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Guidelines for the Petroleum and Geothermal Energy Resource (Resource Management and Administration) Regulations 2014 3.2 Pre-Submission Guidance The following guidance points should be considered when developing a petroleum well activity proposal and planning the associated WMP documentation. 3.2.1 Preliminary Information and Consultation Applicable legislation, international conventions and guidance should be identified early in the conceptual phases of a proposal. Planning the preferred document submission approach should be discussed early with the Department (see Section 3.3 below). It should be understood that the WMP is only one element required for a petroleum application and a coordinated submission approach should be developed. That is, safety and environment considerations require separate applications under the relevant petroleum legislation. 3.2.2 WMP Preparation and Structure Relevant and adequate review and preliminary hazard scoping workshops, should be conducted early in the process to facilitate the planning and preparation of a project WMP. The content and format of a WMP should be discussed between the title holder and the Department prior to document preparation and submission. External evidence supporting the conclusions reached in a WMP must be referenced. The Department will need to be given access by the title holder to relevant documentation if required, this includes reference to supporting documents and applicable standards. 3.2.3 Timeframes for Submission and Assessment Standard Assessment In order to allow the Department adequate assessment time, as a minimum a WMP must be submitted no less than 30 days before the planned start date of the activity. However, it is preferable that the WMP be submitted as early as possible. It is recommended that WMPs are submitted at least 90 days prior to the proposed date of commencement of the drilling petroleum activities and at least six months in advance for larger scale projects and activities – for example batch or campaign drilling programs. Note that if further information is required by the Department to assess the WMP, the assessment is put on hold until the further information is received i.e the clock stops. Records of relevant communications and agreed outcomes during the consideration of a submitted WMP should be kept to ensure common understanding by both parties. 3.3 Submission of Documentation 3.3.1 Regulatory Requirements Regulation 12 of the Petroleum (RMA) Regulations requires that a WMP must be in writing, or in a form approved by the Department. Generally, a hard copy and an electronic copy of a WMP must be submitted. It is important that title holders liaise with the Department before preparation and submission to properly determine the desired format of a WMP. 3.3.2 Definitions Risk classification should be as per the title holder’s risk assessment. However, rather than relating to any specific terminology used by the title holder, the three risk levels used in Table 2 should be applied as follows: • Minor Risks relate to impacts associated with the activity that have been ranked in the lower third of risk (likelihood × consequence) levels in the title holder’s risk assessment for that activity (green zone in Table 1); • Moderate Risks relate to impacts associated with the activity that have been ranked in the middle third of risk levels in the title holder’s risk assessment for that activity (amber zone in Table 1); and • Major Risks relate to impacts associated with the activity that have been ranked in the upper third of risk levels in the title holder’s risk assessment for that activity (red zone in Table 1). Table 1: Example Risk Classification Table Showing Indicative Risk ‘Zones’ for Determining Risk Levels for Table 2. Likelihood Very low 2 3 4 5 Very high Upper third of risk levels Major risk Middle third of risk levels Medium risk Lower third of risk levels Minor risk www.dmp.wa.gov.au | 4 Very low B C D E Very high ConsequencePDF Image | Western Australia Guidelines for Geothermal Energy Resource
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