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Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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M-I AUSTRALIA PTY LTD OPERATIONAL BROOME ENVIRONMENTAL MANAGEMENT PLAN Version number: 1.0 Original issue date: March 2014 Scheduled review date: September 2014

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb TABLE OF CONTENTS 1. INTRODUCTION 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 Scope Objectives Outcomes EMP Structure

BROOME Lot E3
Operational Environmental Plan

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M-I Australia Environmental Management System Site Description QHSE Policy Organization Roles & Responsibilities

2. DESCRIPTION OF OPERATIONS 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 Major Operations Minor Operations Waste Oil Collection Equipment Maintenance Traffic Management Storm Water Management Waste Management Spill Prevention and Control Plans

3. REGULATORY OBLIGATIONS 4. DESCRIPTION OF EXISTING ENVIRONMENT

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb 4.1 4.2 4.3 Regional Setting

BROOME Lot E3
Operational Environmental Plan

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Physical Environment Vegetation

5. ENVIRONMENTAL MANAGEMENT CONTROLS 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 5.10 Emergency Response Spill Response Cyclone Emergency Response Noise Management Insect / Vermin Vector Management Air Quality Bushfire Management Contractors and Carriers Implementation of Emergency Response Plan Key Activities

6. ENVIRONMENTAL RISK REGISTER 6.1 6.2 6.3 7. REFERENCES Definitions Environmental Events Environmental Risks of Significance to M-I Australia Operations

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb 1. INTRODUCTION

BROOME Lot E3
Operational Environmental Plan

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M-I Australia has been operating within the North West of Western Australia for more than 30 years, and within the Broome Light Industrial Area (LIA) and Broome Port since 2008. The primary role of M-I Australia facilities is to provide drilling fluids of both Water Based and Synthetic based make up, along with associated palletized and bulk materials for conditioning the fluids offshore. During the past 30 years M-I Australia has supplied drilling fluids for the offshore Oil and Gas industry in Australia without any major incident or impact to the local environment, and continues to be the industry leader in product quality, safety, environmental and operational standards. Drilling fluids are blended and reconditioned on site and stored in vertical tanks until required by drill rigs. All blending and conditioning of fluids is conducted within an enclosed mixing shed facility and under controlled conditions with trained plant operators. All material is delivered to/from the rig site via Platform Supply Vessels who currently berth at the wharf located within Broome Port Authority grounds, with all materials being delivered to the wharf via road tankers. Company details are as follows; Legal Entity: ABN: Site Address: Site Manager: Phone: Title details: M-I Australia Pty Ltd. 67 009 214 162 Lot E3 Port Drive Broome, Western Australia, 6725 Jeff Hall +61 8 9193 7866 Lot 621 on Deposited Plan 70861 Qualified Certificate of Crown Land Title Volume LR3162 Folio 732; and Lot 698 on Deposited Plan 209491 Qualified Certificate of Crown Land Title Volume LR3002 Folio 356

1.1

Scope

The Operational Environment Management Plan (OEMP) is applicable to the following activities: a) b) c) All activities conducted by M-I Australia within Lot E3, Port Rd, Broome. Those operations conducted by contractors who operate within the Site under M-I Australias direct control. M-I Australia employees and contractors will operate in accordance with the BrPA Environment Management Plan when outside of Lot E3 but within the Port Management Area.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb 1.2 Objectives

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The objectives of this OEMP are: a) b) c) To identify and consider the environmental aspects at the Site; To assess the risks associated with the identified environmental aspects and prioritize them for action; To identify environmental management options and strategies to assist M-I Australia in meeting its environmental management obligations, taking into account existing procedures and mitigation measures; and To describe specific procedures / processes to be implemented by M-I Australia.

d)

1.3

Outcomes

The desired outcomes of the OEMP are: a) b) c) d) A consistent and structured approach to environmental management; To ensure M-I Australia staff and contractor awareness of their shared responsibility to protect the environment; Reduction in operating costs by reducing the need for remedial actions; and Effective environmental management in accordance with legislative requirements.

1.4

OEMP Structure

The OEMP is an umbrella document that describes a framework for environmentally sustainable management at the Site. An activities-based approach has been adopted given that a number of different activities are conducted on site. This document comprises the following sections: a) Section 1, provides a general overview of site, looking at objectives, structure and key roles and responsibilities related to the OEMP. b) Section 2 provides a detailed description of key activities and environmental aspects at the Site. c) Section 3 summarizes M-I Australias obligations with respect to the environment under various State and Commonwealth legislation. d) Section 4 details the existing environment at the Site. e) Section 5 summarizes the Environmental Management Controls in place. f) Section 6 summarizes how events are recorded and some of key environmental risks to applicable to M-I Australia Operations. g) Section 7 summarizes key references

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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Operational Environmental Plan

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1.5

M-I Australia Environmental Management System

The M-I Australia Environmental Management System incorporates policies, planning, procedures, practices, responsibilities, training, monitoring, review and audits that together define a framework for managing the impact of M-I Australias activities, products and services on the environment. This OEMP forms part of M-I Australias Emergency Management System. It will be reviewed periodically and may be revised to incorporate changes in legislation, updated guidelines or altered management practices. It may also be reviewed in response to an environmental incident or the identification of new or changed environmental risks.

1.6

Site Description

The Lot E3 facility is located within the Port Management Area at the Southwest tip of the Dampier Peninsula, in the general area of Entrance Point, Broome, Western Australia. The location of Lot E3 within the Port Management Area is shown in Figure 1.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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Figure 1: Site Location Image courtesy of Golder and Associates

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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Figure 2: Lot E3 site layout

1.7

QHSE Policy

M-I Australia recognizes that the protection of the environment is a key business performance objective, and this has been reflected in the development of our Emergency Management System. The key requirement of our policy is to Minimize our impact on the environment through pollution prevention, reduction of natural resource consumption and emissions, and the reduction and recycling of waste. 1.8 Organizational Structure

The table below reflects the organizational arrangements for operations on M-I Australia sites.
Country Manager

Operations Manager

Quality Operations Support Manager

Site Manager

Warehouse Personnel

1.9

Roles and Responsibilities

All personnel employed on M-I Australia Sites have general obligations under legislation as follows:

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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Operational Environmental Plan

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They must take reasonable action to ensure no person or property is exposed to more than an acceptable level of risk; They must comply with safety procedures and obligations defined within this OEMP; They must avoid wilful or reckless acts that might adversely affect the safety of anyone at the facility; and They must minimize their impact on the environment through pollution prevention, reduction of natural resource consumption and emissions, and the reduction and recycling of waste.

1.9.1

Site Manager Key Roles and Responsibilities

a) To ensure the overall smooth-running of all warehouse and mud plant operations, maintenance of plant and equipment, movement of material and all related documentation. b) Ensure communication relating to the warehouses is maintained with all relevant departments and that all contractually related paperwork and data is distributed as required. c) Implementation of QHSE Program. d) Ensure that all materials are stored safely, and packaged in accordance with the company and clients standard procedures. e) Assure the safe and proper loading and use of assigned vehicles. f) Ensure safety, discipline and motivation of all personnel reporting to self. g) Be responsible for all relevant operational information and documentation presented to the Operations Manager or Country Manager as appropriate. h) Communicate with all relevant parties required to oversee everyday business. i) Ensure through communication and inspection, when necessary, that all Broome Warehouse and Mud Plant equipment is operational, maintained, calibrated and certified. j) Co-ordination of material movements to/from rigs and bulk mud mixing to specification. k) Liaison with the Operations Department for mud formulations. l) Assist with maintenance of up-to-date inventory records and mud plant volumes. m) Implementation of QHSE in warehouse/mud plant/bulk plant and implementation waste management procedures according to the Duty of Care requirements.

1.9.2

Quality Operations Support Manager Roles and Responsibilities

a) Supports the development, maintenance, implementation, & improvement of the Quality Management Processes and Procedures. b) Maintains Facility Site Manager, Line Manager or Operation Managers Quality Awareness such that Quality is an integral part of Geo Market/Area Management responsibilities and objectives.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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Operational Environmental Plan

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c) Ensures Geo Market Management maintains ownership of all Service Quality related reviews. d) Supports Geo Market Management to define, implement, and monitor Service Specific Key Performance Indicators. e) Assists planning of the required infrastructure & resources and assists Geo Market to deliver required Service Quality results. f) Ensures the implementation of specific competency (as well as associated training) requirements for Employees and Contractors as required. g) Provides planning, coordination, communication, and active & visible support and assurance for quality compliance including status, results, follow-up, and actions as required. h) Ensures that systems providing asset integrity are suitable and sufficient. i) Ensures the work place facilities are appropriate for activity level and type. 1.9.3 Operations Manager Roles and Responsibilities

a) Manages the Fluids (Drilling and Completion Fluids) Operations for Australia. b) Responsible for the Fluids Facilities and Fluids Personnel involved in the receipt and supply of product to the field, with respect to meeting operational, HSE, quality, training and budgetary needs. c) Responsibility include employee management anddevelopment,inventory management, maintenance, operations, service, HSE, quality, training, planning and budget management.

1.9.4

Warehouse Personnel Roles and Responsibilities

a) Co-ordination of material movements within the warehouse. b) Bulk mud and brine mixing to specification as per company procedures and related documentation where applicable. c) Maintenance and inspection of all plant and equipment. d) Assist with the maintenance of up-to-date inventory records and mud plant volumes. e) Safe Forklift operations according to company and legislative procedures. f) Driving duties using company vehicle (where applicable) (deliveries and collections). g) Safe loading and unloading of containers, boats, tanks etc. in accordance with company procedures. h) Following company inspection and testing procedures for products/materials arriving into the warehouse and deliveries to customers. i) Take samples of products as instructed by the Warehouse Manager according to company procedure. Samples are required to be logged and stored correctly. j) General duties within the yard, mud plant and bulk plant. k) Adherence to waste management procedures according to Site-specific plan.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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Operational Environmental Plan

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l) Ensure that company vehicles are driven in a safe coherent way in line with company policy. m) Maintain vehicles in a safe, clean condition and report any faults to management.

2. DESCRIPTION OF OPERATIONS Lot E3 is located on the north eastern side of Port Drive within the Broome Port Authority area. The site is bordered to the east by Roebuck Bay with a nature reserve separating the site from the beach area. To the North of the site there is a natural coastal bush block and on the bay there is a hovercraft base supporting the tourism industry. To the West, is Port Drive, with a large logistical facility operated by Toll Mermaid and a Bulk Fuel Storage Depot operated by both Shell and BP. The South of the site is a limestone road train break up and turn around facility mainly used for road trains servicing the adjacent fuel depot. The entire site is to be secured through 6 foot cyclone fencing with two feet of barbed wire runs atop, and secured gates such that the facility can be completely locked down during periods of inactivity. The entire site is to be sealed with either concrete bunds or two coat bitumen seal to ensure any and all materials on site are completely contained. One third of the site consists of concrete bunds to provide secondary containment of all fluids materials stored on site, and catch approximately 1/3 of storm water that falls on site. This in turn reduces the amount of storm water discharge from the site by approximately 1/3 as all of the storm water collected in bund areas will be recycled and used in the making of brines. All warehousing on site has been designed to be weather resistant such that storm water will not penetrate them. To assist in water management on site a water monitoring well has been installed on the eastern side of the lot, closest to the bay. Regular ground water monitoring will be conducted by M-I Australia and Broome Port Authority as per Broome Port Authority TEMR requirements. The site has been designed such that the warehouse is closest to the Roebuck Bay area. The rear of the warehouse only has emergency personnel access doors such that all material stored within the warehouse cannot make its way towards the bay. The liquid tank storage areas are located on the Port Drive side of the site such that emergency access to tanks is available from all sides, with fire and emergency vehicles being able to park vehicles on any side of the tank farm should the need ever arise. All fluid mixing on site is to be conducted within the mixing shed and all bulk powder cutting operations are to be conducted within the large warehouse. These buildings are self bunded and self-contained such that any release of material is contained within the concrete foundations and able to be collected and disposed of through third party approved waste disposal contractor.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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A septic system will be installed on site for the handling / storage of sewage in accordance with Health Act 1911, Heath(Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulation 1974.

2.1

Major Operations Mixing of Synthetic Based drilling fluids; o Conducted within Bunded Mixing Shed. o Processes utilize specifically designed Venturi system to ensure safe blending of all materials, both powdered and liquid. Mixing of Water Based drilling fluids; o Conducted within bunded mixing shed. o Processes utilize specifically designed Venturi system to ensure safe blending of all materials, both powdered and liquid. Testing of drilling fluid properties; o Conducted within Specifically design Mud laboratory located within mixing shed. o Fluid testing within lab to be conducted by qualified Drilling Fluid Engineers only. Loading out drilling fluids to Platform Supply Vessels; o Conducted over specifically engineered bunded concrete load-out bays. Back loading drilling fluids from Platform Supply Vessels; o Conducted over specifically engineered bunded concrete load-out bays. Cutting Bulk Powdered Product; o Conducted within the large warehouse, fully enclosed area. o Operations utilize specifically designed dust collecting system. o Loading out Bulk Powdered Product conducted over concrete load-out pad. o Operations utilize specifically designed dust collecting system. Minor Operations Centrifuging and reconditioning of used fluids; o Conducted within Bunded Mixing Shed. o All drill solid fines and waste to be disposed of through approved third party waste disposal contractor. o All used disposal containers are to be sealed within mixing shed upon completion of processing. Storage of Synthetic Based Fluids; o Fluids contained within specifically designed 1,100bbl storage tanks. o All tanks contained within engineered concrete bunds for secondary containment. o Tanks are fitted with radar fluid level monitoring system, with overflow prevention. o Tanks also have overflow pipes down to 900mm off ground level to ensure fluids 100% contained within concrete bund foundations. Storage of Water Based Fluids; o Fluids contained within specifically designed 1,100bbl storage tanks.

2.2

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb o o o

BROOME Lot E3
Operational Environmental Plan

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All tanks contained within engineered concrete bunds for secondary containment. Tanks are fitted with radar fluid level monitoring system, with overflow prevention. Tanks also have overflow pipes down to 900mm off ground level to ensure fluids 100% contained within concrete bund foundations. Storage of Bulk Powdered Products; o All contained inside the large warehouse on site. o All Bulk powdered material stored in plastic lined woven polypropylene bulk bags. o All Bulk Bags stored out of sunlight to ensure UV breakdown of bags cannot occur. Storage of Palletized Materials; o All palletized liquid materials to be stored in bunded concrete storage area. o All powdered sack materials to be stored in dedicated bunded storage area or warehouses. o All materials to be shrink-wrapped in UV rated Black Plastic for additional protection. Storage of Dangerous Goods; o All Bulk liquid DG material to be AS-1940 compliant storage tank farm. o All Bulk Liquid Storage tanks to be contained in concrete bunded storage area. o All palletized DG materials to be stored correctly in specifically engineered and design Dangerous Goods Storage Shed located in North West corner of yard. o All dangerous goods on site to be stored and handled as per 2007 Dangerous Goods regulations, and as stated by Dangerous Goods Consultant. Repalletization of products; o To be conducted within Large enclosed warehouse. o To be done with use of pallet inverter to minimize sack handling and potential spills. o All palletized material to be covered in additional UV rated black plastic protective covering.

2.3

Waste Oil Collection

Any waste oil or other associated hazardous waste is periodically collected and disposed of by a licensed waste carrier. All waste oil collected on site is stored in 1000L Intermediate Bulk Containers which are in turn stored within concrete bunded areas for secondary containment. Waste oils are then removed from site by third party waste disposal contractor and transported to their facility for disposal. In addition a licensed waste services provider will be periodically contracted to pump out the sumps of the designated bunded areas and other waste collection when sumps are nearing capacity. Each concrete bund is engineered to Australian Standards and designed to contain fluid should any container or tank experience a leak or rupture. Each bund has a self-contained, mesh grated, one cubic meter sump that has been designed such that vacuum trucks are able to lower hoses into them to remove fluid levels below the floor level surface of the concrete foundation. This ensures that maximum amount of fluids can be removed from bunds and minimizes the potential for remaining residue.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb 2.4

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Operational Environmental Plan

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Equipment Inspection & Maintenance

General cleaning and maintenance of onsite equipment (pumps, compressors, forklifts) is conducted by approved third party contractors. Any waste generated from such activities is removed by the third party conducting the maintenance. All maintenance of equipment is to be conducted within the bunded warehouse area to ensure that materials associated with maintenance cannot enter the general surroundings. Maintenance areas have been designed such that all equipment undergoing maintenance can be stored without impacting site operations. All bulk silos are periodically inspected and certified as per AS-3788 (Pressure Vessel Testing) by a government approved third party certification agent, in addition periodic visual checks are conducted internally of all tanks, piping and associated fittings. All bulk silos are registered through WorkSafe WA. Pressure Relief valves in place on bulk silos are inspected by NATA certified testing agents on an annual basis. In addition all associated pressure gauges are tested and replaced as required annually by a NATA certified agent. All Liquid bulk tanks are manufactured to API-650 and are periodically inspected.

2.5

Traffic Management

Lot E3 utilizes a one way traffic flow system in order to help mitigate the risk of a motor vehicle related incident occurring within the base. Traffic will enter off Port Drive and exit through the side gate onto what is currently known as the Hovercraft base road. The posted maximum speed for the base will be 15km/h. All loading and unloading operations will occur within designated loading zones only. Please see below diagram showing the traffic flow within the facility.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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Figure 2.5: Traffic Management diagram

2.6

Storm Water Management

Storm water control measures are in place including: a) Storm water collected within a bund will be processed through an oil and water separator and water pumped is then pumped to the brine mixing facility for re-use within the plant. b) Storm water collected in the two retention ponds is to be tested prior to discharge. If testing is within required limits the water is then pumped via spray bar over rock pitching and released to the environment. If Storm water does not meet specification it is processed through the oil/water separator and tested again. If quality does not meet discharge standards an approved third party waste disposal contractor will pump retention ponds dry and dispose of the fluid as per regulation. c) Prior to first rainfall event at the commencement of the wet season, water monitoring results will be submitted to the Shire of Broome within an agreed period of 7 days from receipt. Water testing Criteria pH Between 6.5 and 7.5

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb Oil Solids Turbidity Chlorides Hardness

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Operational Environmental Plan

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Less than 10ppm Less than 0.2% TSS Less than 40 NTU Less than 40,000mg/L Less than 300mg/L

Where water fails to meet testing limits for release it is then collected by an approved waste disposal contractor. During exceptional rainfall events, storm water can sheet flow overland off the site, transporting sediment and potentially oil contaminated water toward Roebuck Bay. For this reason considerable care is taken to keep the site clean and an independent environmental audit on an occasional basis is conducted.

2.7

Waste Management

Strategies to minimize the potential for disposal liability are employed such as: Reducing the amount of waste generated. Limiting the number of disposal companies used. Compaction of waste generated to reduce volume. Companies contracted for the disposal of waste are audited in accordance with SLB-QHSE-S008 Environmental Standard. Only approved waste service providers are used for disposal of hazardous and non hazardous waste. M-I Australia handles different types of wastes including: Products that are classified as hazardous to the environment i.e. used oil, waste paints, used solvents etc. Products that are non hazardous i.e. used pallets, paper etc. Common waste at M-I Australia facilities includes: Damaged product containers (sacks, bags, drums, plastic containers, barrels). Empty product containers (sacks, bags, drums, plastic containers, barrels). Unusable product. Drill solids acquired from centrifuge process. Waste oil. Used oil filters.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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Unserviceable plant, equipment and components. Soiled rag (oil, grease, chemical). Empty paint and aerosol cans. Used solvents and cleaning fluids. Administrative waste (paper, cardboard, printer and copier cartridges, alkaline batteries). Unserviceable office equipment (computers, printers, photo copiers, telephones). Unserviceable office furnishings (chairs, desks, tables, shelving, cupboards). Obsolete laboratory chemicals. Obsolete mud samples.

Before handling any waste, M-I Australia ensures the related physical, chemical, environmental and health hazards are understood. This includes ensuring that: Containers are correctly labeled. Containers are in good order and condition. Material Safety Data Sheet (MSDS) is available for the product. Appropriate Personal Protective Equipment (PPE) is used to handle waste and containers based on the type of waste involved. Equipment may include gloves, eye protection etc. Below table (2.7.1) is to be completed to ensure roles and responsibilities are clearly assigned for the management of waste streams. Below table (2.7.2) is a copy of the template use for waste classification and disposal routes. Table 2.7.1

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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Operational Environmental Plan

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Table 2.7.2

Storage M-I Australia requires weekly inspections of all chemical storage areas. Inspections must be documented using the Weekly Storage Checklist Form and should address: 1. Are all containers free of leaks, corrosion and deterioration? If leaks, corrosion or deterioration is evident has the product been classified as Grade B or Grade C waste product? 2. Is an accurate manifest on hand specifying exact quantities of Grade B and Grade C waste products? 3. Is each container clearly marked with a label stating its contents? 4. Do all products classified as dangerous goods have appropriate hazard labels? 5. Are sacks, bags, drums, plastic containers, barrels or pallets stored with sufficient aisle space and at a level which allows access to inspect and/or respond to leaks? 6. Are used oil containers clearly labeled Used Oil? 7. Are absorbent materials and other spill cleanup equipment available in sufficient quantities?

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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Operational Environmental Plan

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8. Is PPE available in accordance with MSDS recommendations for all products? 9. Is first aid equipment available in the area and in sufficient quantities? 10. Is area suitably signposted as a Waste Product Storage Area?

2.8

Spill Prevention and Control Plans

In the event of a Spill during the unloading or loading process, the control measures in place are as follows: Continuous monitoring of hoses and connections is conducted by the M-I Australia employee in accordance with Standard Operation procedures (Dry break couplings are utilized for transfers to minimize any spills that may occur. All hose connections coupled outside bunded areas are to be controlled through use of appropriately sized drip trays. All Synthetic base fluid tanks and mud tanks are contained within a bunded area designed to contain 110% of the largest vessel enclosed in accordance with AS-1940, plus 125mm to account
for a 125mm in 24 hour rainfall event.

All drum products are contained with a bunded area. Spill recovery kits are located at the facility. Detailed Spill Response Procedures are available in the event of a spill at the facility. Response procedures are in place for Base Fluids, Brines, diesel, Bulk powders etc. An example is included as Figure 2.2.

Note: All Secondary containment structures are periodically inspected and tested as per Figure 2.8.1 (Test and Inspection Record Form)

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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Figure 2.8.1: Test Inspection record form

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

BROOME Lot E3
Operational Environmental Plan

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Figure 2.8.2: Extract Broome Spill Prevention and Control Plans

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb 3. REGULATORY OBLIGATIONS

BROOME Lot E3
Operational Environmental Plan

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A key policy objective of M-I Australia Pty Ltd is compliance with environmental legislation'. M-I Australia, its staff and its Contractors are required under the Environmental Protection Act 1986 (EP Act) to prevent environmental harm, and also have a duty of care under common law to protect the environment from foreseeable risks. Under the Schedule 1 of the Environmental Protection Regulations 1987, the M-I Australia facility will comprise Category 73 & 75 Prescribed Premises (refer section 2 for additional detail). A License to operate under Part V of the EP Act is therefore required at the Site. Under the Port Authorities Act 1999, BrPA oversees all activities within the Port Management Area. The Site comprises part of the Port Management Area, and is zoned Port Zone under Broome Shire Town Planning Scheme No. 4. M-I Australia is establishing a register of legal and other requirements containing all environmental permits, licenses, works approvals and Ministerial conditions relevant to its operations. The following legislation has been identified as relevant. Environmental protection; EP Act. Environmental Protection Regulations 1987. Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth). Noise, dust, emissions; Environmental Protection (Noise) Regulations 1997. Environmental Protection (Unauthorized Discharges) Regulations 2004. Environmental Protection (Ozone Protection) Policy Approval Order 2000. Environmental Protection (Diesel and Petrol) Regulations 1999. Waste and pollution; Contaminated Sites Act 2003. Environmental Protection (Controlled Waste) Regulations 2004. Environmental Protection (Landfill) Levy Act 1998. Guidelines for Acceptance of Solid Waste to Landfill 2002. Pollution of Waters by Oil and Noxious Substances Act 1987. Environmental Protection and Biodiversity Conservation Act 1999. Water supply and sewerage; Country Areas Water Supply Act 1947. Dangerous goods; Explosives and Dangerous Goods Act 1961. Dangerous Goods (Transport) Act 1998.

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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Dangerous Goods (Transport (General) Regulations 1999. Dangerous Goods (Transport (Explosives by Road and Rail) Regulations 1999. Dangerous Goods (Transport) (Road and Rail) Regulations 1999.

Aboriginal heritage; Aboriginal Heritage Act 1972. Aboriginal Communities Act 1979. Conservation and Wildlife; Conservation and Land Management Act 1984. Agricultural and Related Resources Protection Act 1976. Soil and Land Conservation Act 1945. Soil and Land Conservation Regulations 1992. Wildlife Conservation Act 1950. While care was taken to identify all relevant legislation, these tables should not be assumed to contain every possible statute. 4. DESCRIPTION OF THE EXISTING ENVIRONMENT

This section provides an overview of the existing receiving environment. It is described in terms of the regional setting, physical environment, ecological features and socioeconomic features.

4.1

Regional Setting

The Site is situated on the Dampier Peninsula and is 5km south-west of Broome town site and located within the boundaries of the Port Management Area. The area surrounding Lot E3 is currently natural coastal bush land. Lot E3 currently slopes westwards towards Port Drive and current drainage is determined by the existing environmental lay of land. The site is bounded to the North-West by an access way to Broome Hovercraft base and beyond that is an undeveloped block of remnant native vegetation. To the North-East the property is bounded by native vegetation corridor which stretches to Roebuck Bay. South-East the property has a soft stand road train lay-down and turn around bay, while the South West is bounded by Port Drive.

4.2

Physical Environment

The site is bounded to the east by Roebuck Bay with a native vegetation and pindan cliff conservation area separating the site from the bay. Site drainage has been designed to minimize the current impact of erosion to the pindan cliffs, and is to be monitored and modified as per required to ensure the

Prepared by: Richard Taylor Verified by: Courtney Girdwood Approved by: James Cobb

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protection of the natural vegetation and erosion of this area. Site drainage plan incorporates the catchment of one third of storm water on site to assist in reducing the current downstream erosion potential. Heritage studies have determined that there is no significant site within the boundaries of the lease area, and has been confirmed by the Department of Aboriginal Affairs. There are some significant sites located close by in the bay area and due to the sensitive nature of these sites all practices are to be employed to protect these sites from damage or erosion due to any and all operations on site.

4.2.1

Climate

The site is arid, however Rainfall is generally low (avg. ann. ~517mm), and demonstrates a summer peak (cyclone season), with a lesser winter peak occurring in response to high pressure system traversing southern Australia (Figures 4.2.1 and 4.2.2). The late winter-spring period is generally dry. Temperatures range from a minimum average of ~14C in winter, to an average peak approaching 35C in summer. Wind at the site is largely Westerly (winter) and Easterly (winter) in the morning, swinging south-east and north east respectively in the afternoon (Figure 4.2.3). Wind strengths are generally less than 15knots, but can exceed 20knots.

Figure 4.2.1: Average Rainfall

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Figure 4.2.2: Average Minimum and Maximum Temperature

Figure 4.2.3: Wind strength and Direction for 9am and 3pm observations (source BoM)

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Plant communities in the Port Management Area and surrounds have been surveyed and described by LeProvost Environmental Consultants (1990) and Woodman Environmental Consulting (2008, 2009). The native vegetation present has been determined to be of non-threatened varieties, and processes and practices implemented on site are designed to eliminate any disturbance to vegetation within surrounding areas. Additional site inspections have been undertaken by Coffey Environments (2013a, b). Based on results of an independent environmental site investigation conducted in 2013 the TEC monsoon Thickets, the PEC Mangarr community and the threatened Keraudrenia exastia were not reported to occur within the site boundaries of Lot E3. Monthly site inspections include visual inspection of surrounding areas.

5.

ENVIRONMENTAL MANAGEMENT CONTROLS

Various guidelines procedures have been developed by M-I Australia to manage the impacts of its operations on the environment. These procedures are detailed in a number of documents, primarily: a) Environmental Standard (SLB-QHSE-S008). b) Documentation & Evaluation of Environmental Regulatory Requirements Guideline (SLB-QHSES008G002). c) Hazardous Substance Storage Guideline (SLB-QHSE-S008-G003). d) Industrial Wastewater Discharge Sampling & Analysis Guideline (SLB-QHSE-S008-G004). e) Waste Minimization & Management Guideline (SLB-QHSE-S008-G005). f) Air Emissions Management Guideline (SLB-QHSE-S008-G006). g) Resource Conservation Guideline (SLB-QHSE-S008-G007). h) Wastewater Management Guideline (SLB-QHSE-S008-G008). i) Secondary Containment Test & Inspection Guideline (SLB-QHSE-S008-G010). j) Site Entry & Exit Assessment Guideline (SLB-QHSE-S008-G011). k) Broome Waste Management Plan. l) Broome Cyclone Emergency Response Management Plan. m) Broome Standard Operating procedures. n) Broome JSA/HARCs. o) Broome SOPs (See list below). p) Broome Emergency Response Plan. q) Broome Spill Prevention and Control Plan.

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All persons working within the Site are required to complete a site induction and to comply with the requirements of the HSE Management system List of Broome Safe Operational Procedures (Not exhaustive) 5.1 Forklift Re-fuelling. Fluid building. Fluid mixing procedure (WBM). Fluid mixing procedure (SBM). Fluid mixing procedure (Brine). Bulk liquid transfer (SBM) LMP to bulk road tanker. Bulk liquid transfer (SBM) Road tanker to rig support vessel. Bulk liquid transfer (SBM) Rig support vessel to road tanker. Bulk liquid transfer (SBM) Bulk road tanker to LMP. Bulk liquid transfer (Base Oil) LMP to bulk road tanker. Bulk liquid transfer (Base Oil) Road tanker to rig support vessel. Bulk liquid transfer (Base Oil) Rig support vessel to road tanker. Bulk liquid transfer (Base Oil) Bulk road tanker to LMP. Bulk liquid transfer (Brine) LMP to bulk road tanker. Bulk liquid transfer (Brine) Road tanker to rig support vessel. Bulk liquid transfer (Brine) Rig support vessel to road tanker. Bulk liquid transfer (Brine) Bulk road tanker to LMP. Bulk powder cutting procedure. Bulk powder transfer Cutting bottles to storage silo. Bulk powder transfer Storage silo to road tanker. Bulk powder transfer Road tanker to rig support vessel. Bulk powder transfer Break down of Equipment. Emergency Response Plan

The Emergency Response Plan details the basic guidelines to be followed by M-I Australia personnel in the event of an incident occurring within facility. The Emergency Response Plan is designed to integrate with any other emergency management plans. In addition separate Cyclone Management plans and Spill Prevention and control plans are also in place. 5.2 Spill Response Plan

The M-I Australia Spill Response Plan is designed to help protect the environment in two ways: First, it provides the procedures / processes which will be used to prevent chemical spills, and waste releases; and

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Second, should a spill or release occur, it describes the protocols for immediate coordination of necessary activities to minimize any harmful effects, including notification of appropriate government agencies as required under applicable federal, state, and local regulations. To handle a spill response effectively, the Spill Response Plan provides descriptions of the duties to be performed by facility personnel, procedures to be followed, available equipment, and available outside resources. See below Figure 5.2 (Spill Response Flowchart)

Figure 5.2: Spill Response Flowchart

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Cyclone Emergency Response Plan

M-I Australia has a detailed Cyclone Emergency Response Plan that outlines its actions and responsibilities managing the risk posed by cyclones in the Kimberley Region, and specifically in the Broome Area. Pre-Cyclone actions include awareness training for all employees (including annual online refresher training) preparedness preparations in accordance with BOM guidelines, emergency contacts etc. Further details can be found in the M-I Australia Broome Cyclone emergency response plan.

5.4 Noise Management Noise generated during operations shall be managed in accordance with Environmental Protection (Noise) Regulations 1997. Control measures in place to reduce noise to reasonably practicable levels include but not limited to the following; a) All equipment to be regularly maintained to ensure efficient operation in accordance with manufacturers recommendations. b) Pre-start checks and maintenance schedules shall be in place to ensure equipment performance is in accordance with requirements. c) Noise dampening equipment is fitted where required on equipment in accordance with National Code of Practice. d) Periodic Noise surveys are conducted to ensure exposure levels are with tolerance limits.

5.5 Insect / Vermin Vector Management Insect vector management will focus around control of vermin, flies and mosquitos. Methods of Control Vector controls will focus on utilizing preventative methods to control/reduce or eliminate vector populations. Typical preventative measures are as follows: Habitat Control Removing or reducing areas where vectors can easily breed. Including, stagnant water removal, general waste to be stored in sealed covered bins with weekly removal, removal of retention pond contents in accordance with storm water management plans e.g. after cyclonic rainfall which may serve as mosquito breeding environments. Good management of used water can reduce areas of excessive vector incidence.

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Insecticides, rodenticides and repellents may be used to control vectors. For example, insecticides can be applied to areas where insects may gather, and use of personal repellents can reduce incidence of insect bites and thus infection. The use of rodenticides i.e. baits may be used to help control vermin should they required. If vectors should reach levels where additional action is required a licensed pest controller will be called into initially assess and then implement plan to bring under control.

5.6 Air Quality The Location Manager in conjunction with HSE will implement and maintain a Pollution Prevention Plan that includes: a current list of potential emissions and sources, regulatory requirements, procedures for meeting regulatory requirements, and training and record keeping requirements. The Location Manager will implement pollution prevention measures to minimize point source (e.g. chemical blending in tanks) and fugitive (e.g., yard roadway dust) air emissions. The Site Manager will consult with the APG Environmental Manager or the HSE representative for approved methods. For example, water is the only approved dust suppressant that may be applied to yards to control dust emissions. Typical Type of Emissions; 1) Internal combustion engine - NOx, CO, particulates, SOx, VOCs Standard emissions from Diesel trucks, forklifts, and light vehicles - No more than would be experienced at any site, roadway or commercial precinct. 2) Diesel storage tank - VOCs No more than would be experienced at any site or commercial precinct with diesel storage tank. 3) Bulk plant particulates Rubber curtains on cutting operations to reduce initial created airborne particulates. Silo Vent particulate discharge is suppressed through use of reverse pulsating dust collection/filtration equipment

5.7

Bushfire Management

Prevention and management of bushfire are in accordance with FESA local instructions. The site is to maintain a one meter clear zone inside the perimeter to assist in reducing risk of fire damage in the

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event of bush fire. Three sides of the lease area are easily accessible by Fire and emergency services at all times with the only side not accessible by emergency vehicles being bordered by the large warehouse. Behind the warehouse is a 1m exclusion zone and concrete drainage system which acts as emergency egress for staff that may be present inside the warehouse and unable to exit through normal operational doorways.

5.8

Contractors and Carriers

All contractors carrying at the Site are required to complete a full site induction and also required to operate under the facilitys Permit to Work System. All Contractors will be required to act in accordance with this EMP at all times while on Site.

5.9 Implementation of Environmental Management Plan Management of M-I Australia operational activities that may have an impact upon environment is detailed in our Safe Operational Procedures and JSAs.

5.9.1

Implementation

To ensure effective implementation, M-I Australia: a) Communicate the OEMP to all staff, contractors and train personnel. Failure to involve all staff/contractors means that some may have little understanding of the issues and no ownership of the management measures that should be implemented. b) Make environmental considerations an integral part of the decision making process. c) Ensure that all contractors working on the site follow Safe Operational Procedures in place and comply with the OEMP. d) Periodically review operations where these procedures are implemented. e) Conduct periodic environmental management audits to ensure correct implementation of the OEMP. 5.9.2 Environmental Monitoring and Review

One of the central aspects of environment management plan implementation is monitoring the effectiveness of the procedures in reducing environmental impacts. A monitoring program will be in place so that procedures may be improved or new ones developed. A Monitoring well has been installed on site for collection of environmental data such as water quality.

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Compliance to this OEMP shall be assessed based on the following performance factors: Internal (first and second-party) assessments against the requirements of this OEMP. Number and severity of environmental incidents, in absolute terms and normalized for exposure. Number of proactive environmental activities including near-incident and hazardous situation reports, communication meetings, inspections, etc.

The internal audit assurance process applies to all risk levels; Where only Fundamental level controls apply, a second-party assessment shall be performed every 48 months. Where any Medium level controls apply a second-party assessment shall be performed every 36 months. Where any High level controls apply, a second-party assessment shall be performed every 24 months.

5.10 Key Activities Below is a list of some key activities to be conducted at the facility and proposed management thereof:

Activity: General Cargo Handling (other than dust generating activities, hazardous waste) Objective: Prevent uncontained release of solid waste. Relevant Activities: General Cargo Handling. Environmental Management Procedures: Ensure all products are clearly marked/labeled as to content. Ensure product is packaged in accordance with packaging guidelines including use of UV treated packaging. Ensure packaging materials are collected and properly disposed of. Conduct regular inspections of product / packaging in storage. Ensure that appropriate spill kits are available and regularly checked. Identify any damaged product and pallets and segregate in contained area. (Repalletize or return). Ensure all handling equipment (Forklifts etc) are adequately maintained in accordance with maintenance schedules.

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Likely Pollutants: Solid waste/litter including plastic, chemical spill. Environment at Risk: Ground Surface (Note: Yard is sealed). Considerations: Conduct frequent inspection of storage and handling areas and handling equipment. Keep consistent and accurate records of inspection efforts. Storage structures designed to meet local and state regulatory requirements.

Activity: Product Handling - Dust Generating Materials Objectives: Prevent emission of dust from dry bulk handling activities. Relevant Activities: Handling of dust generating materials such as barite and bentonite. Environmental Management Procedures: Cover storage and handling facilities where practicable. Adoption of dry break hoses to transfer bulk products from tanker to Silo. Process managed through SOP process. Scheduled maintenance and servicing of Silos, Dust collectors, hoses, PRVs etc. in accordance with Maintenance schedules and regulatory requirements. Use of certified Pressure Vessels. Utilize dust suppression mechanisms i.e. Dust Collectors. Utilize water sprays where practical. Minimize stockpile heights. Ensure use of sealed transport vehicles. Ensure hatches are covered when material handling is not being conducted. Conduct routine vacuum sweeping of handling areas. Clean up spills immediately. Likely Pollutants: Dust. Environment at Risk: Surface water and air.

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Considerations: Provide training on handling and transport techniques for minimizing dust pollution. Develop routine inspection and maintenance program and keep records of activities.

Activity: Solid Waste Handling Objectives: Prevent discharge of contaminants associated with solid waste handling. Relevant Activities: Solid waste collection. Solid waste handling. Solid waste disposal. Environmental Management Procedures: Covered waste storage facilities to prevent rainwater from carrying any potential contaminants off the site. Bunded areas to prevent contaminants entering the storm water system. Clearly mark facilities indicating what materials are acceptable for disposal. Provide separate receptacles for hazardous waste materials (e.g. paints and solvents). Provide receptacles for recyclable materials (e.g. aluminum, paper, including cardboard, glass). Provide suitable disposal facilities and procedures for quarantine waste. Ensure that receptacles are easily accessible. Monitor materials placed in receptacles, containers with solvents and paints, and other hazardous wastes. Empty waste receptacles frequently. Ensure all disposal areas are properly lighted to reduce chances of incorrect disposal. Identifying waste reception facilities. Identifying acceptable handling procedures. Encouraging recycling. Likely Pollutants: Litter including plastics. Land, surface water / groundwater.

Activity: Waste Oil Management Objective: Prevent release of pollutants from the handling and storage of waste oil.

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Relevant Activities: Storage, handling and transport of waste oil. Environmental Management Procedures: Cover all waste oil storage areas and ensure adequate ventilation in cases of spills and leaks. Ensure waste is contained in identified bunded area. Contain and properly dispose of leaks and spills from within bund through approved licensed waste disposal company. Seal joints and cracks ensure periodic inspection and integrity checks of bunded areas. Ensure all containers are securely loaded and tied down prior to transport. Avoid transfer of waste oil (from small containers or bunds into drums) in close proximity to drainage areas. Provide secondary containment for all active drums. Immediately contain and stop leaks and spills. Have spill response materials readily available, in strategic locations for use in any location. Clearly mark spill response materials. Likely Pollutants: Hydrocarbons (waste oil). Environment at Risk: Land, surface water, groundwater and marine environment.

Activity: Chemical Storage and Handling Objective: Prevent release of pollutants from the handling and storage of chemicals in 205L drums /ISO tanks. Relevant Activities: Storage and handling of chemicals. Environmental Management Procedures: Cover all chemical storage areas. All liquid chemical storage areas to be bunded and sealed areas. The mixing area and dangerous goods storage areas will be bunded and covered to ensure containment in the unlikely event of a spill. Training provided in Hazardous Chemicals Management to all Material Handlers. Provide adequate ventilation in cases of spills and leaks.

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Raise storage area above surrounding ground surface and berm to minimize seepage into surrounding areas and into the storm water system. Provide an impervious base in storage and handling areas to minimize releases to soils and groundwater. Seal joints and cracks. Protect storage area from vehicle accidents. (One way traffic management system). Restrict access to storage areas through the use of fencing or enclose storage areas. Provide flame-resistant containers where required. Use flame resistant locker for small quantities of materials. Ensure only compatible materials are stored together. Maintain, read and understand material safety data sheets (MSDS) for all chemicals. Minimize quantities of materials stored. Provide designated separate area for leaking hazardous products, which is: Covered and ventilated. Dead-end sumped to contain spills and leaks. Bermed to prevent spread of spills and leaks. Impervious based. Ensure all containers are marked and labeled properly. Ensure storage areas are clearly marked noting materials stored, emergency contacts, and spill cleanup procedures. Maintain copies of relevant MSDSs in a location near to but separate from chemical storage facility. Site Registration for Storage of Dangerous Goods in accordance with the Dangerous Goods Safety Act 2004 and Dangerous Goods Safety (Storage and Handling of Non Explosives) Regulations 2007. Three materials with dangerous goods classification are currently schedule to be stored on site i.e. 2 x synthetic bases oils and 1 x class 8 corrosive Likely Pollutants: Various chemicals including hazardous chemicals. Environment at Risk: Land, surface water, groundwater and marine environment.

Activity: Building and Grounds Maintenance Objective: Prevent or reduce the discharge of pollutants from building and grounds maintenance.

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Environmental Management Procedures: Minimize use of pesticides, herbicides, and fertilizers and use only as directed. Seek less harmful/toxic products. Provide adequate storage space for pesticides and herbicides, and ensure well ventilated. Exercise proper precautions when applying materials near water bodies or storm water systems. Properly dispose of green waste, wash water, sweepings, and sediments. Use "dry" cleaning techniques, such as sweeping, whenever possible. Incorporate landscaped areas that are pervious and will result in less runoff discharged from a site. Incorporate native vegetation to reduce irrigation, fertilizer, and pesticide needs. Likely Pollutants: Pesticides, herbicides, fertilizers. Paints, solvents, thinners and strippers. Litter including plastics. Environment at Risk: Land, surface water, groundwater and marine environment.

Activity: Vehicle and Equipment Maintenance Objective: Prevent the discharge of pollutants during vehicle and equipment maintenance activities. Relevant Activities: Vehicle maintenance. Equipment maintenance. Vehicle equipment painting/stripping. Environmental Management Procedures: All such activities are to be conducted off site by third party contractor

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Activity: Storm water, Erosion and Dust Control Objective: To control storm water movement in order to prevent or reduce soil erosion and the transfer of contaminated sediment to the marine environment. Relevant Activities: Repair of existing disturbed areas. Development of new areas. Control of runoff. Environmental Management Procedures: Identifying storm water pathways and volumes. Determining the extent of currently eroded areas. Identifying erosion problem areas. Develop an erosion control plan. Consider the use of structural storm water and erosion control devices including: earth dikes, drainage swales, interceptor dikes and swales, subsurface drains, silt fences, straw bale barriers, brush barriers, and gravel or stone filter berms. Plant native grasses, shrubs, or ground cover plants in drainage pathways to slow erosion. Incorporate storm water detention/retention to reduce peak runoff flows and to improve water quality. Plant native grasses, shrubs, or ground cover plants to slow erosion. Use mulch on disturbed soil. Provide cover of gravel, wood chips, or straw will help to minimize erosion processes. Consider use of netting or mats as a supplement to mulching. Control dust during dry weather by watering disturbed areas. Likely Pollutants: Contaminated sediment. Environment at Risk: Marine environment.

6.

ENVIRONMENTAL RISK REGISTER

M-I Australia operations and activities, by their nature, have the potential to impact upon one or more aspects of the natural or social environment. The risk register describes activities undertaken at the facility, identifies the potential significant environmental and social impacts, and summarizes operational controls currently in place to mitigate these impacts.

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Air Emissions Hazardous substances, including gases or particulates for which M-I Australia and associated contractors are responsible released into the air. Hazardous air emission sources at M-I Australia sites include, but are not limited to: bulk powder plants, engine exhausts, and some sand blasting operations. Dangerous Goods Dangerous goods are substances or articles that, because of their physical, chemical (physicochemical) or acute toxicity properties, present an immediate hazard to people, property or the environment. The criteria used to determine whether substances are classified as dangerous goods are contained in the Regulations which refer to the Australian Dangerous Goods Code (ADG Code) (available at www.ntc.gov.au). This is closely aligned with the criteria of the United Nations Recommendations on the Transport of Dangerous Goods - Model Regulations. Discharges Release of substances into the environment: Generally refers to the release of liquids into a body of water. Emissions Release of substances into the environment: Generally refers to the release of gases, odours, or particulates (dust) into the air. Environment (OGP) The surroundings and conditions in which a company or individual operates or which it may affect, including living systems (human and other) therein. Environmental Impact Assessment (OGP) A formal, written, technical evaluation of potential effects on the environment (atmosphere, water, land, plants, and animals), of a particular event or activity. Hazardous Waste (M-I Australia Recognized) Any waste that is classified as hazardous (according to government regulations) or otherwise classified as a potential hazard to human health or the environment. Hydrocarbon Fuels Fossil fuels that are combusted for energy or transportation, including petrol, gasoline, diesel, oils heating, generators, engines and kerosene. Leak A leak is a systemic or chronic undesired loss of primary containment of oil, oil products, chemicals, solvents, and/or hazardous substances. A leak is often small with no immediate damage to the

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environment. It is the cumulative effect of many leaks over time that has the potential to damage the environment. Performance Indicator (OGP) A specific measure to describe management, operational process or performance. Prevention of Pollution Use of processes, practices, materials or products that avoid, reduce or control pollution, including recycling, treatment, process/material changes, control mechanisms, efficient use of resources. Responsible Disposal (OGP) The deposition of waste, onto land or into water, using methods appropriate for a given situation. Disposal methods include: landfill, burial, surface discharge, land-spreading or land-farming, and underground injection. Spill (OGP) Any loss of containment that reaches the environment, irrespective of quantity recovered. Waste (OGP) Any material, (solid, liquid, or gas), which is introduced into the work location as a product of the work but which fulfils no further useful purpose, at that location. Waste Minimization and Management A system designed to achieve waste reduction, reuse, reclamation, recycling, and responsible disposal. Wastewater Discharges Industrial Industrial waste water is related to industrial processes such as: manufacturing, cleaning, equipment testing, chemical blending, mechanical, electronic operations; includes the runoff and leachate from areas that receive pollutants such as wash bays, fuel and chemical storage areas; includes all other wastewater that is not defined as domestic/sanitary wastewater or storm water. Wastewater Discharges Sanitary or Domestic Domestic or sanitary water is related to dwellings, camps and business buildings; includes kitchen, bathroom (sewage) and laundry wastewater; sometimes sub-classified as grey water (from showers and kitchens) and black water (from toilets). 6.2 Environmental Events

Reporting of environmental events, inspections, assessments and audits is fully integrated into QUEST, the M-I Australia QHSE data capture and reporting system. All reporting shall initially comply with all local regulatory and BrPA requirements. In addition Company Standards including SLB-QHSE-

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M-I Australia recognizes three types of reportable spills: those involving hazardous substances, crude oil and produced water. For the purposes of internal M-I Australia reporting, refined petroleum products such as motor oil, kerosene, and petrol are to be categorized as hazardous. The severities of environmental incidents are defined in the table below.

Table 6.2: Environmental Incident Severity Classification

6.3 6.3 Environmental Risks of Significance to M-I Australia Operations The below table is indicative. It is non exhaustive list of potential activities that may pose a significant risk to the environment or the impacts that may arise, or of the controls that may be implemented to avoid, remedy or mitigate environmental risks.

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Table 6.3: Environmental Risk Related Activities

7.

REFERENCES SLB Event reporting and Management (SLB-QHSE-S002) SLB Auditing (SLB-QHSE-007) SLB Environmental Standard (SLB-QHSE-S008) SLB Environmental B.O.O.K BPA Environmental Management Plan 2013 SLB QHSE Policy