9 ENVIRONMENTAL MANAGEMENT PLAN

Transcription

1 SLR Environmental Consulting (Namibia) (Pty) Ltd Page ENVIRONMENTAL MANAGEMENT PLAN 9.1 INTRODUCTION SCOPE AND OBJECTIVES The objectives of the EMP are to: fulfil the of Namibian EIA legislation and international Conventions; be consistent with oil and gas industry good practices and Shell s own project standards; identify potential impacts and outline the appropriate mitigation options to ensure that impacts are minimised, after first establishing whether impacts cannot be avoided; provide an implementation mechanism for mitigation measures and commitments identified in the EIA Report; establish a monitoring programme and record-keeping protocol against which Shell and its contractor s/sub-contractor s performance can be measured and to allow for corrective actions or improvements to be implemented when needed; and provide protocols for dealing with unforeseen circumstances such as unplanned events or ineffective mitigation measures SUPPORTING DOCUMENTATION The additional management plans, which will be prepared by Shell prior to the drilling date, include: Oil Spill Response Plan and Emergency Response Plan: These plans will include all res and action required to manage Tier 1, 2 and 3 spills and any impact on the environment, including the Namibian and any neighbouring coastlines. Shipboard Oil Pollution Emergency Plan (SOPEP): Regulation 37 of MARPOL Annex I requires that all ships of 400 gross tonnage and above carry an approved SOPEP. The purpose of a SOPEP is to assist personnel in dealing with unexpected discharge of oil, to set in motion the necessary actions to stop or minimise the discharge, and to mitigate its effects on the marine environment. Ballast Water Management Plan: All ships engaged in international traffic are required to manage their ballast water and sediments to a certain standard, according to a ship-specific ballast water management plan. This plan deals with the ballast water management system on each of the project s, including how it operates and procedures for monitoring and reporting. Waste Management Plan: This plan establishes procedures for the storage, collection and disposal of waste, including liquid and solid waste and hazardous and non-hazardous wastes. Well Control Contingency Plan: This plan is a specific response guide used in the case of well control emergency. The requirement for each of these plans is referred to in the relevant sections of the EMP tables (see Section to ).

2 SLR Environmental Consulting (Namibia) (Pty) Ltd Page EMP STRUCTURE This EMP is divided into the following sections. Section Section 9.1 Contents Introduction s of the EMP and lists the ing documents. Section 9.2 Sensitive Sensitivities in the project area and the implications for the project. Section 9.3 Project Controls and Measures Project controls and mitigation measures to first avoid and, when avoidance was not possible, then reduce potentially significant impacts of the proposed exploration drilling activities. Section 9.4 Roles and Responsibilities environmental management roles and responsibilities with respect to implementation and management of the EMP. Section 9.5 Training, Awareness and Competency Training and awareness provisions for Shell staff and Contractors involved in the project. Section 9.6 Compliance Verification and Corrective Actions Measures to ensure compliance with the EMP and implementation of corrective actions. Section 9.7 Management of Change Procedure to be followed to respond to changes to the EMP and/or drilling design. Section 9.8 Communication Communication channels between Shell, the contractor(s) and external stakeholders. Section 9.9 Document Control and Reporting Document control and reporting (internal and external). Section 9.10 Environmental Management Plan Management commitments that will be implemented to prevent, minimise or manage significant negative impacts and optimise and maximise any potential benefits of the project.

3 SLR Environmental Consulting (Namibia) (Pty) Ltd Page SENSITIVE RECEPTORS An overview of the key sensitivities in the study area and implications for the project is provided below and presented in Figure 9-1. Receptor/Vari able Implications for proposed project 1. Bio-physical considerations Tripp Seamount Namibian Islands Marine Protected Area (NIMPA), including offshore islands and seal/seabird colonies Tripp Seamount is a geological feature located approximately 50 km to the south-east of the area of interest. Seamounts typically complex benthic ecosystems with higher productivity, which in turn enhance foraging opportunities for many other predators, serving as mid-ocean focal points for a variety of pelagic species with large ranges (turtles, tunas and billfish, pelagic sharks, cetaceans and pelagic seabirds) that may migrate large distances in search of food or may only congregate on seamounts at certain times. Aggregations of albacore tuna are known to occur in the vicinity of the Tripp Seamount and are targeted by the tuna pole fishery. The drill cuttings deposition footprint extends up to 7 km from the drill site, while drilling noise is predicted to return back to ambient levels within 32 km of the drill site. In addition, the dominant wind and current direction would result in discharges moving mainly in a north-westerly away from the seamount. Due to the distance between the area of interest and the seamount and the dominant winds and currents, impacts from operational discharges and noise are unlikely to impact marine fauna and fishing at Tripp Seamount. Thus, there are no implications for the project. The NIMPA was established for the purpose of protecting sensitive ecosystems and breeding and foraging areas for seabirds and marine mammals, as well as protecting important spawning and nursery grounds for fish and other marine res (such as rock lobster). It comprises the coastal strip extending from Hollamsbird Island (24º38 S) in the north to Chamais Bay (27º57 S) in the south. It is km 2 in extent, has an average width of 30 km and includes 16 specified offshore islands, islets and rocks. Atlas Bay, Wolf Bay and Long Islands (near Lüderitz) together represent the largest breeding concentration of seals in Namibia. Further colonies are located at van Reenen Bay and Bakers Bay. These islands also provide a vital breeding habitat for seabirds, some of which are threatened (e.g. African penguin, bank cormorants, crowned cormorants, oystercatchers and gannets). Southern right whale calving and nursing activities are known to occur in Elizabeth Bay (approximately 8 km south-east of a direct flight path between the Lüderitz airport and the area of interest) and Hottentot Bay (approximately 60 km north of Lüderitz, well to the north of a direct flight path). The months of main calving and nursing activities include June to September. Helicopters and s operating between Lüderitz and the drilling unit would be required to travel over/through the NIMPA. Helicopter would need to avoid offshore islands, seal/bird colonies and maintain an altitude of at least m within the NIMPA. 2. Socio-economic considerations Fishing Tourism Fishing plays a significant role in providing livelihoods and income for communities living in and around Walvis Bay and Lüderitz. There is thus a need to notify key sectors regarding the drilling programme and exclusion zone around the drilling unit. The large pelagic long-line sector is the only sector that overlaps with the area of interest. The drilling unit would need to maintain the 500 m safety zone around the unit. Support s on route to and from Lüderitz would also need to avoid other fishing s that are limited in their manoeuvrability. There is also a need to manage impacts to the marine environment, especially of un-planned events such as oil spills. Given that tourism in Lüderitz and Walvis Bay is largely centred on ocean-based experiences, the project would have to place significant emphasis on mitigating the impacts associsated with unplanned events such as oil spills. The relatively small size of Lüderitz may require management of accommodation for project personnel in the peak tourist seasons in order that adequate accommodation is still available for other tourists.

4 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-4 Namibian Islands Marine Protected Area Shipping route Area of Interest Tripp Seamount Inset: islands and bays in the NIMPA Figure 9-1: project sensitivities

5 SLR Environmental Consulting (Namibia) (Pty) Ltd Page PROJECT CONTROLS AND MITIGATION MEASURES The mitigation hierarchy, as specified in IFC Standard 1, is widely regarded as a good practice approach to managing risks and is based on a hierarchy of decisions and measures, as described in Table 9-1. This is aimed at ensuring that wherever possible potential impacts are mitigated at rather than mitigated through restoration after the impact has occurred. measures, identified as part of the EIA process, is aimed at first preventing, then minimising or managing significant negative impacts to as low as reasonably practicable (ALARP) and optimising any potential benefits of the proposed project. measures referred to as project controls are integrated into the project design and standard operating procedures (refer to Box 9-1 for the project controls). These measures require proactive checking and verification prior to any project activities in-country. The additional mitigation measures identified by the specialist scientists and EIA Team have been integrated into this EMP and will be integrated into the contract documents for the drilling, drilling services, logistics and other. The specific management commitments (project controls and mitigation measures) that will be implemented are presented in Section Table 9-1: The mitigation hierarchy at Source Abate on Site Abate Offsite/at Receptor Repair or Restore Compensate or Offset ing or reducing at is essentially designing the Project so that a feature causing an impact is designed out (e.g. a waste stream is eliminated). This involves adding something to the basic design or procedures to abate the impact (often called end-of-pipe ) or altered (e.g. reduced waste volume) and is referred to as minimisation Pollution controls fall within this category. If an impact cannot be abated on-site then measures can be implemented off-site an example of this in the case of the drilling programme would be disposing of waste generated on-board at a proper waste facility onshore. Measures may also be taken to protect the receptor. Some impacts involve unavoidable damage to a re, e.g. shoreline pollution arising from an oil spill. Repair essentially involves restoration and reinstatement type measures, such as clean-up of the shoreline. Where other mitigation approaches are not possible or fully effective, then compensation, in some measure, for loss, damage and general intrusion might be appropriate. An example could be compensation for loss of earnings if fisheries were to be permanently impacted by a Project activity.

6 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-6 Box 9-1: Project Controls Project Controls are the physical or procedural controls that are planned as part of the project (i.e. they are embedded into the project design). Shell s offshore exploration projects are carried out within a framework of national regulations, international conventions, corporate policies and procedures, and recognised third party guidelines, all of which have different applications, remits, and implications. Shell has developed Project Controls (or Standards) for offshore drilling and those applicable to this project are listed below. 1. Emissions and discharges Project s comply with the emission criteria within MARPOL 73/78 Annex VI, which prohibits the: > deliberate emission of Ozone Depleting Substances; and > incineration of certain products, such as contaminated packaging materials and polychlorinated biphenyls (PCBs). The drilling unit would use marine diesel that has a maximum sulphur content of 0.1%. The following is specified for Ozone Depleting Substances: > Identification of all Ozone Depleting Substances and maintenance of an inventory until Ozone Depleting Substances are eliminated. > Elimination of halons and hard chlorofluorocarbons (HCFCs) in all operations by end-of-year 2010 and HCFCs by beginning-of-year > Removal of Ozone Depleting Substances from Non-Sealed Systems. > Provision of controls to prevent the loss of Ozone Depleting Substances. > Provision of controls for the recovery and destruction of Ozone Depleting Substances. > the transfer of Ozone Depleting Substances to third parties for re-use. Where permitted by legislation, in-company transfers and transfer to Halon banks are permitted. > Provision of controls to ensure that new installations are not fitted with HCFCs. > Provision of terms that comply with the above in contracts for the purchase, service or disposal of equipment or refrigerant that contains Ozone Depleting Substances. > Ensuring people are aware of equipment that contains Ozone Depleting Substances and the controls required before they perform work that could release these substances. > Application of the Permit to Work system in order to control work on, or disposal of, equipment that contains Ozone Depleting Substance in line with the above. Sewage and grey water discharges from s are regulated by MARPOL 73/78 Annex IV, which specifies the following: > Vessels must have a valid International Sewage Pollution Prevention Certificate. > Vessels must have an onboard sewage treatment plant providing primary settling, chlorination and dechlorination before discharge of treated effluent. > Discharge of sewage beyond 12 nm requires no treatment. However, sewage effluent must not produce visible floating solids in, nor cause the discolouration of, the surrounding water. > Sewage must be comminuted and disinfected for discharges between 3 nm (± 6 km) and 12 nm (± 22 km) from the coast. This would require an onboard sewage treatment plant or a sewage comminuting and disinfecting system. > Disposal of sewage originating from holding tanks must be discharged at a moderate rate while the ship is proceeding on route at a speed not less than 4 knots. Sewage would be treated using a marine sanitation device to produce an effluent with: > a biological oxygen demand (BOD) of <25 mg l -1 (if the treatment plant was installed after 1/1/2010) or <50 mg l -1 (if installed before this date); > minimal residual chlorine concentration of 1.0 mg l -1 ; and > no visible floating solids or oil and grease. The discharge of biodegradable wastes from s is regulated by MARPOL 73/78 Annex V, which stipulates that: > No disposal to occur within 3 nm (± 5.5 km) of the coast. > Disposal between 3 nm (± 5.5 km) and 12 nm (± 22 km) needs to be comminuted to particle sizes smaller than 25 mm.

7 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-7 Box 9-1 cont. 1. Emissions and discharges (cont.) Discharges of water (deck drainage, bilge and mud pit wash residue) to the marine environment are regulated by MARPOL 73/78 Annex I, which stipulates that s must have: > A Shipboard Oil Pollution Emergency Plan (SOPEP). > A valid International Oil Pollution Prevention Certificate, as required by class. > Equipment for the control of oil discharge from machinery space bilges and oil fuel tanks, e.g. oil separating/filtering equipment and oil content meter. Oil in water concentration must be less than 15 ppm prior to discharge overboard. > Oil residue holding tanks. > Oil discharge monitoring and control system. Ballast water discharge would comply with the of the IMO s 2004 International Convention for the Control and Management of Ships Ballast Water and Sediments, including: > the implementation of a Ballast Water Management Plan; and > conducting such exchange at least 200 nm (± 370 km) from the nearest land and in water of at least 200 m depth. Where this is not feasible, the exchange should be as far from the nearest land as possible, and in all cases a minimum of 50 nm (± 93 km) from the nearest land and preferably in water at least 200 m in depth. The discharge of drilling fluids and cuttings would comply with the following standards: > Discharge of cuttings via a caisson at greater than 15 m water depth; > Discharge of cuttings only in water depths greater than 30 m; > 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. Cement returns would be monitored and pumping would be terminated if returns are observed on the seafloor. 2. Social A Social Plan, which includes a Social Investment Strategy, will be established and maintained. Stakeholder engagement will be undertaken in order to: > inform key stakeholders of project progress; > communicate a procedure to receive, track and respond to questions and complaints; and > seek input on the social impacts of business activities, and on mitigation or enhancement measures. 3. Supplier Principles for and suppliers Business integrity: > Contractors and suppliers are required to comply with all applicable laws and regulations. > Contractors and suppliers should not tolerate, permit or engage in bribery, corruption or unethical practices. > Contractors and suppliers are to fair competition. > Conflicts of interest are avoided. Health, Safety, Security and Environment: > Contractors and suppliers must be committed to protect the environment in compliance with all applicable environmental laws and regulations. > Contractors and suppliers must use energy and natural res efficiently. > Contractors and suppliers must minimise waste, emissions and discharge of their operations, products and services.

8 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-8 Box 9-1 cont. 3. Supplier Principles for and suppliers (cont.) Social performance: > Contractors and suppliers are to respect their neighbours and contribute to the communities in which they operate. Labour and human rights: > Contractors and suppliers are to conduct their activities in a manner that respects human rights as set out in the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organisation. Contractors and suppliers should: Not use child labour; Not use forced, prison or compulsory labour; Comply with all applicable laws and regulations on freedom of association and collective bargaining; Not tolerate discrimination, harassment or retaliation and should provide a safe, secure and healthy workplace; and Provide wages and benefits that meet or exceed the national legal standards and comply with all applicable laws and regulations on working hours. 4. Oil spills Design and technical integrity: > Well design would be undertaken in accordance with Shell design manuals and standards, which includes for well engineering, completion and well intervention personnel. Multiple well casings: > Casings would be designed to withstand a variety of forces, such as collapse, burst or tensile failure, as well as chemically aggressive brines; and > Casings would be run to prevent caving-in of upper formations, provide strong foundations for high density fluids, isolate zones of fluid loss or different pressure gradients and prevent fluid loss into or contamination of production zones. Wellbore pressure: > Subsurface pressures above and within the hydrocarbon-bearing strata would be controlled by the use of weighted drilling mud; and > The hydrostatic pressure of the drilling mud in the well would be adjusted by adding weighting agents such as barites to ensure that it is greater than the formation pressure to prevent the undesired influx of fluids into the wellbore (known as a kick ); and > Pressure monitoring would be undertaken during drilling to ensure that kicks are avoided or managed to prevent escalation into a blowout. BOP stack: > BOP stacks would be used to control the pressure of a well through mechanical devices designed to rapidly seal the well (or shut in ) in an emergency. Competent staff: > Shell has competent people who would design the well and monitor drilling. Testing and certification: > Safety critical equipment would be subject to testing and certification to ensure that it meets design specifications. The well design, drilling, preparation and completion plans would go through several stages of review involving experts from Shell and the drilling contractor prior to the commencement of drilling operations. > As standard practice, an Oil Spill Response Plan would be prepared and put in place at all times during the drilling operation. There are three principal components underpinning an Oil Spill Response Plan: Crisis management (Emergency Command and Control Management). Spill response, containment and clean-up. Well control.

9 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-9 Box 9-1 cont. 4. Oil spills (cont.) Emergency command and control management: > Emergency command and control management arrangements range from the On-scene Commander, normally at the of the incident, to the main Emergency Control Centre Incident Commander who takes over control. As each level is activated, the level of response would equally escalate. Well control: > Whilst the Oil Spill Response Plan defines the approach and strategy required to manage the containment, removal and clean up following a major spill, the well control process is focussed on stopping the of the leak. > A Well Control Contingency Plan would be put in place for each well. Cap and containment equipment: > If the BOP does not successfully shut off the flow from the well, the drilling rig would disconnect and move away from the well site while crews mobilise a capping system. The capping system would be lowered into place from its barge and connected to the top of the BOP to stop the flow of oil or gas. Shell is a member of Oil Spill Response Limited (OSRL), which operates advanced well intervention and capping equipment from Saldanha Bay for deployment in the event of a subsea well control incident. All of Shell s wells are designed to allow for capping. Containment and clean-up equipment: > Project s would be equipped with appropriate Tier 1 spill containment and clean-up equipment, e.g. booms, dispersants and absorbent materials. > All relevant crews would be trained in spill clean-up equipment use and routine spill clean-up exercises. Logistical arrangements for the integration of additional would be in place (e.g. from OSRL). 9.4 ROLES AND RESPONSIBILITIES The project would have dedicated competent personnel that would manage and oversee the Environmental, Health and Safety (EHS) aspects over the project lifecycle. Shell would, however, retain the primary responsibility for meeting environmental commitments throughout the project life span. The key environmental management roles and responsibilities are presented in Figure 9-2 and Box 9-2. Shell Operations Manager / Well Delivery Manager Shell HSSE Manager Shell Logistics Manager Offshore Installation Manager Platform Supply Vessel Supply Base Manager Drilling unit crew Platform Supply Vessel Crew Supply Base Personnel Figure 9-2: Organogram of key staff involved in the implementation of the EMP

10 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-10 Box 9-2: Staff Office Based Staff environmental management roles and responsibilities Shell Operations Manager / Well Delivery Manager Shell HSSE Manager Environmental Accountabilities And Responsibilities Accountable for ensuring that this EMP becomes part of the Shell tender documents and eventually part of the contract for all Contractors. Accountable for ensuring the implementation of this EMP and any additional approval conditions contained in the Environmental Clearance Certificate issued by the Environmental Commissioner. Accountable for ensuring that the HSSE Plans of the Contractors (including drilling unit, platform supply, logistics and helicopter) include the of this EMP relevant for their work and role in the project. Accountable for ensuring that sufficient res are deployed to implement this EMP. Accountable for ensuring that all staff (including drilling unit, platform supply and logistics base and helicopter) are given an Environmental Induction and that further environmental refresher training is undertaken at crew change periods. Accountable for developing the Permits and Legal Register and for assigning relevant Shell staff to manage the process of obtaining permits. Responsible for providing the EMP to the Shell Operations Manager / Well Delivery Manager and all other relevant Shell staff. Responsible for ensuring that all Shell and Contractors staff understand their specific accountabilities, responsibilities, ing, communication and information roles. Responsible for reviewing the HSSE Plans of the Contractors (including drilling unit, platform supply, logistics and helicopter) for acceptability and ensuring compliance with this EMP. Responsible for ensuring that the environmental performance objectives in this EMP are achieved. Responsible for ensuring that the Contractors (including drilling unit, platform supply, logistics and helicopter) comply with the in the EMP. Responsible for ensuring that environmental audits are undertaken to measure compliance with the agreed environmental performance objectives. Providing advice in the event of an oil spill or other environmental incidents. Responsible for ensuring that environmental monitoring and reporting are undertaken by the Contractors (including drilling unit, platform supply, logistics and helicopter). Responsible for ing and advising the drilling unit based Shell HSSE representative. Responsible for ensuring that environmental induction and environmental refresher material is developed. Responsible for ensuring that all staff (including drilling unit, platform supply and logistics base and helicopter) are given an environmental induction and that further environmental refresher training is undertaken at crew change periods. Support in-country Shell staff to liaise with the applicable government departments to gain approvals and permits. Support in-country Shell staff with stakeholder engagement as per the outlined in this EMP.

11 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-11 Box 9-2 cont. Staff Office Based Staff Shell Logistics Manager Drilling Unit Based Staff Shell Drilling Superintendent / Well Site Manager Shell HSSE Representative Drilling Unit Offshore Installation Manager Environmental Accountabilities And Responsibilities Responsible for ensuring the implementation of this EMP relevant to logistics and waste. Responsible for ensuring that waste is managed on the drilling unit and sent to shore as per the Waste Management Plan and in the EMP. Responsible for ensuring that the Logistics and Helicopter Contractors comply with the in the EMP. Responsible for ensuring that environmental monitoring and reporting are undertaken by the Logistics and Helicopter Contractors. Support the Shell HSSE Manager in achieving the environmental performance objectives specified in the EMP. Accountable for ensuring that the drilling programme is undertaken as detailed in this EMP. Accountable for ensuring that the management and mitigation measures detailed in this EMP are implemented on the drilling unit. Accountable for ensuring that environmental incidents and non-compliance with the performance objectives, standards and mitigation measures are reported to the Shell Operations Manager / Well Delivery Manager. Accountable for ensuring that periodic environmental audits are undertaken as specified in this EMP. Responsible for monitoring and reporting the status of the implementation of the EMP. Support the Shell Drilling Superintendent / Well Site Manager to ensure that the management and mitigation measures detailed in this EMP are implemented on the drilling unit. Responsible for ensuring that environmental incidents and non-compliance with the performance objectives, standards and mitigation measures are reported to the Shell Drilling Superintendent / Well Site Manager. Responsible for ensuring that periodic environmental audits are undertaken as specified in this EMP. Review the Contractors procedures and provide input into daily toolbox talks. Provide day-to-day environmental for activities. Accountable for ensuring that all operations aboard the drilling unit are carried out in a manner consistent with this EMP. Accountable for ensuring that Shell s HSSE policy is followed. Accountable for monitoring and reporting to Shell on the performance against relevant environmental procedures, legislative, commitments and conditions applicable to the drilling program. Accountable for ensuring that personnel working on the drilling unit receive an environmental induction and environmental refresher training that meets the specified in this EMP. Accountable for recording and reporting incident reports. Accountable for ensuring that all personnel are adequately trained, competent and have the ability to carry out duties as required in this EMP. Accountable for notifying the Shell Drilling Superintendent / Superintendent / Well Site Manager of any incidents arising from operations that may have an adverse impact on the performance objectives identified in this EMP. Accountable for ensuring that emergency drills are conducted as per the drilling unit s schedule. Accountable for ensuring that the drilling unit s Emergency Response Team has been given sufficient training to implement the drilling unit s Shipboard Oil Pollution Emergency Plan.

12 SLR Environmental Consulting (Namibia) (Pty) Ltd Page TRAINING, AWARENESS AND COMPETENCY Shell would identify, plan, monitor and record training needs for personnel whose work may have a significant adverse impact upon the environment. Shell recognises that it is important that employees at all levels are aware of Shell s HSSE policy, potential impacts of their activities, and roles and responsibilities in achieving conformance with the policy and procedures. The personnel with responsibilities in specific environmental practices will be adequately trained to ensure effective implementation of the works instructions and procedures for which they have responsibilities. This training would include awareness and competency with respect to: General awareness relating to deep water exploration well drilling activities, including environmental and social impacts that could potentially arise from project activities; Legal in relation to environmental performance; Necessity of conforming to the of the Environmental Clearance Certificate and EMP, including reporting (i.e. such as incident reporting); Activity-specific training (i.e. waste management practices); Roles and responsibilities to achieve compliance, including change management and emergency response. Training would take cognisance of the level of education, designation and language preferences of the personnel. Shell would also require that each of the appointed institute training programmes for its personnel. Each contractor will be responsible for site HSSE awareness training for personnel working on the project and for identification of any additional training to maintain required competency levels. The contractor training programme will be subject to approval by Shell and it will be audited to ensure that: training programs are adequate; all personnel requiring training have been trained; and competency is being verified. 9.6 COMPLIANCE VERIFICATION AND CORRECTIVE ACTIONS Inspections, monitoring and auditing will be undertaken to confirm appropriate implementation of the EMP, as well as the effectiveness of mitigation measures. Corrective actions include those intended to improve performance, non-compliances and non-conformances INSPECTION Contractors will be required to conduct daily and weekly HSSE inspections in an effort to monitor compliance and implement conditions stipulated in this EMP. The results of the inspection and monitoring activities will be reported to the Shell Drilling Superintendent / Well Site Manager and Shell HSSE Representative MONITORING Monitoring will be conducted to ensure compliance with regulatory and the performance objectives specified in the EMP, as well as to evaluate the effectiveness of operational controls and mitigation measures. The main objectives of the monitoring programme will be to: Gather, record and analyse data required for regulatory and EMP purposes.

13 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-13 Verify the predictions and conclusions made in the EIA. Identify changes in the physical, biological and social environment. Produce information to evaluate environmental performance specified in the EMP. Produce information about emergencies that require an immediate response. Obtain information on the actual and potential environmental impacts of exploration activities. Use monitoring results as a of information and as grounds for decision making regarding the design of new mitigation measures. Describe whether and to what extent discharges from exploration activities have had impacts on the marine environment. Monitoring will include, but not limited to the following: No. Risk Criteria to be monitored Inspections Accountability 1 Sensitive seabed structures Hard substrate and rocky outcrops Type and quantity of benthic fauna ROV inspection prior to drilling Offshore Installation Manager 2 Ballast water Volume discharged and location Compliance with Ballast Water Management Plan 3 Drilling fluids (WBM and SBM) Volume on board Volume used Volume discharged Toxicity, barite contamination and oil content Residual SBM sent to shore (at end of drilling) 4 Cement Volume used Pressure testing on abandonment cement plugs 5 Chemicals and hazardous materials Volume stored Volume consumed 6 Drill cuttings Volume discharged Oil content in drill cuttings 7 Deck drainage/machinery space/bilge water Correct operation of oil separating/filtering equipment and oil content meter (compliance with MARPOL 73/78 standards) 8 Sewage discharge Correct operation of sewage treatment system (compliance with MARPOL 73/78 standards) 9 Galley waste Type and volume discharged/incinerated Correct operation of macerator After de-ballasting Recorded daily in the operational log inspection During cementing operations Daily operational inspection of the: Storage area Management and transfer procedures Log sheet update Recorded daily in the operational log inspection Prior to drilling and once during campaign At start and once during campaign Recorded daily in the operational log inspection At start and once during campaign Drilling Unit Vessel Captain Offshore Installation Manager Offshore Installation Manager Offshore Installation Manager Offshore Installation Manager Drilling Unit Vessel Captain Drilling Unit Vessel Captain Drilling Unit Vessel Captain

14 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-14 No. Risk Criteria to be monitored Inspections Accountability 10 General waste Type and volume of waste generated Type and volume transferred for onshore disposal/incinerated Compliance with Waste Management Plan 11 Hazardous waste Volume of waste generated Volume transferred for onshore disposal Compliance with Waste Management Plan 12 Laboratory wastes Type Usage Toxicity Compliance with Waste Management Plan 13 Fuel usage Type and volume on board Volume consumed 14 Accidental oil and chemical spills Type Volume Compliance with Shipboard Oil Pollution Emergency Plan and Oil Spill Response Plan Prior to waste transfers to supply Prior to waste transfers to supply Prior to drilling and once during campaign Daily operational log inspection Fuel transfer log sheet Ongoing through daily operational log and incident reporting system 15 Radioactive s Test to determine leak levels At start and once during campaign 16 Vertical Seismic Profiling Cetaceans in 500 m shutdown zone Soft-starts procedures and survey periods Responses of marine fauna Temporary termination requests Continuous during VSP Drilling Unit Vessel Captain Offshore Installation Manager Offshore Installation Manager Drilling Unit Vessel Captain Offshore Installation Manager Offshore Installation Manager Offshore Installation Manager 17 Well (flow) testing Volume Continuous Offshore Installation Manager 18 Lost equipment Establish a hazards database listing: > the type of gear left on the seabed > date of abandonment/loss > location; and > where applicable, the dates of retrieval 19 Disruption/ interference to fishing/shipping Interactions with other s (via radio) Number of grievances/incidents logged 20 Fauna interaction Bird reaction to lights Incidents of injury/death, Stray land birds resting on drilling unit Ongoing through daily operational log and incident reporting system Continuous Ongoing through daily operational log and incident reporting system Offshore Installation Manager Offshore Installation Manager Offshore Installation Manager

15 SLR Environmental Consulting (Namibia) (Pty) Ltd Page AUDITING Monthly audits Beyond the routine inspection and monitoring activities conducted, formal monthly audits will be carried out internally by Shell s on-board HSSE Representative to ensure compliance with the EMP and its own HSSE standards and policies. The audit data will include the Contractor s monitoring and inspection records. The audit will include amongst other things, checking: completeness of HSSE documentation, including planning documents and inspection records; conformance with monitoring ; efficacy of activities to address any non-conformance with monitoring ; and training activities and. Findings would be documented in monthly audit reports, which will be submitted to Shell s Operations Manager / Well Delivery Manager for action and follow-up Independent EMP close-out compliance audit An independent EMP close-out compliance audit will also be conducted. This report will, amongst other things, outline the implementation of the mitigation measures and compliance levels with achieving the performance objectives as detailed in the EMP Audit methodology An audit methodology, programme and protocol needs to be developed for the internal monthly audits and the independent EMP close-out compliance audit. These audits are an integral part of the implementation of the EMP and audit findings can be used as a basis to measure compliance and confirm the efficacy and efficiency of the mitigation measures. Periodic environmental auditing as identified in this EMP is the key element to environmental management and functions best when done to identify the "root causes" of each audit finding. Root causes are the primary factors that lead to non-compliance events. The proposed approach to auditing consists of four basic steps: (i) planning the audit; (ii) conducting the audit; (iii) producing audit findings (measuring compliance and identifying problems); and (iv) reporting audit findings for management action. Audit findings shall undergo a root cause analysis to identify underlying causes to non-compliance events. Management actions will be taken to correct the underlying causes behind the audit findings and improvements will be made before another audit is conducted. This audit process allows for problems to be corrected, compliance to be improved and prevention of the same findings during subsequent audits. Identifying the root cause of an audit finding means identifying not only the failures that require correction but also successful practices that promote compliance and prevent violations. In each case, a root cause analysis should uncover the failures while promoting the successes so that there is continual progress toward environmental excellence.

16 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-16 A four level rating scale is proposed to assess the performance of the EMP against each individual element. Elements in weighted standards are rated individually at 100% (full compliance), 50% (partial compliance) or 0% (no compliance) as per the table below. Full compliance 100% Partial compliance 50% Not applicable NA The EMP elements are not applicable. Non compliance 0% All of the of the EMP element have been fulfilled. Element has been documented and monitored and upon verification is found to be fully implemented. Only certain of the key have been fulfilled and a plan is in place to progress to full compliance. Element has been documented and monitored but not consistently or completely implemented. The of the EMP have not been fulfilled. No evidence or incomplete evidence of compliance. Each mitigation measure (or element) is assigned a unique reference number in Sections , and The different project stages have been assigned the following weights, which sum to 100 (percent): Mobilisation: 40 Operation: 50 Demobilisation: 10 measures, which are similar in theme within the different project stages (e.g. mobilisation, operation and demobilisation), have been grouped together and assigned a specific weight (see Table 9-2). Table 9-2: Weighting of EMP elements No. Module themes / management action (or element) reference numbers/elements - Refer to Sections to Audit weighting 1. Mobilisation Systems, policy and processes Stakeholder engagement Re Efficiency and Pollution Prevention Biodiversity Conservation and Sustainable Management of Living Natural Res 1.5 Social performance Organisational capacity and competency Emergency preparedness and response review External communications 2, 3, 4, 11 Grievance mechanisms 1, 13, 26, 27, 40, 42, 59, 64 Re efficiency 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 41, 43, 44, 45, 46, 47, Pollution prevention 48, 49, 50, 51, 52, 53, 60, 61, 62, 63, 65, 66, 67, 68 Protection and conservation of biodiversity Protection of ecosystem services Community Health, Safety and Security Labour and working conditions 5, 54, 55, 56, 57, 58, 70 6, 7, 8, 9, 10,

17 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-17 No. Module themes / management action (or element) reference numbers/elements - Refer to Sections to Audit weighting 2. Operation Systems, policy and processes Stakeholder engagement Re Efficiency and Pollution Prevention Biodiversity Conservation and Sustainable Management of Living Natural Res 2.5 Social performance Organisational capacity and competency Emergency preparedness and response review 8, 9, 10, 11, 12, 13, 14, 15, 16, 35, 63, 64, 79, 89, 90, 92, 93, 94, 96, 105, 106 External communications 4, 6, 7, 17, 18, 19, 97,111 Grievance mechanisms Re efficiency 20, 21, 22, 23, 24, 25, 26,27, 28, 29, 30, 31, 32, 33, 34, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, Pollution prevention 51, 52, 53, 54, 70, 71, 72, 73, 74, 75, 76, 77, 78, 91, 95, 98, 99, 100, 101, 103, 104 Protection and conservation of biodiversity Protection of ecosystem services Community Health, Safety and Security Labour and working conditions 55, 56, 57, 58, 59, 60, 61, 62, 65, 66, 69, 85, 86, 87, 88, 102, 107, 108, 109, , 2, 3, 5, 67, 68, 80, 81, 82, 83, Demobilisation Systems, policy and processes Stakeholder engagement Re Efficiency and Pollution Prevention Biodiversity Conservation and Sustainable Management of Living Natural Res 2.5 Social performance Organisational capacity and competency Emergency preparedness and response review External communications 6, 9, 68 Grievance mechanisms 3, 4, 23, 24, 37, 39, 56, 61 Re efficiency 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 25, 26, 27, 29, 29, 30, 31, 32, 33, 34, 35, 36, 38, 40, 41, 42, 43, Pollution prevention 44, 45, 46, 47, 48, 49, 50, 57, 58, 59, 60, 62, 63, 64, 65, 66, 67, 69, 70 Protection and conservation of biodiversity Protection of ecosystem services Community Health, Safety and Security Labour and working conditions 5, 7, 8, 51, 52, 53, 54, Total 100 1,

18 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-18 To score a specific mitigation measure or element ( refer to specific reference numbers/elements in Sections , and ), assign a compliance factor achieved of 0 for non-compliance, 0.5 for partial compliance or 1.0 for full compliance. If an element (mitigation) is determined to be not applicable, then the element does not count towards the total number for purposes of scoring a module. To calculate the total score of a Module (see Box 9-3 for worked example), sum the individual scores achieved for each element in the grouped themes, divide them by the total number of elements considered, and then multiply by the weighted factor to arrive at a final Module score (refer to formula below). The final EMP audit score is the sum of all the Mobilisation, Operation and Demobilisation module scores. Box 9-3: Calculation of Module Audit Score A worked example for the Systems, Policy and Processes module within the Mobilisation stage is provided below. A1 B C D E F 2 1. Mobilisation Phase 3 4 Allocated module audit weighting 16 5 Total no. of elements within module 8 6 Element reference numbers Individual element Individual element Module Compliance level 7 (refer to Section of EMP) compliance factor (1, 0.5 or 0) audit score * Systems, policy and processes 1 Full compliance Full compliance Non compliance Full compliance Full compliance Partial compliance Full compliance Full compliance Module score (Sum of the individual Element Scores) 13 * 4. 5 This worked example achieves a Module Audit Score of 13 out of a possible CORRECTIVE ACTIONS The Contractor s HSSE staff will implement a formal non-compliance and corrective action tracking procedure for investigating cause and identifying corrective actions in response to accidents, environmental and/or social non-compliances. Where corrective actions are deemed necessary, specific measures will be developed, with designated responsibility and, and implemented. In this way, continuous improvement in performance would be achieved.

19 SLR Environmental Consulting (Namibia) (Pty) Ltd Page 9-19 The Contractor s HSSE staff will be responsible for keeping records of corrective actions and for overseeing the modification of environmental or social protection procedures and/or training programmes to avoid repetition of non-conformances and non-compliances. 9.7 MANAGEMENT OF CHANGE The development and implementation of the EMP is an ongoing process that is iterative in nature. This document must thus be seen as a living document and amendments may need to be implemented during the course of the project. Typical changes that can affect the EMP include: A material project design change that occurs after the EMP has been compiled and approved. Changes in the feasibility/availability of specific mitigation measures. Personnel changes on the project. This document is thus the first version of the EMP. Certain aspects of this document may be expanded/made more specific during the detailed design stage to ensure, firstly, that it includes all conditions of approval and, secondly, that it addresses all issues related to the detailed design. The following scenarios may apply: Minor changes to the EMP that are not considered to be materially significant departures or material to the findings of the EIA can be made and implemented by Shell s HSSE Manager. Any significant revisions to the EMP document that are considered to be materially significant departures from the mitigation measures listed in the EIA must be communicated to MME and MET before the amended EMP is implemented. Any changes to the project scope that are considered to be material to the findings of the EIA must be communicated to MME and MET. A register of changes to the EMP will be kept with an approval sign off sheet. 9.8 COMMUNICATION Channels of communication will be established between Shell, the contractor(s) and external stakeholders. The Shell Operations Manager / Well Delivery Manager will establish and maintain procedures for: Internal communication between the various levels and functions of the project staff organisation; and Receiving, documenting and responding to relevant communication from external interested parties. A grievance procedure will be established and maintained by the Shell Windhoek Office to record any complaints or comments received from the public during the drilling programme. The grievance procedure will be underpinned by the following principles and commitments: Disseminate key information to directly impacted stakeholders; Seek to resolve all grievances timeously; and Maintain full written records of each grievance case and the associated process of resolution and outcome. The responsibility for responding to grievances will lie with Shell.

20 SLR Environmental Consulting (Namibia) (Pty) Ltd Page DOCUMENT CONTROL AND REPORTING DOCUMENTATION Shell will control HSSE documentation, including project licences, approvals, management plans, associated procedures, checklists, forms and reports, through a formal procedure. The document control procedure will describe the processes that the project will employ for official communication of both hardcopy and electronic documents and the requirement for electronic filing, document tracking and version control numbers. The Contractor(s) will be required to develop a system for maintaining and controlling its own HSSE documentation and describe these systems in their respective HSSE plans INCIDENT REPORTING Following any HSSE incidents, Shell would conduct an incident investigation and prepare a report detailing the events and corrective and preventative measures implemented as a result. All incidents where local regulatory standards are exceeded will be reported to MET and MME INDEPENDENT EMP CLOSE-OUT COMPLIANCE REPORT Shell will submit an independent EMP close-out compliance report to MME. Amongst other things, this report will outline the implementation of the mitigation measures and compliance levels with achieving the performance objectives as detailed in the EMP ENVIRONMENTAL MANAGEMENT PLAN This section details the specific management commitments that will be implemented to prevent, minimise or manage significant negative impacts and optimise and maximise any potential benefits of the project. These commitments are presented for the three project phases, namely: Mobilisation Phase Section Operation Phase Section Decommissioning Phase Section This EMP is structured in the following manner so that the mitigation measures have a clear and logical context within which they are designed, implemented, monitored and evaluated: Activities; Aspects; ; s; Indicators; Targets; ; ; ; Timing; and Record Keeping Requirements. Refer to Box 9-4 for the content details.