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ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
Project specific activities• 21‐day BID comment period• Advertisements• Notification letters• Meetings held with: MET & MME ‐Windhoek MFMR ‐ Swakopmund Fishing Associations – Walvis Bay Environmental NGOs ‐
Swakopmund Public – Walvis Bay Public – Lüderitz
• 17 written submissions received
• 30‐day DSR comment period• 35 written submissions received
• MET meeting
• FSR approved 4 September 2017
• Drill Cuttings and Oil Spill Modelling • Noise Assessment • Marine and Coastal Ecology Assessment
• Commercial Fisheries Assessment • Socio‐Economic Assessment
• 30‐day Draft EIA Report comment period
• Advertisements• Notification letters
Engagement with the Ministry of Fisheries and Marine
Resources in Swakopmund
Engagement with Fishing Industry in Walvis Bay
PROJECT LOCATION
Place Names
Bathymetry Lines
3D seismic acquired by Shell in 2014
Area of Interest (2 500 km2)
Shell Licence Block (12 299 km2)
Other Licence Blocks
Number of wells 1 ‐ 2
Drilling depth ~ 3 000 m
Drilling duration 2 months per well
ASPECTS AND IMPACTS REGISTERActivity Phase Activity Aspect Potential Impact
1. Mobilisation Phase
Transit of drilling unit and support vessels to drill site
Underwater noise levelsDisturbance of behaviour (foraging and anti-predator) and physiology of marine fauna
Air emissions and local reduction in air quality due to exhaust gases
Potential contribution to cumulative impact on local air quality
Discharge of waste to sea (e.g. deck and machinery space drainage, sewage and galley wastes) and local reduction in water quality
Physiological effect on marine fauna
Increased food source for marine fauna
Increased predator - prey interactions
Exclusion zone around drilling unitDisruption of shipping routes by ships having to make detours
Disruption to fishing activities
Discharge of ballast water Introduction of invasive alien species Loss of biodiversity
Rental of accommodationRequirement for rental and owner-occupied housing
Revenue or income for landlords and rental businesses
Rental of quay spaceRequirement for quay space for onshore facility and support vessels
Revenue or income for Namport
Appointment of local service providersRecruitment for temporary jobs Temporary job creation and earning of salariesBusiness opportunities Income for local service providers
Procurement of equipment / materials from the local market
Business opportunities Income for suppliers
2. Operation Phase
Operation of drilling unit and support vessels
Increase in underwater noise levels
Disturbance / behavioural changes to marine fauna
Fish avoidance of key feeding areas (e.g. Tripp Seamount)
Reduced fish catch and increased fishing effort
Discharge of waste to sea (e.g. deck and machinery space drainage, sewage and galley wastes) and local reduction in water quality
Physiological effect on marine fauna
Increased food source for marine fauna
Fish aggregation and increased predator - prey interactions
Exclusion zone around drilling unitDisruption of shipping routes by ships having to make detours
Reduced fishing grounds and catch
Increase in ambient lightingDisorientation and mortality of marine birds
Increased predator - prey interactions
Operation of helicopters Increase in noise levels
Disturbance of coastal and marine fauna
Avoidance of key breeding areas (e.g. coastal birds and cetaceans)
Abandonment of nests (birds) and young (birds and seals)
Seabed survey using a ROV Sediment disturbance Physical damage to and mortality of benthic species / habitats
Well drilling (including spudding)
Sediment disturbancePhysical damage to and mortality of benthic species / habitats
Disturbance of or damage to cultural heritage material (e.g. historical shipwrecks)
Increase in underwater noise levels
Disturbance / behavioural changes to marine fauna
Fish avoidance of key feeding areas (e.g. Tripp Seamount)
Reduction in fish catch and increased fishing effort
Discharge of residual cement during cementing operations
Accumulation of cement on seafloor and sediment disturbance
Toxicity and bioaccumulation effects on marine fauna
Discharge of cuttings and drilling fluidAccumulation of cuttings on seafloor and sediment disturbance
Smothering of benthic fauna
Toxicity and bioaccumulation effects on marine fauna
Increased water turbidity and reduced light penetration
Physiological effect on marine fauna
Placement of wellhead on seafloor Increased hard substrate on seafloor Increase in benthic biodiversity and biomass
Well testing (optional for appraisal well only)
Increase in air emissions and ambient lightingDisorientation and mortality of marine birds
Physiological effect on marine fauna
Discharge of produced water and local reduction in water quality
Physiological effect on marine fauna
3. Demobilisation Phase
Abandonment of wellhead on seafloor Increased hard substrate on seafloorObstruction to or damage of fishing gear
Increased benthic biodiversity and biomass
Drilling unit / support vessels leave drill site and transit to port or next destination
Increase in underwater noise levels during transit Disturbance to marine fauna
Discharge of waste to sea (e.g. deck and machinery space drainage, sewage and galley wastes) and local reduction in water quality during transit
Physiological effect on marine fauna
Increased food source for marine fauna
Increased predator - prey interactions
4. Unplanned Activities
Dropped objects / Lost equipment Increased hard substrate on seafloorPhysical damage to and mortality of benthic species / habitats
Obstruction to or damage of fishing gear
Loss of fuel from vessel accidentRelease of fuel into the sea and localised reduction in water quality
Effect on faunal health (e.g. respiratory damage) or mortality (e.g. suffocation and poisoning)
Small instantaneous spills
Discharge of fuel into sea during bunkering bunkering and localised reduction in water quality
Discharge of hydraulic fluid into sea due to pipe rupture and localised reduction in water quality
Loss of well control / well blow-out Uncontrolled release of oil / gas from well
Effect on faunal health (e.g. respiratory damage) or mortality (e.g. suffocation and poisoning)
Smothering of coastal habitats
Reduced fishing grounds and increased fishing effort
Reduced catch
PROJECT ALTERNATIVES
DRILLING STAGES
Riserless Drilling Stage
Drill string
Drilling fluid(Water Based Mud)
WBM & cuttings returns
Conductor pipe
Wellhead
Risered Drilling Stage
SBM and cuttings
Blow-out PreventerWellhead
Conductor pipe
Drilling fluid (SBM)
Marine riser Discharge of treated cuttings
Alternative Description
Drill site Shell is limiting well drilling to the northern portion of the licence area. Impacts are of similar significance no
matter where the well is drilled, assuming that localised hard substrates are avoided.
Drill
scheduleAlthough Shell is proposing to drill in a future summer window period, impacts on sensitive receptors
(specifically fishing at Tripp Seamount) remain of similar significance throughout the different seasons of the
year.
Drilling unit Shell is currently considering two alternative drilling units, either a semi‐submersible drilling vessel or a drill‐
ship. There are no additional impacts or differences in impact significance relating to the choice of drilling unit.
Drilling fluid Two types of drilling fluid would be used during drilling, namely water‐based muds (WBM) and synthetic‐based
muds (SBM). The use of WBMs should be maximised at all times, using risered SBMs only when necessary.
Well
completionDuring well abandonment the wellheads would either remain on or be removed from the seafloor. The
proposed abandonment of well(s) would not contribute to a long‐term or cumulative impact on demersal
fishing.
Logistic base An onshore logistics base would be located in either the Port of Lüderitz or the Port of Walvis Bay. The overall
positive impact on the local economy would be greater if the shore base is located in Lüderitz.
No-Go Alternative Lost opportunity to establish the extent of offshore indigenous oil and gas reserves.
Drill ship Semi‐submersible
SUMMARY OF SENSITIVE RECEPTORS
Shipping route
Namibian Islands Marine Protected Area
Area of Interest
Tripp Seamount
Proposed Orange Shelf Edge EBSA
RECEPTOR DESCRIPTION
1. BIO-PHYSICAL
Tripp SeamountTripp Seamount is located 50 km south-east of the area of interest at its
closest point.
Benthic communities
Deep water benthic fauna inhabiting unconsolidated sediments is
comprised of fast-growing species able to rapidly recruit into disturbed
areas.
Namibia Islands Marine
Protected Area (NIMPA)
The NIMPA comprises the coastal strip north-east of the area of interest.
It has an average width of 30 km and includes 16 offshore islands.
Orange Shelf Edge
Ecologically or Biologically
Significant Area (EBSA)
Licence area overlaps slightly with the proposed transboundary Orange
Shelf Edge EBSA.
2. COMMERCIAL FISHERIES
Commercial fisheries
The area of interest overlaps with only the large pelagic long-line sector.
Aggregations of albacore tuna are known to occur in the vicinity of the
Tripp Seamount and are targeted by the tuna pole fishery.
3. SOCIO-ECONOMIC
Lüderitz and Walvis Bay –
Goods and Services
Namibia doesn’t have an upstream oil and gas industry and because of
the highly specialised nature of the project there will be a reliance on
international service companies and technical skills. Opportunities for
local employment and procurement will be identified.
Lüderitz and Walvis Bay –
Tourism
Ocean and desert-based tourism in Lüderitz and Walvis Bay contributes
significantly to these local economies.
DISCHARGE OF CUTTINGS AND DRILLING FLUIDS
Issue:Physical disturbance of seabed sediments and accumulation of cuttings on the seabed, as well as the increase of sediment in the water column. Impacts include:• Smothering.• Toxicity and bioaccumulation effects.• Physiological and biochemical effects.
Key receptors:Deep water benthic fauna inhabiting unconsolidated sediment, i.e. fast‐growing species that are able to rapidly recruit.
Project Controls:• Pre‐drilling seabed survey with ROV.• Treatment of cuttings to reduce residual SBM content.• Discharge cuttings > 15 m below surface.
Impact Assessment:
Mitigation:Well to avoid identified vulnerable benthic habitats by >500 m.
Residual Impact:Insignificant to Very Low Significance.
Illustration of cuttings discharge from an offshore drilling unit
A seabed survey will be conducted prior to drilling to avoid impacts on deep water corals
September discharge scenario December discharge scenario
17 km2
20 km2
Max. thickness: 71 mm
Max. thickness: 68 mm
UNDERWATER NOISE
Issue:Project activities would increase the ambient noise levels in the vicinity of the drill site . Impacts include:• Physical injury to hearing or other organs.• Masking or interfering with other biologically important sounds.• Behavioural changes or displacement from important feeding areas.
Key receptors:Pelagic seabirds, turtles, large migratory pelagic fish and cetaceans, some of which are ‘Critically Endangered’, ‘Endangered’ or ‘Vulnerable’, specifically at Tripp Seamount.
Project Controls:The size of the area of interest was reduced to increase the distance between the drill site and Tripp Seamount.
Impact Assessment:• Ambient noise level range: 80 – 120 dB re 1 μPa.
(In underwater sound “dB re 1 µPa” is the standard reference unit of sound pressure level in decibels (dB) relative (re) to 1 µPa (micro Pascal or one‐millionth of a Pascal).
• Project noise range: 184 – 190 dB re 1 μPa. • Project noise levels decrease back to below the median ambient noise level
within 32 km.• Project noise decreases to below the upper boundary of ambient background
level of 120 dB within a distance of less than 5 km from the drill site.
Mitigation:Vertical seismic profiling: Pre‐start scan and “soft‐start” procedure.
Residual Impact: Insignificant to Very Low Significance.
Noise level attenuation with distance
Median ambient level
32 km
Distance back to the median ambient noise level
FISHING – IMPACT OF EXCLUSION ZONE AND NOISE
Issue:Reduced catch and/or increased fishing effort due to exclusion zone around drilling unit and operational noise.
Key receptors:• Sector affected by exclusion zone: Large pelagic long‐line sector. • Sectors affected by noise: demersal trawl, demersal long‐line, large pelagic
long‐line and tuna pole fisheries.
Project Controls:The size of the area of interest was reduced to increase the distance between the drill site and Tripp Seamount.
Impact Assessment:• Exclusion zone: 500 m around drilling unit.• Project noise levels will reduce back to below the
median ambient noise level within 32 km.
1. Large pelagic long‐line:
• Effort overlaps with exclusion zone and predicted 32 km project noise zone.
• Less than 1% of total long‐line effort and catch recoded within area of interest (2005 – 2015).
2. Demersal trawl:
• No overlap with exclusion zone.• Western extent is located within 32 km
of area of interest.
Shell licence bock
Initial EIA area
Revised EIA area
Original and revised area of interest
FISHING – IMPACT OF EXCLUSION ZONE AND NOISE (cont.)
Impact Assessment:3. Tuna pole: 4. Demersal long‐line:
• No overlap with exclusion zone.• Minor effort located within
32 km of area of interest.
5. Pelagic purse‐seine: 6. Mid‐water trawl:
• No overlap with exclusion zone.• No effort located within
32 km of area of interest.
Mitigation:• Stakeholder notification: Radio Navigation Warnings and Notice to Mariners.• Vertical seismic profiling: Pre‐start scan and “soft‐start” procedure.
Residual Impact:
• No overlap with exclusion zone.• Minor effort located within
32 km of area of interest.
• No overlap with exclusion zone.• No effort located within
32 km of area of interest.
Sector Significance Sector Significance Sector Significance
Large pelagic long‐line : Very Low Tuna pole: Insignificant Pelagic purse‐seine: No impact
Demersal trawl: Insignificant Demersal long‐line: Insignificant Mid‐water trawl: No impact
SOCIO‐ECONOMIC ‐ PROJECT SPENDING AND TOURISM
Issue:The project would result in a temporary spending injection that would benefit the local economy. All expenditures would lead to increased economic activity in Namibia.
Boost to tourism in the project area(s) through its facilitation of increased business tourism.
Key receptors:The communities living in and businesses operating out of Lüderitz and Walvis Bay.
Project Controls:• Shell’s HSSE & SP Control Framework standards for Social Performance.• Shell’s supplier principles for contractors and suppliers.
Impact Assessment:• Employment:
• Project spending:
• Total project spending:
Mitigation:• Inform local stakeholder of project timing and
opportunities for jobs and procurement.
Residual Impact:
Port support activities
Total personnel requirements 170 – 290 people
Opportunities for local Namibians 15 – 50 people
Employment duration 1 – 12 months
Cumulative local income ± N$ 1 ‐ 2 million
Spending by non‐local personnel ± N$ 2 ‐ 5 million
Spending on food and other supplies ± N$ 3 ‐ 5 million
± N$ 6 million ‐ N$ 12 million
Business tourism:
Historical sites
Water sports
Recreational fishing
Accommodation
Impact Significance
Project spending: Low (+ve)
Tourism: Very Low (+ve)
SOCIO‐ECONOMIC – MARINE TRAFFIC
Issue:The presence of the drilling unit and associated exclusion zone present a potential risk of interference with key shipping routes.
Key receptors:The area of interest is located on the eastern boundary of the main traffic route to and from Cape Town.
Project Controls:• 500 m exclusion zone.• Support vessels to enforce exclusion.
Impact Assessment:• Drilling unit would be stationary and is therefore easily avoidable with minimal
adjustment to a vessel’s course.
Mitigation:• Radio Navigation Warnings.• Notice to Mariners.
Residual Impact:Insignificant.
Maritime traffic
Area of Interest
50 km
Key shipping route
500 m exclusion zone
LARGE OIL SPILL: WELL BLOW‐OUT
Issue:Oil spilled in the marine environment would have an immediate detrimental effect on water quality, resulting in mortality of marine fauna or affecting faunal health. An oil spill would also result in several indirect impacts on fishing.
Key receptors:Namibia Islands Marine Protected Area (NIMPA), Tripp Seamount and associated marine fauna. Fishing sectors operating in southern Namibia.
Project Controls:• Technical and HSSE standards and procedures.• Equipment testing and certification.• Multiple barriers, e.g. Blow‐out Preventer, casings and wellbore pressure.• Oil Spill Response Plan and Well Control Contingency Plan.
Impact Assessment:• The probability of a well blow‐out occurring is highly unlikely.• There is a low probability of oil extending into key fish spawning/nursery areas.
Mitigation:• Implement emergency plans.• Use low toxicity dispersants only with the permission of MET/MFMR.
Residual Impact: Medium Significance.
Stochastic analysis – 8‐day blow‐out (400 000 bbl) Stochastic analysis – 90‐day blow‐out (4 500 000 bbl)
Spill orientation North‐West
Shoreline oiling None
Zone of highest oiling (75‐100% probability)
125 km
Spill orientation North‐West
Shoreline oiling None
Zone of highest oiling (75‐100% probability)
200 km
SMALL OIL SPILL: LOSS OF MARINE DIESEL
Issue:Small instantaneous spills would have an immediate detrimental effect on water quality, with the toxic effects potentially resulting in mortality of marine fauna or affecting faunal health. There may also be potential indirect impacts on fishing.
Key receptors:• Pelagic seabirds, turtles, large migratory pelagic fish and cetaceans. • The area of interest overlaps with the large pelagic long‐line sector.
Project Controls:• Technical and HSSE standards and procedures.• Equipment testing and certification.• Competent staff.
Impact Assessment:
Mitigation:• Implement Shipboard Oil Pollution Emergency Plan.• Use low toxicity dispersants only with the permission of MET/MFMR.• Inspect and maintain all chemical / fuel containers.
Residual Impact:Impact Significance
Marine fauna: Insignificant
Fishing: Very Low
Spill orientation North‐West
Shoreline oiling None
Zone of highest oiling (75‐100% probability)
1 km
Zone with probabilities >1% of oiling
12.5 km
Instantaneous release of 10 000 litres of diesel
EIA CONCLUSIONS
• Ecological integrity:• The area of interest is far removed from
sensitive coastal receptors.• Atlantic Offshore Bioregion is classified as
Least Threatened.• Deep water benthic fauna inhabiting
unconsolidated sediments is less susceptible to the effects of smothering.
• Recovery of benthic fauna in 2 – 5 years.• Negligible loss of ecological integrity.
• Economic efficiency:• Project is largely compatible with key
socio‐economic policies and plans.• Only the large pelagic long‐line sector is
directly affected – exclusion from 500 m safety zone.
• Adverse underwater noise impacts at the Tripp Seamount are considered unlikely.
• Limited jobs and local project spending.• Economically efficient, as no other party/ies
would be significantly impacted.
• Equity and social justice:• No unfair discrimination on any one party.• Negative impacts are not unequally
distributed.
The generally INSIGNIFICANT to LOWsignificant impact with mitigation should
support a positive decision and the issuing of an Environmental Clearance Certificate
SUMMARY OF IMPACTS AND SIGNIFICANCE RATINGS – NORMAL OPERATIONS
No. Activities ImpactsProbability with
mitigation
Significance
Without
mitigationWith mitigation
1 Emissions to the atmosphere:
1.1Emissions from vessel operation (incl.
incineration of waste and well testing)
Physiological effect on marine fauna and contribution to global
greenhouse gas emissionsProbable Very Low VERY LOW
2 Discharge of wastes to sea:
2.1 Discharge of cuttings, drilling fluid and cement
Smothering by cuttings, drilling fluid
and cement
Unconsolidated sediments PossibleInsignificant ‐
Very Low
INSIGNIFICANT ‐
VERY LOW
Hard substrates Improbable Low ‐Medium INSIGNIFICANT
Toxicity and bioaccumulation effects on
marine fauna
WBM Possible Very Low INSIGNIFICANT
SBM Probable Very Low VERY LOW
Cement Possible Very Low INSIGNIFICANT
Increased water turbidity and reduced light penetration Possible Insignificant INSIGNIFICANT
Reduced physiological functioning of marine organisms due to
indirect biochemical effectsPossible Insignificant INSIGNIFICANT
3 Physical disturbance of the seabed sediments:
3.1Seabed survey, spudding and wellhead
installation
Physical damage to, mortality of and physiological effects on
benthic faunal communitiesProbable Very Low VERY LOW
Emissions from drilling unit operation and well testing / flaringSeabed disturbance due to infrastructure installation
Drill string and wellhead guide base
SUMMARY OF IMPACTS AND SIGNIFICANCE RATINGS – NORMAL OPERATIONS
No. Activities ImpactsProbability with
mitigation
Significance
Without
mitigationWith mitigation
4 Noise
4.1Noise emissions from the operation of the
drilling unit and support vessels
Masking of biologically significant sounds Probable Very Low VERY LOW
Behavioural changes or displacement from important feeding or
breeding areasPossible Insignificant INSIGNIFICANT
4.2 Noise emissions from Vertical Seismic ProfilingMasking of biologically significant sounds and behavioural changes or
displacement from important feeding or breeding areasPossible Very Low INSIGNIFICANT
5 Physical presence of subsea infrastructure:
5.1 Abandonment of the well(s) on the seafloor Increased the benthic biodiversity and biomass Definite Low (neutral) LOW (NEUTRAL)
6 Local project spending:
6.1Employment of local staff and purchase of
goods and services
Increased economic activity linked to employment and incomes
(salaries, fees, rentals, etc.)Definite Very Low (+ve) LOW (+VE)
7 Commercial fishing:
7.1Noise emissions from vessels and drilling
operations
Loss of catch and / or increased fishing effort due to behavioural
changes or displacement of fish from important feeding areasPossible Insignificant INSIGNIFICANT
7.2 Discharge of well drill cuttings and cementLoss of catch and / or increased fishing effort due to affect predator–
prey interactions (large pelagic long‐line sector only)Improbable Insignificant INSIGNIFICANT
Key noise sources:
Drilling unit Helicopter operationsSupport vessels Drilling Vertical Seismic Profiling (VSP)
SUMMARY OF IMPACTS AND SIGNIFICANCE RATINGS – UNPLANNED ACTIVITIES
No. Activities ImpactsProbability with
mitigation
Significance
Without
mitigationWith mitigation
1 Small operational spill
Toxic effect on faunal health (e.g. respiratory damage) and mortality
(e.g. suffocation and poisoning)Possible Low INSIGNIFICANT
Impact on commercial fishing through exclusion from polluted areas
and reduced recruitmentProbable Very Low VERY LOW
Exclusion of sea‐based tourism activities Improbable Low VERY LOW
2 Large well blow‐outs
Effect on faunal health (e.g. respiratory damage) or mortality (e.g.
suffocation and poisoning)Improbable High MEDIUM
Impact on commercial fishing through exclusion from polluted areas,
reduced recruitment and fishing gear damageImprobable Medium MEDIUM
Impact on tourism through the exclusion of sea‐based tourism
activities Improbable Low VERY LOW
3 Dropped objectsPhysical damage to and mortality of benthic species / habitats Possible Low INSIGNIFICANT
Increased the benthic biodiversity and biomass Possible Insignificant NO IMPACT
Capping stack systemBlow‐out preventer
Project controls for oil spillsImprobable event of an 8‐day blow‐out (400 000 bbl) –
worst case simulation scenario
Oil spill booms
EXTRACT FROM ENVIRONMENTAL MANAGEMENT PLAN – OPERATION PHASE
No. Activities AspectsKey
Receptors
Environmental
and Social
Performance
Objective
Indicators TargetsMitigation and Management
actions
Type of
Mitigatio
n Option
Responsi‐
bility
Frequency
/ timing
Monitoring
and record
keeping
require‐
ments
1 Operation
of drilling
unit at drill
site
Creation of
an exclusion
zone around
drilling unit
which other
vessels
cannot enter
Fishing
industry
and
mariners
Ensure
navigational
safety
All maritime
stakeholders
informed of
project
timing, vessel
information,
transit and
location
Zero maritime
incidents
All maritime
stakeholders
on project
database
notified
Request, in writing, HyrdoSAN to
release Radio Navigation
Warnings via Navigational Telex
(Navtext) and Lüderitz radio.
Avoid /
reduce at
source
Shell 7 days
prior to
establish‐
ment at
drill site
and
throughout
drilling
Confirm that
request was
sent to
HydroSAN
2 Distribute a Notice to Mariners to
fishing companies and directly
onto vessels. The notice should
give notice of:
the co‐ordinates of the well
location;
an indication of the proposed
drilling timeframes;
an indication of the 500 m
safety zone around the drilling
unit; and
provide details on the
movements of support vessels
servicing the drilling operation.
Avoid /
reduce at
source
7 days
prior to
establish‐
ment at
drill site
Copies of all
correspon‐
dence
Fisheries Notification:
Radio Navigation warning and Notice to Mariners
Drill ship:
A 500m safety zone will be established around the drilling unit according to Article 60 of the United Nations Convention of the Law of the Sea
EXTRACT FROM ENVIRONMENTAL MANAGEMENT PLAN – OPERATION PHASE
No. Activities AspectsKey
Receptors
Environmental
and Social
Performance
Objective
Indicators TargetsMitigation and Management
actions
Type of
Mitigation
Option
Respon‐
sibility
Frequency /
timing
Monitoring
and record
keeping
require‐
ments
3 Well
drilling
Discharge of
drill cuttings
Marine
fauna,
specifically
benthic
fauna
Protect
sensitive
seabed
habitats
Smothering
of hard
substrates
Zero
disturbance
of hard
substrates,
which house
sensitive
benthic
communities
Review ROV footage of pre‐
drilling surveys to identify
potential vulnerable habitats
within 500 m of the drill site.
Ensure drill site is located more
than 500 m from any identified
vulnerable habitats.
Avoid /
reduce at
source
Drilling
contractor /
Shell
Prior to
spudding
ROV footage
4
5 Drilling fluid
additives
Use only low‐
toxicity and
biodegradable
additives in
drilling fluid
Ensure only low‐toxicity and
partially biodegradable
additives are used in drilling
fluid.
Avoid /
reduce at
source
Drilling
contractor
Prior to
drilling
Volume
discharged
Additives in
drilling fluid
Oil content
of SBM drill
cuttings
6 Oil content:
≤6.9%
PAH: 0.001
Hg: <1 mg/kg
Cd: <3 mg/kg
Treatment of cuttings to reduce
the:
Oil content to 6.9% or less of
dry cutting weight;
PAH to less than 0.001;
Hg to less than 1 mg/kg; and
Cd to less than 3 mg/kg.
Reduce at
source
Drilling
contractor
Throughout
risered
drilling
Cuttings treatment:
Shale shakers separate solids from liquids. The liquids are pumped back downhole, while the solids are removed and undergo further treatment before disposal
Pre‐drilling seabed survey:
An remotely operated vehicle (ROV) will be used for pre‐drilling seabed survey