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Santos Ltd ABN 80 007 550 923 PL 17 Santos Operations 2010 Annual Report Pipeline Licence 17 SA BORDER TO MOOMBA SECTION OF THE JACKSON TO MOOMBA OIL PIPELINE Commercially Sensitive Information For PIRSA Internal Use Only This report has been prepared in accordance with the requirements of the Petroleum and Geothermal Energy Act 2000 and the Petroleum and Geothermal Energy Regulations 2000 and covers all of the operations conducted for the SA Cooper Basin Joint Venture by Santos Ltd during the period January 1 2010 – December 31 2010.

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Santos Ltd ABN 80 007 550 923 PL 17 Santos Operations

2010 Annual Report

Pipeline Licence 17

SA BORDER TO MOOMBA SECTION OF THE

JACKSON TO MOOMBA OIL PIPELINE

Commercially Sensitive Information For PIRSA Internal Use Only

This report has been prepared in accordance with the requirements of the Petroleum and Geothermal Energy Act 2000 and the Petroleum and Geothermal Energy Regulations 2000 and covers all of the operations conducted for the SA Cooper Basin Joint Venture by Santos Ltd during the period January 1 2010 – December 31 2010.

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2010 PL 17 Annual Report

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TABLE OF CONTENTS 1 INTRODUCTION .............................................................................................................................. 4 2 EXECUTIVE SUMMARY .................................................................................................................. 4 3 SUMMARY OF REGULATED ACTIVITIES ..................................................................................... 4 4. PERFORMANCE ............................................................................................................................. 4 5. INCIDENTS ...................................................................................................................................... 4 6 TECHNICAL INFORMATION ........................................................................................................... 5

Table 1 – SA Border to Moomba Pipeline (PL 17) Technical Data ................................................................... 5 Figure 1 – Jackson to Moomba Oil Pipeline ....................................................................................................... 6 Figure 2 - PL 17 SA Border to Moomba ............................................................................................................ 6

7 OPERATIONAL & MAINTENANCE ACTIVITIES - 2010 ................................................................. 7 7.1 Operations & Maintenance Activities .................................................................................................... 7 7.2 Patrol Activities ..................................................................................................................................... 7 7.3 Leak Detection ....................................................................................................................................... 7 7.4 Coating Integrity .................................................................................................................................... 7 7.5 Cathodic Protection ................................................................................................................................ 8 7.6 Electrical and Instrumentation ............................................................................................................... 8 7.7 Communications .................................................................................................................................... 8 7.8 Pigging operations ................................................................................................................................. 8

8 LAND MANAGEMENT ..................................................................................................................... 8 9 ENVIRONMENTAL MANAGEMENT ............................................................................................... 8 10 EMERGENCY RESPONSE ......................................................................................................... 9

10.1 EMERGENCY RESPONSE CAPABILITY ......................................................................................... 9 10.2 EMERGENCY RESPONSE PROCEDURES ....................................................................................... 9 10.3 EMERGENCY RESPONSE DRILLS ................................................................................................... 9 10.3.1 Cooper Basin Oil Spill Preparedness Exercise ........................................................................................ 9 10.4 EMERGENCY RESPONSE ................................................................................................................ 10

11 REGULATORY COMPLIANCE .................................................................................................. 10 12 REASONABLY FORESEEABLE THREATS .............................................................................. 10

12.1 RISK ASSESSMENT .......................................................................................................................... 10 12.1.1 Pipelines................................................................................................................................................. 10

13 MANAGEMENT SYSTEM .......................................................................................................... 11 13.1 ENVIRONMENT, HEALTH & SAFETY MANAGEMENT SYSTEM (EHSMS) ........................... 11 13.1.1 Management Standards .................................................................................................................... 11 13.1.2 Hazard Standards ............................................................................................................................. 12 13.1.3 Training and Awareness .................................................................................................................. 12 13.2 AUDITS, ASSESSMENTS AND REVIEW PROCESSES ................................................................ 12 13.3 Environmental Audits .......................................................................................................................... 13

14 REPORTS ISSUED DURING THE 2010 LICENCE YEAR ....................................................... 13 15 VOLUME OF PRODUCT TRANSPORTED ............................................................................... 13 16 PROPOSED OPERATIONAL ACTIVITIES FOR 2011 ............................................................. 13 17 STATEMENT OF ACTUAL AND PROPOSED EXPENDITURE 2010/2011 ............................ 14

Appendix 1 - Environmental Objectives and Performance – Production and Processing SEO ........................ 15 Appendix 2 PIRSA Meetings – 2010............................................................................................................. 26

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LIST OF ABBREVIATIONS

AIMS Asset Integrity Management System ALARP As Low As Reasonably Practicable AS2885 Australian Standard 2885 Pipelines - Gas and Liquid Petroleum CSE Confined Space Entry CMF Coriolis Mass Flow Micro Motion meters CP Cathodic Protection DCGV Direct Current Voltage Gradient EHS Environment, Health and Safety EHSMS Environment, Health and Safety Management System EOC Emergency Operations Centre ERP Emergency Response Plan ILI In Line Inspection IMP Integrity Management Plan IMS Incident Management System Kbbls Kilo barrels (1,000 barrels) MIC Microbiological Induced Corrosion MLV Mainline Valve PFW Produced Formation Water PIRSA Primary Industries and Resources South Australia PL 17 Pipeline Licence 17 PPE Personal Protective Equipment RBI Risk Based Inspection - approach ROW Right of Way RTU Remote Terminal Unit SACBJV South Australian Cooper Basin Joint Venture SAR Search and Rescue SCADA Supervisory Control and Data Acquisition SEO Statement of Environmental Objectives SIMP Santos Incident Management Plan

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1 INTRODUCTION This report is submitted in accordance with the requirements of Pipeline Licence 17 and the SA Petroleum and Geothermal Energy Act and Regulations 2000. This report reviews operations carried out from 1 January 2010 to 31 December 2010. This Annual Report for all activity was prepared considering the relevant Statements of Environmental Objectives (SEO).

2 EXECUTIVE SUMMARY The Jackson to Moomba pipeline transports liquid hydrocarbon from Jackson (QLD) to Moomba (SA) and has a total length of 274 km. This report relates to the portion of the pipeline covered by PL 17 which is the section of the pipeline from the SA border to Moomba, a distance of 81.8 km. The Jackson to Moomba Oil Pipeline is owned, operated and maintained by Santos Ltd. The conduct of all operational activity in PL 17 is to the same standards and utilises the systems and procedures in place for Santos operated activity in the Cooper Basin. For specific detail of those this annual report should also refer to Annual Report of South Australian Cooper Basin Joint Venture Operations.

3 SUMMARY OF REGULATED ACTIVITIES This report reviews operations carried out during 2010 and intended operations for 2011.

4. PERFORMANCE The activities covered by this report are administered in accordance with the Petroleum and Geothermal Energy Act (2000), Petroleum and Geothermal Energy Regulations (2000) and the relevant SEO’s.

There was good compliance with the requirements of the Act and Regulations and the SEO. There were no reportable incidents during the period.

In accordance with the Petroleum Regulations a performance assessment is also provided

with regard to the Statement of Environmental Objectives.

5. INCIDENTS The Petroleum and Geothermal Energy Act (2000) and the relevant SEO define all events that are required to be reported to PIRSA. There were no incidents resulting in any injury to any member of the public. There was no Serious Incidents recorded during 2010 for PL 17 that required reporting as soon as practicable after the occurrence. Reportable incidents are reported to PIRSA at the Quarterly Performance meetings listed in Appendix 1. There were no Reportable incidents that required reporting for PL 17 in 2010.

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6 TECHNICAL INFORMATION Table 1 summarizes the technical aspects of the PL 17 and Figure 1 and 2 show diagrammatically the pipeline system.

Table 1 – SA Border to Moomba Pipeline (PL 17) Technical Data Date Constructed 2008 Date Commissioned 2008 Length PL17 – SA Border to Moomba 81.8 km Length pipeline - Jackson to Moomba 273 km External Diameter 219 mm Wall Thickness: - Normal - Special Crossings (rivers, roads etc.)

5.5 mm 6.5 mm

Pipe Grade API 5LX-70 Manufacture Type ERW MAOP 13.9 MPa Coating FBE - 550 microns DFT Depth of cover Nominal 1200 mm

2000 mm at major road and creek crossings Main Line Valves Dullingari (KP 206), Strzelecki (KP 225) and

Moomba (KP 274) Fluid Liquid Hydrocarbon Meter Stations Flow metering at Moomba. One Coriolis service

meter and one Coriolis proving meter. Custody transfer quality.

Corrosion Protection Temporary anodes installed. Secondary protection to be provided by an impressed

current CP system SCADA system Integrated with Moomba SCADA system. Fibre

optic system installed with pipeline. Pipeline controlled from Moomba.

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Figure 1 – Jackson to Moomba Oil Pipeline

Figure 2 - PL 17 SA Border to Moomba

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7 OPERATIONAL & MAINTENANCE ACTIVITIES - 2010 Santos field pipelines are designed in accordance with AS2885 and engineering standards. Operation and Maintenance of pipelines is managed by the Santos Pipeline Asset Management System which sets standards for integrity management and design life review to ensure EHS risks are ALARP.

Individual Integrity Management Plans (IMP) are in place for each pipeline in the Santos network. These IMP’s indicate the activities and frequencies of inspections required to manage integrity of each asset, based on estimated risk analysis.

7.1 Operations & Maintenance Activities As shipping pumps are manually started, a local operator interface at Jackson is required. The pumps may be locally shutdown or remotely shutdown from the Moomba Control Room.

Compulsory biocide dosing, regular pigging and product sampling/analysis are carried out to reduce the effects of Microbiological Induced Corrosion (MIC). A scheduled maintenance program and log is set-up to monitor the usage of the biocide chemicals.

A detailed Integrity Management plan for the pipeline and pigging facilities is being followed.

7.2 Patrol Activities The annual pipeline patrol was not carried out in 2010 due to limited access along the pipeline Right Of Way due to flooded.

7.3 Leak Detection A proven proprietary Leak Detection system has been installed to meet operational, environmental and regulatory requirements.

Metering at Jackson and Moomba and sensing points along the pipeline provides input to the leak detection system via the fibre-optic cable. The system provides protection under both dynamic and static conditions and is expandable to allow for addition of side streams to the pipeline.

Detection of a leak automatically stops the pipeline pumps and closes the pipeline inlet and outlet valves and actuated section valves at the Dullingari and Strzelecki MLV stations. Remote closure of section valves from the Moomba control centre is also possible.

The leak detection system underwent preliminary testing in 2009, looking at completing commissioning in the first half of 2010.

7.4 Coating Integrity A Direct Current Voltage Gradient (DCVG) was carried out in 2009. Due to high levels of coating and CP integrity found there was no plan to carry out further surveys in 2010.

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7.5 Cathodic Protection The Cathodic Protection Transformer Rectifiers for the pipeline’s impressed current Cathodic Protection system were inspected every two months; however a Cathodic Protection survey was not carried out due to access problems (flooding).

7.6 Electrical and Instrumentation Micro Motion Coriolis mass flow (CMF) transmitters are installed at Jackson and Moomba. Both units are used for leak detection system and specified for the custody transfer metering. The Micro Motion meters feed the Fisher ROC RTU. Totalized flow can be calculated within the fisher ROC RTU.

DN 80 CMF Elite+series meter with enhanced flow accuracy and density accuracy are installed. The meter selected is capable of measuring the entire flow spectrum; from 795 to 7,950 m3/d within acceptable accuracy limits. Each metering skid has one service meter and a proving meter. The valving around the two meters is a double block and bleed type for provable isolation when zeroing and testing.

The meters were certified at the factory for 13,910kPag operations and to ANSI/API MPMS 5.6 for custody transfer measurement to satisfy the Queensland regulatory standard for custody transfer.

7.7 Communications A fibre-optic cable has been installed together with the new pipeline for improved communications between Jackson and Moomba. Two strands of this cable are used for leak detection and pipeline control for this pipeline.

7.8 Pigging operations

The pipeline was pigged by production in accordance with the IMP requirements. A corrosion inhibitor batch treatment was also carried out in accordance with the IMP requirements. The Pig launcher & Receiver were treated in 2010 as per the Integrity Management Plan. Due to significant floods, the In-Line Inspection (ILI) planned for this pipeline in 2010 was not carried out. This activity has been re-scheduled for completion in 2011.

8 LAND MANAGEMENT There are 2 properties covering the SA border to Moomba section of the pipeline. Both properties have extensive Petroleum facilities on them related to SACBJV activity and close relations are maintained for all activity and awareness of working with these facilities on the properties. 9 ENVIRONMENTAL MANAGEMENT Appendix A contains the “Assessment of Declared Objectives” completed for the Liquids Line.

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10 EMERGENCY RESPONSE An Emergency Response Plan (ERP) was developed for activities in South Australia, including PL 17. In the event of an incident resources would be mobilised to assist.

10.1 EMERGENCY RESPONSE CAPABILITY Santos maintains a dedicated emergency response crew at Moomba. This consists of fully trained Emergency Officers (Fire crew) and medical response personnel together with a large inventory of emergency response equipment, material and vehicles.

10.2 EMERGENCY RESPONSE PROCEDURES Detailed, scenario-based emergency response procedures have been developed and implemented under the Santos Incident Management Plan (SIMP) to guide personnel in emergency incident response. Emergency response drills are regularly held in order to continuously update plans and maintain a high degree of readiness among personnel. In the event of the emergency response procedures being used in response to an actual event a debrief of all relevant parties is conducted in order to ensure learnings are incorporated into the plans.

10.3 EMERGENCY RESPONSE DRILLS Refer the SACBJV Annual report, appendix 3, for a comprehensive review of exercises held for Santos’ operation in 2010 Emergency Services conducted a number of Drills, Exercises and Desktop Exercises in 2010 including Evacuation Drills, Muster Point Training, Operational Exercises, EOC Training and Exercises, SAR Exercises and CSE Training and Rescue Rehearsals etc. An agreement with PIRSA provides for a summary within the SACBJV report with regard the requirements of Reg 31 (5) of the Petroleum Regulations 2000, the preparation and submission of a report after a drill. The drills held during 2010 have met the requirements of Reg 31 (6) that outlines the requirements for a report under Reg 31 (6). They have demonstrated the adequacy of the emergency response procedures and the competency of personnel to execute the procedures. The following provides some additional detail on a significant response drill Santos conducted, or participated in, during 2010, that is of particular relevance to PL 17.

10.3.1 Cooper Basin Oil Spill Preparedness Exercise

The planned Moomba Oil spill response exercise for the Cooper Creek and related waterways was modified to initially be a table top review of the preparedness levels and to identify all of the issues that currently exist. A full exercise will then be conducted.

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Exercise ”MOOSPILL” is a crisis management discussion exercise, designed to examine procedures and processes that require consideration in the event of a major oil spill in the Moomba environs. Objectives • Determine initial scene requirements and incident management

arrangements • Review activation, response, coordination requirements • Review preparedness levels. • Examine information reporting procedures and communications • Identify issues and opportunities for further development of training,

equipment deployment techniques and site logistics. This table top exercise was completed on Tuesday 7th December 2010

The findings from this debrief including all associated action items have been recorded. This exercise identified a number of improvements to be made to the emergency response plan and associated processes and procedures; this included the availability and adequacy of spill response equipment.

10.4 EMERGENCY RESPONSE There were no events in PL 17 requiring emergency response.

11 REGULATORY COMPLIANCE Every endeavor is made to ensure that design, manufacture, construction, operation, maintenance and testing of all appropriate facilities, is carried out in accordance with AS2885. There are no known outstanding non compliances for the Crude Oil pipeline that Santos Ltd is aware of against:

• The Petroleum and Geothermal Energy Act & Regulations 2000 • The Pipeline Licence (PL17) • The Statement of Environmental Objectives

Any non-compliance identified is logged in the IMS where it is tracked to conclusion.

12 REASONABLY FORESEEABLE THREATS There were no serious threats identified during operation of this pipeline during the reportable period.

12.1 RISK ASSESSMENT Risks are managed to as low as reasonably practicable (ALARP). The outcomes of any risk review regarding SACBJV activities are applied to PL 17 activity.

12.1.1 Pipelines Management of pipeline integrity occurs by targeting pipeline systems and

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associated equipment which are high risk or near the end of design life (Risk Based Inspection - RBI - approach). Main targets of Pipeline Integrity Management are: - Redirection of pipeline operating risks to ALARP - Address safety risks - Maintain integrity of ageing pipeline network - Standards compliance - AIMS (IMP) compliance

The Asset Integrity Management System (AIMS) is the framework used within Pipeline Integrity to provide effective through-life integrity management of pipeline assets to meet operational availability, as well as achieving Statutory and Corporate compliance with Safety, Health and Environment

An annual risk assessment was carried out as part of the pipeline integrity review process and signed off in December 2010.

13 MANAGEMENT SYSTEM Activity in PL 17 is managed to standards that apply to SACBJV activity. These are fully reported in the 2010 SACBJV annual report and in some cases meaningful data or information are not possible given the low level of activity in this PL compared to all SA Cooper Basin activity. A summary of key elements is repeated in this report.

13.1 ENVIRONMENT, HEALTH & SAFETY MANAGEMENT SYSTEM (EHSMS) The implementation and review of the Santos Environment, Health and Safety Management System (EHSMS) continued as an organisational priority during 2010. Implementation was monitored and communicated to PIRSA at quarterly meetings. Management standards performance was further validated by the use of internal auditors to monitor improvement initiatives highlighted by the 2009 EHSMS audit and assessment program.

The EHSMS contains both management standards and hazard standards. The management standards provide a framework for the sustainable achievement of acceptable EHS outcomes, whilst the hazard standards provide a clear process for control of hazards that are specific to Santos’ business.

In 2009, the structure of EHSMS documents was reformatted to differentiate information between mandatory requirements, and guidance material. In 2010 this update continued. There are now 39 standards that have been updated to the new format.

13.1.1 Management Standards Further implementation of management standards continued throughout 2010. Process safety (the prevention of high consequence/low frequency events involving sudden loss process fluids/gasses) standards continue to be imbedded into the business. Process Safety data continues to be collected and analysed. Trending information is fed back through the monthly Eastern Australia leadership committee. There were 4 management standards amended and updated in 2010 – Operating procedures, Management of Personnel Change, First Aid/ Medical and Management Review. A significant review was undertaken on Contractor Management. The top 10

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contractors were audited and this resulted in a number of proposed changes to the existing standard, processes and procedures.

13.1.2 Hazard Standards Further development and implementation of hazard standards progressed in 2010. Air transportation and excavations standards were reviewed and updated. There also continues to be a strong focus on land transportation and heat stress. Implementation of the health and well-being hazard standard continued, with significant focus on workforce health awareness and education. A specific program was put in place for high risk individuals; staff with 5 health risks from previous health check were offered personal health coaching. Drug and alcohol testing continued in 2010 with employees and contractors at all field and office locations being subject to random, for cause and post incident testing. Results indicate a very low failure rate. A fatigue management program was implemented in 2009, including awareness programs, self-management tools and reporting protocols. This program continued in 2010 with awareness sessions in the office and specific work on reviewing rosters in the field.

In 2010, sites continued to identify and focus on their ‘top 5’ hazards standards. These standards were aligned with their Significant Hazard Risk Register, to ensure a constant site-based focus on the most significant hazards. During 2010 sites continued to review and update their Significant Hazard Risk Registers and there top 10 risks and controls were reported back through the monthly Eastern Australia leadership committee.

13.1.3 Training and Awareness A new program was launched in 2010 to raise the awareness of high risk safety activities. The Santos Lifesaver Program consisted of 10 topics – Working with Electricity, Excavation, Working with Hydrocarbons, Driving Vehicles, Working at Heights, Lifting, Confined Space Entry, Working in the Heat, Management of Change and Start-up process Safety. The program contained a toolbox talk, promotional material (displays, posters, table topper, and screen saver), quiz, workplace inspection and audit. This program was successful in raising the level of awareness and resulted in an increase in reporting on these topics. The Lifesaver program will also be rolled out in 2011- the same topics with a different presentation/focus. A “safety Intervention” training program was developed and rolled-out in 2010. This program was about learning intervention skills in a safety situation i.e. when you see an unsafe activity, being able to intervene and provide feedback. Over 700 staff participated in the training and this received positive feedback. Finally in 2010 an on-line risk management training program was developed. This program provides an understanding of risk management, basic principles and practical application. This on-line training will be rolled out during 2011.

13.2 AUDITS, ASSESSMENTS AND REVIEW PROCESSES The following summarises some of the Audit, Assessment and Review processes used to determine system conformance, effectiveness and fitness for purpose.

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The EHSMS Assessment process was developed to drive the effective implementation of the EHSMS. Detailed Assessment/Audit Guides were developed for each standard and these were used by internal and external certified auditors to determine the status of conformance across all management standards. Each site/area received an annual progress review, audit or assessment. Each site received a report which provided an overview of conformance against relevant requirements of each management standard. Where a requirement was not at full conformance the report detailed the corrective action required to achieve full conformance. In 2010, internal auditors were used to conduct audits and progress reviews.

Results of progress review, audit and assessment reports were tabled at Eastern Australia Leadership and Site Committee meetings for discussion and tracking of actions. The general findings were also presented at the Environment, Health, Safety and Sustainability Board meeting.

In 2008 we started to report, investigate and record any High Potential Incidents (HiPo’s) that occurred within the company. HiPo’s are defined as any incident that had potential to result in a fatality. Tracking and reporting HiPo’s has given the company another avenue to learn from incidents and improve our overall safety performance. The tracking of HiPo’s continued in 2010, and was reported to senior management on a regular basis. 13.3 Environmental Audits

Appendix 1 contains the “Assessment of Declared Objectives” completed for the Liquids Line. 14 REPORTS ISSUED DURING THE 2010 LICENCE YEAR There were no reports generated for Santos purposes or forwarded to PIRSA for the Jackson to Moomba Oil Pipeline in 2010. 15 VOLUME OF PRODUCT TRANSPORTED

Volume Transported 2010 Estimated to be Transported 2011 1,805 Kbbls 2394 Kbbls

16 PROPOSED OPERATIONAL ACTIVITIES FOR 2011 During 2011 the following activities are proposed for the Jackson to Moomba Oil Pipeline. • Complete all scheduled routine maintenance activities. • Submission of a 2010 Annual Report in early 2011. • Conduct Cleaning Pigging Runs as per the Pipeline Integrity Management Plan • Conduct a baseline In-Line Inspection (ILI) by running an intelligent pig. • Cathodic Protection survey deferred from 2009 due flooding • Conduct Pipeline Patrol along with a 100% Cathodic Protection Survey in accordance

with the Pipeline Integrity Management Plan.

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• Treat the pig launcher & receiver barrels in 2011 in accordance with the Pipeline Integrity Management Plan.

• Continuous batch biocide injection in accordance with the Pipeline Integrity Management Plan.

• Annual pigging batch treatment of the pipeline in accordance with the Pipeline Integrity Management Plan.

17 STATEMENT OF ACTUAL AND PROPOSED EXPENDITURE 2010/2011

Jackson – Moomba Pipeline apportioned for SA Section Confidential

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Appendix 1 - Environmental Objectives and Performance – Production and Processing SEO Environmental

Objectives Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Objective 1Minimise any safety risk to public and other third parties.

:

Reasonable measures

implemented to ensure no injuries to the public or third parties.

All employees and contractor personnel complete a safety induction prior to commencement of work in the field.

All employees and contractor personnel undertake a refresher induction every 2 years.

Signage in place to warn third parties of access restrictions to operational areas, with particular warnings when potentially dangerous operations are being undertaken.

Permit to Work systems in place for staff and contractors for appropriate work activities/tasks.

Appropriate PPE (personnel protective equipment) is issued and available as required in accordance with company operating requirements and applicable standards.

Pipelines are compliant with AS2885 pipeline standards. Emergency Response Plan (ERP) and procedures are in place. Annual

exercise of ERP. Communication of rig movements and other potential hazards

associated with drilling and well operations to potentially affected parties prior to commencement of operations.

Compliance with relevant speed restrictions on access roads and tracks. Measures implemented to minimise visibility of pipeline ROW at access

track crossings (e.g. ROW width reduced to 9m, ROW doglegged so that less than 100m is visible either side of track, some trees or shrubs left on ROW to break line of sight, verge of the track reinstated).

Reporting systems for recording injuries and accidents in place and annual (at minimum) review of records to determine injury trends.

Implementation of appropriate corrective actions. Ensuring safety management plans are updated and reviewed. Wastewater disposal in accordance with Objective 11.

• There were no injuries to the public or third

parties from the regulated activities

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Environmental

Objectives Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Objective 2Minimise disturbance and avoid contamination to soil.

:

No evidence of significant subsoil on surface (colour) on the pipeline ROW following construction.

Construction Activities (e.g. pipelines and roads)

No subsidence is evident over pipeline trench.

At pipeline dune crossings, dune profiles have been restored consistent with surrounding dune profiles.

No visual evidence of soil compaction following remediation of the pipeline easement (e.g. hard soil, local water pooling).

The extent of erosion on the ROW is consistent with surrounding land.

No unauthorised off-road driving or creation of shortcuts.

No construction activities are carried out on salt lakes or steep tableland slopes (as defined in EIR).

0, +1 or +2 GAS criteria are attained for goals related to this objective.

.

Santos operational procedures and guidelines are in place and will be followed for construction activities, for example to conserve soil resources:

Construction Activities (e.g. pipelines and roads)

topsoil is stockpiled separately from subsoil and respread during reinstatement

no windrows remain after pipeline construction (except on dunes where some windrows are inevitable after reprofiling but will quickly disappear

if a crown over the pipeline trench is left to alleviate subsidence, periodic breaches are left to avoid channelling water flows down the ROW

areas of compacted soil are ripped Consider alternate routes during planning phase to minimise

environmental impacts. Works are restricted to construction ROW. The need to traverse sensitive land systems and the method of

managing the impacts must be justified in accordance with company procedures, recorded and available for auditing.

Annual audit of construction practices.

Results of emergency response procedures carried out in accordance with Regulation 31 show that an oil spill contingency plan in place in the event of a spill is adequate and any necessary remedial action needed to the plan is undertaken promptly.

Spill Response / Contingency Planning

Oil spill contingency plan (reviewed annually) is up to date with specific scenarios relating to spills to creeks and floodplain areas.

Spill response equipment is audited annually. Annual spill response training exercise is undertaken. Refer to Section 3 “Reporting” for clarification of incident reporting

requirements

• There was no unauthorised off road driving

or creation of short cuts. All accesses were planned for optimal access while maintain a small footprint

• The number of site visits was minimized • All landowners were contacted prior to

regulated activities. There were no landowner complaints

• ROW was filmed by aerial survey on project completion in 2008 to record reinstatement

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Environmental Objectives

Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Objective 2 contMinimise disturbance and avoid contamination to soil

:

No spills/leaks outside of areas designed to contain them.

Fuel and Chemical Storage, Handling and Transportation

Soils remediated to a level as determined by the SHI Decision Framework.

Also refer to Objective 12.

No spills/leaks outside of areas designed to contain them.

Oil/Condensate Spills (Pipeline/Road Transport)

Level of hydrocarbon continually decreasing for in situ remediation of spills.

Soils remediated to a level as determined by the SHI Decision Framework.

All domestic wastes are disposed of in accordance with EPA licensing requirements.

Waste Disposal (domestic, sewage and sludges)

No evidence of rubbish or litter on ROW or at campsites / facilities.

No spills or leaks from sludge treatment process and sludge pits.

No increase in contamination at LTUs designated treatment area.

Refer to assessment criteria for Objective 11.

All fuel, oil and chemicals are stored, handled and transported in accordance with appropriate standards and guidelines e.g. Australian Standard AS 1940, Australian Dangerous Goods (ADG) Code, EPA guidelines 080/07 Bunding and Spill Management.

Fuel and Chemical Storage, Handling and Transportation

Fuel and chemical storage, handling and transport procedures are reviewed and monitored in audit process.

Records of spill events and corrective actions are maintained in accordance with company procedures.

Spills or leaks are immediately reported and clean up actions initiated. Logged incidents are reviewed annually to determine areas that may

require corrective action to reduce spill volumes in subsequent years (and drive continual improvement).

Audit against EHSMS standards for underground storage tanks and bunds on a four yearly minimum frequency.

Pipelines are compliant with AS2885 pipeline standards Oil/Condensate Spills (Pipeline/Road Transport)

Pipeline Management System is reviewed annually. Pipelines are inspected and maintained in accordance with Pipeline

Integrity Management System Spills or leaks are immediately reported and clean up actions initiated. Records of spill events and corrective actions are maintained in accordance

with company procedures.

Site activities to be audited against EPA licence for Waste Depot on a minimum two years schedule.

Waste Disposal (domestic, sewage and sludges)

EHS04 Waste Management is adhered to. Audit against EHS04 Waste Management – 4 yearly minimum. Covered bins are provided for the collection and storage of wastes. All loads of rubbish are covered during transport to the central waste facility. Disposal areas are not established in locations, which pose an

unacceptable hazard to stock or wildlife. Sewage treatment facilities to be operated in accordance with design

criteria. Refer to Objective 11.Refer to Objective 11.

• Emergency procedures for spill

responses are in place and regularly drilled. Learnings from drills and actual events are included in Plans.

• Oil Spill Plans are up-to-date and regularly tested. • Spill response equipment and

procedures are regularly audited.

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Environmental Objectives

Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Objective 3Avoid the introduction or spread of pest plants and animals and implement control measures as necessary.

: No weeds or feral animals

are introduced to, or spread in, operational areas as a consequence of activities.

Weed management plans are implemented where priority weed species are identified.

Where appropriate, weed and feral animal management strategy is in place

(avoidance and control strategies). Vehicle and equipment wash downs to be initiated in accordance with the

management strategy.

• Existing roads and tracks used

where possible. • There have been no reports of

weeds and feral animal introduced • Number of site visits kept to a

minimum • Vehicles used are located in the area

Minimise disturbance to drainage patterns and avoid contamination of surface waters and shallow ground water resources.

Objective 4:

0, +1 or +2 GAS criteria are attained for goals related to this objective

Construction Activities (e.g. pipelines and roads)

Construction activities (e.g. access tracks or pipelines) are located and constructed to maintain pre-existing water flows (i.e. channel contours are maintained on floodplains and at creek crossings).

No water (surface or groundwater) contamination as a result of construction activities.

Soils remediated to a level as determined by the SHI Decision Framework. Also refer to Objective 12.

Fuel and Chemical Storage, Handling and Transportation

No water (surface or groundwater) contamination as a result of these activities.

Constructed activities undertaken are designed and managed to avoid diversion of water flows.

Construction Activities (e.g. pipelines and roads)

Sensitive land systems (e.g. wetlands) avoided wherever possible. Where activities are undertaken in or near these areas, appropriate review, assessment and mitigation measures are in place to ensure that surface water flows are maintained and contamination of surface water and groundwater is avoided.

All fuel, oil and chemicals are stored, handled and transported in accordance with appropriate standards e.g. Australian Standard AS 1940, Australian Dangerous Goods (ADG) Code, EPA guideline 080/07 Bunding and Spill Management.

Fuel and Chemical Storage, Handling and Transportation

Fuel and chemical storage, handling and transport procedures are reviewed and monitored in an audit process.

Records of spill events and corrective actions are maintained in accordance with company procedures.

Spills or leaks are immediately reported and clean up actions initiated. Logged incidents are reviewed annually to determine areas that may

require corrective action to reduce spill volumes in subsequent years (and drive continual improvement).

Implementation of the SHI Decision Making Framework approved in January 2010.

• There were no reported incidents of

contamination of surface water and groundwater

• Existing tracks and roads were used where possible

• There were no surface or below ground disturbance activities undertaken during the reporting period

• Emergency response procedures for spill response are in place and regularly exercised. Learning from exercises and actual events are included in Plans.

• Oil Spill Plans are up-to-date and regularly drilled.

• Spill response equipment and procedures are regularly audited.

• Regular drills are conducted.

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Environmental Objectives

Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Objective 4 Cont

No spills/leaks outside of areas designed to contain them.

Oil/Condensate Spills (Pipeline/Road Transport)

Level of hydrocarbon continually decreasing for in situ remediation of spills.

Soils remediated to a level as determined by the SHI Decision Framework

Pipelines are compliant with AS2885 pipeline standards. Oil/Condensate Spills (Pipeline/Road Transport)

Pipeline Management System is reviewed annually. Pipelines are inspected and maintained in accordance with Pipeline

Integrity Management System. Spills or leaks are immediately reported and clean up actions initiated. Records of spill events and corrective actions are maintained in accordance

with company procedures. Refer to Section 3 “Reporting” for clarification of incident reporting

requirements

Results of emergency response procedures, carried out in accord with Regulation 31, show that the oil spill contingency plan in place in the event of a spill is adequate and any necessary remedial action needed to the plan is undertaken promptly.

Spill Response / Contingency Planning

Oil spill contingency plan (reviewed annually) is up to date with specific scenarios relating to spills to creeks and floodplain areas.

Spill response equipment is audited annually. Annual spill response training exercise is undertaken.

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Environmental Objectives

Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Avoid disturbance to sites of cultural and heritage significance.

Objective 5:

Proposed well sites and

access tracks have been surveyed and any sites of Aboriginal and non-Aboriginal heritage identified.

Any identified cultural and heritage sites have been avoided.

Consultation with stakeholders (i.e. government agencies, stakeholders etc)

in relation to the possible existence of heritage sites, as necessary. Heritage report forms completed for any sites or artefacts identified and

completed forms forwarded to the Aboriginal Heritage Branch, Aboriginal Affairs and Reconciliation Division (AARD).

Survey records are kept and are available for auditing. Areas requiring remediation which lie outside previously surveyed sites

should be surveyed in accordance with company heritage clearance procedures.

Induction for all employees and contractor addresses heritage site recognition and management.

A procedure is in place for the appropriate response to any sites discovered during operations.

Note: Where a negotiated agreement or determination for heritage clearance is in place, compliance with the negotiated agreement or determination takes precedence over the above criteria.

• All relevant aboriginal groups were

notified before the commencement of cultural heritage clearance activities

• Aboriginal monitors were used to identify and avoid cultural heritage sites

• Existing roads and tracks were used wherever possible.

• Number of site visits were kept to a minimum

Minimise loss of aquifer pressures and avoid aquifer contamination.

Objective 6 There is no uncontrolled

flow to the surface (i.e. no free flowing bores)

No significant change in water quality from the injection aquifer.

Produced Formation Water (PFW) Waterflood Injection Wells

The volume/flow of water used by the Moomba Plant is continuously

monitored to ensure appropriate management. Water usage is monitored, reviewed and management strategies

implemented to minimise wastage. Review water licensing requirements and allocation plans.

Aquifer water quality monitored where appropriate through testing carried out during Waterflood activities.

Produced Formation Water (PFW) Waterflood Injection Wells

• There was no drilling or uncontrolled

water flow to the surface as part of this activity

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Environmental Objectives

Assessment Criteria

Guide to How Objectives Can Be Achieved Objective Achieved

Objective 7Minimise disturbance to native vegetation and native fauna.

:

Construction Activities Borrow Pits

Refer to assessment criteria for objectives 2 and 4.

Fuel and Chemical Storage and Management

Refer to assessment criteria for objectives 2 and 4.

Waste Management

Significant Environmental Benefit (SEB) for native vegetation clearance approved by PIRSA (where delegated authority applies) or Native Vegetation Council (NVC).

Native Vegetation Act SEB

Significant environmental benefit obligation is ultimately satisfied / implemented.

Fauna Management

Construction Activities Borrow Pits

Fuel and Chemical Storage and Management

Covered bins are provided for the collection and storage of putrescible wastes.

Waste Management

All loads of rubbish are covered during transport to the central waste facility. Refer to Objective 11.

Work (or payment to Native Vegetation Fund) undertaken to achieve an SEB for native vegetation clearance.

Native Vegetation Act SEB

SEB requirement either: - determined using the Guidelines (DWLBC 2005) or - negotiated with PIRSA or the Native Vegetation Council where SEB

calculation differs from the standard methodology in the Guidelines.

No domestic pets allowed at camps or worksites. Fauna Management

Feeding of wildlife (e.g. dingoes) is not permitted.

There was no construction activity in 2010 • All rare, vulnerable and endangered

species sites were avoided • There were no reports of damage to

native vegetation as a result of this activity.

• The number of site visits were only as deemed necessary

• Vegetation re spread over ROW during reinstatement.

• All waste generated as part of the activities were collected and taken off site and disposed of as per Santos procedures.

• Any hazardous or regulated waste was taken to Moomba and disposed of as per company procedures

• SEB obligations reported during 2010 with overall SACB report and obligations progressed

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Environmental Objectives

Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Minimise air pollution Objective 8:

and greenhouse gas emissions.

Compliance with EPA requirements.

Gathering Systems/Satellite Facilities/Moomba Plant

Conduct production operations in accordance with appropriate industry accepted standards.

Gathering Systems/Satellite Facilities/Moomba Plant

Continually review and improve operations. Appropriate Emergency Response Procedures are in place in case of a gas

leak.

Operations conducted in accordance with established standards

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Environmental Objectives

Assessment Criteria

Guide to How Objectives Can Be Achieved Objective Achieved

Objective 9Maintain and enhance partnerships with the Cooper Basin community.

: No unresolved

reasonable complaints from the community.

Relevant affected parties are notified and consulted on proposed activities. Forward development plans are presented to the local community. Local community projects and events are sponsored and supported where

appropriate. Industry membership of appropriate regional land management committees

and boards

• Relevant parties are notified of

proposed activities and future development plans.

• Local community events and projects are actively supported.

• Santos maintains active representation on relevant local committees and boards.

• Emergency assistance is provided to landholders, tourists and third parties.

Avoid or minimise disturbance to stakeholders and/or associated infrastructure

Objective 10: No reasonable

stakeholder complaints left unresolved.

Induction for all employees and contractors covers pastoral, conservation,

tourism, legislation and infrastructure issues. Relevant stakeholders are notified prior to survey and construction of well

sites, camp sites and access tracks and undertaking of operations (pursuant to the Regulations). Borrow pits left open (unrestored) if requested by stakeholder and upon receipt of letter of transfer of responsibility to stakeholder.

Gates or cattle grids are installed to a standard, consistent with pastoral infrastructure instead of fences where crossings are required for access.

All gates left in the condition in which they were found (i.e. open/closed). Fences repaired to ‘as before’ standard following pipeline construction. Potential sources of contamination (e.g. formation water ponds) are fenced

as appropriate to prevent stock access. Written evidence that stakeholder is satisfied with water disposal

arrangements. System is in place for logging stakeholder complaints to ensure that issues

are addressed as appropriate. Requirements of the Cattle Care and Organic Beef accreditation programs

are complied with. In recognised conservation reserves (i.e. Innamincka Regional Reserve)

excavations are left in a state as agreed

• Company and contractor employees

are advised of the requirements in respect of pastoral interests.

• Relevant stakeholders are advised of construction activities prior to commencement.

• Gates are left “as found”. • Where necessary, areas of potential

contamination are fenced to prevent stock access.

• A system is in place to record stakeholder complaints. No such complaints were recorded in 2009.

• Cattle management systems (Cattle Care) are recognised and complied with.

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Environmental Objectives

Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Optimise (in order of most to least preferable) waste avoidance, reduction, reuse, recycling, treatment and disposal

Objective 11:

Domestic wastes are

disposed of in accordance with EPA licensing requirements.

Wastewater (sewage and grey water) disposed of in accordance with the Public and Environmental Health (Waste Control) Regulations 1995 or to the Department of Health’s satisfaction.

No spills or leaks from sludge treatment process and sludge pits.

No increase in contamination at LTUs designated treatment area

Chemicals and oil are purchased in bulk. ‘Bulki bins’ or other storage tanks

are in place for large volume items. Fencing around waste disposal facility is regularly inspected and maintained. Waste streams are segregated on site to maximise opportunities for waste

recovery, reuse and recycling. Evidence/records are maintained showing that recyclable material has been

returned to Moomba Waste Management Depot. Production of waste is minimised by specifying reusable, biodegradable or

recyclable materials in procurement, where practical. Waste audit conducted at 5 year minimum interval. Waste water (sewage) disposal is where possible in accordance with the

Public and Environmental Health (Waste Control) Regulations 1995 (which require that the waste water disposal system must either comply with the Standard for the Construction, Installation and Operation of Septic Tank Systems in SA or be operated to the satisfaction of the Department of Health) and the Environment Protection (Water Quality) Policy 2003.

Evidence/records maintained to show that appropriately designed sewage facilities have been constructed.

• Refer Objective 4 above.

Integrated Waste Management contract put in place covering the collection, transport, segregation and disposal of waste, including recycling.

• Septic tank systems are regularly emptied and cleaned.

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Environmental Objectives

Assessment Criteria Guide to How Objectives Can Be Achieved Objective Achieved

Objective 12Remediate and rehabilitate operational areas to agreed standards.

:

Contaminated Site Remediation

Construction Site and Access Track Restoration

Borrow Pit Restoration

Production Facility Abandonment

Pipeline Abandonment

Rehabilitation/abandonment plans for regulated activities will be developed in

consultation with relevant stakeholders.

Compacted soil areas have been ripped (except on gibber and tablelands) and soil profile and contours are reinstated following completion of operations.

Construction Site and Access Track Restoration

The following steps will typically be undertaken unless otherwise agreed with the regulator and stakeholders:

Pipeline Abandonment

all aboveground pipes and supports will be assessed for the condition of the pipe for either salvage or for dismantling and re-use.

all underground pipe work will be cut-off (at a minimum depth of 750mm below the natural surface or at pipeline depth, removed and blinded below the surface.

all aboveground signs and markers will be removed. all pipeline protection systems will be removed to allow the pipeline to

degrade in-situ. monitoring and auditing of abandoned pipelines will be undertaken. all pipelines which are partially or wholly left in-situ will be accurately mapped

and recorded. Records will be prepared and submitted to the appropriate authority.

No stakeholder complaints are unresolved. No contaminated sites Access tracks are restored in accordance with restoration guidelines. No borrow pits No abandonment activities

Minimise as far as reasonably practicable interruptions to natural gas supply.

Objective 13: No interruptions to natural gas supply that cause significant social disruption

Adequate contingencies are in place which seek to address a prudent level of

security of supply in the case of short and unforseen interruption events (e.g. adequate gas storage).

Pipelines are designed, operated and maintained in accordance with AS 2885.

Not applicable to oil pipeline

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Appendix 2 PIRSA Meetings – 2010 Over and above the significant reporting requirement to PIRSA associated with the conduct of operations in the Cooper Basin under the Petroleum and Geothermal Energy Act (2000) and Petroleum and Geothermal Energy Regulations (2000), a series of regular meeting are held with PIRSA at quarterly intervals, to review performance. These meetings included the following: Quarterly Santos / PIRSA Performance Meeting

4th Quarter, 2009 - 5 February 2010 1st Quarter, 2010 - 14 May 2010 2nd Quarter, 2010 - 6 August 2010 3rd Quarter, 2010 - 5 November 2010 2010 Development Plan & Operational Review - 10 May 2010