Victorian Desalination Project - AquaSure

Victorian Desalination Project 

TDJV D&C EMP 

Attachment I 

Commissioning Environmental Sub-plan (CESP) 

DOCUMENT NUMBER 

TDV 0 EV SB 0021.I 03

Table of Contents 


Definitions and Acronyms ............................................................................................... 6 

1 Purpose and application .......................................................................................................... 9 

1.1 Purpose ........................................................................................................................... 9 

1.2 Application ..................................................................................................................... 10 

1.2.1 Commissioning Stages ......................................................................................... 10 

1.3 References..................................................................................................................... 11 

2 Project Overview .................................................................................................................... 12 

2.1 VDP Project Scope......................................................................................................... 12 

2.1.1 Area 1 - Marine Intake and Outlet Structures ........................................................ 14 

2.1.2 Area 2, 3 and 4 - Desalination Plant and Facilities ................................................ 14 

2.2 Environmental Objectives and Targets ........................................................................... 15 

3 Commissioning Overview ...................................................................................................... 15 

3.1 Commissioning Scope .................................................................................................... 15 

3.2 Commissioning Components .......................................................................................... 16 

3.3 Legal Obligations ........................................................................................................... 17 

3.4 Environmental Context and Significant Environmental Aspects ....................................... 18 

4 Commissioning Delivery Approach ...................................................................................... 23 

4.1 Project Delivery Mode and Contractual Requirements .................................................... 23 

Project Phases ............................................................................................................... 23 

4.3 Commissioning Phasing and Handover to O&M Phase ................................................... 24 

4.4 Project Management Documentation .............................................................................. 26 

4.5 Commissioning Documentation ...................................................................................... 26 

4.6 Operational Management Control ................................................................................... 27 

4.6.1 Commissioning Work Area Packs ......................................................................... 27 

4.6.2 Commissioning Work Packs ................................................................................. 28 

4.6.3 Work Method Statements & Procedures ............................................................... 29 

4.6.4 Job Safety Environmental Analysis ....................................................................... 29 

4.6.5 Inspection Test Plans (ITPs) ................................................................................. 30 

5 Commissioning Organisational Structure and Resourcing ................................................. 30 

5.1 Leadership and Individual Responsibility ........................................................................ 30 

5.2 Commissioning Organisational Structure ........................................................................ 31 

5.3 TDJV Roles and Responsibilities .................................................................................... 32 

5.4 AquaSure Roles and Responsibilities ............................................................................. 34 

5.5 Independent Reviewer and Environmental Auditor .......................................................... 34 

6 Commissioning Environmental Management Documentation ............................................. 35 

6.1 Overview ........................................................................................................................ 35 

6.2 Documentation ............................................................................................................... 36 

6.2.1 Attachment I.1 – Risk Register.............................................................................. 36 

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6.2.2 Attachment I.2 – Commissioning Management Strategies ..................................... 37 

6.2.3 Attachment I.3 – Monitoring, Inspection, Reporting and Auditing Schedule............ 37 

6.2.4 Attachment I.4 – Commissioning Monitoring Program, interfacing with the 

Baseline Marine Monitoring Program (BMMP) ...................................................... 37 

6.2.5 Attachment I.5 – Monthly Environmental Checklist ................................................ 37 

6.3 Authorisation and Distribution ......................................................................................... 37 

6.4 Control of Environmental Documents.............................................................................. 38 

6.5 Reference Documents .................................................................................................... 39 

6.6 Master Documents ......................................................................................................... 39 

7 Competency Training and Awareness .................................................................................. 40 

7.1 Project Personnel ........................................................................................................... 40 

7.2 Subcontractors and Consultants ..................................................................................... 40 

7.3 Training .......................................................................................................................... 40 

7.4 Maintaining Qualifications/Skills and Records ................................................................. 40 

7.5 Commissioning Induction................................................................................................ 41 

7.5.1 Project Induction ................................................................................................... 41 

7.5.2 Commissioning Work Package Induction .............................................................. 41 

7.5.3 Visitor Induction .................................................................................................... 41 

8 Communications .................................................................................................................... 42 

8.1 AquaSure Communications ............................................................................................ 42 

8.2 Internal Communications ................................................................................................ 42 

8.3 Enquiries and Complaints Management.......................................................................... 42 

9 Incident and Emergency Preparedness and Response ....................................................... 43 

10 Checking ................................................................................................................................ 44 

10.1 Monitoring and Measurement ......................................................................................... 44 

10.1.1 Environmental Monitoring ..................................................................................... 44 

10.1.2 Environmental Inspections .................................................................................... 45 

10.2 Evaluation of Compliance ............................................................................................... 45 

10.3 Non-conformity, Corrective and Preventative Actions ...................................................... 45 

10.4 Control of Records ......................................................................................................... 46 

10.5 Audits ............................................................................................................................ 47 

10.5.1 AquaSure ............................................................................................................. 47 

10.5.2 TDJV .................................................................................................................... 47 

10.5.3 External ................................................................................................................ 47 

11 Review, Reporting and Improvement .................................................................................... 48 

11.1 Reporting Environmental Performance ........................................................................... 48 

11.2 Management Review ...................................................................................................... 48 

Attachment I.1: Environmental Risk Register .......................................................................... 49 

Attachment I.2: Commissioning Management Strategies: ...................................................... 50 

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Attachment I.3: Monitoring, Inspection, Reporting and Auditing Schedule ........................... 51 

Attachment I.4: Commissioning Monitoring Program, interfacing with the Baseline 

Marine Monitoring Program (BMMP) and Operational Marine Monitoring Program 

(OMMP) ......................................................................................................................... 52 

Attachment I.5: Monthly Environmental Checklist .................................................................. 53 

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Definitions and Acronyms 

AEMP Area Environmental Management Plan 

AQS AquaSure 


AquaSure The proponent for the Victorian Desalination Project, TDJV’s client 

Area 1 Marine intake and outlet structures 

Area 2 Desalination plant and facilities 

Area 3 / 4 Utilities comprising: 

• Transfer pipeline from the desalination plant to Melbourne’s water supply 

system at Pakenham 

• Power supply comprising high voltage alternating current (HVAC) underground 

cable network transmission and power supply from the desalination plant to 

Cranbourne. 

BMMP Baseline Marine Monitoring Program 

CCAP TDJV Commissioning and Commercial Acceptance Plan 

CER Commissioning Environmental Representative 

CESP Commissioning Environmental Sub-plan 

CIP AquaSure Community Involvement Plan 

Client Capital Projects Division of Department of Sustainability and Environment, 

AquaSure’s client 

Close-out When the balance of D&C activities, remaining after Commercial Acceptance, have 

been completed in accordance with the Project Deed 

Close-out works While construction will be largely complete, some construction items will require to 

be completed after the plant has started delivering desalinated water. These items 

are the close-out works 

Commercial 

acceptance 

The stage when most of the D&C activities are complete and the desalinated water 

supply system is able to be safely operated 

Commissioning Commissioning is the program of activities to test and run-in the plant so that it can 

become fully operational 

CMS Commissioning Management Strategy 

CWAP Commisioning Work Area Pack - used to collate the CWPs into individual 

commissioning systems. 

CWP Commissioning Work Pack – a discrete element of work used in the detailed 

planning, execution, verification and generation of Project records. 

Contractor The AquaSure appointed D&C Contractor (Thiess Degrémont Joint Venture) and 

the O&M Contractor (Degrémont Thiess Services Joint Venture) 

D&C Design and Construction 

D&C Contractor Thiess Degrémont Joint Venture 

D&C Management 

Team 

Project Director, Area Project Directors, Commercial Director, Design Director, 

Stakeholder and Completions Director, D&C Environmental Manager, Planning and 

Program Director, Human Resource Director, Construction Managers and their 

teams 

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DC-CIP Design and Construct Community Involvement Plan 

DCP Design and Construction Plan 

Defects liability 

period 


This is the period after the completion of the works during which the D&C 

Contractor is responsible for any defects. The period is specified in clause 24.6 of 

the Deed and is generally 24 months. 

DPCD Department of Planning and Community Development 

DSE Department of Sustainability and Environment 

DSEWPC Department of Sustainability, Environment, Water, Population and Communities 

DTS Distributed temperature sensing 

DTSJV The AquaSure appointed O&M Contractor, Degrémont Thiess Services Joint 

Venture 

DMPF Dual Media Pressure Filter 

DWSS Desalinated Water Supply System, including the marine intake/outlet facilities, the 

desalination plant and water transfer pipeline. 

EES Environment Effects Statement 

Electricity Supplier AGL 

EMP Environmental Management Plan. Refers to the D&C EMP and/or AEMP as 

relevant in the context of the document 

EMR Environmental Management Representative 

EMS Environmental Management System 

EPA Environment Protection Authority 

EPA Section 30A 

Commissioning 

Approval 

Means by which the EPA may authorise emergency storage, use, discharge etc. of 

waste under the Environment Protection Act 1970. In the case of VDP this relates 

to permitting commissioning activities and associated discharges to the outlet (i.e. 

prior to establishment of a licenced mixing zone) – refer to Section 30A(1)(a) and 

30A(1A)(c) of the EPA Act. 

EPBC Environment Protection and Biodiversity Conservation 

Gigalitres (GL) Billion litres 

HVAC High Voltage Alternating Current 

InCite A web-based document management system managed by Nexus Point Solutions 

adopted for use on the Project. 

ISO 14001 AS/NZS ISO 14001:2004 Environmental Management systems – Requirements 

with guidance for use 

JSEA Job Safety and Environmental Analysis 

MIRA Schedule Monitoring, Inspection, Reporting and Audit Schedule 

O&M Operations and Maintenance 

O&M Contractor Degrémont Thiess Services Joint Venture 

OMMP Operational Marine Monitoring Program 

PPEF Project Planning and Execution Framework - provides the structure, including a 

checklist for preparing Commissioning Work Packs (CWPs). 

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Potabilisation Close-Out – is broadly when the balance of D&C activities, remaining after 

Commercial Acceptance, have been completed in accordance with the Project 

Deed 

PR Performance Requirement 

Preliminary 

Commercial 

Acceptance (PCA) 

Process 

Commissioning 

When the Desalinated Water Supply System is able to be safely and legally 

operated to deliver at least 50 GL of desalinated water per year 

Commissioning of the water treatment process machinery and systems. Automatic 

running and optimisation (fine tuning) of all related systems during operation with 

design fluids and chemicals. 

Project Victorian Desalination Project 

Project Deed (the 

Deed) 

Contractual arrangement between the State and AquaSure Pty Ltd for the delivery 

of desalinated water from the Project to Victoria's water supply system 

PS&PR Project Scope and Performance Requirements set out in Annexure 3 to the Project 

Deed 

Reference 

document 

Reliability Test 

Finalisation 

Reverse Osmosis 

(RO) 

Reference Documents includes the documents referred to in Appendix S2 

(Reference Documents) to the PS&PR (Annexure 3 to the Project Deed) 

(RT Finalisation) – is broadly when all reliability testing of the Desalinated Water 

Supply System is completed in accordance with the Project Deed. 

Two stages of reverse osmosis, where seawater is pushed through ultra-fine 

membranes under high pressure. Fresh water will pass through, leaving sea water 

concentrate behind. 

SCADA Supervisory control and data acquisition 

Screen and Pump 

Station 

An initial screening that removes fine particles including sand and sediment 

SEP Site Environmental Plan 

SEWPAC Department of Sustainability, Environment, Water, Population and Communities 

*Formally DEWHA (Department of Environment, Water, Heritage and the Arts) 

State The Minister for Water of the State of Victoria for and on behalf of the Crown in the 

Right of the State of Victoria 

TDMS Thiess Degrémont Management System 

TDJV The AquaSure appointed D&C Contractor, Thiess Degrémont Joint Venture. 

VDP Victorian Desalination Project 

WAB Work Activity Briefing 

WMS Work Method Statement 

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1 Purpose and application 

1.1 Purpose 


The purpose of this Commissioning Environmental Sub-plan (CESP) is to achieve compliance with the 

environmental Performance Requirements (PRs) of the Victorian Desalination Project (the Project) and with 

other applicable environmental legislation for the commissioning phase of the Project. The CESP defines 

what is included within the commissioning phase of the Project and establishes the environmental 

management controls to be implemented, including contingency measures. 

This CESP describes Thiess Degrémont Joint Venture’s (TDJV) system for minimising and managing 

environmental risks associated with Project commissioning activities. The CESP has been prepared in 

accordance with AquaSure’s Environmental Management System (EMS) Manual, the TDJV Environmental 

Management Plan (EMP) and with reference to AS/NZS ISO 14001:2004. The key purposes of the CESP 

are to: 

• comply with the contractual Project Deed including the Project Scope and Project Requirements 

(PS&PR) for the identified commissioning activities 

• implement the AquaSure, Thiess and Degrémont environmental policies 

• deliver the prescribed environmental outcomes for relevant commissioning activities 

• supplement the system for legislative and contractual compliance 

• establish mitigation and management measures to achieve the environmental requirements of the 

Project during the commissioning phase. This involves the risks the Project poses to the 

environment specifically during the commissioning activities associated with the Project. 

• Incorporate Project commissioning processes to minimise the potential impacts of the Project 

commissioning activities to the environment and community 

• effectively manage potential impacts to the environment and community during the commissioning 

of the Project through Commissioning Work Packs (CWPs) 

• develop, implement and monitor management measures 

• establish the environmental commissioning management requirements for subsidiary 

environmental management documentation. 

This CESP identifies and addresses: 

• the environmental risks associated with commissioning 

• how the Project will meet the PRs as set out in 

• the D&C EMP 

• the requirements of Appendix S8 Commissioning Tests to Annexure 3 PS&PR of the 

Project Deed for commissioning to comply with the Environmental Requirements. 

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1.2 Application 


This CESP is Attachment I of the TDJV D&C EMP (TDV-0-EV-PL-0010-05) and applies to TDJV, its 

consultants and subcontractors in the commissioning of the Project. All personnel must comply with the 

requirements of this CESP. 

Commissioning is the program of activities to test and run-in the plant so that it can become fully 

operational. For the purposes of the CESP this consists of all commissioning activities from the initial 

intake of seawater through to RT Finalisation. It does not include any Cleaning and Construction 

Verification activities, as these are addressed through the Design and Construction Area Environmental 

Management Plan (D&C EMP), and the Plant and General Area (P&GA) and Utilities EMPs. The 

commissioning of the underground high voltage power supply is not included within this CESP, as this is 

addressed in the Utilities D&C EMP. The broader commissioning of the Project is described in more detail 

in Section 1.2.1. 

All commissioning activities will be supported by documentation and all data will be recorded for training 

and documentation to transfer to the O&M Team. All required documentation related to commissioning can 

be found in the relevant Commissioning Work Pack (CWP – described in more detail in Section 4.6.2). 

This includes but is not limited to: 

• Manufacturer and Supplier O&M manuals and QA/QC reports 

• Discipline Inspection and Test Reports (ITR) 

• Factory Acceptance Test (FAT) reports 

• Drawings and Functional Descriptions 

1.2.1 Commissioning Stages 

The commissioning processes, including cleaning and construction verification activities, typically includes 

the three following stages (applicable to all areas of the Project), generally in order: 

1) Pre-Commissioning Dry: 

• Design and construction inspections against specifications and drawings. 

• Media and element loadings (if applicable) 

• Testing and adjusting individual pieces of equipment and instrumentation and their 

• interface with the SCADA System 

2) Pre-Commissioning Wet: 

• Pipes, tanks and vessels flushing. 

• Manual start-up and testing of each component and individual sub-system with fluid. 

3) Process Commissioning: 

• Automatic running and optimisation (fine tuning) of all related systems during operation 

• with design fluids and chemicals. 

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NOTE: This CESP addresses all Process Commissioning activities which commence following the 

initial intake of seawater and continue through to RT Finalisation. The Pre-Commissioning stages 

(wet and dry) are addressed through the D&C EMP, the D&C P&GA EMP and the D&C Utilities EMP. 

1.3 References 

The following documents have informed the development of this CESP: 

• Project Deed between AquaSure and the State 

• D&C Contract between AquaSure and TDJV 

• AquaSure EMS Manual 

• TDJV D&C EMP 

• TDJV Commissioning and Commercial Acceptance Plan 

• Environmental management requirements of Thiess and Degrémont 

• Department of Sustainability and Environment 2008. Victorian Desalination Project – Environment 

Effects Statement (including EPA Works Approval Application) 

• Mitchell K et al. 4 December 2008. Report of the Inquiry to the Minister for Planning - Victorian 

• Minister for Planning. January 2009. Victorian Desalination Project – Assessment under 

• Environment Effects Act 1978 

• AS/NZS ISO 14001:2004. Environmental Management Systems – Requirements with guidance for 

use. 

• 30A Commissioning Approval Application. 

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2 Project Overview 

2.1 VDP Project Scope 


The VDP will be capable of supplying up to 150 gigalitres (GL) of water a year - a third of Melbourne's 

annual water needs - with capability to expand to 200 GL a year in the future. As part of the D&C scope, 

TDJV is delivering the commissioning phase of the Project. 

The processing plant of the Project is located near Wonthaggi in the Bass Coast region south east of 

Melbourne. The Project involves the components shown in Table 2-1. 

Table 2-1: Project components and delivery 

Area Key Components 

Area 1 - Marine intake and outlet structures 

(Excludes land-based construction activities 

associated with the tunnels and marine structures) 

Area 2 - Desalination plant and facilities (Includes 

land-based construction activities associated with 

the tunnels and marine structures. Includes the 

general shared land-based facilities for the plant 

and marine structures construction) 

Area 3/4 - Utilities comprising: 

• Transfer pipeline from the desalination plant to 

Melbourne’s water supply system at Pakenham 

• Power supply comprising high voltage 

alternating current (HVAC) underground cable 

network transmission and power supply from 

the desalination plant to Cranbourne 

• Ancillary fibre-optic cable 

Marine intake and outlet structures (risers and 

precast structures) 

• Box cut for tunnel boring machines (TBMs) 

• Lined intake and outlet tunnels 

• Seawater intake pumps and screens 

• Pre-treatment plant and buildings 

• Reverse osmosis plant and buildings 

• Treated water storage 

• Electrical substation 

• Ancillary buildings e.g. chemicals storage 

• Landscaping and rehabilitation 

• 84 km pipeline to link to Melbourne Water’s 

Cardinia-Percedale main in Berwick 

• Booster pump station approximately 74.5km 

north of the desalination plant near the 

intersection of Pound Road and McCormacks 

Road 

• 87 km HVAC underground cable to Cranbourne 

Terminal Station (same corridor as the transfer 

pipeline, except for the final 8km at the 

Cranbourne end) 

• Intermediate stations at the Booster Pump 

Station and a mid-point site at or near the 

intersection of Rayner Hoff Drive and the Bass 

Highway 

• Fibre-optic cable in separate trench along 

pipeline alignment 

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Figure 1 shows the regional context of the components of the Project. 

Figure 1 - Regional View of VDP 


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2.1.1 Area 1 - Marine Intake and Outlet Structures 


The desalination plant requires that structures are constructed in the ocean to deliver seawater to the plant 

and return the concentrated saline brine stream to the ocean. Refer to Figure 2 for approximate location of 

the intake and outlet structures. The activities managed by this area exclude land-based construction 

activities associated with the tunnels and marine structures. It includes the land-based logistics to support 

the marine construction activities. 

2.1.2 Area 2, 3 and 4 - Desalination Plant and Facilities 

The general location of the desalination plant in proximity to the Powlett River and foreshore is shown in 

Figure 2. The desalination plant will draw saline water from Bass Strait and treat it to potable standards 

using reverse osmosis (RO) technology. The plant has a 200 Gigalitres (GL) per year ultimate capacity to 

meet the State’s water supply targets but the plant itself is only being constructed to 150 GL per year 

capacity. Figure 2 shows the alignment of the utilities. 

Figure 2 - General Location of Victorian Desalination Plant and Marine Structures 

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2.2 Environmental Objectives and Targets 

The overarching environmental objectives of the Project are to: 


• comply with the environmental standards established for the Project through design and 

appropriate risk management 

• optimise energy efficiency through project design and offset any impact through the purchase of 

renewable energy credits for 100% of the electricity used at the Desalination Plant and Transfer 

Pipeline 

• protect the beneficial uses of the coastal and marine environment. 

The PRs specified in the Project Scope and Performance Requirements (PS&PRs) have been set as more 

detailed Project objectives and targets for the Project, particularly Appendix S3 Environmental 

Requirements to Annexure 3 of the PS&PRs. 

3 Commissioning Overview 

3.1 Commissioning Scope 

• Commissioning is the program of activities to test and run-in the plant so that it can become 

operational. For the purposes of the CESP this consists of all commissioning activities from the 

initial intake of seawater through to RT Finalisation. This involves the sequential and cumulative 

commissioning of the following elements of the Desalinated Water Supply System (DWSS), as 

shown in Table 3-1. From Preliminary Commercial Acceptance (PCA), the Operations and 

Maintenance (O&M) EMP will be the controlling document with appropriate parts of the D&C EMP 

documentation (including the CESP) embedded within. A detailed table of the commissioning 

process and sequencing is included in Appendix A of the Section 30A Commissioning Approval 

Application (TDV-0-EV-PL-0500). 

Table 3-1: Commissioning Components 

Component Description Liquid Discharge Solid Waste 

Marine Tunnels 

and Sea Water Lift 

Pump Station 

Commissioning 

Pre-Treatment 

Commissioning 

Reverse Osmosis 

and Potabilisation 

Commissioning 

Intake and discharge of seawater 

through the Seawater Lift Pump 

Pre-treatment including filtration 

through the Screen and Pump 

Station, and Dual Media Pressure 

Filter 

The reverse osmosis desalination of 

water and the potabilisation of 

desalinated water and the use of 

the Plant Substation 

Sea water (possibly with 

neutralised chemicals if 

shock chlorination occurs at 

this stage). pH increase due 

to leaching from concrete. 

pH buffered, filtered sea 

water (including neutralised 

chemicals) 

pH buffered, filtered sea 

water (including neutralised 

chemicals) 

None 

Organic 

screen 

rejects 

Ferric sludge 

Lime sludge 

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Component Description Liquid Discharge Solid Waste 

Desalinated Water 

Production 

Commissioning 

(Overall Systems 

Commissioning) 

The production of desalinated 

water, and discharging of brine. 

This includes: 

• using the treated water 

storages, 

• transfer pump station 

• transfer pipeline 

Brine (including neutralised 

chemicals) 

Lime sludge 

Ferric 

Sludge 

Organic 

screen 

rejects 

For 150 GL/yr capacity, the process involves three parallel streams, each of 50GL capacity. One stream 

will be progressively commissioned to produce desalinated water, with the commissioning of the remaining 

streams occurring in parallel after successful completion of the commissioning of the first stream. The 

commissioning of the underground high voltage power supply is not included within this CESP, as this is 

addressed in the Utilities D&C EMP. Cleaning and Construction Verification activities are addressed 

through the D&C Area EMPs, as part of the construction activities. 

The requirements for the generation, handling and disposal of waste from commissioning are the subject of 

a separate authorisation from the EPA. This is outlined in Section 3.3 below. 

3.2 Commissioning Components 

The CESP consists of all commissioning activities from the initial intake of seawater through to Overall 

Systems Commissioning (see Figure 3). This involves the cumulative commissioning of the following 

components: 

• Marine Tunnels and Sea Water Lift Pump Station Commissioning 

• Pre-Treatment Commissioning 

• Reverse Osmosis and Potabilisation Commissioning 

• Overall Systems Commissioning 

The location of these components is shown in Figure 3. Stream 1 will be commissioned initially. Stream 2 

and Stream 3 will be commissioned subsequent to Overall Systems Commissioning. Each of the four 

commissioning components have their own Commissioning Management Strategy, included in Attachment 

I.2 to this CESP and described in more detail in Section 6.2.2 below. During the commissioning of Stream 

1, it is likely that the Commissioning Management Strategies will be operational sequentially and not 

concurrently. During the commissioning of Stream 2 and Stream 3, several Commissioning Management 

Strategies may be operational in parallel. Appendix I.2 provides detail on the triggering and close out of the 

Commissioning Management Strategies. 

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Stream 3 

Stream 2 

Stream 1 

3.3 Legal Obligations 

Stream 3 

Stream 2 

Stream 1 

Figure 3 – Commissioning Components 


Marine Tunnels and Sea Water Lift 

Pump Station 

Pre-treatment 

Reverse Osmosis and Potabalisation 

Overall Systems 

The Environmental Legislation Register (Attachment E of the D&C EMP) identifies all Commonwealth and 

State legislation relevant to the Project. 

The Project Deed sets out that Project works require a number of approvals, licences and permits to allow 

the works to be constructed, commissioned and put into operation. 

Additional EPA commissioning approvals will be required specifically for the commissioning of the Project 

and will be in the form of an EPA Section 30A Commissioning Approval under the Environment Protection 

Act 1970 (hereon referred to as EPA Commissioning Approval). 

EPA Commissioning Approvals will permit the EPA to authorize storage and discharge of waste to enable 

the commissioning of the Project. Applications for EPA Commissioning Approvals must be made to the 

EPA in writing and will be valid for a period of 120 days. 

The D&C Environmental Manager is responsible for managing the commissioning approvals process and 

ensuring all the required approvals from Statutory Authorities are obtained. 

Project personnel, in particular the senior management team, are responsible for liaising with the 

Stakeholder and Completions Director, Commissioning Director, Commissioning Environmental 

Representative, Environmental Manager and Area Environmental Managers in timely planning of activities 

that require approval prior to commencement. To ensure permits, licences and approvals are obtained 

through the most streamlined route, TDJV will engage with the relevant regulatory agencies prior to and 

throughout the relevant approvals process to gain an understanding of their requirements. 

TDJV will submit new or revised licences, permits or approvals to the AquaSure EMR, who in turn will 

forwarded these to the State. Issues relating to problems with compliance with statutory approvals will be 

notified promptly to AquaSure, in addition to the reporting requirements in Section 10.1 of the D&C EMP. 

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3.4 Environmental Context and Significant Environmental Aspects 

A detailed risk assessment of the four commissioning activities (i.e., Marine Tunnels and Sea Water Lift 

Pump Station, Pre-treatment, Reverse Osmosis and Potabilisation and Overall Systems) has been applied 

to this CESP. This is set out in Attachment I.1, along with risks associated with abnormal events or 

emergencies. The Commissioning Management Strategies for each component (see CESP Attachment I.2) 

describe the existing conditions, environmental risk and management controls for each environmental 

aspect. 

The commissioning risk assessment considers all relevant environmental aspects. Table 3-2 provides a 

summary of the significant environmental aspects related to the commissioning of the Project and the 

potential hazards and impacts. 

Overall 

Activity 

Marine 

Tunnels and 

Sea Water Lift 

Pump Station 

Commissioning 

Pre-Treatment 

Commissioning 

Table 3-2: Significant environmental aspects 

Significant Environmental Aspect Potential Hazards and Impacts 

Start up and commissioning of Sea 

Water Lift Pump and bypass water 

to outlet. 

Transport & unloading of pretreatment 

and sludge chemicals. 

(Ferric Sulphate, Sulphuric Acid, 

Coagulant Aid, Sodium Bisulphide, 

Sodium Hypochlorite). 

Use of pre-treatment and sludge 

chemicals. (Ferric Sulphate, 

Sulphuric Acid, Coagulant Aid, 

Sodium Bisulphide, Sodium 

Hypochlorite). 

Commissioning of the Sludge 

System. 

• Leaks from pumps impacting to marine flora 

and fauna 

• Increased turbidity due to material in the 

tunnels impacting marine flora and fauna 

• Underwater noise from pumps causing 

discomfort to recreational users / marine 

fauna 

• Chemical spills resulting in localised 

contamination of soils or groundwater/surface 

water systems affecting surface water and 

groundwater systems downstream of the 

plant site 

• Overdosing resulting in off-spec discharge 

and impact to marine flora and fauna 


and impact to marine flora and fauna. 

• Wetter sludge produced and disposal of 

waste to the incorrect offsite facility. 

• Generation of odour and impact on 

neighbourhood amenity. 

Disposal of sludge waste. • Inappropriate offsite management/disposal 

resulting in Impact to land or water at location 

of disposal; pollution; neighbourhood 

amenity. 

Commissioning of the DMPF 

system. 

• Overdosing resulting off-spec discharge and 

impacts to marine flora and fauna. 

• Failure of inline monitoring system resulting 

in off-spec discharge and impacts to marine 

flora and fauna. 

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Overall 

Activity 

Reserve 

Osmosis and 

Potabilisation 

Commissioning 

Overall 

Systems 

Commissioning 



Potential injection of dilute sodium 

hypochlorite for biofilm control of 

SWLP, DMPF, Cartridge filter 

systems prior to feed to RO. 

Biofilm control of systems prior to 

feed to RO. 

Commissioning of RO Chemicals 

and potabilisation chemical 

systems, including sodium 

hypochlorite, sodium bisulphite, 

antiscalant, carbon dioxide, FSA, 

Lime. 

Flushing of RO piping from 

Cartridge Filter to RO 1st & 2nd 

Pass (Disposal of water to Outfall 

from RO Building Pipe Flushing). 

Commissioning of 1st & 2nd pass 

RO system without retention of 

permeate. 

RO commissioning and 


Process Commissioning, without 

retention of permeate. 


Retention of permeate and 

discharge of brine. 

Commissioning of Stabilisation 

Pond. 

Commissioning of the VDP - 

multiple streams & retention of 

permeate. 

• Overdosing or poor neutralisation resulting in 

off-spec discharge and impact on marine 


• Overdosing or poor neutralisation resulting in 

off-spec discharge and impact on marine 


• Spills or leaks of chemicals resulting in 

contamination of soils and/or 

groundwater/surface water and associated 

ecosystems 

• Spills during truck loading/unloading resulting 

in contamination of soils and/or 

groundwater/surface water and associated 

ecosystems 


and impacts to marine flora and fauna 

• Construction debris remaining in tunnel 

causing discoluration and/or turbidty resulting 

in impacts to marine environment. 

• Overflowing of pits in RO building resulting in 

contamination of surface water runoff. 

• Overdosing of caustic soda to 2 nd pass feed 

resulting in off-spec discharge and impacts to 

marine flora and fauna. 

• Potential discharge of potabilisation 

chemicals resulting in off-spec discharge and 

impacts to marine flora and fauna. 

• Failure of inline monitoring system resulting 

in off-spec discharge and impacts to marine 


• Brine discharge causing impact to marine 

flora and fauna 

• Low flows resulting in poor dilution and 

impacts to marine flora and fauna 

• Discharge of insufficiently neutralised 

chemicals to the outlet resulting impacts to 

marine flora and fauna. 

• Brine discharge causing impact to marine 

flora and fauna 

Pipeline Commissioning. • Discharge of chlorinated and/or turbid water 

resulting in impact to Cardinia Reservoir 

• Leakages resulting in uncontrolled discharge 

and impact to surface water ecosystems 

// Page 19 

// TDV-0-EV-SB-0021.I-03

Overall 

Activity 



RO membranes 

Clean in Place (during operation, 

after approx 6-12 months from 

commissioning). 

• Disposal of neutralised effluent from Cleaning 

in Place / flushing of membranes resulting in 

impact to marine flora and fauna. 

Management and monitoring of the potential hazards and impacts listed in Table 3-2, together with those 

associated with other environmental issues/receptors is done so through a combination of the existing D&C 

Environmental Management Plan (and associated Area EMPs) and specific controls developed as part of 

this CESP. This relationship is outlined below in Table 3-3, grouped by environmental issue/receptor. 

Environmental 

issue/receptor 

Table 3-3: Management and Monitoring summary of environmental hazards and impacts 

M 

G 

M 

T 

M 

O 

N 

I 

T 

Existing EMPs CESP 

Reference Documents 

Archaeology � � Continue to be managed and 

monitored through the D&C PGA 

EMP and its associated 

Archaeological and Cultural Heritage 

Sub Plan (Attachment I1). 

Hazardous materials � � Storage and handling of hazardous 

materials is managed and monitored 

through the D&C PGA EMP and its 

associated Hazardous Materials Sub 

Plan (Attachment I2). 

Newly created habitat 

(site rehabilitation) 

� � Managed and monitored through the 

D&C Utilities and PGA EMPs. 

Air quality � � Conformance with the State 

Environment Protection Policy (Air 

Quality) is managed and monitored 

through the D&C PGA EMP and its 

associated Air Quality Sub Plan 

(Attachment I4). 

Flora and fauna � � Management and monitoring of 

terrestrial flora and fauna is 

addressed through the D&C PGA 

EMP and its associated Flora and 

Fauna Sub Plan (Attachment I5). 

Resource efficiency � � Managed and monitored through the 

Resource Efficiency Sub Plans of the 

Area EMPs. 

Soil management � � Managed and monitored through the 

D&C PGA EMP. 

M 

G 

M 

T 

M 

O 

N 

I 

T 


� � Management and monitoring of 

hazardous materials is 

addressed in this CESP. 

� � Monitoring and assessment 

managed and monitored through 

this CESP and associated 

Commissioning Procedure for 

Odour Assessment (COMM-52). 

� � The impact on aquatic flora and 

fauna due to the discharge of 

off-specification water is 


this CESP. 

� � Management and monitoring of 

energy, water and wastes 

directly associated with 

commissioning is addressed 

through this CESP. 

// Page 20 

// TDV-0-EV-SB-0021.I-03

Environmental 

issue/receptor 

M 

G 

M 

T 

M 

O 

N 

I 

T 


Existing EMPs CESP 


Noise � � Conformance with constructionrelated 

noise requirements is 

managed and monitored through the 

D&C PGA EMP and its associated 

Noise and Vibration Sub Plan 


Water quality and 

erosion management 

Waterways and 

wetlands 

� � Freshwater quality and erosion 

management and monitoring is 

addressed through the D&C PGA 

EMP and its associated Water 

Quality and Erosion Management 

Sub Plan (Attachment I9). 



Waterways and Wetlands Sub Plan 


Acid sulfate soils � � Managed and monitored through the 


Acid Sulphate Soils Sub Plan 


Marine flora and 

fauna 

Coastal processes 

and activities 

Marine pest and 

pathogen 

Underwater noise 

Sub-plan 


D&C Marine Area EMP, its 

associated Marine Flora and Fauna 

Sub Plan (Attachment I4) and the 

BMMP. 



associated Coastal Processes and 

Activities Sub Plan (Attachment I1) 

and the BMMP. 



associated Marine Pest and 

Pathogen Management Sub Plan 

(Attachment I6) and the BMMP. 



associated Underwater Noise Sub 

Plan (Attachment I7) 

M 

G 

M 

T 

M 

O 

N 

I 

T 


� � Any additional noise 

management and monitoring 

requirements during 

commissioning are addressed 

through this CESP and 

associated Environmental Noise 

Assessment (COMM-51). 

� � Marine water quality and surface 

water quality related specifically 

to commissioning is managed 

and monitored through this 

CESP. 

� � The impact on waterways and 

wetlands due to the venting of 

water from the pipeline is 


this CESP. 

� � Managed and monitored through 

the Environmental Monitoring 

and Control procedure. 

Discharge will be monitored and 

responded to through this 

CESP, the BMMP and 30A 

Comissioning Approval. 


BMMP. 


the BMMP. 

� � Managed through the CESP and 

associated Environmental Noise 

Assessment (COMM-51). 

// Page 21 

// TDV-0-EV-SB-0021.I-03


// Page 22 

// TDV-0-EV-SB-0021.I-03

4 Commissioning Delivery Approach 

4.1 Project Delivery Mode and Contractual Requirements 


The State has contracted AquaSure to deliver the Project. As such, from 1 September 2009, the official 

status of Project proponent has been transferred from the State to AquaSure. The environmental 

requirements are set out in the Project Deed between AquaSure and the State. Clause 58.3 of the Project 

Deed permits AquaSure to subcontract its obligations to the D&C Contractor. 

AquaSure has contracted TDJV to design, construct and commission the Project as its D&C Contractor. 

The relevant environmental requirements in the Project Deed have been transferred to TDJV via the D&C 

Contract between AquaSure and TDJV, although it should be noted that AquaSure is still required to meet 

all legislative requirements and has an obligation to ensure appropriate environmental management is 

implemented. 

TDJV has contractual responsibilities and obligations with a number of organisations to facilitate delivery of 

the Project. 

4.2 Project Phases 

The D&C component of the Project has the following phases: 

• Design and pre-construction 

• Construction 

• Commissioning 

• Close-out 

• Defects liability 

Key features implemented during the Design and pre-construction, and Construction phases of the D&C 

component include, but are not limited to: 

• Bunding of chemical storage areas 

• Construction testing and verification 

• Pre-Commissioning cleaning, verification and calibration. 

TDJV’s approach to environmental management during the Commissioning Phase is set out below: 

• The Commissioning and Commercial Acceptance Plan has been developed which establishes a 

high level framework for environmental management during commissioning activities. 

• Environmental risks associated with commissioning equipment failure and design and construction 

errors are identified and managed. 

• Specific environmental risks associated with commissioning are identified and addressed. 

• Changeover of environmental roles, responsibilities and accountabilities from the D&C Contractor 

to the O&M Contractor is managed effectively. 

// Page 23 

// TDV-0-EV-SB-0021.I-03


In addition to the D&C EMP and this CESP, the following TDJV management plans are relevant: 

• Commissioning and Commercial Acceptance Plan 

• Overall Commissioning Sub-Plan 

4.3 Commissioning Phasing and Handover to O&M Phase 

The phasing of the CESP in relation to the D&C and O&M phases of the Project is shown in Figure 4. The 

O&M Phase commences at Preliminary Commercial Acceptance (PCA) and overlaps with the D&C Phase 

until the D&C Phase concludes at RT Finalisation. 

Following PCA, the O&M EMP will be the controlling document and any outstanding D&C EMP 

requirements will be transferred to the O&M EMP including this CESP. The D&C Project Phase continues 

after the O&M EMP has been initiated at PCA and will comprise relevant D&C Activities including 

commissioning. 

// Page 24 

// TDV-0-EV-SB-0021.I-03

D&C Project Phase 

Design and 

Construction 

Works 

Completion 

D&C Environmental Management Plan 

Area Environmental Management Plans 

Commissioning 

Tests 

Preliminary 

Commercial 

Acceptance 

Environmental Management System 

D&C Commissioning 

Environmental Subplan 

Performance 

Tests 

Commercial 

Acceptance 

Performance 

Test Reports 

Submission 

and Approval 

Production Test 


O&M Environmental Management Plan 

Area Environmental Management Plans 

O&M Commissioning Environmental 

Subplan 

Figure 4 - Project Phase Environmental Management 


Reliability 

Test Reports 

Submission 

and Approval 


Finalisation 

O & M Project Phase 

// Page 25 

// TDV-0-EV-SB-0021.I-03

4.4 Project Management Documentation 

MANAGEMENT PLAN STRUCTURE 

RO PLANT 

IMPLEMENTATION 

PLANS 

TUNNEL 


PLANS 

D&C MANAGEMENT PLAN 

TRAFFIC MANAGEMENT 

MARINE 


PLANS 


The relationship between the D&C Project Management Plan, the D&C EMP and the other Project plans is 

shown in Figure 5. This CESP is a Sub-plan to the D&C EMP. 

PEOPLE & SAFETY 

APPROVALS 

ENGINEERING 

PROJECT CONTROLS 

STRATEGY & SUPPORT 

COMMERCIAL & 

FINANCE 

• IR STRATEGY 

• PEOPLE MANAGEMENT 

PLAN 

• OH&S MANAGEMENT 

PLAN 

• ENVIRONMENTAL 

MANAGEMENT PLAN 

• COMMUNITY 

INVOLVEMENT PLAN 

• CRISIS MANAGEMENT 

PLAN 

• DESIGN PLAN 

• PROJECT CONTROLS 

PLAN 

• PROJECT PLANNING & 

SCHEDULING PLAN 

• DOCUMENT & RECORDS 


• QUALITY PLAN 

• PROCUREMENT 


• COMMISSIONING & 

COMMERCIAL ACCEPT. 


• COMPLETION PLAN 

• COMMERCIAL & FINANCE 


• RISK MANAGEMENT 

PLAN 

• ICT MANAGEMENT PLAN 

WONTHAGGI AREA 

CONSTRUCTION MANAGEMENT 

PLAN 

4.5 Commissioning Documentation 

AQUASURE PROJECT 


21 JUNE 2010 

TD 

PIPELINE 


PLANS 

AQUASURE 

PIPELINE & POWER 

CONSTRUCTION MANAGEMENT 

PLAN 

POWER 


PLANS 

Figure 5 - Project management plan structure 

The Commissioning and Commercial Acceptance Plan (CCAP): 

• Details all contractual requirements and obligations with respect to Commissioning and 

Commercial Acceptance 

DTS 

TDJV STEERING COMMITTEE 

O&M MANAGEMENT PLAN 

O&M 

• COMMUNITY 

INVOLVEMENT PLAN 

• WATER QUALITY RISK 


• INCIDENT 


• HANDOVER PLAN 

• KPI PERFORMANCE 

MONITORING PLAN 

• CRITICAL 

INFRASTRUCTURE 

PROTECTION PLAN 

• PROTECTION ENVIRONMENTAL PLAN 


• Provides the management plan structure within which all requirements and obligations will be 

satisfied 

• Assigns responsibility for each requirement and obligation. 

The CCAP identifies environmental requirements including to: 

• Update the D&C EMP for commissioning, including developing a Commissioning Environmental 

Sub-plan; 

• Obtain approvals to manage waste streams during commissioning 

// Page 26 

// TDV-0-EV-SB-0021.I-03

• develop an O&M EMP 


• obtain approvals and licences to manage waste streams during the O&M Phase 

Commissioning Envionmental Monitoring and control Procedure (CEMCP): 

• Documents below the level of the EMP Sub Plans, such as Work Packs, Work Area Packs, 

Temporary Work Packages and Environmental Procedures, are used to inform Sub Plans and 

Environmental controls, and undergo the review process outlined in the D&C EMP. 

• For Commissioning works environmental controls are incorporated into the CEMCP. 

• The CEMCP is reviewed by the AquaSure EMR and Approved by the TDJV Environmental 

Manager. 

4.6 Operational Management Control 

The operational management controls addressed in this section are: 

• Commissioning Work Area Packs (CWAPs) 

• Commissioning Work Packs (CWPs) 

• Work Method Statements and Procedures 

• Job Safety Environmental Analysis (JSEA) 

• Inspection Test Plans (ITPs) 

4.6.1 Commissioning Work Area Packs 

Commissioning Work Area Packs (CWAPs) are used to collate the CWPs into individual commissioning 

systems. The CWAPs provide a commissioning system area overview for each of the main system phases 

of commissioning i.e. Seawater Lift Pump commissioning, DMPF Commissioning, RO Commissioning etc. 

The CWAPs: 

• Provide an area overview of subsystem for commissioning 

• Provide an overall environment impact assessment and risk mitigation 

• Provide the risk control measures and / or feed into respective commissioning procedures to 

ensure risk is controlled 

• Provide overall monitoring of environmental compliance 

• Provide overall reporting of monitoring variables 

// Page 27 

// TDV-0-EV-SB-0021.I-03

4.6.2 Commissioning Work Packs 


The Project Planning and Execution Framework (PPEF) provides the structure, including a checklist for 

preparing Commissioning Work Packs (CWPs). The CWPs create manageable scopes of work and 

generate the Project records required for Commissioning and to assure AquaSure, the IR&EA and the 

State that TDJV has met its obligations under the D&C Contract. 

A CWP is comprised of a number of components, including: 

• Work method statement & Procedures 

• Job safety environmental analysis 

The CWPs are used to collate the various work process documents which define the sequential method of 

production or control and detail the criteria for management of risk (including environmental risks), 

constructability and workmanship, equipment to be used, verification activities and related 

authorities/responsibilities. The CWPs include consideration of the relevant environmental risks, including 

links to the CESP, as well as additional controls in the Work Method Statements and Procedures as 

required. 

Typically a number of CWPs will be allocated to various Project engineers who will be expected, with their 

manager’s guidance, to plan, organise, monitor and cost forecast the activities with an assigned supervisor, 

both being co-located in the same office. Where the works are executed under a subcontract, the 

subcontract will include requirements to create and maintain CWPs and hand over completed records. 

A register of CWPs is maintained in accordance with the Documents and Records Management Plan. 

CWPs that are relevant to this CESP are shown in Table 4-1 below. 

CWP 

Number 

CWP Title 

Table 4-1: Commissioning Work Packs Relevant to CESP 

CWP 

Number 

CWP Title 

COMM 001 Seawater Lift Pump Station COMM 024 Antiscalant 

COMM 002 Drum Screens COMM 025 Caustic Soda 

COMM 003 DMPF feed pumps COMM 026 Carbon Dioxide 

COMM 004 DMPF Stream 1 COMM 028 Centrifuges Feed Polymer 

COMM 005 DMPF Stream 2 COMM 030 Fluorosilicic Acid 

COMM 006 DMPF Stream 3 COMM 031 RO CIP Chemicals 

COMM 010 Reverse Osmosis Stream 1 COMM 035 Sludge Treatment 

COMM 011 Reverse Osmosis Stream 2 COMM 037 2nd Pass Permeate Service Water 

COMM 012 Reverse Osmosis Stream 3 COMM 038 Potable Water 

COMM 013 1st Pass Permeate Service Water COMM 039 Chemical Sumps 

COMM 014 Lime Preparation & Dosing COMM 042 Transfer Pump Station 

COMM 015 Membrane Testing Skids COMM 043 

Transfer Pipeline - One Way Tank 

KP10.3 

// Page 28 

// TDV-0-EV-SB-0021.I-03

CWP 

Number 

CWP Title 

CWP 

Number 

COMM 016 Treated Water Tanks COMM 044 

COMM 017 

COMM 018 

Sodium Hypochlorite - Pre- 

Treatment 

Sodium Hypochlorite - 



CWP Title 

Transfer Pipeline - One Way Tank 

KP29.1 

COMM 045 Transfer Pipeline - PRVs at CP1 

COMM 046 Transfer Pipeline - Delivery Points 

COMM 019 Sulphuric Acid COMM 047 Booster Pump Station 

COMM 020 

Ferric Sulphate - Sludge 

Treatment 

COMM 051 Noise Validation 

COMM 021 Ferric Sulphate - Pre-Treatment COMM 052 Odour Validation 

COMM 022 Coagulant Aid - Pre-Treatment COMM 053 Diffuser Validation 

COMM 023 Sodium Bisulphite 

4.6.3 Work Method Statements & Procedures 

TDV-2-EV- 

PRD-0006 

Environmental Monitoring Procedure 

A work method statement (WMS) is a high level, activity-specific risk assessment and step by step planning 

tool contained within each CWP. A WMS details the steps involved in a particular commissioning activity 

along with their respective risk control measures. The WMS will identify key environmental risks for 

commissioning activities and ensure appropriate controls and mitigation measures – taken from the CESP - 

are implemented to ensure that Project objectives, targets and obligations are achieved. Procedures are a 

more detailed task specific work instruction that is contained within each CWP and used to control specific 

activities. Environmental controls are incorporated into specific procedures as part of the CWP 

development as outlined by the Project Planning and Execution Framework (PPEF). 

Commissioning work method statements and procedures (where applicable) will be prepared for all 

commissioning activities. They are prepared by the Site Engineer in conjunction with the Site Supervisor, 

Foreman and environment team. WMS’s require Comissioning Completion Manager (or delegate) review 

for extreme and high-risk (pre-control) Environmental aspects as per the Risk Register prior to works 

commencing. It is the responsibility of the Environmental Manager (or delegate) to review proposed 

mitigation measures to reduce the extreme and high risks to an acceptable level. 

WMSs and procedures will reference relevant controls from the CESP or incorporate additional activity 

specific controls. 

4.6.4 Job Safety Environmental Analysis 

A Job Safety Environmental Analysis (JSEA) is a medium level, activity-specific risk assessment and 

planning tool which will be prepared by the Site Supervisor or Site Foreman with input from Engineers and 

the environment team. JSEAs will identify the specific environmental management measures – taken from 

the CESP, or developed and implemented for the specific commissioning activity being undertaken. 

JSEAs require Environmental Manager (or delegate) approval for extreme and high-risk (pre-control) 

aspects prior to commissioning works commencing. It is the responsibility of the Environmental Manager 

(or delegate) to review proposed mitigation measures in order to reduce extreme and high risks to an 

acceptable level. 

// Page 29 

// TDV-0-EV-SB-0021.I-03


JSEAs will be developed in accordance with the requirements set out in the Occupational Health and 

Safety Management Plan. 

4.6.5 Inspection Test Plans (ITPs) 

ITPs are an operational control which are specific for each Commissioning Work Pack. For further 

information on ITPs refer to specific CWPs. ITPs detail all activities that will be conducted when performing 

the commissioning activities for a System / Subsystem as described in the relevant commissioning 

procedure. The ITP will demonstrate that the commissioinig activity is performed as per the Procedure. The 

ITP is the document which highlights activities that would require either witness or hold points for internal or 

external parties. 

5 Commissioning Organisational Structure and Resourcing 

5.1 Leadership and Individual Responsibility 

Management at all levels and supervisory personnel will lead by example and set the highest standards for 

environmental management. 

Environmental responsibility, promotion of environmental awareness and the encouragement of ownership 

are key approaches for environmental management implementation of this Project. These approaches will 

bolster the prevention and, where required, the prompt correction of any nonconforming conditions or 

behaviours leading to continual improvement at every opportunity. 

The provision of competent and qualified environmental personnel throughout the duration of the Project 

including during commissioning is critical to ensure that the PRs are achieved. 

The TDJV Project Director has ultimate responsibility for ensuring that all the necessary activities are 

undertaken to comply with regulatory and contractual requirements and mitigate identified environmental 

risks through implementation of strategies and plans. 

The Stakeholder and Completions Director is responsible to ensure the commissioning team 

documentation, including environmental aspects, meets the requirements of the D&C contract. 

// Page 30 

// TDV-0-EV-SB-0021.I-03

5.2 Commissioning Organisational Structure 

The Commissioning Organisation Structure is shown in Figure 6. 

Commissioning Director 

Plant Commissioning 

Manager 

Area Lead 

Seawater Lift Pump and 

Marine Tunnels 

Commissioning 

Team 

Project Director 

Commissioning 

Completion 

Manager 

Area Lead 

Pre-treatment 

Commissioning 

Team 

Commissioning 

Environmental 

Representative 

Area Lead 

RO and potabilisation 

Commissioning 

Team 


Stakeholder and 

Completions Director 

TDJV Environment 

Manager 

Area Environment 

Managers 

Environment Team 

Figure 6 - Commissioning Orgnisation Structure 

Area Lead 

Overall Systems 

Commissioning 

Team 

Specialist 

Environmental 

Consultants and 

Subcontractors 

// Page 31 

// TDV-0-EV-SB-0021.I-03

5.3 TDJV Roles and Responsibilities 

TDJV roles and responsibilities are given below in Table 5-1. 

Title Role and Responsibility 

Table 5-1 Roles and Responsiblities 


Project Director • Establish, develop and lead the TDJV team to drive the performance of design, construction 

and commissioning to meet PRs, including environmental, and key stakeholder 

relationships. 

Stakeholder 

and 

Completions 

Director 

Commissioning 

Director 

Commissioning 

Manager 

Commissioning 

Completion 

Manager 

Commissioning 

Area Leads 

Commissioning 

Environmental 

Representative 

• Lead the environment team in the implementation of their environmental management plans 

and the Commissioning and Commercial Acceptance Plan. 

• Develop and sustain relationships with key external stakeholders to facilitate efficiencies in 

the various review and approval processes. 

• Lead the commissioning teams and drive the Project delivery performance to meet 

requirements. 

• Ensure effective integration and collaboration with other teams. 

• Ensure alignment and leadership of to optimise overall coordination and delivery outcomes 

on the Project. 

• Participate and lead development and implementation of work method statements, JSEA 

and related commissioning management tools to ensure environmental risks are correctly 

managed in accordance with best practices. 

• Assist the Environmental Manager perform their duties, including identifying, administering 

and supporting the obtaining of environmental and planning approvals required for the 

Project in accordance with legislative requirements. 

• Achieve and document commissioning completion for non process related activities in order 

to satisfy the requirements of the CCAP and the Commissioning Sub-Plan (including this 

Commissioning Environmental Sub-Plan). 

• Liaise with the environment team to identify the detailed requirements for Commissioning 

Completion. 

• Obtain all necessary third party approvals relevant to commissioning. 

• Help develop the relevant documents required to communicate these requirements to the 

relevant teams on the Project. 

• Manage all aspects of completions required for Commissioning that are not directly linked to 

process activities (3rd parties, construction handover of areas, environment). 

• Manage all Environmental aspects linked to Commissioning as defined in the CESP. 

• Implement the CESP. 

• Assist CER and AEM with implementation of the EIRP where Commissioning Incidents are 

involved. 

• Lead and participate in commissioning team to successfully commission a section of the 

plant in accordance with the plans and programme, including develop commissioning 

documentation, plans, procedures, ITP, Work Method Statements. 

• Participate and coordinate commissioning tasks. 

• Document commissioning results and reporting on commissioning activities and progress. 

• Identify, administer and support obtaining commissioning environmental and planning 

approvals required for the Project in accordance with legislative requirements and assist the 

Commissioning Director to: 

• Proactively and positively work with the regulators and authorities with regard to 

environmental standards compliance and impact targets. 

• Work with Commissioning Team and Environmental Manager to obtain approvals consistent 

// Page 32 

// TDV-0-EV-SB-0021.I-03


with Project delivery requirements. 

Environmental 

Manager 

Area 

Environmental 

Managers 

Environment 

Team 

Commissioning 

Team 

Specialist 

Environmental 

Consultants 

and 

Subcontractors 


• Coordinate the implementation of the CESP, including evaluation, reporting and auditing of 

compliance. 

• Coordinate the transition (along with the Environmental Manager and O&M Environmental 

Manager) from the CESP to the O&M EMP. 

• Create systems and manage all processes and resources to ensure best practice 

documentation. 

• Assist the Area Environmental Managers to respond to environmental incidents and review 

the EIRPs, procedures and tools following incidents, near-hits and complaints. 

• Identify, administer and support obtaining environmental and planning approvals required 

for the Project in accordance with legislative requirements and assist the Stakeholder and 

Completions Director to: 

• Proactively and positively work with the regulators and authorities with regard to 

environmental standards compliance and impact targets. 

• Work with design, construction and subcontractor teams to obtain approvals consistent with 

Project delivery requirements. 

• Coordinate the implementation of the D&C EMP, including evaluation and reporting of 

compliance. 

• Support the Stakeholder and Completions Director. 

• Work with the Commissioning Completions Manager and Commissioning Environmental 

Representative to ensure the CESP is maintained and implemented. 

• Monitor environmental compliance and coordinate with the Area Environmental Managers 

and Commissioning Environmental Representative. 

• Assist in the implementation of the CESP along with the Environmental Manager and 

Commissioning Environmental Representative. When required, they will assist the 

Commissioning Director to: 

• Assist the Commissioning Environmental Representative in managing the relationship 

between the Project, the regulators and authorities relating to environmental standards 

compliance and impact targets. 

• Lead the provision of advice to the Commissioning Environmental Representative in areas 

of environmental risk management and delivery. 

• Manage environmental incidents and review the EIRPs, procedures and tools following 

incidents, near-hits and complaints. 

• Conduct surveillance of works, confirming systems are being implemented, and stop work 

immediately if observed likely damage to environment. 

• Inform Project managers, engineers and site supervisors, the relevant TDJV Area 

Environmental Manager and the Comissioning Environmental Representative of corrective 

actions. 

• Support the CER. 

• Participate in development and implementation of work method statements, JSEA and 

related commissioning management tools to ensure environmental risks are correctly 

managed in accordance with best practices. 

• Inform Commissioning Manager and Commissioning Environmental Representative of any 

departures from procedure. 

• Marine biological monitoring. 

• Water quality monitoring program - sampling and analysis. 

• Air quality monitoring program. 

• Noise and vibration monitoring. 

// Page 33 

// TDV-0-EV-SB-0021.I-03


All Staff, 

employees and 

contractors 

• Others as required during the course of commissioning. 


• Comply with environmental procedures and risk mitigation measures. 

• Conduct regular environmental inspections in accordance with job responsibilities. 

• If a likelihood of damage occurring to the environment as a result of Project activities, notify 

their supervisor, and take appropriate corrective action including ceasing work activities, 

procedures or similar corrective actions. 

• Ensure communication external to the Project regarding incidents occurs through the 

designated channels. Share learning and contribute to Project’s knowledge. 

5.4 AquaSure Roles and Responsibilities 

The AquaSure EMS Manual describes the roles and responsibilities of AquaSure staff including the 

AquaSure Environmental Management Representative (EMR). 

5.5 Independent Reviewer and Environmental Auditor 

The Project Deed requires the engagement of the Independent Reviewer and Environmental Auditor 

(IR&EA). The IR&EA is a joint appointment of the State and AquaSure under Clause 8 of the Project Deed. 

The key function of the IR&EA with respect to environmental matters relevant to D&C was to verify that the 

design documentation for each design package complied with the requirements of the State Project 

Document. If the design package does comply, the IR&EA issues a certificate in the form set out in the 

Certificate Schedule. The Environmental Management Framework (EMS and subordinate EMPs) are State 

Project Documents and therefore the IR&EA is required to confirm that the EMS and EMP comply with the 

requirements of the Project Deed including the environmental performance requirements. As part of the 

audit and surveillance program, the IR&EA is also required to assess compliance of construction works 

with the D&C EMP. During commissioning, the IR&EA will undertake audits on commissioning activities, 

the EMS Manual, EMP documentation and the Environmental Requirements. The IR&EA will issue 

Environmental Audit Reports to the State and AquaSure. 

// Page 34 

// TDV-0-EV-SB-0021.I-03


6 Commissioning Environmental Management Documentation 

6.1 Overview 

The CESP relates to the D&C EMP as set out in below. Details on the attachments for this CESP and 

where to find them are set out in Table 6-1 and Section 6.2. 

Attachments 

Plant & 

General Area 

EMP 

Attachments 

and Sub- 

Plans 

Attachment I.1 

Risk Register 

D&C EMP 


Commissioning 

Management Strategies 


Monitoring, Inspection, 

Reporting and Auditing 


Commissioning 

Monitoring Program, 

interfacing with the 

BMMP and OMMP 


Monthly Environmental 

Checklist 

Marine EMP Utilities EMP 

Attachments 

and Sub- 

Plans 

Attachments 

and Sub- 

Plans 

D&C Commissioning 

Environmental Sub-Plan 

Attachment I.2.1 

Marine Tunnels and Sea Water Lift 

Pump Station Commissioning 

Management Strategy 


Pre-Treatment Commissioning 



Reverse Osmosis and Potabalisation 

Commissioning Management Strategy 


Overall Systems Commissioning 



Commissioning Control Measures 

Table 

BMMP 

OMMP 

Figure 7 - CESP Document Structure 

O&M EMP 

Attachments 

Environmental Noise Assessment 

(COMM 051). 

Commissioning Procedure for Odour 

Assessment 

(COMM 052). 

Tracer Testing (Difuser Validation) 

and Direct Toxicity Assessment 

(COMM 053). 

Commissioning Phase Sludge 

Sampling and Classification 

procedure 

(PR-TDV-EN-2-N-000-0001). 

Transfer Pipeline Hydrostatic Test 

and Commissioning Phase 

Environmental Discharge Procedure 

(PLV-3-EN-PR-0003-00). 

Commissioning 

Environmental Monitoring 

and Control Procedure 

(TDV-2-EV-PRD-0006-00) 

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Table 6-1: Register for Environmental Commissioning 


Item Where information can be found 

Compliance Ready Reference D&C EMP Attachment A 

List of technical reports and documents D&C EMP Attachment D 

Environmental Legislation Register D&C EMP Attachment E 

Environmental licences, permits and approvals register D&C EMP Attachment F 

Environmental Obligations Register D&C EMP Attachment G 

Environmental Training Matrix D&C EMP Attachment H 

Enquiries and Complaints Process D&C EMP Attachment J 

Commissioning Environmental Risk Register CESP Attachment I.1 

Commissioning Components CESP Section 3.2 and Attachment I.2 

Environmental Incident Response Plan 

Commissioning Monitoring, Inspection, Reporting and Auditing 

Schedule 

Commissioning Monitoring Program, interfacing with the 

Baseline Marine Monitoring Program (BMMP) 

D&C PGA EMP Attchment K; and 

D&C Utilities EMP Attachment K 

CESP Attachment I.3 

CESP Attachment I.4 

Commissioning Monthly Environmental Checklist CESP Attachment I.5 

6.2 Documentation 

The content of each attachment of the CESP is as follows: 

6.2.1 Attachment I.1 – Risk Register 

The purpose of the commissioning environmental risk assessment is to identify the environmental risks 

related to activities undertaken during the commissioning of the Project. 

The risk analysis methodology specified in the AquaSure EMS has been used to conduct the 

environmental risk assessment. The methodology applied is consistent with that described in the D&C Risk 

Management Plan with the following variation. The environmental risk consequence level definitions on the 

final page of the environmental risk analysis contain more detail than the D&C Risk Management Plan to 

enable appropriate classification of environmental risks. 

Risks are classified as ‘extreme’, ‘high’, ‘medium’ or ‘low’ in the Environmental Risk Register and require 

documented controls. The Risk Register also captures residual risks. These will be implemented through 

Commissioning Management Strategies (Attachment I.2) and Work Area Packages (Section 4.5.1). 

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6.2.2 Attachment I.2 – Commissioning Management Strategies 


For the purpose of this CESP, commissioning involves the sequential and cumulative commissioning of 

several elements of the Desalinated Water Supply System, as set out in Figure 3 (Section 3.2 

Commissioning Components). A Commissioning Management Strategy for each of these elements is 

included within this Sub-plan. Each of these Commissioning Management Strategies is a procedural and 

practical document that clearly sets out the strategy for the commissioning of each component, including 

the environmental risks that are unique to the commissioning process and the measures to control these 

risks. Contingency risks and associated contingency control measures are also addressed within CESP 

Attachment I.2. The relevant contingency risks are similar to those outlined in the D&C PGA Risk Register, 

however contingency risks that are unique to Design and Construction are not covered within this CESP 

and will continue to be managed through the D&C EMP. 

6.2.3 Attachment I.3 – Monitoring, Inspection, Reporting and Auditing Schedule 

Environmental monitoring will be conducted in accordance with the Monitoring, Inspection, Reporting and 

Audit Schedule (MIRA Schedule). More information on monitoring and reporting is included in Section 10. 

6.2.4 Attachment I.4 – Commissioning Monitoring Program, interfacing with the Baseline 

Marine Monitoring Program (BMMP) 

The Commissioning Monitoring Program includes the following monitoring programs: 

• Baseline Marine Monitoring Program (BMMP) - This program comprises two components: 

• Coastal Processes Monitoring: impact monitoring commences at intake of seawater. 

Intake of seawater commences with the Marine Tunnels and Sea Water Lift Pump Station 

• Marine Ecosystems Monitoring: Impact monitoring commences with intake of seawater 

(inshore components) and discharge of brine (offshore components). Brine is first 

discharged during Overall Systems Commissioning. 

• Section 8 of the Section 30A Commissioning Approval Application which includes In-Plant Water 

Quality Monitoring and Diffuser Performance Monitoring. 

• Section 9 of the Section 30A Commissioning Approval Application which includes the following 

Tests and Assessments: Tracer Testing and Diffuser Validation, Direct Toxicity Assessment, 

Waste Characterisation, Odour Assessment and a site wide Noise Assessment. 

6.2.5 Attachment I.5 – Monthly Environmental Checklist 

Inspection requirements are set out in the MIRA Schedule (Attachment I.3). Any actions required, or 

measures determined not to be effective, will be identified on the Monthly Environmental Checklist, which 

facilitates the auditing process. 

6.3 Authorisation and Distribution 

Without limiting TDJV’s obligation to notify any proposed revisions or amendments to the D&C EMP and 

the Commissioning Sub-plan to AquaSure, the State and the IR&EA and TDJV overall responsibility for the 

D&C EMP, revisions or amendments to this CESP are subject to the authorisation process set out in the 

tables below. 

Table 6-2: CESP authorisation 

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Action Responsibility Initial 

Issue 

Consultation with relevant 

government agencies 

TDJV 


Major 

Revision 

Minor 

Revision 

� � X 

Consultation with AquaSure TDJV � � � 

Approval Commissioning Director, TDJV � � � 

Approval AquaSure EMR � � � 

Consent The State � � � 

Review and Assent Independent Reviewer and 

Environmental Auditor 

� � � 

Major revisions are required to be submitted to the Minister for Environment and Climate Change for 

approval and to the State for consent. Major revisions to this CESP and its attachments will occur where 

there is a significant change to environmental requirements, methodology and/or scope that change the 

approach to the works. 

Minor revisions are those that do not change the approach to the works or the environmental performance 

standards in the CESP or attachments and may include changes which: 

• Provide clarification or improvement to environmental management practices 

• Add / modify activities and associated controls such that there is no increase in level of 

environmental risks 

• Add new obligations and associated controls e.g. for a new environmental permit. 

All revisions to the CESP and/or attachments require State consent. Minor revisions will be undertaken as 

per the following protocol: 

Minor revisions protocol to CESP documentation 

• Proposed minor changes will be tabulated by TDJV in a Changes Register and tabled at the 

Environment Working Group (EWG) meeting for review and consideration. The EWG comprises 

the State, IR&EA, TDJV and AquaSure. 

• If the IR&EA consider the changes to be minor, the State will confirm this with DSE Biodiversity 

and Ecosystem Services (DSE BES) and advise AquaSure of the DSE BES decision. 

• If the changes are confirmed to be minor, TDJV are to amend the documentation in accordance 

with the submitted Change Register and formally submit a complete revised version of the CESP 

via AquaSure to the State (cc IR&EA). 

• Upon State consent, new revisions will be uploaded to AquaSure’s web site and the Project’s 

document management system (INCITE). 

6.4 Control of Environmental Documents 

The Commissioning Environmental Representative will ensure that environmental documents and records 

nominated in the EMS Manual and specific to implementation of the CESP are maintained, archived and 

controlled. 

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CESP documentation will be controlled in accordance with the Documents and Records Management Plan. 

The Commissioning Environmental Representative and Area Environmental Managers, together with the 

document controllers, are responsible for ensuring that all controlled documents are: 

• Developed, reviewed and approved prior to issue 

• Issued for use 

• Controlled 

• Stored 

• Removed from use when superseded or obsolete. 

The minimum retention periods for all documents is as nominated in the AquaSure EMS Manual. 

The Commissioning Environmental Representative is responsible for maintaining CESP documents as 

current at the point of use. 

6.5 Reference Documents 

This CESP has been developed to comply with the Reference Documents. These are set out in Appendix 

S2 to the PS&PR. More information on the Reference documents used in the preparation of this Sub-plan 

is included in Section 6.2 of the D&C EMP. 

6.6 Master Documents 

The master of the CESP and associated attachments are stored as an electronic PDF file attached to the 

record located within the Projects document management system (InCite) along with all related 

management plans and associated documentation. 

Where required, hard copies are to be derived from the signed electronic master and are deemed 

‘uncontrolled’. 

‘Masters’ that have been superseded are identified and located within the Controlled Documents File. 

Documents are controlled in accordance with the Document and Records Management Plan. 

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7 Competency Training and Awareness 

7.1 Project Personnel 


The People and Safety Director and Commissioning Director are to ensure that all commissioning 

personnel are suitably qualified or experienced to undertake their work, using the requirements of the 

Human Resources Management Plan. Commissioning personnel are selected on the basis of skills, 

experience and cultural fit. Where a training need is identified, arrangements will be made for the 

appropriate training and development in line with the individual’s needs. 

Where necessary, assistance will be provided until the required competency level has been attained. 

7.2 Subcontractors and Consultants 

The competency of subcontractors and consultants to perform their environmental responsibilities will be 

specified and assessed as part of the procurement process, in accordance with the Procurement 

Management Plan. 

Following appointment, where a subcontractor or consultant proves not competent to perform their 

environmental responsibilities, the contract manager is responsible for taking remedial action which 

includes: 

• Communication and an agreed action plan with the subcontractor or consultant 

• Training by TDJV of the relevant personnel 

• Additional support to the subcontractor or consultant 

• Taking remedies under the contract. 

7.3 Training 

Training for the Project commissioning is in accordance with the training procedures set out in Section 8.2 

of the D & C EMP. 

7.4 Maintaining Qualifications/Skills and Records 

Records and means to maintain competencies, skills and qualifications will be in accordance with the 

Human Resources Management Plan. 

The following details must be included in environmental training records: 

• Name of Project personnel attending the training 

• Type of training attended 

• Date of attendance 

• Name of trainer 

• Name of the organisation providing the training 

• Refresher training requirements. 

Copies of environmental training records will be maintained on the Project document management system. 

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7.5 Commissioning Induction 

7.5.1 Project Induction 


All Project personnel, subcontractors, consultants and visitors will receive inductions into TDJV’s 

environmental obligations prior to commencing on site. All environmental inductions will be conducted as 

part of the Project induction. The Project induction courses will be reviewed on a six monthly basis or in the 

event of a substantial change in environmental procedure, to ensure it reflects current working practice. All 

Project and area environmental induction materials will be submitted to the AquaSure EMR for approval. 

Records will be maintained of all inductions conducted, including: 

• Names and signatures of personnel attending 

• Date of attendance 

• Name of trainer/facilitator. 

7.5.2 Commissioning Work Package Induction 

The environmental requirements of WMSs and JSEAs will be communicated to relevant Project and 

subcontractor personnel via a pre-start meeting or work activity briefing (WAB), prior to that person 

commencing work in accordance with the process procedure. Environmental matters are also 

communicated through Desal Daily and toolbox talks. 

7.5.3 Visitor Induction 

All visitors going onto site must undergo a visitor’s induction. Consultants and subcontractors are 

responsible for the actions and conduct of their visitors and must ensure that all visitors obey the site 

environmental requirements. 

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8 Communications 

8.1 AquaSure Communications 


TDJV will participate, as requested, in the following meetings facilitated by AquaSure: 

• Fortnightly meeting with the AquaSure EMR 

• Fortnightly Environmental Working Group meetings with the key stakeholders including the State 

and AquaSure 

In addition, TDJV will attend: 

• Regular meetings of environmental agencies, convened by the State 

• Regular meetings with key stakeholders including DSE and EPA. 

8.2 Internal Communications 

A program of internal communication networks, interfaces and regular meetings has been established 

within the TDJV Project team as highlighted in the D&C Management Plan. The Stakeholder and 

Completions Director, Environmental Manager, or delegate, will participate in communications and 

interfaces where there are significant environmental issues during the commissioning process. The 

AquaSure EMR, in accordance with the AquaSure EMS, will also participate where necessary. 

Within the Project team, commissioning issues that may impact environmental considerations will be 

conducted, as a minimum, by the following methods: 

• InCite 

• Weekly Project meetings 

• Regular commissioning coordination meetings 

• Regular environmental communications, such as, toolbox talks, pre-starts, daily commissioning 

meetings, and work instructions. 

The Environmental Manager will convene regular meetings of the environmental team during the 

commissioning phase, including commissioning team members and the Area Environmental Managers. 

The purpose of these meetings will be to: 

• Review and set strategy for implementing CESP in an efficient and appropriate manner 

• Provide a consistent approach to environmental management across the Project 

• Facilitate two way feedback on issues and performance 

• Coordinate between construction and commissioning activities. 

8.3 Enquiries and Complaints Management 

Enquiries and complaints will be handled in accordance with Attachment K of the D&C EMP. 

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9 Incident and Emergency Preparedness and Response 

Environmental incidents and emergency preparedness and response will be managed according to the 

D&C PGA and D&C Utilities Environmental Incident Response Plans (EIRPs), based on the location where 

the incident took place being either on the Plant site or along the Utilities corridor respectively. The EIRPs 

integrate with the D&C Crisis Management Plan and as such covers environmental incidents only. The 

EIRPs will be reviewed and, where applicable, updated. The D&C Crisis Management Plan and D&C PGA 

and Utilities EIRPs provide a standard approach for the notification, recording, classification, investigation 

and reporting of all work related incidents, including those involving sub-contractors, other persons working 

on the TDJV site, ensuring safe and effective handling of incident situations. The EIRPs also provide 

contact details and specific time frames for relevant authorities that may need to be notified in the event of 

an environmental emergency. 

The objectives of the D&C PGA and Utilities EIRPs are to: 

• Define a procedure to manage environmental incident situations 

• To ensure that the impact of an incident on the environment, TDJV, AquaSure and all stakeholders 

is minimised 

• To ensure that the continuity of operations is maintained through implementation of effective 

environmental incident management procedures and response plans 

• To ensure that appropriate internal reporting procedures are in place that include prompt 

notification to AquaSure, the State, EPA, corporate management and other required agencies 

• To ensure that communications protocols result in a coordinated public response, including any 

public reporting obligations 

• To ensure that results of all incidents are assessed, reported and corrective actions implemented. 

As well as TDJV responsibilities, the EIRPs sets out the responsibilities of the AquaSure EMR to participate 

in managing, responding to and investigating incidents. 

The Commissioning and Completions Manager and Commissioning Environmental Representative 

(supported by the Area Environmental Managers as required) have key roles to play in managing 

commissioning environmental incidents and reviewing the EIRPs, procedures and tools following incidents, 

near-hits and complaints. 

The Commissioning Director through the Plant Commissioning Manager and the Area Environmental 

Manager will be responsible for ensuring that the environmental emergency procedures are practised on a 

regular basis during commissioning of the Project and is to provide the means for the Commissioning 

Manager to ensure that the project team is trained and equipped to deal with a range of situations, to 

include but not be limited to: 

• Fuel spills (terrestrial and marine) 

• Chemical spills (terrestrial and marine) 

• Ground contamination 

• Unplanned discharge of water to waterways/marine environment. 

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10 Checking 

10.1 Monitoring and Measurement 


Environmental monitoring will be conducted in accordance with the MIRA Schedule (Attachment I.3). The 

MIRA Schedule is a controlled document. Implementing the MIRA Schedule is the responsibility of the 

persons nominated in the Schedule. As required in Appendix S3 of the PS&PR, the MIRA Schedule has 

been developed in discussion with relevant government agencies. 

Monitoring and measurement addresses: 

• Baseline Marine Monitoring Program (BMMP) 

• In-Plant Water Quality Monitoring 

• Diffuser Performance Monitoring (refer to the Section 30A Commissioning Approval Application) 

• Monitoring requirements to establish operational performance parameters including (refer to the 

Section 30A Commissioning Approval Application): 

• Tracer Test (Diffuser Validation) 

• Direct Toxicity Assessment 

• Waste Characterisation 

• Air quality (odour) 

• Noise 

• Commissioning environmental compliance requirements. 

A summary of the environmental components addressed within the MIRA schedule is shown in Table 3-3: 

Management and Monitoring summary of environmental hazards and impacts. 

10.1.1 Environmental Monitoring 

The monitoring program is a centralised schedule of monitoring actions for the Project commissioning 

based on obligations or controls nominated in Attachment I.3. Where required, specialist consultants will 

be engaged to help establish internal monitoring systems and to train relevant personnel in the collection of 

samples, use of scientific instrumentation and recording and analysis of data. 

Monitoring will be conducted in accordance with relevant standards and guidelines for environmental 

management identified in the EES, approvals and Reference Documents, such as Victorian Government 

requirements, Australian Standards or, in the absence of an Australian Standard, industry acceptable 

procedures. All analytical testing shall use National Association of Testing Authorities (NATA) approved 

procedures where applicable. 

Inspection, testing and calibration of monitoring equipment will be managed by TDJV in accordance with 

the Quality Plan. Specialist monitoring consultants will be responsible for maintaining their monitoring 

equipment in accordance with relevant standards. The minimum frequency and standard for monitoring is 

that listed in applicable approvals, licences, and regulations. Monitoring results will be reviewed on a 

regular basis (as soon as possible after results are received) depending on the data source to: 

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• Evaluate performance relative to predicted impacts of the Project commissioning 

• Evaluate performance and compliance with legal and other commitments 

• Assess progress against targets for the EMPs. 

Monitoring results exceeding the relevant standards/goals or performance criteria will be managed as per 

the contingency protocol set out in the MIRA Schedule (Attachment I.3). Any monitoring results that exceed 

the relevant performance criterion, as a result of the Project’s commissioning activities, will be managed in 

accordance with the Procedure for Non-conformances as described in the Quality Plan. Corrective action 

will be implemented, where needed, such as environmental Sub-plans or WMS modified, as appropriate 

and as soon as possible after results are received. 

AquaSure, the IR&EA and the State will be advised of any non-conformances from monitoring and the 

results will be reported in the Monthly Environmental Report. 

10.1.2 Environmental Inspections 

Regular inspections will be conducted. Inspection requirements are set out in the MIRA Schedule attached 

at Attachment I.3. Any actions required, or measures determined not to be effective, will be identified on the 

inspection checklist and closed out on the Monthly Environmental Checklist (Attachment I.5). 

10.2 Evaluation of Compliance 

The Monthly Environmental Checklist included in Attachment I.5 will be used in order to monitor 

compliance with commissioning environmental requirements. 

10.3 Non-conformity, Corrective and Preventative Actions 

A non-conformance is a failure to comply with environmental legislation or with the requirements of the 

EMS Manual and/or EMP, which in turn contain Appendix S3 Environmental Requirements including the 

PS&PRs. Non-conformances, will be managed in accordance with the Procedure for non-conformance as 

described in the Quality Management Plan. 

Non-conformances may be identified through a number of mechanisms including through IR&EA, EMR or 

internal TDJV audits and complaints. 

Once a non-conformance has been identified, corrective and/or preventive action will be initiated is 

accordance with the MIRA schedule (CESP Attachment I.3). Also, any environmental management 

improvement opportunities, identified as a result of incidents or emergencies, monitoring and 

measurement, audit findings or other reviews, will be documented. These may also lead to corrective or 

preventive actions. All employees have the authority to raise a non-conformance or preventative action 

should they occur. 

The tools and methods to be utilised for documenting, tracking, reporting and communicating nonconformances 

are described in Table 10-1. 

Table 10-1: Non-conformance Management Tool 

Type of activities raising non-conformances Appropriate management tool 

Inspection Inspection record 

Incidents, procedural breaches, and high potential 

near hits 

Incident report 

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Type of activities raising non-conformances Appropriate management tool 

Monitoring results Monitoring report 

External and internal audits Audit report 

Executive Management Team reviews Management review report 

Environment Team reviews, EMP reviews Meeting minutes 

Localised inspection observations (which are not 

incidents, procedural breaches, Near Hits) 

Complaints (not found to be incidents) Complaints Register 

Inspection Checklists tabled and reviewed at 

area-based HSE Progress meetings 

Records may be kept in the Thiess HSE Reporting System Action Database. This database collects 

environment, health and safety statistical and incident data for reporting and analysis purposes. The 

database allows personnel to track actions through to close out. 

All corrective actions from reviews, audits or incidents or new controls to be implemented shall be recorded 

in the Project HSE Reporting System Action Database to ensure all actions have been assigned to the 

responsible TDJV person(s) and actions have been tracked and closed out in the appropriate timeframe. 

Implementation of corrective actions or controls shall adhere to the following timeframes as per the Thiess 

HSE Reporting System Action Database: 

• Extreme Priority Actions completed immediately 

• High Priority Actions completed within 7 days 

• Normal Priority Actions completed within 7 – 14 days 

• Low Priority Actions completed within 14 – 21 days. 

Priorities for response shall be determined based on the risk to the environment. As guidance, an extreme 

priority action should be allocated to prevent immediate risk to the environment. Low priority actions should 

be allocated to prevent long-term recurrence of the inappropriate situation. 

The response to incidents will be managed in accordance with TDJV’s Crisis Management Plan and the 

Commissioning Environmental Incident Response Plan. 

The Commissioning Director, Commissioning Manager and Environmental Manager are accountable for 

tracking closure of environmental non-conformances, inspection checklists, monitoring reports and incident 

reports. Outstanding actions shall be reviewed weekly and reported monthly. 

Where appropriate, work on non-conforming activities on-site may be stopped by the Stakeholder and 

Completions Director, Environmental Manager, Commissiomning Environmental Representative, Area 

Environmental Managers, Environment Officers, Project Directors or their nominees. This stoppage will 

remain in force until corrective actions are implemented or authority is given to continue. Following a plant 

shutdown event an Environmental Restart Permit, signed by the CER (or delegate), is required prior to the 

recommencement of plant operation. 

10.4 Control of Records 

Records will be managed in accordance with the Documents and Records Management Plan as set out in 

Section 8.4 of the D&C EMP. 

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10.5 Audits 

10.5.1 AquaSure 

TDJV will facilitate audits by the AquaSure EMR. 


The Commissioning Director, Commissioning Manager, Environmental Manager or Area Environmental 

Managers will respond to audit reports of the CESP received from the AquaSure EMR within the time 

specified by the EMR. TDJV will formulate a plan of action to follow-up the findings and recommendations 

of the audit, including: 

• Describing the planned corrective action/s for each finding 

• Nominating a time frame to complete the corrective actions 

• Nominating the responsible persons to carry out the corrective actions.: 

• Implement remedial/corrective actions within the agreed timeframes 

• Notify the EMR of close-out 

• Provide evidence of completion where agreed. 

The AquaSure EMR will review the close out of the audit findings. 

10.5.2 TDJV 

Internal environmental audits will be conducted in accordance with the MIRA Schedule (Attachment I.3) 

and to the standards described in the ‘Environmental Audits’ procedure attached to the EMS Manual. 

If the AquaSure EMR conducts an audit on an EMS component, that is also scheduled to be audited by 

TDJV, the EMR’s audit may suffice as the TDJV audit, with the consent of the EMR. As a guide, the 

AquaSure EMR and Environmental Manager will (separately or together) undertake the following types of 

audits on a regular basis (minimum quarterly): 

• D&C EMP - the scope of the audit will assess the level of implementation of the D&C EMP and the 

CESP through document review and on-site assessment 

• High Risk Activities- the scope of these audits will include an audit focussing on high risk 

activities to ensure that environmental controls and procedures outlined in the D&C and AEMPs 

are being implemented 

Non-conformances will be recorded and managed as set out in Section 9. 

10.5.3 External 

The IR&EA or the State may audit any part of the Project or EMS Manual or other environmental 

documentation with reasonable notice for the purposes of confirming compliance with Project 

environmental PRs. 

TDJV will facilitate audits by other parties, including the IR&EA and the State as set out in Section 9.5.3 of 

the D&C EMP. 

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11 Review, Reporting and Improvement 

11.1 Reporting Environmental Performance 


Reporting will be conducted in accordance with the MIRA Schedule included at Attachment I.3. 

The Environmental Manager will provide a monthly report to the Stakeholder and Completions Director, 

based on the template provided at Attachment I.5. 

11.2 Management Review 

The CESP must be reviewed and updated if at any time it: 

• does not adequately address the matters it is intended to address 

• is causing non-conformity or is otherwise necessary to comply with the Project Deed 

• no longer represents current or appropriate practice 

• is otherwise required by the Project Deed to be updated. 

Management reviews will be conducted as set out in the D&C EMP Section 10.2. 

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Attachment I.1: Environmental Risk Register 


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// TDV-0-EV-SB-0021.I-03


Attachment I.2: Commissioning Management Strategies: 

Attachment I.2.1: Seawater Lift Pump Commissioning 

Attachment I.2.2: Pre-Treatment Commissioning 

Attachment I.2.3: Reverse Osmosis and Potabilisation Commissioning 

Attachment I.2.4: Overall Systems Commissioning 

Attachment I.2.5: Control Measures Table 

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Attachment I.3: Monitoring, Inspection, Reporting and Auditing 

Schedule 

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Attachment I.4: Commissioning Monitoring Program, interfacing 

with the Baseline Marine Monitoring Program 

(BMMP) and Operational Marine Monitoring 

Program (OMMP) 

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Attachment I.5: Monthly Environmental Checklist 


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Victorian Desalination Project - AquaSure

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