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During construction, there is a risk of spills of fuel and oil from construction equipment and temporary storage tanks. Other substances, such as paints, coating and cleaning products may be used on site, and there is a potential of spills onto the ground, resulting in the contamination of soil and groundwater. These potential impacts should be managed through the use of environmental management plan for the construction phase (CEMP). Storage and disposal areas should be clearly segregated and designed to prevent spills from reaching the ground.

Other potential impacts relate to construction phase wastewater. The operation and maintenance of temporary washing areas and toilets should be well managed to prevent the accidental discharge of wastewater onto the ground. The construction wastewater will be collected in a concrete-lined pit, neutralized, filtered and will be reused.

Similar potential impacts and management measures apply for the commissioning and start-up phases. In addition, wastewater will be generated due to hydrotesting, cleaning, boil-out and chemical washing of lines, vessels and tanks. A commissioning phase management plan should be developed and followed to prevent the discharge of any effluents and chemicals to the ground.

It is considered that the construction impacts relating to soil contamination will be restricted to the site and immediate surrounding areas. The impacts are considered to be temporary (as they will occur during the construction period of the project only) and reversible as long as appropriate clean up operations are carried out allowing excavation and removal of contaminated soils. The impacts could potentially be cumulative if contamination of soils occurs associated with the construction of plant on adjacent industrial facilities. Overall the environmental impact associated with soil contamination during construction is low risk.

Probability Consequence Risk

Rare Minor Low

Operation

The solvents and other chemicals proposed to be used in the process pose a risk of contamination of the soil and groundwater if they are not handled and stored cautiously.

Moreover, spills of HCl and sodium hypochlorite might release large amount of acid fumes and chlorine gas, respectively.

Any impacts are considered to be reversible through appropriate remediation works. The impacts could potentially be cumulative if contamination of soils occurs associated with the operation of the adjacent plant. Overall the environmental risk associated with soil and groundwater contamination during operation is moderate.

Probability Consequence Risk

Likely Minor Moderate

Decommissioning

During decommissioning of the plant there will be the potential for contamination of site soils and groundwater as a result of the planned activities of dismantling and demolition of plant structures and equipment. Details of the decommissioning plan are not available at the time of writing, therefore it is assumed that decommissioning will comprise the removal of all site structures above ground level. Contamination of soil and groundwater could potentially occur as a result of: spillage of residual fluids, oils and chemicals within plant equipment during dismantling; spills and leaks of waste materials stored on site;

inappropriate handling of waste materials.

A decommissioning phase management plan should be developed and followed to prevent the discharge of any effluents and chemicals to the ground.

It is considered that the decommissioning impacts relating to soil contamination will be restricted to the site and immediate surrounding areas. The impacts are considered to be temporary (as they will occur during the period of decommissioning only) and reversible as long as appropriate clean up operations are carried out allowing excavation and removal of contaminated soils and groundwater. The impacts could potentially be cumulative if contamination occurs on adjacent industrial facilities at the during the same period of decommissioning. Overall the environmental impact associated with soil contamination during construction is low risk.

Probability Consequence Risk

Rare Minor Low

Rare Minor Low Fuel, oil and chemical storage facilities to include 110%

secondary containment.

Refuelling & maintenance to be carried out at designated sealed hardstanding area/s with appropriate spill clean up and containment facilities.

Provision of spill kits in all vehicles.

Waste storage in designated sealed hardstanding area with appropriate spill clean up and containment facilities.

Development of a CEMP and monitoring plan.

Emergency shut down and spill response procedures for a hazardous waste spill will be required to be developed and implemented by the EPC contractor.

Regular inspections of plant and equipment.

The EPC contractor will encourage workers to report all spills using a ‘no blame’ culture.

If inadvertent leakage or spillage of hydrocarbons occurs, EPC Contractor will implement spill response measures to contain and excavate any contaminated soil present.

EHSMS CoP 12 –

EPC contractor to develop OEMP and environmental monitoring plan.

Appropriate protocols will be established for the transfer and disposal of contaminated fuel, oil and soil in accordance with Municipality requirements in the Waste Management Plan.

Fuel, oil and chemical storage facilities to include 110%

secondary containment.

Refuelling & maintenance to be carried out at designated sealed hardstanding area/s with appropriate spill clean up and containment facilities.

Regular inspections of plant and equipment.

If any inadvertent leakage or spillage of hydrocarbons occurs, the operator will implement spill response measures to contain and excavate any contaminated soil present.

Chemical Management, Waste Management, Emergency and Spill Response plans will be established for the site.

All contaminated wastewater will be treated to within appropriate discharge limits prior to disposal.

EHSMS CoP 12 –

Impact Description Phase

Score

Significance Potential Mitigation

Applicable Environmental Standard / Limits

Probability Consequence

Decommissioning

Rare Minor

Low

It is anticipated that activities and impacts, and hence mitigation measures for decommissioning will mirror the construction phase.

EHSMS CoP 12 – Water Quality and CoP 13 - Land Management version 1.2 July 2009

-5.4.3.2. Selected Mitigation Measures