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PART C - ENVIRONMENTAL MANAGEMENT
PROJECT SEA DRAGON PTY LTD
CORE BREEDING CENTRE AND BROODSTOCK
MATURATION CENTRE, BYNOE HARBOUR
ENVIRONMENTAL IMPACT STATEMENT
Error! No text of specified style in document. part c - Environmental Management 2-i
Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART C ‐ ENVIRONMENTAL MANAGEMENT 15‐284
15 ENVIRONMENTAL MANAGEMENT
15.1 TERMS OF REFERENCE ADDRESSED IN THIS CHAPTER
This chapter describes the environmental management measure proposed to minimise potential impacts
identified in the risk assessment and environmental assessment process.
Specifically, in relation to the potential impacts on the marine environment from construction of the project
and the discharge of water from the project, in the SoR the NT EPA state the following:
Generally, it is expected that benthic habitats would recover once the pipes are in place
The NT EPA is satisfied that the potential impacts and risks associated with installation of the seawater
intake pipe are unlikely to be significant and can be adequately managed through the implementation of
measures proposed in the NOI. In relation to the release point, there is potential for acid sulfate soils to be
disturbed in a limited area but impacts are likely to be localised and minimal if such material is managed
appropriately
The NT EPA considers that the interim water quality guidelines / values provide a reasonable basis for
assessment of potential impacts until the guidelines values can be refined
The NT EPA considers the proposed release of discharge water to Wheatley Creek is not likely to
significantly affect the regional water quality of Bynoe Harbour in the long term, though there may be
some localised, longer term enrichment near the point of discharge in Wheatley Creek.
Furthermore, in relation to erosion and sediment control, ASS, biting insects and weeds, the NT EPA state in the
SoR that potential risk associated with erosion and sediment control, acid sulfate soils, biting insects and weeds
can be adequately managed through the implementation of standard measures. Further adding, that the
proponent has committed to preparing and implementing detailed management plans for potential impacts of
the Project (Appendix 19).
Table 15‐1 summarises the requirements from the ToR for the Project of relevance to socio‐economics and
references where they have been addressed.
TABLE 15‐1 TERMS OF REFERENCE
Terms of Reference Sections
5 Environmental Management
The specific safeguards and controls proposed to be employed to minimise or
remedy environmental impacts identified in the risk assessment process are to
be included in an EMP. The EMP should be strategic, describing a framework for
continuing management, mitigation and monitoring programs for the significant
environmental impacts of the Project.
The scope, content and structure of the EMP will be a function of the outcomes
of the environmental risk assessment and determined by the significance of the
environmental impacts. The EMP should not be prepared in isolation but should
be consistent and integrated with the principles of an environmental
management system. The EMP should include specialised management plans
where it is necessary to provide a high level of operational detail. As much detail
Chapter 15
Appendix 19
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Terms of Reference Sections
as is practicable should be provided to enable adequate assessment of the
proposed environmental management practices and procedures.
The EMP needs to address the Project phases (construction, operation and
decommissioning/rehabilitation) separately. It must state the environmental
objectives, performance criteria, monitoring, reporting, corrective action,
necessary resourcing, responsibility and timing for each environmental issue.
Further information on the development of an EMP is available in the NT EPA’s
Guideline for the Preparation of an Environmental Management Plan, accessible
on the NT EPA webpage at: https://ntepa.nt.gov.au/environmental‐
assessments/assessmentguidelines.
15.2 ENVIRONMENTAL MANAGEMENT STRATEGIES
Environmental management strategies have been prepared based on the environmental risks identified in the
Chapter 6, and potential impacts, mitigation measures and monitoring identified in the EIS Part B ‐
Environmental Assessment. These environmental management strategies consolidate and summarise the
commitments made as part of the EIS, and will be used to develop site specific management procedures after
approval of the Project.
Construction and operational strategies to manage potential impacts are summarised below and detailed
further in Appendix 19:
C1 ‐ Erosion and Sediment Control Strategy
C2 ‐ Land and Soils Management Strategy
C3 ‐ Acid Sulfate Soil Management Strategy
C4 ‐ Vegetation Management Strategy
C5 ‐ Weeds and Pests Strategy
C6 ‐ Fauna Management Strategy
C7 ‐ Surface Water Management Strategy
C8 ‐ Groundwater Management Strategy
C9 ‐ Waste Management Strategy
C10 ‐ Air and Noise Management Strategy
C11 ‐ Effluent Management Strategy
C12 ‐ Hazardous Materials Management Strategy
C13 ‐ Traffic Management Strategy
C14 ‐ Social Impact Management Strategy
C15 ‐ Cultural Heritage Management Strategy
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15.3 ENVIRONMENTAL ASPECTS AND IMPACTS
Risk assessment will be conducted as part of each site / phase specific management plan, in order to define site
and phase specific risks, and develop appropriate mitigation and management measures.
Risk assessment follows a standard semi‐quantitative approach consistent with AS/NZS ISO 31000:2009 Risk
Management – Principles and Guidelines. The project risk assessment is outlined in the EIS, Volume 1,
Chapter 6.
15.4 RELEVANT LEGISLATION AND APPROVALS
A Legislation and Approvals Register is required to be developed and regularly updated as part of the project,
outlining the legislation relevant to the Project by jurisdiction, administering authority and relevance. It is
intended to be developed on a site by site basis, and the Legislation and Approvals Register template can be
used for this purpose.
The EIS, Volume 1, Chapter 4 ‐ Approvals, Conditions and Agreements ‐ provides the relevant legislation and
approvals, and will be incorporated into this register once Project approval is gained.
It is the responsibility of the relevant Environmental Manager to ensure the register is up to date, and the
project complies with the legislative requirements of the register.
Project / phase specific management plans are required to reference this register, and determine the specific
impacts of the relevant legislation on that particular project and management plan.
Some sources of information to develop and maintain the register are:
Commonwealth
Federal Register of Legislation
https://www.legislation.gov.au/
Commonwealth Department of the Environment: Legislation
http://www.environment.gov.au/about‐us/legislation
Commonwealth Department of the Environment: Permits, assessments and licenses
http://www.environment.gov.au/about‐us/business‐us/permits‐assessments‐licences
Business.gov.au Environmental legislation (commonwealth and state environmental legislation links)
http://www.business.gov.au/business‐topics/business‐planning/environmental‐
management/Pages/environmental‐legislation.aspx
Northern Territory
Current Northern Territory Legislation Database
http://dcm.nt.gov.au/strong_service_delivery/supporting_government/current_northern_territory_legisla
tion_database
NT EPA Legislation
http://www.ntepa.nt.gov.au/about‐nt‐epa/legislation
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15.5 ROLES AND RESPONSIBILITIES
The general descriptions of the key roles are outlined below, with the organisational structure and specific
personnel included in Appendix 19.
Note where reference is made in this document to the ‘relevant Environmental Manager’, this will be the Chief
Environmental Manager for EMS / corporate level matters or covering all sites, and the relevant site
Environmental Manager for site matters.
15.5.1 Chief Operating Officer
Establish the overall direction of Project Sea Dragon from an environmental perspective, and lead or
support the development of the Environmental Policy
Provide sufficient resources to support the objectives of the EMS
Provide resources for the ongoing review and continual improvement of the EMS.
15.5.2 General Manager ‐ Health, Safety & Environment
Develop and refine environmental objectives, targets and EMS level procedures
Monitor overall EMS performance
Provide input to the ongoing review and continual improvement of the EMS
Ensure site managers have relevant approvals, management plans (i.e. EMP) and licenses to undertake the
works
Ensuring that adequate resources are deployed in a manner to support Site Managers in achieving their
environmental objectives
Develop training materials for EMS / corporate level training requirements.
15.5.3 Site Managers
Responsible for day to day compliance
Ensure that site specific EMPs are implemented on the site
Ensure that personnel and sub‐contractors are appropriately inducted and are aware of requirements of
the EMPs
Relay information to site personnel.
15.5.4 Site Environmental Role ‐ Site Manager, or Delegate
Responsible for developing and implementing site specific EMP
Liaise with Site Manager
Responsible for environmental inspections and monitoring
Develop training materials for site level training requirements and conduct training
Implement non‐conformance processes (incident and complaint management, corrective actions,
notification)
Act as the site contact for governmental officers (Commonwealth, State/Territory, Councils)
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Liaise with environmental consultants when necessary
Lead periodic review and updates of site specific EMP as required.
15.5.5 Site Staff and Sub‐contractors
Adhere to relevant aspects of the site specific EMP (Appendix 19) communicated during inductions, and to
directions given by the Site Manager and Environmental Manager
Have a general duty to not cause environmental harm
Notify their supervisor / employer of any environmental (and other) incidents, near misses and hazards
immediately. Supervisors/employers to ensure the site manager and/or environmental manager is notified
as soon as possible.
15.6 TRAINING AND AWARENESS
Project Sea Dragon Pty Ltd will ensure that all employees are appropriately trained and/or qualified to carry out
their duties. All persons working for or on behalf of Project Sea Dragon Pty Ltd, including staff and contractors,
will be made aware of the environmental policy, and the requirements of the EMS and site specific EMPs. This
will include their role and responsibilities, the significant actual or potential environmental aspects and
associated impacts of their work activities, benefits of improved performance, and the consequences of the
departure from EMS requirements.
Training will comprise the following elements:
Personnel assigned roles within the EMS (including site specific EMPs) will ensure they are appropriately
qualified and experienced
Site induction will be carried out for all new employees and those who have not received such training to
ensure they are appropriately briefed on the relevant aspects of the EMS and the relevant site and phase
specific EMPs
Regular toolbox talks or similar will be held onsite to discuss items and issues of relevance to the EMS.
Form EM‐00‐FO‐001 Training Needs Analysis is provided to identify additional training requirements.
15.7 COMMUNICATION
15.7.1 External Communications
Relations between Project Sea Dragon Pty Ltd and the public are important for maintaining a good working
relationship within the community. Project Sea Dragon Pty Ltd is committed to being a part of the community
as a whole, seeking advice and views as appropriate.
Key points of contact within the organisation for external communication (public, statutory agencies, etc.) are
outlined in the EM‐00‐CT‐0001 Organisational Chart.
The following website will remain the main entry point on the internet for dissemination and communication
with the wider public:
http://seafarmsgroup.com.au/project‐sea‐dragon/
Refer also to Section 15.11 for details of responding to non‐compliance events.
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15.7.2 Board Meetings
Project Sea Dragon Pty Ltd will incorporate the Environmental Policy and EMS Objectives and Targets into
regular management level meetings, communications and discussions, and will implement the management
review process, which reviews environmental objectives and targets, progress towards project aims, changes in
legal and other requirements and the EMS in general. In particular, management will review audit reports, non‐
compliance and project time tables as appropriate.
15.7.3 Internal
At a site level, the results of internal audits, monitoring reports and any non‐compliance will be directed to the
Site Manager / Environmental Manager as they become available. The Site Manager / Environmental Manager
should be advised of any monitoring results or other activity that does not comply with any of the conditions of
development or the EMS / site EMPs as soon as practicable but within at least 48 hrs of the event or receipt of
results (as applicable).
At a corporate level, internal audit and review reports will be circulated amongst the management team and
will form part of board meeting content for discussion and review. Regular site compliance reports will be
reviewed by the General Manager ‐ Health, Safety & Environment, with significant actual or potential issues
raised at the board and/or Chief Operating Officer level.
EM‐00‐CT‐001 Organisational Chart shows the relevant roles and persons, and the preferred communication
channels.
15.8 SUPPLIER AND SUB‐CONTRACTOR MANAGEMENT
Sub‐contractors will be responsible for adhering to the EMS and site specific EMPs, and to directions given by
the Site Manager and Environmental Manager in regards to environmental management.
Sub‐consultants are required to confirm they have policies and procedures in place to allow them to conform
to the relevant aspects of the EMS and site specific EMPs. Procedure [B3] – sub‐contractor management sets
out arrangements to ensure this is undertaken.
The Site Manager must induct each sub‐contractor prior to beginning works on the site.
Each sub‐contractor is to have a nominated contact point to the Site Manager.
15.9 MONITORING AND REVIEW
The key monitoring and review components of the EMS are shown in EM‐00‐RG‐0003 Monitoring and Review.
This outlines the strategic level monitoring required, and elements common to all sites, particularly those
required to report to the Project Sea Dragon Pty Ltd corporate level.
A regular external audit of the EMS and individual sites would also be beneficial as a check against internal
auditing and management of the system and project.
15.10 NON‐COMPLIANCE AND CORRECTIVE ACTION
Non‐compliance with any aspect of the EMS or site specific requirements (including EMPs), the project consent
conditions and/or monitoring limits will require corrective action and reporting. Other incidents such as fire,
unplanned animal release, disease outbreak, or other natural or man‐made incidents should be included. The
type and scale of corrective action and reporting will depend on the type and scale of the non‐compliance.
Generally, non‐compliance will be of the following forms:
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1. Non‐compliance with specific condition of approval, monitoring limit, etc.
2. Non‐compliance with other EMS or EMP requirement or target, including key EMS Objectives and Targets
3. Spills or other incidents causing or with the potential to cause environmental harm (including fire, release
of prawns to the environment, disease outbreak, etc.) (may be captured in items 1 or 2 above)
4. Near miss for the above
5. Complaints.
All of the above items require an incident / complaint / improvement form to be filled out (EM‐00‐FO‐0002).
Corrective actions undertaken at the time of the incident will be described, and additional actions required for
the incident defined when filling out the form. The incident will also be entered into the incidents complaints
register (EM‐0x‐RG‐0004), which assigns actions, responsible person(s), closeout date, and opportunities for
improvement. Improvements or revisions required to EMS documents (including site EMPs) are also to be
included in this register, including as results from audits and reviews.
15.11 COMPLAINTS MANAGEMENT
All complaints and inquiries should be directed to the Environmental Manager. In consultation with the site
manager, the Environmental Manager will assess the validity and seriousness of the complaint or inquiry and
respond as appropriate. Any complaints will be recorded on an incident / complaint / improvement form (EM‐
00‐FO‐0002), and stored within the incidents / complaints / improvement register (EM‐0x‐RG‐0004).
Complaints will be logged with date, time and contact details. The complaint would be forwarded to either the
Site or General Manager ‐ Health, Safety and Environment of Project Sea Dragon Pty Ltd depending on the
nature of the complaint. A response to a complaint during the working week would normally be made within
48 hours.
15.12 DOCUMENTATION AND RECORDS
15.12.1 Document Control
Document control is managed through the use of the document register (EM‐00‐RG‐0001), which is to be
updated when any document is prepared or revised by the author of that document. The register is under the
primary responsibility of the Chief Environmental Manager, but will be edited by site Environmental Managers
to add site specific documents.
Release of new documents for the system is to be approved by the immediate Environmental Manager for that
document, namely:
For EMS / corporate level documents, the Chief Environmental Manager
For site specific documents, the Site Environmental Manager.
Any document not signed and authorised for release is not considered a current document for the purposes of
the EMS. It is the responsibility of the author of a document (new or revision) to obtain approval for release
from the relevant Environmental Manager.
The document control page from this manual (page after the cover page) is to be present for all system
documents other than forms and registers. In all cases, headers and footers are to contain the same
information as in this document, including:
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Document name
Document reference
Revision
Date Printed
A note stating that Printed copies are uncontrolled
Page number and number of pages
Only current documents shall be in use and it is the responsibility of the relevant Environmental Manager to
ensure that any updates are propagated as required to the points of issue and any old issues are taken out of
circulation. Primary controlled documents will be maintained electronically on the project intranet, with
revised copies superseding older copies of documents. These older documents will be moved to an ‘archive’
folder.
Any changes in documentation or legislative or other requirements will be followed by a review by the relevant
Environmental Manager (or by the report author, communicated to the relevant Environmental Manager) of
the possible impacts on the remainder of the system and changed where necessary. The scale of this review
will depend on the nature of the changes.
15.12.2 Document Numbering
The documentation numbering scheme is as shown below. Where site specific documents are required in
addition to the EMS level document, such as the Monitoring and Review register, these are to take the same
numbering as the EMS level document, regardless of the number of site level documents (e.g. EMS level = EM‐
00‐0003, site level = EM‐01‐0003).
[Aspect]‐[Site]‐[Doc Type]‐[Doc Number][revision] [Short name]
e.g. EM‐00‐RG‐0001b Document Register, EM‐01‐MP‐0001a‐CBC and BMC Facility EMP
Where:
[Aspect] = Selected from the following list:
EM = Environmental, generally all EMS documents, but allows for other quality level or WHS documents to use
the same numbering system
[Site] = site code, selected from the following list:
00 = EMS level (no / all sites)
01 = CBC and BMC Facility
[Doc Type] = Document type, selected from the following list:
RG = Register
MN = Manual
CT = Chart (e.g. organisational chart)
FO = Form
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MP = Management Plan (e.g. construction environmental management plan)
[Doc Number] = consecutive numbering for this type of document, as 4 numerals starting at 0001
[revision] = lower case letters (a, b, c etc.) for drafts, and numerals (0, 1, 2, 3, etc.) for issued documents
[Short name] = a very short name to aid in identification, generally less than 24 characters including spaces
15.12.3 External Documents and Standards
Preferably, standards and guidelines will be sourced directly from the primary source when accessed, rather
than from locally stored copies. Where locally stored copies are stored and used, it is the responsibility of the
relevant Environmental Manager to maintain the latest copies of such documents for use.
SAI Global Standards Watch is a useful tool for keeping apprised of updates to relevant standards:
https://infostore.saiglobal.com/store/AboutSWatch.aspx.
15.12.4 Records
Relevant documentation shall be retained as records within the EMS system, stored on the project intranet.
These records shall include (but not be limited to):
information on compliance, including audit and review (internal or external) reports or forms
details of nonconformities and corrective and preventive actions, including Non‐conformance forms and
the incident/complaint/improvement register
evidence of fulfilment of objectives/targets, including review / audit reports
information on participation in training, including training needs analysis forms (copies of each update
saved separately with date)
permits, licences or other forms of legal authorization,
results of inspection and calibration activity and
results of operational controls (maintenance, design, manufacture).
15.13 REPORTING
Reporting requirements are detailed in the EM‐00‐RG‐0003 Monitoring and Review register and site specific
Monitoring and Review registers (e.g. EM‐01‐RG‐0003 Monitoring and Review).
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