. Operations and Maintenance Activities ......................................................................................... 8

4.4. Pipeline Patrol Activities ................................................................................................................. 9

4.5. Leak Detection ................................................................................................................................ 9

4.6. Coating Integrity ........................................................................................................................... 10

4.7. Cathodic Protection ...................................................................................................................... 11

4.8. Electrical and Instrumentation Maintenance Activities ............................................................... 12

4.9. Communications ........................................................................................................................... 12

4.10. Mechanical Maintenance Activities ...................................................................................... 13

4.11. Pipeline Integrity ................................................................................................................... 13

4.12. Pigging ................................................................................................................................... 13

5. Incident Reporting ........................................................................................................................ 14

6. Land Management ........................................................................................................................ 14

6.1. Land Owner Liaison ....................................................................................................................... 14

6.2. Pipeline Safety Awareness ............................................................................................................ 14

6.3. Pipeline Locations and Referral Services ...................................................................................... 14

7. Environmental Management ........................................................................................................ 15

7.1. Control Document and Training.................................................................................................... 15

7.2. Weed Control – African Rue ......................................................................................................... 15

7.3. Soil Erosion and Subsidence Management ................................................................................... 16

7.4. Environmental Audits and Monitoring ......................................................................................... 16

7.5. Cultural Heritage ........................................................................................................................... 16

7.6. Assessment of Declared Environmental Objectives ..................................................................... 16

8. Emergency Response .................................................................................................................... 16

9. Regulatory Compliance ................................................................................................................. 17

10. Risk Management ......................................................................................................................... 17

11. Management System Audits ......................................................................................................... 18

11.1. Health and Safety .................................................................................................................. 18

11.2. Management Audit ............................................................................................................... 18

12. Reports Issued during the Reporting Period ................................................................................. 19

13. Volume of Product Transported ................................................................................................... 19

14. Proposed Operational Activities for the next year ....................................................................... 19

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15. Statement of Expenditure ............................................................................................................. 20

16. Conclusion ..................................................................................................................................... 20

Appendix A ............................................................................................................................................ 21

SEO Assessment of Declared Objectives ............................................................................................... 21

Appendix B ............................................................................................................................................ 33

Pipeline Cathodic Protection Data ........................................................................................................ 33

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LIST OF ABBREVIATIONS AS2832 Australian Standard 2832 Part 1 – Cathodic Protection – Pipelines and Cables AS2885 Australian Standard 2885 Pipelines – Gas and Liquid Petroleum CGR Corporate Governance Risk CMMS Computerized Maintenance Management System (MAXIMO) CP Cathodic Protection CPU Cathodic Protection Unit CS Compressor Station DBYD Dial Before You Dig DCVG Direct Current Voltage Gradient DSD Department of State Development EESA Epic Energy South Australia Pty Ltd EMP Environmental Management Plan EMS Environmental Management System FEED Front End Engineering Design HAZID Hazard Identification HSE Health, Safety and Environment ILI In Line Inspection IMP Integrity Management Plans KP Kilometre Point LDS Leak Detection System MAOP Maximum Allowable Operating Pressure MAPS Moomba to Adelaide Pipeline System MLV Mainline Valve MPBLL Moomba to Port Bonython Liquids Line NGERS National Greenhouse and Energy Reporting System PCR Pipeline Control Room PL2 Pipeline Licence 2 PS 1‐4 Pump Stations 1, 2, 3 and 4 SACBJV South Australian Cooper Basin Producers Joint Venture SCADA Supervisory Control and Data Acquisition SEO Statement of Environmental Objectives SMS Safety Management Systems SWER Single Wire Earth Return TR Transformer Rectifier TRU Transformer Rectification Unit UHF Ultra High Frequency VHF Very High Frequency WHS Workplace Health and Safety

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1. Purpose This report is submitted in accordance with the requirements of Pipeline Licence 2 (PL2) and the South

Australian Petroleum and Geothermal Energy Act 2000 and Regulations 2013.

2. Scope The Moomba to Port Bonython Liquids Pipeline (MBPLL) is owned by the South Australian Cooper

Basin Producers Joint Venture (SACBJV) and is monitored and maintained under contract by Epic

Energy South Australia Pty Ltd (EESA).

This report reviews operations carried out during 2014 and the intended operations for 2015.

In accordance with the Petroleum and Geothermal Energy Regulations 2013, a performance

assessment is also provided with regard to the Statement of Environmental Objectives (SEO) for PL2.

3. Technical Aspects Table 1 summarises the technical aspects of MBPLL. Figure 1 indicates the pipeline location and layout.

Table 1 – MBPLL Technical Data

Date Constructed 1983

Date Commissioned 1984

Length 659km

External Diameter 355.6mm

Wall Thickness

Normal

Special Crossings (rivers, roads etc)

7.14mm 8.74mm

Pipe Grade API 5LX 52

MAOP 10,340kPa

Coating Double layer polyethylene tape reinforced with adhesive butyl rubber

Depth of Cover

Normal

Road, rail, creek crossings

900mm 1200mm

MLV Adamson and Chronsiter Gate Valves (25 in total)

Actuators (remote activation)

Shafer (17 in total)

Actuators (Local activation)

8 Manual gear type operators

Fluid High vapour pressure liquid hydrocarbon

Pump Stations 1 Active (at Moomba), 1 Decommissioned (PS3 – 370km south of Moomba)

Meter Stations 1 with 3 runs (at Moomba)

Corrosion Protection

Primary protection provided by coating, secondary protection provided by an impressed current CP system, 12 transformer rectifier units installed

SCADA system Digital microwave link from Moomba to Port Bonython with VHF radio coverage for voice communication and UHF for a number of valve sites

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Figure 1 – Moomba to Port Bonython Pipeline System

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4. Operational and Maintenance Activities

4.1. Risk Management Review

A five yearly Safety Management Study review for the MPBLL was carried out in 2012 as per the

requirements of AS2885 (refer to EESA document number S‐34‐102‐RAE‐G‐008). This workshop

review did not identify any significant threats that had not been identified in previous workshops,

nor did it identify any significant shortcomings in the controls required to be applied in accordance

with AS 2885.

4.2. Training

EESA continues to meet its contractual, operational and technical requirements in a safe and

competent manner by ensuring its employees and contractors have the relevant competencies

to meet the challenges of the gas transmission industry.

On an ongoing basis our training and development team, along with key personnel ensure that

current employee skills and competencies are of the highest level, in alignment with legislative

requirements and industry standards.

Training is maintained by utilising a Learning Management System program. The system identifies

individuals required to complete mandatory training, ensuring the employee has the right skills &

knowledge to confidently continue to carry out their duties; also eliminating any potential non‐

conformance.

When individuals or groups are identified as requiring training, there are a number of methods

and platforms used, including: In‐house ‐ self‐paced modules, group presentations and one on

one session’s; External ‐ Registered Training Organisations; Professionals offering certified and

specialised courses; Lectures seminars and conferences.

Courses and training undertaken by both Epic personnel and contract labour is listed in Table 2

below:

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Table 2 – Courses and Training

4.3. Operations and Maintenance Activities

EESA have been engaged by the SACBJV to monitor and maintain the MPBLL in accordance with

AS2885.3 and other relevant standards.

All maintenance can be identified in EESA’s Computerised Maintenance Management System

(CMMS) and is scheduled by this system which generates work orders for maintenance staff to

complete.

Some of the key items in the maintenance schedule include:

Six monthly Cathodic Protection (CP) system full line surveys;

Two monthly CP system transformer rectifier unit inspections;

Coating survey (3 yearly);

Quarterly road & aerial patrols with all action items identified during the patrols rectified immediately by the patrolling officer or entered into the CMMS and scheduled for repair during other routine activities;

Quarterly SCADA system MLV pressure & temperature transducer calibrations;

Six monthly inspection and servicing of all portable fire extinguishers;

Six monthly mechanical inspections, operational checks & servicing of equipment at all MLV and scraper station sites;

Six monthly Pig vessel and mainline valve bypass line relief valve checks;

Pressure vessel inspections (using suitably accredited external contractors) on all vessels on the MPBLL;

COURSES ATTENDED ‐ 2014

Alcohol + Other Drugs Fire Safety & Extinguisher

awareness

Hydrocarbon Properties &

Principles

Pole Top Rescue Training

course and Ladder Use

Santos Port Bonython

Induction ‐ SA

Apply First Aid Fire Warden + Fire Extinguisher

training (in‐field)

Incident Management Plan +

Team training

PPE 2014 Santos Rev 7.4 permit to work

AS 2885.3 Pipelines Gas &

Liquid Petroleum ‐ O & M (in‐

house)

Fire Warden Training 2014 Incident Management Team

training

Root cause analysis course ‐ 2daSantos Rev 7.4 PtW + Gas Test

Class C Drivers Licence Validity First Aid in the field Intimidating & Aggressive

persons

Safe Systems of Work Strategic Vision

Combustion Basics (in‐house) Forklift Operator Certificate of

Competency LF

IVMS Portal Overview 2014 Safe Work week Conference SWER Training

Confined Space Awareness (in‐

house)

Gas Safety (In‐house) Journey Management 2014 Santos ‐ EHS Toolbox Taxation & Payroll Training

Contract Law Essentials Gas Test Atmospheres 2013 Liquids Line familiarisation Santos ‐ Hazard Management

using Stepback & JHA

Third Party Works

Driver aware 2014 GBM Training with DGPS Unit LVR Santos EHS Induction L1 White Card ‐ National OHS

Common Industry Induction

Dry Creek Induction 2014 GIS & GBM (in‐house) LVR / CPR in the field Santos Heat Stress Awareness

2014 ‐ New Starter

White Card Refresher

Dry Creek Induction On Line Hazard And Incident Reporting Manual Handling 2014 Santos Heat Stress Awareness ‐

New Starter

Working at Heights ‐

Awareness

EEHA Installation and

Maintenance

Hazardous Substances &

Dangerous Goods

MR Class Licence ‐ Medium Rigi Santos Heat Stress Awareness ‐

RefresherEEHA Refresher Heat Hazards 2014 Operate Vehicles in the Field Santos Heat Stress Awareness

2014 ‐ Refresher

Electrical Safety Heat Stress Awareness 2014 Operation Field Induction 2014 Santos Heat Stress for Leaders

Environmental Induction ‐ On

line

High Risk License Operations Field Induction On L Santos HR code of conduct

Environmental Induction 2014 HR Class Licence ‐ Heavy Rigid Pipe Location ‐ General Epic Santos ID 2014

Excavation of Pipelines (in‐

house)

HR Directors Forum Pipeline Surveillance Santos Level 1 Induction ‐ QLD

and SA

Extinguisher Training 2014 HR Kiosk Pipeline Voice Communications Santos Level 2 ‐

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Annual cleaning pigging operations;

Communications system mast maintenance;

Annual communications system un‐interruptible power supply and battery maintenance;

Annual communications system VHF, UHF and microwave bearer checks and tests;

Excavation and repair of coating defects;

Excavation and pipeline integrity inspections;

Leak detection system testing;

Low depth of cover restoration;

Creek erosion remediation;

Painting above ground facilities; and

TRU switching unit replacements.

A summary of the Operations and Maintenance activities for 2014 is provided below.

4.4. Pipeline Patrol Activities

Three monthly road and aerial patrols (aerial patrols are conducted between PS3 and the Port

Bonython terminal only) scheduled to alternate at six weekly intervals were completed in 2014.

The road and aerial patrols ensure that the following pipeline activities are addressed:

signage is in suitable condition and if not, repairs are affected as soon as is practically possible. Any issues not addressed during the patrol are fed back into the CMMS in the form of a work order and scheduled for repair as resources permit;

to ensure there are no unauthorized activities occurring along the pipeline route or at any of the facilities;

restoration of any soil erosion due to wind and water is addressed;

there are no leaks occurring at any of the pipeline facilities or along the pipeline route;

all sites are secure, kept clean, neat and tidy; and

items including above ground pipe coating condition, fences, gates, padlocks, signage, fire extinguishers, weeding and other housekeeping activities are addressed at the mainline valve and scraper station facilities associated with the pipeline system.

Signage that required replacement was replaced between Moomba and PS3 (MAPS Compressor

Station 4) in 2014.

Low depth of cover issues identified on routine patrols at KP380, KP485 and KP600 were rectified

in November 2014. No significant issues were identified during Pipeline Surveillance activities

during 2014.

4.5. Leak Detection

EESA’s Pipeline Control Room (PCR) located at Dry Creek, South Australia operates a SCADA system that continuously monitors the MPBLL. Incorporated into the SCADA package is a Pipeline Leak Detection System (LDS) that provides real‐time leak detection capability based on line pack inventory, flows in and out of the system, hydrocarbon type and pressure and temperature change rates. This provides alarms to allow the duty controller to respond to and action any anomalies that may be occurring and notify field maintenance personnel to investigate further onsite if and as required.

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The PCR staff can, if required, isolate the pipeline remotely using any one of 17 out of 24 remotely operable valves to isolate sections of the pipeline and minimise any leakage.

The real‐time leak detection system is supported by maintenance activities along the pipeline (e.g. patrols, valve servicing) that assist in the identification of any pipeline leakage and ensure that appropriate resources are mobilised to address the problem in a timely manner.

Santos has an active project to upgrade the leak detection system on the pipeline. The project

milestones include:

comprehensive review of prepared documents and supplier proposals;

workshop, attended by key stakeholders, identified key areas requiring further investigation;

field trip along the pipeline to check and review LDS and radio network hardware;

completion of the draft Front End Engineering Design (FEED); and

confirmation that the first three sites along the communications network will be subject to

embargo in 2‐3 years.

To progress to the next phase, the key areas requiring further input are baseline performance of the existing LDS, verification of the future communications system to support the LDS and determination of LDS specification. No leaks occurred in the MPBLL in 2014. All leak alarms were investigated by the PCR duty

officer and found to be spurious. An ongoing alarm rationalisation process is being run by EESA

in parallel with Santos leak detection software replacement project to ensure continued

vigilance in monitoring MPBLL operations and following through all alarms and notifications.

This project is anticipated to continue in 2015.

4.6. Coating Integrity

EESA carries out coating defect (direct current voltage gradient, or DCVG) surveys on the MPBLL

every three years in accordance with the Santos‐prepared Integrity Management Plans (IMP):

AIMS‐PI‐IMP‐6469 for the pipeline section between Moomba and PS2;

AIMS‐PI‐IMP‐7081 (PS2 to PS3);

AIMS‐PI‐IMP‐7082 (PS3 to PS4); and

AIMS‐PI‐IMP‐7083 (PS4 to Pt Bonython)

The most recent DCVG survey was completed in 2014. A defect comparison report was prepared

to assess 2014 survey results with those recorded in 2011. This comparison identified eight

defects warranting verification by direct assessment. These are to be planned as required by

Santos in accordance with the overall IMP.

All defects identified in the 2011 coating survey have been excavated, inspected and repaired as

recommended in the survey report.

The pipeline coating system is considered to be in good condition. The defects repaired to date

have been in areas affected by boulders in trenches, or due to manual handling during

construction and the absence of padding causing mechanical damage to the coating. Some minor

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coating issues have been found in the past where pipe work enters the ground, especially at MLV

sites. These have been repaired where appropriate and all ground interfaces are monitored as

part of regular maintenance activities.

No major corrosion, pitting or stress corrosion cracking has been found on the pipeline to date.

All corrosion anomalies are acceptable to the requirements of AS 2885.3.

Above ground coating work carried out in 2014 including painting MLVs 2 through 10, as well as

the pig launcher and receiver at PS2.

4.7. Cathodic Protection

CP full line surveys were completed in 2014 as part of EESA’s preventative maintenance program

for the MPBLL. On/off readings are taken at all test points to assess the pipe to soil potential, and

ensure the potential on all parts of the pipeline is equal to, or more negative than ‐850 mV with

respect to a saturated copper/copper sulphate reference electrode (the ‐850 mV criterion). The

default program requires two surveys: one in winter and one in summer, to provide for seasonal

variation in ground conditions (moisture and temperature).

The most recent CP full line survey was carried out in August 2014. This survey reported a total

measured compliance of 97.54% based on a total of 488 test post readings. The previous full line

survey, carried out in February 2014 showed 93% compliance.

CP station checks are also carried out every two months to check the condition and performance

of the transformer rectifiers (TRs). The most recent survey was completed in December 2014,

reporting a total equipment reliability of 100%.

Refer to Appendix B for a graphic representation of full line compliance figures and TRU survey

results during 2014.

Other CP system refurbishment activities completed during 2014 include:

Installation of 26 new test posts between Moomba and PS3; and

Installation and commissioning of new modular TRs for locations KP161.4 and KP402.6, both damaged by lightning strike.

Under the CP system refurbishment program the installation of twenty new test posts and two

new modular TRs have been identified for the 2015 program.

A CP audit was carried out by Santos in 2013 to identify any gaps in the management of CP

systems against AS2832.1. Improvement opportunities were identified in the following key areas:

Data review and assessment to ensure proper operation of CP system;

Interference testing and control of interference current;

Commissioning of cathodic protection systems;

Maintenance of CP test equipment; and

Demonstration of competence of personnel

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As part of the CP Audit recommendations, a mutual interference testing program was

implemented in 2014. Interference testing was carried out in the Moomba South Central Area

and in the vicinity of the Port Bonython Liquids Plant. The interference testing shall be carried out

once a year and shall involve both EESA and Santos representatives.

A follow up to the CP Audit recommendations was carried out in 2014 by Santos, finding

improvements on the key areas pointed out by the Santos auditor. These areas will be monitored

during the CP quarterly meetings.

4.8. Electrical and Instrumentation Maintenance Activities

Routine quarterly pressure and temperature transmitter calibrations were completed in 2014 to

verify the accuracy of data being fed into the SCADA system, allowing accurate control of the

liquids hydrocarbon transportation process to ensure it stays within the design parameters at all

times.

Six monthly mainline valve remote operational checks were carried out in conjunction with

scheduled routine pressure and temperature transmitter calibrations. All sites were tested twice

in the year as per the 6 monthly scheduling requirements.

The flow computers at Moomba and Port Bonython were replaced as they had reached the end

of their lifecycle. The original three Sarasota flow computers controlling three meter runs were

replaced with two Emerson FloBoss S600+ units. One new flow computer controls all three meter

runs simultaneously and at both locations set‐up in a duty and stand‐by configuration. The

installation was completed within the planned schedule with minimal production interruption.

4.9. Communications

All process variables and valve control functions are communicated to the central control system located at PCR at Dry Creek Adelaide via a microwave link that runs parallel to the buried pipeline system.

In addition to the microwave link, a VHF radio link to allow voice communications between staff and the PCR plus a UHF link to transmit process data and commands to the main microwave link from remote sites are also supported by the communications system.

This system is essential for the safe monitoring and control of the pipeline and the following range of routine maintenance activities were carried out in 2014 to ensure the communications system provided a constant level of availability and reliability:

Routine Microwave bearer, UHF and VHF communications system maintenance tasks;

Routine maintenance tasks associated with the SCADA RTU calibration;

Routine maintenance tasks associated with the communications system uninterruptible power supply batteries and their associated charging system;

Routine maintenance tasks associated with the communications system solar generated power supply batteries; and

Six monthly communications equipment air conditioning unit maintenance.

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All communication outages were minor in nature and for short periods. There were no significant

communications issued reported in 2014.

EESA will be reviewing options to improve reliability of the communication system in 2015 to

address these minor outages.

4.10. Mechanical Maintenance Activities

Routine six monthly mainline valve and scraper station maintenance tasks were carried out in

2014.

All pipeline pressure regulator and over pressure protection devices were tested in compliance

with the relevant Australian standard and the maintenance schedule.

Ancillary equipment, such as pipe supports, pipe ground entry points, valves and pigging facilities,

are routinely inspected as part of the facilities inspections and as a part of the mechanical

maintenance routines. The stem seals were replaced in MLVs 24 & 25 in 2013. This involved the

removal of the MLV actuator and installation of new seal carriers and seals to ensure the integrity

of the stem seals in the MLV’s.

An ongoing program of stem seal replacement is planned for 2015.

4.11. Pipeline Integrity

Pipeline external corrosion is monitored and controlled by carrying out six monthly full line on/off potential surveys, 2 monthly Cathodic Protection Unit (CPU) surveys and painting programs for above ground facilities. Refer sections 4.6 and 4.7 above for further detail.

Four locations between Moomba and PS4 were excavated in 2014 for direct assessment based on the results of the 2009 In Line Inspection (ILI). All locations were recoated with no significant defects identified. Minor stem seal leaks on the Adamson Chronister MLVs have developed at several sites along the pipeline. Santos engaged an external consultant to design and develop a prototype assembly to carry out permanent repairs to these sites. Testing and preliminary site work has been completed in 2012, and full repairs were carried out at MLV 24 and MLV 25 in 2013.

Whilst MLV25 had a like for like seal installed, MLV24 had a prototype installed under pressurised conditions. The lessons learnt from this will be reviewed and changes made to the repair procedure for the remaining 23 valves.

4.12. Pigging

In accordance with the Santos Moomba – Port Bonython liquids line Pipeline Integrity

Management Plan a combined corrosion inhibitor (CORTON IRN 2449) treatment and pigging

program was carried out in March 2014. Pig Trash samples were collected for analysis to monitor

Bacteria (SRB) levels during each pigging run. These samples were sent to Port Bonython

laboratory for analysis.

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5. Incident Reporting

There were no serious or reportable incidents associated with the MPBLL during 2014.

6. Land Management

6.1. Land Owner Liaison

There are approximately 44 landholders along the MPBLL. In January 2014 EESA began an 18

month Land Owner Liaison Program to visit all properties (or other nominated contact

addresses), completing a questionnaire during the visit, updating contact details, current and

proposed land use, awareness of the pipeline location and reminding landowners of their

responsibilities with respect to working in the pipeline vicinity. Where landholders were not

available to be seen in person, the questionnaire is completed via telephone. EESA is currently

on target for completion in June 2015, and will then revert to a 12 month program aligned with

the Financial Year rather than Calendar Year.

Landowners who have been involved with encroachments or near‐misses in the past will be

visited twice during the extended program.

As part of EESA’s pipeline awareness program, all landowners were also contacted via mail on

two occasions, with a newsletter sent in May 2014 emphasising the importance of using the Dial

Before You Dig (DBYD) system and a 2015 EESA calendar containing information on pipeline

safety and their responsibilities sent in December 2014.

6.2. Pipeline Safety Awareness

EESA conducts a Community Awareness Program, which entails holding awareness meetings with

communities, government departments, utilities, emergency services and contractors along the

pipeline route. Twenty six of these meetings were held in the mid north with services in close

proximity or associated directly with the MPBLL. Some of these presentations were held in

conjunction with presentations for the Moomba to Adelaide Pipeline System (MAPS).

The presentations focused on MPBLL as well as the MAPS, and included information on the general

properties of the liquid hydrocarbons transported, the process of liquids hydrocarbon

transmission by pipeline, location of the high pressure liquids pipeline in the regions concerned,

correct procedures when working within pipeline easements, pipeline threats and dealing with

emergency situations. (Note: The presentations are tailored to the specific audience and where

appropriate EESA discusses the differences between Liquids Hydrocarbon and natural gas

transportation as both pipeline systems exist in a number of areas within South Australia).

6.3. Pipeline Locations and Referral Services

EESA continues to provide a free service to locate any pipeline that they own or operate on behalf

of third parties. Historically this service was primarily used by companies and third parties carrying

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out civil works in the vicinity of the pipelines, with contact made via either direct telephone to

EESA or via the free call 1100 “DBYD” asset referral service.

In 2014 EESA continued emphasising to all landowners the importance of using the free DBYD

service for any works near a pipeline.

EESA received twenty one DBYD enquiries in relation to third party activity in the vicinity of the

MPBLL.

In 2014 EESA updated the ‘Managing Third Party Works Procedure’ to provide a clear and well

defined process for managing significant land disturbing activities near the pipeline.

7. Environmental Management

7.1. Control Document and Training

EESA regularly reviews and updates elements of the Environmental Management System (EMS)

including the relevant environmental procedures and work instructions and specific

Environmental Management Plans (EMP).

In 2014 EESA updated online environmental training module and provided training to all

employees and contractors entering the field on behalf of EESA. This induction provides an

overview of environmental risks, control measures and responsibilities.

The documents reviewed and updated in 2014 were:

African Rue Management Plan;

Bushfire Management Procedure;

National Pollutant Inventory Reporting Procedure;

Weed Management Procedure

7.2. Weed Control – African Rue

The recently updated African Rue Management Plan describes a three year program to trial new

herbicides and rate performance using different spray techniques.

The plan includes:

Restriction of vehicle and machinery access into infested areas;

Vehicle hygiene procedures implemented where access to infested areas is unavoidable;

Signage to allow for easy identification of infested areas;

A herbicide spray program along the easement conducted annually;

Herbicide spray trials to identify the most effective products and application methods; and

Monitoring weed distribution. The management plan has proven effective in controlling populations and preventing the spread

of African Rue along the pipeline easement.

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7.3. Soil Erosion and Subsidence Management

No erosion or subsidence was reported in 2014.

7.4. Environmental Audits and Monitoring

Following completion of the 2014 MPBLL Repair Program, an audit was conducted on

compliance with environmental requirements of EESA’s Excavation Procedure. Excavation

checklists and photograph records completed during the repair program, demonstrate

compliance with the procedure.

Of the four pipeline repair locations, two were selected as a representative sample to be

included in EESA’s Environmental Monitoring Program, whereby they will be monitored annually

for vegetation cover and erosion for at least five years, or until such time as they are deemed to

resemble the surrounding landscape.

7.5. Cultural Heritage

No cultural surveys were required on the MBPLL in 2014. No cultural sites were identified by

EESA workers.

7.6. Assessment of Declared Environmental Objectives

Appendix A contains the “Assessment of Declared Environmental Objectives” completed for the

MPBLL.

8. Emergency Response

The Petroleum and Geothermal Energy Regulations 2013 require that an Emergency Response

exercise is to be conducted on the MPBLL once every two years, and in addition to this exercise a

set of Emergency Response procedures is to be developed and maintained. These procedures are

detailed in EESA’s “Incident Management Plan”.

EESA have reviewed the outcomes of the 2012 exercise and have developed an Emergency

Response Plan in line with the new EESA organisational structure.

Exercise “Liquid Line Pipe Strike” was carried out on the 6 August 2014 involving Santos personnel

located at Dry Creek, EESA field personnel, EESA Dry Creek personnel and the PCR. The exercise

was considered a success with a number of learnings incorporated into the Incident Management

Plan and the training regime.

Issues and observations made during the exercise have been addressed. Amendments to the

Emergency Response Manual are required. Santos is in the process of providing feedback to allow

EESA to issue the revised manual.

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9. Regulatory Compliance

EESA ensures that design, manufacture, construction, operation and maintenance and testing of

all appropriate facilities is carried out in accordance with the relevant Acts of Parliament, licence

conditions and AS2885 requirements.

EESA attends quarterly meetings with DSD and Santos, where operational regulatory compliance

is discussed in an open manner.

EESA monitors legislative changes through SAI Global, an organisation which monitors, tracks

and advises EESA of legislative changes that could affect the operation of the pipeline.

EESA is not aware of any regulatory non‐compliance for this pipeline, and believe it is fulfilling its

obligations in relation to the following requirements:

Petroleum and Geothermal Energy Act 2000;

Petroleum and Geothermal Energy Regulations 2013;

Pipeline Licence 2 (PL2); and

The Statement of Environmental Objectives (SEO) for PL2

Significant items are reported through to DSD and are raised at quarterly compliance meetings

held between DSD, Santos and EESA.

There have not been any significant regulatory compliance issues during this reporting period.

10. Risk Management

EESA has continued to use the Safety Management System (SMS) that was established during

2013 that meets obligations under the harmonised Workplace Health and Safety (WHS)

legislation and AS2885:2012; and is aligned to AS4801 – Occupational Health and Safety

Management Systems.

The WHS Safety Management System consists of an overarching Safety Management Plan,

Policies, Guidelines, Procedures and Work Instructions; and has been implemented across all

elements of the business.

EESA utilise an online Risk Management database known as Corporate Governance Risk (CGR).

CGR is a web‐based risk management platform that performs the following key functions:

Risks, which incorporates HAZID style workshop outcomes, e.g. risks, causes, controls,

consequences and risk rankings;

Learnings, which captures HSE and operational lessons learnt, including related actions;

Actions, which tracks actions from risk workshops, incident reporting, inspections/audits and

meetings;

Incidents, which records information on incidents in the areas of clinical health, injury,

environment, asset, reputation, security, legal and financial; and

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Audits, which allow audits and other checklists to be created and generated.

Recommendations arising from the checklists can be elevated to actions and transferred to the

action component.

11. Management System Audits

11.1. Health and Safety

WHS audits are undertaken by EESA to provide assurance and to assess the effectiveness of WHS

management practices to determine if they are effective for ongoing and future management of

significant risks in line with best industry practice and company policies.

A legal compliance audit was conducted by the firm Norton Rose Fullbright in April/May 2014. A

comprehensive 3 Year WHS Plan was established identifying 7 key areas for the company to work

on.

Audits undertaken during 2014 are listed below:

Norton Rose Fullbright legal compliance review;

WHS and Assurance;

DSD Self‐Assessment audit alignment to AS4801; and

63 field based safe systems of work observations / audits

In addition to these systems audits, EESA have established, as part of its Tasks and Targets for

Supervisors and Managers, tools to conduct field based quality assurance inspections to ensure

that the system is being appropriately utilised in the field.

11.2. Management Audit

EESA completed a number of management audits during 2014. These were a combination of

EESAs internal audit program and external audits by industry experts initiated by EESA.

The following topics were subject to audit during 2014:

Aviation Audits;

Compliance with National Greenhouse and Energy Reporting Scheme (NGERS);

Single Wire Earth Return (SWER) Maintenance Plan;

The auditing program offers the opportunity to identify and promote continual improvement

within EESA and completion of these audits is recognised as a key performance indicator by

management and the Board.

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12. Reports Issued during the Reporting Period

The following reports were issued for PL2 during 2014:

2013 Pipeline Licence 2 Moomba To Port Bonython Liquids Pipeline Annual Report;

Dig Up Report 2014 LL‐1 KP 26.017;

Dig Up Report 2014 LL‐2 KP50.627;



Emergency Exercise Santos Liquids Line Scenario Pipe Strike;

Emergency Exercise Santos Liquids Line Timeline 1;

Proposal for redundant analyser sampling lines decommissioning and removal; and

Epic Energy Port Bonython Natural Gas And Liquid PIPELINE ‐ Electranet 275KV/132KV LFI/EPR Interference Study And Mitigation Design ‐ Phase 1

Analysis and Modelling

13. Volume of Product Transported

2,763,445 m3 of product was transported through the MPBLL during 2014.

14. Proposed Operational Activities for the next year

The following activities are proposed for the MPBLL in 2015:

Completion of all scheduled routine maintenance activities and corrective maintenance activities;

Submission of the 2014 Annual Report;

Conduct a Pipeline Cleaning/Biocide injection pigging program;

In Line Inspection (ILI) survey to be planned and executed in 2015 / 2016;

Paint one above ground facility (site to be determined);

MLV stem seal repairs for up to 10 MLVs;

Replacement of TRs at KP 0.2 and KP 67.5;

Replacement of 26 CP test point posts;

Continuation of the Leak Detection System software replacement project; and

Review of the digital microwave communications system reliability

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15. Statement of Expenditure

Information relating to expenditure by Santos in relation to the regulated activities of the pipeline is

provided as “Commercial in Confidence” in accordance with sub regulation 33(9) of the Petroleum

and Geothermal Energy Regulations 2013, where public disclosure is not required in accordance with

sub regulation 33(4).

16. Conclusion

The maintenance and inspection programs carried out on the Moomba – Port Bonython Liquids during

2014 have ensured the pipeline is fit for service and capable of operating within its intended design.

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Appendix A

SEO Assessment of Declared Objectives

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ASSESSMENT OF DECLARED ENVIRONMENTAL OBJECTIVES

Objectives and Assessment Criteria

Assessment criteria have been developed to be “black and white”. Professional judgement is required to assess whether non‐compliance is minor or major. It is

necessary to ensure that adequate information is available to enable this judgement to be made.

OBJECTIVE GOAL MEASURE/HOW OBJECTIVE ACHIEVED OBJECTIVE ACHIEVED?YES/NO

SUPPORTING COMMENTS

1. To avoid unnecessary disturbance to 3rd party infrastructure, landholders or land use

1.1 To minimize disturbance or damage to infrastructure / land use and remediate where disturbance cannot be avoided

Incident report.

Records of communications with adjacent landholders / 3rd party prior to and during maintenance work.

Landholder contact records database.

Photo points or inspection reports, specifically to look at: removal of waste products, re-instatement of soil profiles, adequate re-contouring of surface profile, return of land use.

Damaged infrastructure will be reinstated to a condition similar to or better than the original condition or as agreed with the landholder

Where disturbance is unavoidable or accidental, infrastructure or land use is restored to the satisfaction of the landholder or to undisturbed condition.

Duration of disturbance does not exceed agreed timeframe.

No reasonable landholder complaints.

Yes There have been no incidents or negative communications with landholders / third parties during 2014.

Environmental Monitoring Report indicates correct reinstatement of soil profiles and re-contouring following pipeline repair program.

1.2 To minimize disturbance to landholders

Records of communications with adjacent landholders / 3rd party prior to and during maintenance work.

Landholder contact records database.

Landholder activities not restricted as a result of pipeline activities.

Completed land disturbance checklist.

No reasonable landholder complaints.

Landholder activities not restricted or disturbed as a result of pipeline activities unless by prior arrangement.

Yes No complaints were received from landholders during 2014.

Excavation checklists were completed for all pipeline repairs, demonstrating compliance with the environmental requirements of EESA’s Excavation Procedure.

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SUPPORTING COMMENTS

2. To maintain soil stability / integrity

2.1 To remediate erosion as a result of pipeline operations in a timely manner.

Timed photo points or annual land survey, specifically to look at evidence of erosion, subsidence, vegetation loss on easement & compare to adjacent land.

Inspections undertaken as part of regular patrols, following specific works, following significant storm events.

Preventative measures implemented and monitored in susceptible areas.

The extent of soil erosion on the easement was consistent with surrounding land

Yes Regular vehicle and helicopter patrols are conducted to identify anomalies on the easement.

No erosion was reported or repaired in 2014.

2.2 To prevent soil inversion

Annual land survey to look for soil discoloration, success of vegetation return as an indicator.

Disturbance checklist signed off to indicate top soil/subsoil is stockpiled separately and soil profiles appropriately reinstated following the re-instatement of works/excavations.

Vegetation cover is consistent with surrounding land.

No evidence of subsoil on surface (colour).

Landholder signoff.

Yes Land surveys did not identify areas of soil inversion restricting rehabilitation of vegetation following land disturbance. Photo points recorded to monitor revegetation at disturbed sites in following years.


2.3 To minimise disturbance to erosive soils to prevent on-going risk of soil erosion

Disturb only the minimum area necessary, particularly areas of protective gibber and/or plant cover.

Extent of soil erosion on the easement consistent with surrounding land.

Yes No erosion was reported or repaired in 2014.


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SUPPORTING COMMENTS

3. To maintain native vegetation cover on the easement

3.1 To maintain re-growth of native vegetation on the easement to be consistent with surrounding area

Annual land survey to look for evidence of disturbance to vegetation on easement (apart from access tracks).

Disturbance checklist (including timed photos) signed off to indicate adequate steps undertaken to facilitate re-growth.

Follow-up rehabilitation work was undertaken where natural regeneration was inadequate.

Species abundance and distribution on the easement was consistent with the surrounding area.

Note: assessment of the consistency with surrounding areas will take into account that re-growth is a time and rainfall dependent process.

Yes The condition of the native vegetation within the pipeline easement is consistent with the surrounding vegetation.

Excavation checklists completed for the pipeline repair program.

Land surveys did not identify areas of soil inversion restricting rehabilitation of vegetation following land disturbance. Photo points recorded to monitor revegetation at disturbed sites in following years.

Vegetation is trimmed rather than cleared to maintain line of sight within pipeline easement

3.2 To minimize additional clearing of native vegetation as part of operational activities

Annual land survey to look for evidence of disturbance to vegetation on easement (apart from access tracks).

Use of Disturbance checklist and photo points before, during & after any excavation or land disturbance activity.

Vegetation trimmed rather than cleared where possible.

Consideration of sensitive vegetation during vegetation trimming and / or clearing activities.

Vegetation clearing within the easement or on land adjacent to the easement is limited to previously disturbed areas or areas assessed to be of low sensitivity, unless prior regulatory approval obtained.

Yes No previously undisturbed vegetation was cleared on the liquids line in 2014.


Vegetation is trimmed rather than cleared to maintain line of sight within pipeline easement.

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SUPPORTING COMMENTS

3.3 To ensure maintenance activities are planned and conducted in a manner that minimises impacts on native fauna

Use of Disturbance checklist and photo points before, during & after any excavation or land disturbance activity.

Vegetation clearing within the easement or on land adjacent to the easement to be limited to previously disturbed areas or areas assessed to be of low sensitivity, unless prior regulatory approval obtained.

Where practicable, the time between clearing and rehabilitating the easement when excavations are required will be minimised.

In event of pipeline repair, open trenches are monitored daily and not left open for more than 72 hours.

Impacts to native fauna as a result of excavation work will be restricted to as low as reasonably practicable

Yes No previously undisturbed vegetation was cleared on the liquids line in 2014.


Open trenches included escape ramps and were monitored for fauna daily.

4. To prevent the spread of weeds and pathogens

4.1 To ensure that weeds and pathogens are controlled at a level that is at least consistent with adjacent land

Regular patrols undertaken to look for evidence of weeds on easement and adjacent land (if weeds on easement but not adjacent land must implement control to prevent spread).

Liaise with adjacent land holders.

Records of outbreaks found, weed control activities and photo monitoring of significant outbreaks.

Vehicle wash down register.

Where appropriate, closure of ROW access road.

The presence of weeds and pathogens on the easement was consistent with or better than adjacent land.

No new outbreak or spread of weeds reported.

Yes The presence of weeds and pathogens on the easement is consistent with adjacent land.

Regular vehicle patrols check for any change to weed distribution on the easement.

No new declared weed outbreaks identified, and no pathogens have been identified in the pipeline easement or facilities.

A management program is in place to control the declared weed African Rue.

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SUPPORTING COMMENTS

5. To minimize the impact of the pipeline operations on surface water resources

5.1 To maintain current surface drainage patterns

Regular patrols and annual survey undertaken to look for evidence of erosion, abnormal vegetation growth or death.

Observations also to be undertaken following significant storm events.

Use of Disturbance checklist and photo points before, during & after excavations, CP installation, construction activities, etc.

For excavations, surface drainage profiles restored.

For existing easement, drainage is maintained to pre-existing conditions or better.

Yes Soil profiles and contours are reinstated following the pipeline repair program. A photo log of a sample of sites is recorded in the Environmental Monitoring Report.

During the reporting period no alterations have been made to the landscape through which the pipeline traverses and therefore current drainage patterns have been maintained.

6. To avoid land or water contamination

6.1 To prevent spills occurring, and if they occur minimise their impact

Evidence of soil discoloration, vegetation or fauna death during patrols.

Incident / Spill reports.

Use of spill protection methods where work is completed within or adjacent to environmentally sensitive areas.

Containment of all hazardous substances and liquid waste in appropriate vessels.

Prevention program including pigging, intelligent pigging and pipe maintenance.

No evidence of any spills or leaks to areas not designated to contain spills.

In the event of a spill, the spill was:

Reported

Contained

Cleaned-up, and

Cause investigated and corrective and/or preventative action implemented.

Compliance with relevant sections of the Environment Protection Act.

Yes There were no hydrocarbon spills on the liquids line in 2014.

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SUPPORTING COMMENTS

6.2 To remediate and monitor areas of known contamination arising from pipeline operations

Incident / Spill reports.

Active remediation methods implemented where it is determined that contamination is spreading or level of contamination is not decreasing.

Use of groundwater monitoring bores.

Use of soil farms for remediation.

Contamination confined to known area.

Level of contamination continually decreasing, ultimately to meet EPA guidelines.

Yes There are no areas of contamination occurring as a result of the pipeline operations.

6.3 To prevent the spread of contamination where the easement intersects known contaminated sites


Identification of contaminated sites along easement and establishment of monitoring points.

No evidence of movement of contaminated material along easement (i.e. vegetation death, soil discolouration, subsidence).

Yes Excavation checklists completed for the pipeline repair program.

No contamination sites have been identified on the pipeline easement.

6.4 To ensure that rubbish and waste material is disposed of in an appropriate manner.

Regular patrols or annual survey undertaken to look for evidence of rubbish, spills (soil discoloration).

Waste disposal records, chemical manifests. Appropriately licensed contractors used for any hazardous waste disposal and records are maintained for all hazardous waste disposal.


No evidence of rubbish or litter on easement or at facilities.

No evidence that waste material is not contained and disposed of in accordance with EESA approved procedures.

Yes All rubbish and waste material is managed in accordance with EESA’s Waste Management Procedure.

All controlled and listed waste is collected and disposed of by a licensed carrier.

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SUPPORTING COMMENTS

6.5 To prevent impacts as a result of hydro test water and waste water (water bath heaters and wash down water) disposal

Water disposed of in a manner that prevented discharge or runoff to watercourses or environmentally sensitive areas.

Water discharged onto stable ground, with no evidence of erosion as a result of discharge.

Records on source of water and discharge method/location.

Testing of water quality prior to release/disposal of waste water.

Inspection of water disposal sites for evidence of water entering a watercourse or environmentally sensitive area.

No evidence of impacts to soil, water and vegetation as a result of water disposal (i.e. soil erosion, dead vegetation, water discoloration).

Yes During the reporting period there were no operational requirements to dispose of any waste water.

6.6 To ensure the safe and appropriate disposal of grey water (sullage, sewage)

Compliance with the relevant local government regulations or relevant health and sanitation regulations.

No evidence of non-compliance with local or state government regulations.

Yes All waste water at EESA’s facilities is disposed of in accordance with the Waste Management Procedure (via a licensed carrier).

7. To minimise the risk of oil spills from the pipeline or

7.1 To minimise oil losses during pigging and other routine pipeline operations

Spill protection methods are used during routine operations.

All liquid wastes are contained within impermeable containers or containment.

Incident / spill reports.

No evidence of spills from pigging or other routine pipeline operations.

Yes No spills have been reported during pigging activities during this reporting period.

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SUPPORTING COMMENTS

pipeline infrastructure

7.2 To monitor the condition of the pipeline to ensure that potential pipeline leaks are identified and appropriate action implemented.

Results of pigging and intelligent pigging programmes.

Record of analysis of pigging waste for evidence of pipeline corrosion.

Records of bactericide use following pigging to kill and prevent any bacteria growth.

Action plans for remediation of any issues identified.

Condition of pipeline demonstrated by monitoring in accordance with requirements of AS2885.3

Intelligent pigging occurs on an as condition basis.

Corrective and/or preventative action implemented in a timely manner.

Yes Refer to Section 4.3 (Operational and Maintenance Activities).

7.3 To prevent unauthorised activity on the easement that may adversely impact on the pipeline integrity.

Inspection / patrol reports and records.

Comprehensive landholder liaison program and records of communications with landholders.

Community education program implemented in regional areas.

‘Dial before you dig’ number available and widely advertised.

Clear identification of the pipeline signs installed in accordance with AS2885.

All reports of unauthorised activity are reported and investigated.

No unauthorised activity on the easement that has the potential to impact on the pipeline integrity.

Yes No Encroachments

Danger signage compliant with AS 2885 is in place and maintained.

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SUPPORTING COMMENTS

8. To minimise the risk to public health and safety

8.1 To adequately protect public safety during normal operations

Job Hazard Analysis.

Records of Annual Reports, Fitness for Purpose Reports, Risk Assessments and inspections.

Records (including above) demonstrating compliance to AS2885.

No injuries or incidents involving the public.

Demonstrated compliance with AS 2885.

Emergency procedures implemented and personnel trained.

Yes No injuries or incidents involving the public occurred in 2014.

Established safe systems of work including the use of approved work instructions and procedures, job hazard analysis, permit to work and experienced staff all contributes to EESA meeting this objective

8.2 To adequately protect public safety during maintenance

Job Hazard Analysis’.

Records of communications with adjacent landholder prior to & during maintenance work including advice of the nature and schedule of maintenance activities.

Use of signage or bunting to identify all potentially hazardous areas.

Adequate implementation of traffic management practices.

Records of regular emergency response training for employees and review of procedures.

Incident Reports.

No injuries or incidents involving the public.


Yes All landowners and relevant authorities are advised whenever any work is scheduled on their property or land under their control.

All potentially hazardous work sites are marked

During the reporting period no activities were undertaken that required specific traffic management procedures to be in place.

8.3 To avoid fires associated with pipeline maintenance activities

Incident reports.

Records of regular fire safety and emergency response training for all operations personnel and review of procedures.

Established procedures for minimizing fire risk during maintenance.

No pipeline related fires.


Yes There were no pipeline related fires during the reporting period.

All EESA personnel are trained in fire safety and emergency response.

Field workers comply with EESA’s Bushfire Management Procedure.

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SUPPORTING COMMENTS

9. Minimise impact of emergency situations

9.1 To minimise the impact as a result of an emergency situation or incident

Incident reports.

Emergency response trials (carried out at least annually) and associated documentation.

Routine inspection of emergency equipment (annually).

Records of regular emergency response training for all personnel and review of procedures.

Link between ER exercises and Risk assessment.

Emergency response procedures are effectively implemented in the event of an emergency.

Emergency response exercises are aligned with credible threats and consequences identified in the risk assessment.

Yes No emergency situations have been recorded or managed during this reporting period.

SANTOS and EESA conducted a joint emergency response exercise in 2014.

All personnel have current ‘Apply First Aid’ certificates.

9.2 To restore any damage that may occur as a result of an emergency situation

Refer to previous criteria

(Objective 1, 2, 3 & 6).

Refer to previous criteria

(Objective 1, 2, 3 & 6).

Yes No emergency situations have arisen during this reporting period

10. To minimise noise due to operations

10.1 To ensure operations comply with noise standards

Incident reports.

Monitoring results, where deemed necessary (e.g. frequent complaints).

Operational activities comply with noise regulations, under the Environment Protection Act 1993.

No complaints received.

Yes No noise related incidents reported.

All maintenance tasks performed during the reporting period were of a nature that did not contribute to any increased levels of noise pollution.

11. To minimise atmospheric emissions

11.1 To eliminate uncontrolled atmospheric emissions

Incident reports. No, uncontrolled atmospheric emission.

Yes There were no uncontrolled atmospheric emissions during the year

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SUPPORTING COMMENTS

11.2 To minimise the generation of dust.

Incident reports.

Compliance with EMS Procedures (vehicle movement, dust suppression, etc).

No complaints received.

No dust related injuries recorded.

Yes No dust complaints or dust related injuries were recorded in 2014.

Following pipeline excavation and backfill, vegetation is re-spread over the site to stabilise the topsoil and encourage revegetation.

EESA maintains native vegetation cover on the pipeline easement which aids dust suppression.

12. To adequately protect cultural heritage sites and values during operations and maintenance

12.1 To ensure that identified cultural sites are not disturbed

Consultation with relevant heritage groups if operations occurring outside known surveyed areas.

Surveys / Cultural heritage monitoring before / during excavations.

Records of site locations on operations GIS.

Use of Disturbance checklist prior to undertaking maintenance works.

Site examined for cultural heritage material prior to work involving off-easement disturbance or in an area of archaeological potential or in an area identified as being of known medium to high archaeological sensitivity.

No impact to known sites.

Any new sites identified are recorded in Land Management System and reported to appropriate authority.

Yes EESA maintains a GIS database of known cultural sites and previous cultural survey areas.

EESA has an Aboriginal and Cultural Heritage Management Procedure that provides guidance on the requirement to undertake cultural

For a description of cultural surveys conducted in 2014, refer to the ‘Environmental Management’ section above.

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Appendix B

Pipeline Cathodic Protection Data

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Liquids Line Cathodic Protection data

400

600

800

1000

1200

1400

0

9.4

21.2

36.8

52.9

67.8

83.5

99.6

116.6

131.8

149.3

162.3

180.1

194.5

212.2

223.8

239.7

255.9

271.9

288.3

305.3

323.3

341

352.6

365.6

383

399

411.3

424.9

440.1

454

468.1

483.7

500

510.2

528.6

548.7

566.8

583.4

602.1

610.4

619.8

638.1

649.3

658.1

OFF Potential readings

MPBLL. OFF Potential readings 2014

Feb‐14

Aug‐14

P PS4

PS3

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