Shelburne Basin Venture Exploration Drilling Project Environmental Protection Plan

Transcription

1 Shelburne Basin Venture Exploration Drilling Project Environmental Protection Plan Project Document Title Document Number Document Revision Document Status Document Type Owner / Author Shelburne Basin Venture Exploration Drilling Project Environmental Protection Plan EP O8A Final - Redacted Controlled Candice Cook-Ohryn/Lara Smandych Issue Date November 15, 2016 Expiry Date Security Classification Disclosure None None

2 Document History REVISION STATUS APPROVAL Rev. Date Description Originator Reviewer Approver 1 20-Feb-15 Initial Draft C. Cook-Ohryn G. Krauss C. Pagan 2 27-May-15 2 nd Draft C. Cook-Ohryn G. Krauss C. Pagan 3 30-July-15 3rd Draft L. Smandych G. Krauss C. Pagan 4 16-Oct-15 Final L. Smandych G. Krauss C. Pagan 4 16-Oct-15 Final-Redacted L. Smandych G. Krauss C. Pagan 5 27-Nov-15 Final-Redacted L. Smandych G. Krauss S. Labonte 6 3-May-16 Final Redacted Main Updates: Section 11.6, reduction in number of supply vessels and Section 12.8 L. Smandych G. Krauss S. Labonte 7 29-Sep-16 Updates to Section 12.8 and number of OSVs L. Dalton G. Krauss/ C. Mack/ A. Whyte/ L. McCafferty S.Labonté 8 15-Nov-16 Minor wording updates to Sections 11.5, 12.8 and 13.1 L. Dalton G. Krauss N/A Signatures for this Final revision Date Role Name Signature or electronic reference ( ) 11/14/2016 Reviewer Greg Krauss 9/22/2016 Reviewer Chris Mack 9/16/2016 Concurrence Andrew Whyte

3 9/16/2016 Concurrence Louise McCafferty 9/28/2016 Approver Stéphane Labonté

4 Acronyms and Abbreviations Accord Acts...Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act and Canada-Nova Scotia Offshore Petroleum resource Accord Implementation (Nova Scotia) Act Accord... Canada-Nova Scotia Offshore Petroleum Resource Accord ADW... Approval to Drill a Well ALARP... as low as reasonably practicable API... American Petroleum Institute ALARP... as low as reasonably practical BIP... Business Improvement Plan BOP... blowout preventer CACO... Canada Civil Aviation Contingency Operations CAPP... Canadian Association of Petroleum Producers CCG... Canadian Coast Guard CEA Agency... Canadian Environmental Assessment Agency CEAA, Canadian Environmental Assessment Act, 2012 CEAR... Canadian Environmental Assessment Registry CEPA, Canadian Environmental Protection Act, 1999 C-NLOPB... Canada-Newfoundland and Labrador Offshore Petroleum Board CNSOPB... Canada-Nova Scotia Offshore Petroleum Board CO... carbon monoxide CO 2... carbon dioxide COGOA... Canadian Oil and Gas Operations Act Compensation Guidelines... Compensation Guidelines Respecting Damage Relating to Offshore Petroleum Activity COSHH... Control of substances Hazardous to Health CPRA... Canadian Petroleum Resources Act CSMP... UA Contractor HSSE Management Process CWS...Canadian Wildlife Service DFO... Fisheries and Oceans Canada DNV... Det Norske Veritas DSL... Domestic Substances List DWOP... Drilling Well on Paper

5 EA... environmental assessment ECE... environmentally critical element EEM... environmental effects monitoring EIS... Environmental Impact Statement EL... Exploration Licence EPP.... Environmental Protection Plan EPPG... Environmental Protection Plan Guidelines ERP... Emergency Response Plan EVLT... Extended Venture Leadership Team FCP... Fisheries Communication Plan GHG... greenhouse gas GWMS... Global Wells Management System H2S....Hydrogen Sulphide HEMP... hazards and effects management process HPU... hydraulic pumping unit HAZID... Hazard Identification Study HRA... health risk assessment HSE... Health, Safety and Environment 1 HSE MS... Health, Safety and Environment Management System HSSE... Health, Safety, Security and Environment HSSE & SP... Health, Safety, Security, Environment and Social Performance HSSE & SP CF....Health, Safety, Security, Environment and Social Performance Control Framework HSSE & SP MS....Health, Safety, Security, Environment and Social Performance Management System HUEBA....Helicopter Underwater Emergency Breathing Apparatus IA... impact assessment IADC... International Association of Drilling Contractors IAS... Integrated Automated System IATA... International Air Transport Association IMO... International Maritime Organization IOGP... International Association of Oil & Gas Producers 1 The term HSE can be used interchangeably throughout this submission with the terms HSSE, HSSE & SP, HSE &SP

6 ISM... International Safety Management JRCC... Joint Rescue Coordination Centre LMRP... lower marine riser package MARPOL International Convention for the Prevention of Pollution from Ships MARS... Marine Animal Response Society MBCA... Migratory Birds Convention Act MEDEVAC... medical evacuation MEG... monoethylene glycol MERP... Medical Emergency Response Plan MMO... marine mammal observer MOC... management of change MODU... mobile offshore drilling unit MS... Management System MSDS...Material Safety Data Sheet NEB... National Energy Board NEBA... Net Environmental Benefits Analysis NOTMAR... Notice to Mariners NOTSHIP... Notice to Shipping NO x... nitrogen oxides NPRI... National Pollutant Release Inventory OA... Operations Authorization OCNS... Offshore Chemical Notification Scheme OCSG... Offshore Chemical Selection Guidelines OIM... Offshore Installation Manager OPRC/IOPP... Oil Pollution Preparedness, Response and Co-Operation OSP... Offshore Safety Plan OSPAR... Oslo and Paris Commissions OSRL... Oil Spill Response Limited OSRP... Oil Spill Response Plan OSV... offshore support vessel OWTG... Offshore Waste Treatment Guidelines PAM... passive acoustic monitoring PARCOM... Paris Commission PCPA... Pest Control Products Act PIC... Person In Command

7 PLONOR... Pose Little or No Risk to the Environment PMS... Planned Maintenance System PMR... Performance Monitoring and Reporting Project... Shelburne Basin Venture Exploration Drilling Project PRV... pressure-reducing valve PSM...Process Safety Manual QA/QC... Quality Assurance/Quality Control RAM... Risk Assessment Matrix RCMP... Royal Canadian Mounted Police RWCP... Relief Well Contingency Plan SBM... synthetic-based mud SDL... Significant Discovery Licence SEPCO... Shell Exploration and Production Company Shell... Shell Canada Limited SIA... Shell Internal Audi SMBR... Shell Maritime Business Review SMS... Stena Drilling Management System SOCP... Statement of Canadian Practice with Respect to the Mitigation of Seismic Sound in the Marine Environment SOPEP... Shipboard Oil Pollution Plan SOU...Shell Open University SO x... sulphur oxides Stena... Stena Drilling Limited SWIS... Subsea Well Intervention Service TDG... Transportation of Dangerous Goods TIPS...Technical Integrity Performance Standards TQSP... Training and Qualifications Standard Practice TVD... true vertical depth UA... Shell Upstream Americas UAX... Upstream Americas Exploration UK... United Kingdom VLT... Venture Leadership Team VOC... volatile organic compound VSP... vertical seismic profile WBM... water-based mud

8 WCB... Workers Compensation Board WCP... Well Containment Plan WRP... Wildlife Response Plan

9 DEFINITIONS The following are specific terms and/or words that require additional clarification in this document: Shell Canada Limited - in the context of this document Shell Canada Limited (Shell) refers to the Operator of the Shelburne Basin Venture and the Shelburne Basin Venture Drilling Project (the Project), as well as those parts of the Shelburne Basin Venture Team that undertake activities on behalf of Shell Upstream Americas Exploration (UAX), e.g., the Shelburne Basin Venture Leadership Team (VLT). Shelburne Basin Venture - all activities related to the Shell Canada Limited EL acquisitions of 2012 and The Project - the 2015 Shelburne Basin Venture Drilling Project, which is comprised of all activities related to the drilling, and the suspension or abandonment of, two Deepwater exploration wells in the Nova Scotia Offshore Area, from mid-2015 through This document: will be held in the Common Library and can be accessed via the Shelburne Venture SharePoint site. Controlled versions and revision announcements will be published, and communicated to the appropriate Shell and contractor personnel to ensure local implementation. Copies or extracts of this document, which have been downloaded from the Sharepoint site, are uncontrolled copies and cannot be guaranteed to be the latest version. may set requirements supplemental to applicable law and policy. However, nothing herein is intended to replace, amend, supersede or otherwise depart from any applicable law relating to the subject matter of this document. In the event of any conflict or contradiction between the provisions of this document and applicable law as to the implementation and governance of this document, the provisions of applicable law shall prevail.

10 TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS... 3 DEFINITIONS... 8 FORWARD GENERAL PURPOSE AND SCOPE PROJECT DESCRIPTION Exploration Drilling Project versus Drilling Program Initial Well locations Stena IceMax Drillship Helicopter Support Onshore Supply Base Support vessels Office LEGAL REQUIREMENTS Regulatory Framework Guidance and Adopted Standards Environmental Guidelines Adopted Codes and Standards Shell s Environmental Standards Applicable Plans and Procedures Routine Operations Emergency Preparedness and Response SHELL HSSE MANAGEMENT SYSTEM Leadership and Commitment Policies and Objectives Shell s Commitment and Policy Stena Health, Safety & Environmental Health Policy Statement Stena Management System Objectives & Targets ORGANIZATION, RESPONSIBILITIES AND RESOURCES Venture Level Organization and HSE Accountability Contractor Level Roles & Responsibilities Environmentally Critical Roles EPP Responsibilities HAZARD IDENTIFICATION AND RISK EVALUATION Hazard and Effects Management Process Risk Assessment Matrix (RAM) Bow Tie Analysis Environmental Assessment HSSE Studies HSSE Study Results... 56

11 8. AWARENESS, COMPETENCE AND TRAINING Awareness Competence Training Contractor Management EPP MANAGEMENT EPP Review and Revision Document Control EPP Communication and Distribution OPERATIONAL CONTROL Operations and Maintenance Procedures Structures, Facilities, Equipment and Systems Critical to Environmental Protection Certificate of Fitness and Certification Management of Change MONITORING AND REPORTING Performance Measurement and Compliance Monitoring Audits and Inspections Managing Non-Conformities Records Management Continual Improvement Environmental Reporting ENVIRONMENTAL PROTECTION AND COMPLIANCE MONITORING OF WASTE STREAMS Offshore Production Waste Streams Summary of Offshore Waste Streams Authorized Discharges Subject to Compliance Monitoring/Reporting Authorized Waste Discharges Requiring Routine Reporting but not Compliance Monitoring Authorized Waste Discharges Not Requiring Compliance Monitoring or Routine Reporting Prohibited Discharges or Discharges Requiring Case by Case Authorization Air Emissions Overview Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting Bilge and Ballast Discharges Overview Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting... 79

12 12.4 Deck Drainage Overview Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting Sewage and Grey Water Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting Cooling Water Overview Environmental Protection Measures Compliance Monitoring Requirements Reporting Drilling Discharges Overview Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting Blowout Preventer Fluids Overview... Error! Bookmark not defined Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting Firewater and Fire Protection Overview Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting ADDITIONAL ENVIRONMENTAL PROTECTION CONSIDERATIONS Handling of Helifuel Overview Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements Reporting Transfer of Fuel, Bulk Drilling Fluids and Liquid Wastes between Vessels and Rig Environmental Objectives Environmental Protection Measures Compliance Monitoring Requirements... 92

13 Reporting Vessel Operations Mobile Offshore Drilling Unit (MODU) Offshore Support Vessels (OSVs) Helicopter Operations CHEMICAL SELECTION AND MANAGEMENT Chemical Selection Offshore Chemical Management Reporting WASTE MANAGEMENT SPECIALIZED OPERATIONS Routine Testing of Blowout Preventer BOP Seal Hydrate Buildup Prevention See Section 12.8 of the EPP for further information on this activity Routine Testing of Fire Suppression System Vertical Seismic Profiling Well Abandonment ENVIRONMENTAL INCIDENTS Incident Reporting and Investigation Incident Reporting to the CNSOPB Incident Reporting to Other Authorities Incident Investigation Exceedances and Sheens ADDITIONAL ENVIRONMENTAL MONITORING Stranded Bird Monitoring and Handling Marine Mammal Monitoring Spill Environmental Effects Monitoring PUBLIC AND STAKEHOLDER COMMUNICATION Communication with the Public Communication with Commercial and Aboriginal Fisheries Communication with Regulatory Agencies REFERENCES APPENDIX A SHELBURNE BASIN VENTURE ORGANIZATION CHART APPENDIX B LEACH S STORM PETREL: GENERAL INFORMATION AND HANDLING INSTRUCTIONS (WILLIAMS AND CHARDINE 1999) APPENDIX C SUMMARY OF MITIGATION, MONITORING AND FOLLOW UP COMMITMENTS APPENDIX D CEAA DECISION STATEMENT CONDITIONS

14 LIST OF TABLES Table 4.1 Legislation/Regulations/Directives Table 4.2 Environmental Management Plans Table 4.3 Emergency Response Plans Table 6.1 EPP Roles and Responsibilities Table 7.1 EIS Assessment Summary Table 7.2 HSSE Studies Table 7.3 Identified and Assessed Project Hazards Table 9.1 Document Control Records and Storage Location Table 9.2 EPP Distribution List Table 12.1 Summary of Operational Discharges Table 13.1 Operating Criteria for Stena IceMAX Table 13.2 Operating Criteria for Helicopters Table 17.1 Other Authorities LIST OF FIGURES Figure 3.1 Project Location Figure 5.1 HSSE & SP Control Framework Figure 5.2 Shell HSSE & SP Commitment and Policy Figure 5.3 Stena Drilling Health, Safety and Environmental Health Policy Figure 5.4 Stena Drilling Environmental Protection Policy Figure 7.1 Hazard Identification System Figure 7.2 Risk Assessment Matrix Figure 7.3 Bow-Tie Analysis Diagram Figure 8.1 Onshore/Offshore Operations Interface Organizational Chart Figure 10.1 Management of Change Figure 11.1 Shell s continual Improvement Cycle... 72

15 FOREWORD This Environmental Protection Plan (EPP) (EP ) is intended to provide the environmental components of the larger HSSE management system framework for the Shell Canada Limited (Shell) Shelburne Basin Venture Drilling Project (the Project) to ensure the implementation of sound environmental management and protection in association with the operational activities under the jurisdiction of the Canada-Nova Scotia Offshore Petroleum Board (CNSOPB). It is Shell s policy to comply fully with all applicable statutory and regulatory requirements. Approvals granted under the CNSOPB for the Project do not exempt Shell from complying with all applicable legislation and other legal requirements. Note that if Shell requires a higher level of environmental protection or management than the applicable laws and regulations, the most stringent requirement will apply. Should a case be noted where local regulatory requirements impedes on the higher Shell standard, the issue will be brought to the attention of the appropriate regulatory agency. This EPP identifies and outlines the environmental management for all personnel, including contractors, that function in any capacity within the project and has been developed to provide effective guidance on environmental management for Project activities. The EPP is established to identify and outline the environmental management measures to be implemented in association with the Project and required of all personnel, including contractors, that function in any capacity in association with the Project. Additionally, this EPP is put in place to ensure compliance with relevant existing environmental management commitments and requirements for Project operations. As a result, this document should be read in conjunction with other environmental regulatory documents, such as the Environmental Impact Statement (EIS) for the Project (Stantec 2014) and regulatory approvals obtained in support of the Project, for further detail and background. The table below is a concordance table showing where each section of the CNSOPB/C- NLOPB/NEB Environmental Protection Plan Guidelines (the Guidelines) can be found in this document. Document # EP November 15, 2016

16 CONCORDANCE TABLE: CNSOPB EPP GUIDELINES TO SHELL S EPP SEC # CNSOPB EPP GUIDELINES SEC # SHELL EPP 4.1 GENERAL 4.2 PURPOSE AND SCOPE OF THE EPP ENVIRONMENTAL POLICY STATEMENT APPLICABLE PLANS AND PROCEDURES 4.5 PLANNING FOREWORD GENERAL PURPOSE SCOPE SHELL HSE POLICY STENA ENVIRONMENTAL PROTECTION POLICY APPLICABLE PLANS AND PROCEDURES OPERATIONS AND MAINTENANCE PROCEDURES HAZARD IDENTIFICATION, HAZARD IDENTIFICATION AND RISK EVALUATION AND RISK EVALUATION 7.2 MITIGATION ENVIRONMENTAL ASSESSMENT LEGAL REQUIREMENTS 4.1 REGULATORY FRAMEWORK COMMITMENTS BY THE OPERATOR GUIDANCE AND ADOPTED STANDARDS OBJECTIVES AND TARGETS DISCHARGE LIMITS IMPLEMENTATION AND OPERATIONS RESOURCES, ROLES, RESPONSIBILITIES AND AUTHORITY COMMITMENT, LEADERSHIP AND PARTICIPATION AWARENESS, COMPETENCE, AND TRAINING AWARENESS 8.1 AWARENESS 8.2 COMPETENCE COMPETENCE AND TRAINING 8.3 TRAINING COMMUNICATION ADOPTED CODES AND STANDARDS SHELL S ENVIRONMENTAL STANDARDS ENVIRONMENTAL PROTECTION AND COMPLIANCE MONITORING OF WASTE STREAMS ORGANIZATION, RESPONSIBILITIES AND ACCOUNTABILITIES LEADERSHIP AND COMMITMENT VENTURE LEVEL ORGANIZATION AND HSE ACCOUNTABILITY EPP COMMUNICATIONS AND DISTRIBUTION PUBLIC AND STAKEHOLDER COMMUNICATION DOCUMENT CONTROL 9.2 DOCUMENT CONTROL Document # EP November 15, 2016

17 CONCORDANCE TABLE: CNSOPB EPP GUIDELINES TO SHELL S EPP SEC # CNSOPB EPP GUIDELINES SEC # SHELL EPP OPERATIONAL CONTROL OPERATIONS AND MAINTENANCE PROCEDURES STRUCTURES, FACILITIES, EQUIPMENT AND SYSTEMS CRITICAL TO ENVIRONMENTAL PROTECTION SELECTION AND USE OF CHEMICAL SUBSTANCES OPERATIONS AND MAINTENANCE PROCEDURES ENVIRONMENTAL CRITICAL EQUIPMENT CHEMICAL SELECTION AND MANAGEMENT DISPOSAL OF WASTE MATERIAL 15 WASTE MANAGEMENT MANAGEMENT OF CHANGE 10.3 MANAGEMENT OF CHANGE ENVIRONMENTAL INCIDENTS EMERGENCY PREPAREDNESS AND RESPONSE INCIDENT REPORTING AND INVESTIGATION 4.7 CHECKING COMPLIANCE MONITORING AND PERFORMANCE MEASUREMENT ENVIRONMENTAL EFFECTS MONITORING AUDITING AND REVIEW MANAGING NON-CONFORMITIES EMERGENCY PREPAREDNESS AND RESPONSE INCIDENT REPORTING AND INVESTIGATION PERFORMANCE MEASUREMENT AND COMPLIANCE MONITORING ADDITIONAL ENVIRONMENTAL MONITORING MANAGEMENT OF NON CONFORMITIES CONTROL OF RECORDS 11.4 RECORD MANAGEMENT 4.8 CONTINUAL IMPROVEMENT 11.5 PERFORMANCE MEASUREMENT AND COMPLIANCE MONITORING Document # EP November 15, 2016

18 1. GENERAL This Environmental Protection Plan (EPP) has been developed in support of the proposed Shell Canada Limited (Shell) Shelburne Basin Venture Exploration Drilling Project (the Project) to meet the requirements of Shell s Commitment and Policy on Health, Security, Safety, the Environment and Social Performance (HSSE & SP Commitment and Policy), further described in Section 5, which requires consideration of environmental protection in all operations and activities as well as a systematic approach to HSSE management in order to ensure compliance with the law. Additionally, this EPP has been developed to meet the requirements for implementation of a management system under the Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act (S.C. 1988, c.28) and Section 6(d) and 9 of the Nova Scotia Offshore Drilling and Production Regulations (SOR/ ) which require that an EPP is submitted in support of an application to conduct work or activities related to drilling operations offshore Nova Scotia. This EPP is the written demonstration that the Project complies with internal Shell, external CNSOPB environmental management requirements and all related provincial and federal legislation, including the Conditions outlined in the Decision Statement issued under Section 54 of the Canadian Environmental Assessment Act, 2012 (CEAA) (Appendix E). Document # EP November 15, 2016

19 2. PURPOSE AND SCOPE The purpose of this EPP is to communicate Project requirements and commitments for environmental management and protection to all Project personnel (including Shell staff and contractors), regulatory agencies, other stakeholders, and potentially affected and interested First Nations. This EPP outlines the respective environmental management processes and procedures from the Shell HSSE & SP Control Framework (HSSE & SP CF) which is Shell s overarching Safety and Environmental Management System that will be executed for the Project. This EPP is aimed at outlining Project-specific environmental protection and management procedures intended to manage potential Project-environment interactions and identified hazards. Additionally, included in the EPP are relevant operational commitments made and conditions imposed in association with the Environmental Assessment completed in compliance with the Canadian Environmental Assessment Act, 2012 or to ensure compliance with environmental regulatory requirements. The scope of the EPP includes activities for the Project which will consist of the drilling, and the suspension or abandonment of two Deepwater exploration wells, commencing Q The wells will be drilled by a mobile offshore drilling unit (MODU), with support from one dedicated stand-by vessel, up to three offshore supply vessels (at least one of which will be a back-up stand-by vessel), helicopter operations and a dedicated onshore supply base. Document # EP November 15, 2016

20 3. PROJECT DESCRIPTION 3.1 Exploration Drilling Project versus Drilling Program The Project will be phased and divided into two separate drilling campaigns consisting of up to seven exploration wells drilled over a four year period, from 2015 through 2019, in accordance with the exploration period of the Exploration Licences (ELs). The second drilling campaign or Project phase will be dependent upon the results of the first campaign. For the purpose of the EPP, the Project will consist of the drilling, and the suspension or abandonment of two Deepwater exploration wells, commencing in Q An Operations Authorization (OA) and two Approval to Drill a Well (ADW) approvals will be required from the CNSOPB prior to commencing operations. The exploration drilling Project Area is shown in Figure 3.1 and encompasses portions of Shell s offshore ELs 2423, 2424, 2425, 2426, 2429 and The Project Area is located approximately 250 km offshore from Halifax in a geographical offshore area known as the Southwest Scotian Slope and a geological region known as the Shelburne Basin. Water depths in the Project area range from 1500 m to 3000 m Figure 3.1 Project Location Document # EP November 15, 2016

21 3.2 Initial Well locations Specific drilling locations have been selected using data gathered from the 2013 Shelburne Basin 3D Seismic Survey, as well as more detailed Seabed, Geotechnical and Geo-hazard Survey that was conducted in Initially two exploration wells will be drilled in the Project Area, commencing in Q The specific technical details for the wells will be outlined in the drilling programs for these wells, and will be submitted to the CNSOPB. 3.3 Stena IceMax Drillship Each well in the first drilling campaign will be drilled using the Stena IceMax drillship. The Stena IceMax is a dual mast, dynamically positioned, Polar Class 4, harsh environment, ultra Deepwater drillship, designed and certified for year round worldwide operations. Further details and description of the drillship and Stena s Health, Safety and Environment (HSE) Management System is provided in the Stena IceMax HSE Case and Section 11.3 of this EPP. 3.4 Helicopter Support Shell will have three Sikorsky S-92 helicopters under contract. Two will be equipped for passengers (16 18 passengers), and one SAR/Medivac. They will be based at a Heliport located at the HNZ/Canadian Helicopters Hangers at the Halifax Stanfield International Airport will be used for the transfer of personnel from Heliport to the Stena IceMax. One of the helicopter s will be used for crew change from Heliport to the Stena IceMax while the other will serve as a technical back-up for the primary crew change helicopter and for the SAR helicopter. A third helicopter is dedicated to Search and Rescue flights and Medivac. It has the capability of rescue from vessels and the water using divers. A thorough risk assessment has been performed for this operation and a mitigation plan will be in place, with appropriate actions closed including pre-startup checks prior to rig operations start-up. 3.5 Onshore Supply Base The Woodside Supply Base (the Supply Base), located in Dartmouth, Nova Scotia in Halifax Harbour is managed by the Blue Water Group under contract to Shell. The Supply Base will allow for the storage of equipment and will have a Mud Plant and Cement Silos, which are required to support Project drilling activities. Supply vessels can moor directly at the Supply Base for vessel loading/off-loading of mud, equipment or other materials. The Mud Plant operations at the Supply Base and the supply of equipment to the Supply Base are outside the scope of this document. Document # EP November 15, 2016

22 3.6 Support vessels Various support vessels (standby and supply) will be on contract for the duration of the Project to support the Stena IceMax with day to day operations. The support vessels will be prepared and certified for passenger transfers to the IceMax. 3.7 Office Project operations will be managed from the Shell Halifax Office, which includes an Emergency Control Center. The address is as follows: Shell Canada Limited 1701 Hollis Street 10th Floor Founders Square Halifax, Nova Scotia B3J 3M8 24 hour Duty Officer <Redacted> Nova Scotia HSSE Manager <Redacted> Document # EP November 15, 2016

23 4. LEGAL REQUIREMENTS 4.1 Regulatory Framework Petroleum activities in Nova Scotia s offshore area are regulated by the CNSOPB, a joint federal-provincial agency reporting to the federal Minister of Natural Resources Canada and the provincial Minister of Energy. Additionally, a number of Federal regulators are mandated for the management of various environmental resources and components relevant to the Project. The key Acts, Regulations and Directives relevant to environmental management of Project operations within the scope of this EPP are summarized in Table 4.1. Document # EP November 15, 2016

24 Table 4.1 Legislation/Regulations/Directives Statutory Document Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act and Canada-Nova Scotia Offshore Petroleum Resource Accord Implementation (Nova Scotia) Act (Accord Acts) Nova Scotia Offshore Petroleum Drilling and Production Regulations Nova Scotia Offshore Petroleum Installation Regulations Nova Scotia Offshore Area Petroleum Geophysical Operations Regulations (and associated Guidelines) Nova Scotia Offshore Certificate of Fitness Regulations Canadian Environmental Assessment Act, 2012 Canadian Environmental Protection Act and Regulations Migratory Birds Convention Act and Regulations Species at Risk Act Fisheries Act and Regulations Hazardous Product Act and Regulations Navigation Protection Act and Regulations Transportation of Dangerous Goods Act and Regulations The Oceans Act, 1996 Responsible Regulatory Authority CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CEAA Environment Canada Environment Canada Environment Canada, Parks Canada, Fisheries and Oceans Canada Fisheries and Oceans Canada and Environment Canada Health Canada Transport Canada Transport Canada Fisheries and Oceans Canada Document # EP November 15, 2016

25 4.2 Guidance and Adopted Standards Environmental Guidelines A number of existing guidance documents have been used to guide the development of this EPP and to inform the requirements for environmental management and protection during Project Operations. These environmental guidelines include: CNSOPB/CNLOPB Drilling and Production Guidelines (2009) CNSOPB/CNLOPB/NEB Environmental Protection Plan Guidelines (2011) CNSOPB/CNLOPB/NEB Offshore Waste Treatment Guidelines (2010) CNSOPB/CNLOPB/NEB Offshore Chemical Selection Guidelines (2009) CNSOPB/CNLOPB/NEB Offshore Physical Environment Guidelines (2008) Compensation Guidelines Respecting Damage Relating to Offshore Petroleum Activity CNSOPB/CNLOPB Guidelines for Reporting and Investigation of Incidents (2012) Statement of Canadian Practice with Respect to the Mitigation of Seismic Sound in the Marine Environment (SOCP) Environment Canada s Avoidance Guidelines for Migratory Birds Shell HSSE &SP CF Environment Manual Guides o Water in the Environment Guide (V3-2013) o Biodiversity Guide (V1-2013) Adopted Codes and Standards The Project will operate to current industry codes and standards along with Shell and Contractor internal design standards to demonstrate asset integrity. The primary Industry Organizations that support Project Operations are: International Association of Drilling Contractors (IADC) International Association of Oil & Gas Producers (IOGP) American Petroleum Institute (API) Shell and Stena also comply with applicable Marine Codes and standards from the following organizations in regards to environmental protection and management: IMCA International Marine Contractors Association IMO International Maritime Organization o IMO International Convention for the Prevention of Pollution from Ships (MARPOL) Document # EP November 15, 2016

26 o IMO International Convention on Oil Pollution Preparedness, Response and Co-Operation (OPRC/IOPP) Shell s Environmental Standards Section 5.3 of the OSP provides a detailed list of Shell s primary drilling and logistical standards that will be adopted for the Project and are inclusive of environmental protection and management requirements where necessary. In addition to these primary standards, Shell s Health, Safety, Security, Environment and Social Performance (HSSE & SP) Control Framework (HSSE &SP CF) contains a number of manuals that specifically outline the associated requirements for environmental management. The following internal environmental standards outlined under the HSSE &SP CF have been used to inform and guide the environmental protection and management for the Project and construction of this EPP: Environmental Manual Biodiversity (V3-2012) Environmental Manual Greenhouse Gas and Energy Management (V4-2013) Environmental Manual Specification for Discharge to Water (V3-2013) Environmental Manual Water in the Environment (V3-2013) Environmental Manual Waste (V2-2009) Projects Manual Impact Assessment (V3-2011) Product Stewardship Manual Product Stewardship (V2-2009) 4.3 Applicable Plans and Procedures In order to ensure operational compliance with both internal and external requirements, commitments and standards for environmental protection and management, a number of Project level plans have been compiled, inclusive of this EPP, to guide operational activities. These plans are intended to ensure that Project operations are conducted in a manner that aligns with the established environmental standards and expectations for the Project, accomplishes and complies with environmental mitigation commitments and requirements and meets the outlined objectives and targets for environmental performance. The sections below provide an overview of the associated plans established to support routine Project operations as well as emergency response in association with environmental protection and management. Relevant procedural and guidance documents incorporated into the associated plans or used to guide the plan have been referenced in the sections below as relevant. Document # EP November 15, 2016

27 4.3.1 Routine Operations The plans outlined in Table 4.2 are operational documents established to outline environmental management and protection measures and requirements for routine Project operations. Document # EP November 15, 2016

28 Table 4.2 Environmental Management Plans Operations Safety Plan (OSP) Title Description Stena MS Shell MS An Project specific OSP has been created to support exploration drilling activities. This plan has been drafted in to meet the requirements of Section 6(c) and Section 8 of the Regulations as well as internal safety requirements under Shell s HSSE &SP CF.. This plan will be managed as an evergreen document. The OSP is aimed at providing the HSSE Management System framework for the Project. The management system is intended to ensure operators have documented policies and procedures for how they will carry out their activities while ensuring compliance and safety, environmental protection and prevention of waste (resource conservation). Stena IceMax HSE Case L4-DOC-ICE-4126 L4-DOC-ICE-4127 L4-DOC-ICE-4128 L4-DOC-ICE-4129 L4-DOC-ICE-4131 Refer to OSP for full list of Stena MS safety management document. Shelburne Basin Venture Operations Safety Plan (EP ) The OSP is aimed at demonstrating compliance to the CNSOPB Acts and Regulations and is used to aid the Project Team to achieve its business objectives of driving continuous HSSE & SP performance improvements and achieving Shell s objective of Goal Zero, which is no harm to people and no harm to the environment. A Project specific WMP has been drafted to support exploration drilling activities and is included as Appendix C of this EPP. The purpose of the WMP is to detail the management processes and procedures for waste that is generated in association with the Project. In line with Shell s internal CF requirement the WMP seeks to Incorporates controls to reduce waste generation into procedures and working practices Waste Management Plan (WMP) Environmental Protection Policy L1-POL-MD-005 Management of Waste Offshore L2-DOC-LPD-0102 Waste Management L4-DOC-ICE-4320 Handling of Toxic and Other Environmental Manual Waste Specification (V2-2009) Wells HSSE & SP Manual WS Gen Section 10.7 Shelburne Basin Venture Waste Management Plan Document # EP November 15, 2016

29 Table 4.2 Environmental Management Plans Title Description Stena MS Shell MS Identify opportunities to reuse waste for the same or alternative applications or return unused materials to suppliers Dangerous Materials L2-DOC-LPD-3777 (EP ) Identify recycling and recovery opportunities for Hazardous Goods Handling waste material Procedure Identify waste (types), segregates and stores waste L2-DOC-MAT-0180 All waste streams will be reported and opportunities for reuse identified and implemented. All waste generated by Wells activities must be identified, segregated, and stored to meet the requirements of the asset/venture and local legislation. Environmental Protection Plan (EPP) This EPP will be managed as an evergreen document throughout Project operations. The EPP is intended to provide the environmental components of the larger HSSE management system framework for the Project to ensure the implementation of sound environmental management and protection in association with the operational activities. The EPP is established to identify and outline the environmental management measures to be implemented in association with the Project and required of all personnel, including contractors, that function in any capacity in association with the Project. Additionally, this EPP is put in place to ensure compliance with relevant existing environmental management commitments and requirements for Project operations. Discharges to Sea L2-DOC-LPD-0215 Environmental Signposts L2-DOC-LPD Identification of Environmental Aspects and Impacts L2-DOC-LPD-0104 Identifying and Managing Environmentally Critical Elements L2-DOC-LPD-4996 See above listed Shell manual standards and guides Document # EP November 15, 2016

30 4.3.2 Emergency Preparedness and Response A Project Emergency Response Plan (ERP) is in place to address response and recovery activities related to significant potential emergencies. These plans cover the following potential environmental hazards: Fire and Explosion Uncontrolled Well Flow Ship Collision Hurricane/ Storm H2S Helicopter Ditching in the Sea, or on Deck Hydrocarbon Spills to the Water These plans outline Emergency Response procedures and follow the proper protocols for establishing an incident command in support of all local and governmental regulations. Table 4.3 outlines the various emergency response plans that will be in place for the Project and describes how they relate to the emergency response. Plans are available in the Shell Halifax Office. Site-specific Emergency Plans are available for Aviation, Marine, Shore-base, and Drilling. Plans will be exercised prior to initiating operations to ensure proper protocols are adhered to. Plans will be exercised prior to initiating drilling operations to ensure proper protocols are adhered to. Document # EP November 15, 2016

31 Table 4.3 Emergency Response Plans Title Description Stena MS Shell MS Emergency Response Plan (ERP) Shelburne has adopted the Shell HSSE & SP Control Framework standard for Emergency Response, which will be the basis for managing Emergencies. All Businesses delivering activities and projects within the venture are required to implement this Shell CF Mandatory Manual, and expected to ensure that all activities carried out are supported by a robust Emergency Response Plan (ERP) aligned with the CF requirements, including a Medical Emergency Response Plan (MERP) and Spill Response Plan, where applicable. Each one of the Businesses delivering activities and projects within the venture, are expected to respond to emergencies in accordance with their established plans, and to notify the venture as follows. Emergency Response plans are established as per the CF manual section Emergency Response and escalation routes to Crisis Management Plans are in place. Reference Element 5 Planning and Procedures for the plans, procedures and drills related to Emergency Preparedness and Response of the HSSE & SP CF. Drills and exercises to test both the Incident Command System structure and the site specific ERP are conducted regularly. Site-specific scenarios include but are not limited to: Gas releases, Fires/explosions, Injuries/fatalities, Hazardous material spills, Stena IceMax HSE Case- Part 5 Emergency Response L4-DOC-ICE-4130 Onshore Emergency Response L2-PM-LPD-0305 Emergency Contacts L4-DOC-ICE-4339 Introduction Rig Emergency L4-DOC-ICE Shelburne Basin Emergency Response Plan (EP ) Document # EP November 15, 2016

32 Table 4.3 Emergency Response Plans Oil Spill Response Plan (OSRP) Title Description Stena MS Shell MS Loss of Station Keeping. Safety equipment inspections are completed for eyewash stations, first aid kits and other designated safety equipment. The Emergency Response Plan including the MERP will be submitted to, and reviewed by the CNSOPB as part of the Drilling Operations Authorization approval process. The Oil Spill Response Plan (OSRP) is intended as a planning document to help identify and establish the basis for Shell s oil spill prevention and recovery in the event of any hydrocarbon spill and as such, by its very nature, cannot anticipate all possible contingencies. Objectives of the OSRP include: Describe Shell s IMT Assign individuals to fill positions on the IMT Define the roles and responsibilities of team members Define notification, activation, and mobilization procedures to be followed if a discharge occurs Document equipment, manpower, and other resources available to assist with the response Ensure compliance with Shell Upstream Americas Corporate Environmental Policy The OSRP is also comprised of the following supplemental plans: Net Environmental Benefits Analysis (NEBA) Dispersants Operations Plan Shipboard Oil Pollution Plan (SOPEP) - Stena Ice Max L4-DOC-ICE-4242 Shelburne Basin Venture Oil Spill Response Plan (EP ) Shelburne Basin Venture Wildlife Response Plan (EP ) Document # EP November 15, 2016

33 Table 4.3 Emergency Response Plans Title Description Stena MS Shell MS Source Control Contingency Plan Well Control Plan Wildlife Response Plan (WRP) The OSRP, NEBA, WRP and Dispersants Operations Plan will be submitted to, and reviewed by the CNSOPB as part of the Drilling Operations Authorization approval process. The Source Control Contingency Plan is made up of several specific documents to create the whole plan. The Source Control Contingency Plan is intended to provide specific details on how to combat a major event (blowout, Tier 2/3 Spill, etc.). The plans that make up the Source Control Contingency Plan are: Relief Well Contingency Plan Capping Procedure Subsea Dispersant Plan Each plan is specific to the Project to ensure the procedures and controls are activated to help mitigate an event. The Plans are submitted to, and reviewed by the CNSOPB as part of the Drilling Operations Authorization approval process. The Well Control Plan (often referred to as the Blowout Contingency Plan) is one of the well(s) specific response guides that is applicable to organizational levels which include (unless otherwise noted): Initial Response Procedures, Surface Blowout Scenarios, Logistics, Emergency Classifications, and Critical Elements which include: Equipment, Personnel, Suppliers, Mobilization, Safety, General Intervention Strategies, and Emergency Management Contractor Procedure are to follow Shell Requirements Contractor Procedure are to follow Shell Requirements Relief Well Contingency Plan (EP ) Source Control Contingency Plan (EP )Shelburne Basin Capping Procedure (EP ) Shelburne Basin Subsea Dispersant Plan ( )) Cheshire 1-97 Well Control Plan (EP ) Document # EP November 15, 2016

34 Table 4.3 Emergency Response Plans Title Description Stena MS Shell MS Organization. Note: The Well Control Plan excludes Relief Well Contingency Plans. Document # EP November 15, 2016

35 5. SHELL HSSE MANAGEMENT SYSTEM Shell s general operating principles are underpinned by a deliberate focus on safety and environmental protection. Shell meets or exceeds regulatory requirements applicable to its operations, which are designed to reduce risks to the environment and keep people safe. Shell s safety record is built on strict adherence to company standards and multiple safety barriers to prevent incidents from occurring. Shell s safety standards also includes a culture that requires workers, contractors and visitors to stop any unsafe activities. Shell maintains a high level of integrity to protect the environment and the people that work at its locations. The following sections will outline the Shell HSE Management System and how it will be applicable to working offshore Nova Scotia. The Shell HSSE & SP Control Framework (Figure 5.1) forms the basis for all activity level documents, plans and procedures. The HSSE & SP Standards are organized by topic into Manuals covering appropriate subjects. Lower level plans and procedures are available within each subject area. The HSSE & SP CF, Manuals and the 8 Elements of the HSSE & SP Management System describe how HSSE & SP is managed in Shell and who is designated with accountabilities and responsibilities within the Shell Shelburne Basin Venture. Document # EP November 15, 2016

36 Figure 5.1 HSSE & SP Control Framework Document # EP November 15, 2016

37 5.1 Leadership and Commitment The HSSE & SP CF embodies Shell s corporate policies and commitments to operate legally, ethically, and in a manner that is socially responsible and sustainable. Leadership and Commitment to HSSE & SP performance is a foundational element of Shell s HSSE & SP MS. Shell s HSE management system outlines the necessary leadership required to create and sustain a culture that: establishes health, safety and environmental responsibility as core values among employees; meets the requirements of Shell HSSE & SP policies and objectives and operates in full compliance with all permits, regulations and HSE procedures; trains, develops and empowers employees to execute their defined HSSE & SP roles; defines accountability for HSSE &SP performance; and evaluates and continuously improves HSSE & SP performance. Shell Senior Leadership/Management ensure that HSSE &SP is an integral part of the work place's culture by: Requiring that policies be implemented and that standards and procedures be followed; actively and visibly participating in HSSE & SP activities (leading by example), such as incident investigations, HSSE &SP MS training, reward and recognition programs, industry/contractor workshops, inspections, open discussions with interested third parties and audits; setting specific HSSE & SP objectives and targets for employees/workgroups, and visibly monitoring performance and follow up; jointly developing and discussing HSSE & SP results and activity improvement targets with contractors; reviewing the progress of the development, implementation and verification of HSSE &SP MS and HSSE & SP cases and making the resources and expertise available to meet the targets; and through managers conducting site visits ensuring actions items are tracked for closure. Document # EP November 15, 2016

38 5.2 Policies and Objectives Shell s Commitment and Policy Shell s HSSE & SP Commitment and Policy applies across the organization and is designed to help protect people and the environment. It includes aims aligned with the Shell General Business Principles on how we operate and work to involve communities close to our operations. Shell s commitment and policy reflects the integrated way work is conducted across Shell in the areas of HSSE & SP. All Shell companies, contractors and joint ventures under operational control are required to manage HSSE & SP in line with the Commitment and Policy. The Shell HSSE & SP Commitment and Policy (see Figure 5.2) provides the foundation for a systematic approach to HSSE & SP management and outlines specific commitments regarding objectives and performance expectations. The HSSE & SP Commitment and Policy is communicated to employees and contractors, as well as being displayed in office and work locations and underpins Shell s HSSE & SP MS. Document # EP November 15, 2016

39 Figure 5.2 Shell HSSE & SP Commitment and Policy Document # EP November 15, 2016

40 5.2.2 Stena Health, Safety & Environmental Health Policy Statement Stena Drilling s Health, Safety and Environmental Health Policy (Figure 5.3) outlines the company core values and beliefs and their commitment and aim for all business to be conducted in a safe and efficient manner with no injury to people, harm to the environment, or damage to equipment and the workplace. To meet this goal a number of objectives are outlined in their policy statement which has been endorsed by Stena s Managing Director and Operating Manager. Additionally, this policy outlines the responsibilities and accountabilities of employees, management and supervisors in ensuring that the outlined objectives are implemented and the overarching HSSE & SP goal is met. Figure 5.3 Stena Drilling Health, Safety and Environmental Health Policy Stena Environmental Protection Policy As part of Stena s Health, Safety and Environmental Health Policy, Stena has developed a separate Environmental Protection Policy to specifically outline Stena s Document # EP November 15, 2016

41 commitment to environmental protection second only to considerations affecting the safety of people (Figure 5.4). In conducting their work in accordance with this policy, Stena strives to ensure that all their business and operations are conducted in an environmentally responsible manner. Figure 5.4 Stena Drilling Environmental Protection Policy Stena Management System The Stena Drilling Management System (SMS) is an integrated management system through which the company defines and delivers its business objective, identifies and manages risk and systematically reviews performance. The management system is further described in the Stena IceMax HSE Case: Part 2- Management System (L4- DOC-ICE-4127). Stena s management system follows the Quality Standard ISO 9001 and is certified to the ISO Environmental Standard. Stena Drilling has also achieved compliance with the International Safety Management (ISM) Code, an international standard for the safe management and operation of vessels and for pollution prevention adopted by the International Marine Organization (IMO) in Compliance with this code is mandatory for drilling vessels and is verified on an annual basis. The Stena Document # EP November 15, 2016

42 Management System contains a number of documented procedures which address these requirements and verifies ongoing compliance. Where relevant to environmental management, these documents have been referenced in the EPP Objectives & Targets Shell s main objective is Goal Zero: no harm and no leaks, an accident free workplace and one free of significant incidents. In addition, Shell has a vision to deliver safe, profitable, environmentally and socially responsible activities and projects, in line with the expectations of our customer & stakeholders Project Level Objectives and Targets HSSE & SP performance data from the Project are collected and reported to the Venture Leadership Team on a weekly basis and to the CNSOPB quarterly, annually and at the end of the exploration program. At the asset level, the goal is Zero injuries, Zero environmental spills and 100% compliance with regulatory requirements. Dissemination of information, including communication of hazards, mitigations, targets and goals, is achieved through a number of different mediums: Presentations from Line Management via established monthly meetings Orientation training during arrival on the vessel/rig and for all new hires working the project. Discussions during Quarterly Contractor Management Meetings. Document # EP November 15, 2016

43 6. ORGANIZATION, RESPONSIBILITIES AND RESOURCES 6.1 Venture Level Organization and HSE Accountability Shell s organization for the Shelburne Basin Venture Exploration Drilling Project is a function-based organization drawn primarily from its Upstream Americas (UA) organization, which includes all upstream operations in North and South America. The UA organization provides the majority of technical and managerial support to field operations in the Shelburne Basin through a matrix style organization. This organization contains expertise in Safety, Environmental Protection, Health Management and Emergency Response. The Shelburne Basin Venture organization chart and roles is included in Appendix A. Venture Manager (Atlantic Canada) <Redacted> The Venture Manager is the person accountable for ensuring Health, Safety, Security, & Environmental Management Systems are fully implemented and effective, providing input on strategy development for each project deliverable, sanctioning the manpower and resources necessary for implementation of the EPP and holding personnel accountable for its implementation and continued maintenance. Shelburne Basin Venture Wells Operations Manager < Redacted> The Shelburne Basin Venture Operations Manager is the local senior focal responsible for the project and the implementation of the EPP. Shelburne Basin Venture Leadership Team (VLT) Members of the VLT are responsible for ensuring compliance with the requirements of the EPP, to the extent applicable to their respective teams. Shelburne Basin Extended Venture Leadership Team (EVLT) The leads of these teams are responsible for familiarizing themselves with the EPP, communicating the specific requirements applicable to their team members and contractors, while ensuring that deliverables and commitments are met within the stipulated timelines. HSE Representation HSE representatives have been allocated for all Project components and workspaces (MODU, Supply Base, Road, Marine, Aviation) to support execution of all parts of Shell and contractor HSE management systems and the EPP. All Shell line management personnel have an HSE oversite role. Document # EP November 15, 2016

44 Local Staff (Halifax and Offshore) Shell Staff are responsible for ensuring the EPP is followed while identifying areas for improvement to their respective managers and team leaders. Contractors All Contractors are responsible for familiarizing themselves with Shell s Operations Safety Plan (OSP), EPP and other various work documents. Workers are orientated to the EPP to ensure that Shell s Environmental objectives are achieved and maintained. All Contractors providing a service or support for the Project are required to work in accordance with the provisions of this EPP Contractor Level Roles & Responsibilities Contractors are selected within the rigors of a well-defined bid and selection process. A part of this selection process includes an assessment of resources (manpower, equipment, and asset) required for the project; contractors are responsible to provide fully certified equipment onshore and offshore including a MODU that meets its class designation including the rig equipment, crews, and HSE management systems; and meet local regulatory regulations, requirements and standards. To ensure that the Health, Safety, and Environmental Management System is integrated into all of its business activities, all Contractors will: Advise each manager, supervisor, employee of his/her HSE rolls and responsibilities; Comply fully with all applicable HSE laws and regulations; Provide safe working rules, practices and procedures based on risk experience, safety knowledge and competent work direction; Assess all anticipated known risks prior to starting a new activity or one that is conducted very rarely; Ensure employees are qualified, trained, and competent to perform the work they are assigned; Eliminate or minimize potential damage to equipment, vessel or environment; Investigate all incidents/accidents and take corrective action as appropriate; Ensure a rapid and appropriate response to emergencies is established and maintained; Provide adequate and trained professional staff to support HSE activities; Document # EP November 15, 2016

45 Monitor and report HSE performance for continuous improvement; and Establish a strong HSE culture within all working groups/teams and contractor/shell interface. Every employee of the contractor has the responsibility to: Promptly report all hazards, incidents and near miss occurrences; Provide ideas and identify concerns to ensure environmental protection and safety efforts and commitments are appropriately implemented and continuously improved; Comply with all applicable federal, provincial and local regulations related to health, safety, and environmental programs Environmentally Critical Roles In accordance with the EPP Guidelines, an environmentally critical role is defined as assigned work or responsibility key to the mitigation of the effects of pollution, or to monitoring or managing structures, facilities, equipment and systems critical to environmental protection (CNSOPB 2011). Environmentally critical roles for the Project have been identified in association with bowtie analyses performed to assess the identified major hazards for the Project. Further information on Shell s risk assessment and management and the associated bowtie analysis can be found in Section 5.3 of this document as well as section of the OSP (EP ). The list below outlines the associated personnel considered to be in environmentally critical roles onboard the MODU and onshore: Drilling Supervisor Shell Onboard HSE Officer Stena HSE Officer Master/OIM Barge Master Senior DPO Chief Engineer Senior Operations Engineer Wells Operations Manager Rig Manager Drilling Superintendent Document # EP November 15, 2016

46 Wells HSE (Well Planning) Further details regarding required competencies and training for individuals in HSSE critical roles is included in Section 8.3. Full details of the individual training requirements for environmentally critical position training requirements can be found in the Shelburne Basin Training and Competency Management Plan (EP ). 6.2 EPP Responsibilities The Project will be managed by Shell, which organizes its deepwater exploration ventures to include the disciplines and expertise required to deliver a project. During drilling, the two largest disciplinary teams will be the Well Delivery Team and the Subsurface Team. Additional disciplinary support teams associated with the Project include: Contracting and Procurement; Logistics; HSSE & SP; Environmental; Regulatory; Commercial; Social Performance; Stakeholder Consultation; Indigenous Relations; External Communications; Legal; and Finance. The Operations Manager, Shell Drilling Superintendent, Stena Rig Manager and OIM will have ultimate responsibility for ensuring the execution of and compliance with the EPP on the MODU during operations. The Logistics Lead is responsible for executing the relevant components of the EPP that apply to the Supply Base, Road, Marine, and Aviation operations. Table 6.1 summarizes the delegation of responsibilities pertaining to the management and implementation of this EPP. Document # EP November 15, 2016

47 Table 6.1 EPP Roles and Responsibilities Role Shell Venture Manager Shell Operations Manager Shell Drilling Superintendent Shell Venture HSE Manager Shell Logistics Lead Shell Wells HSE Supervisor Shell Environmental Lead Stena Rig Manager Stena Master/ Offshore Installation Manager (OIM) Stena Safety Officer Shell Senior Offshore HSE Technician Offshore Personnel and Contractors EPP Accountabilities & Responsibilities Overall accountability for the Shelburne Basin Venture Exploration Drilling Program Accountability for operational execution and installation compliance during the Project inclusive of EPP implementation Responsible for reporting environmental incidents to the CNSOPB and other relevant regulatory authorities. Planning and execution of daily drilling operations in a manner that maximizes HSE values and complies with HSE commitments and regulatory requirements. Overall accountability for ensuring the appropriate HSE systems are in place and functioning Accountability for Support Vessel, Road Transport and Helicopter operations. Overall accountability for ensuring the appropriate HSE systems are in place and functioning Development and maintenance of the EPP Obtains CNSOPB Approval of EPP Supports communications pertaining to the content of the EPP. Reviews monthly compliance reporting Responsible for ensuring submission of monthly environmental compliance reporting to CNSOPB Overall accountability for HSE for Stena s operations in support of Shell s Shelburne Basin Venture Exploration Drilling Program Overall authority and accountability regarding environmental protection and implementation of the EPP on the drilling rig. Supports the implementation of the EPP including monitoring performance and compliance. Compilation and review of environmental compliance data for reporting to CNSOPB Works with the Offshore Stena Safety Officer to support the implementation of the EPP Conducts inspections and audits Executes all activities in compliance with EPP Document # EP November 15, 2016

48 7. HAZARD IDENTIFICATION AND RISK EVALUATION Shell s Health, Safety, Security, Environment and Social Performance Management System (HSSE &SP MS) requires the identification of hazards that could potentially impact personnel, the environment, assets or reputation. Proactive management is required to ensure that these potential hazards are identified and the associated risks assessed to ensure that appropriate controls are put in place and maintained to reduce risks to as low as reasonably practicable (ALARP). Identification and management of hazard associated HSE risks is conducted in a systematic manner as outlined below and is ongoing throughout the full Project life cycle (Planning to Operations). 7.1 Hazard and Effects Management Process Shell s hazards and effects management process (HEMP) as shown in Figure 7.1 relies on the principles of 'identify', 'assess', 'control' and 'recover', which are applied by completing the following steps: 1. Identify HSE hazards and document their effects on people, assets, environment and reputation in a Hazards and Effects Register 2. Assess the risk of identified hazards for worst case credible scenarios using the Risk Assessment Matrix (RAM), and document this assessment of risk in the Hazards and Effects Register (The Shell Risk Assessment Matrix or RAM is further described in Section 7.1.1). 3. Manage Hazards having risks in the dark and light blue areas of the RAM through effective implementation of the HSE Management System. 4. Where reasonably practicable, eliminate hazards or substitute hazards that have risk in the yellow area and red area of the RAM with ones having lower risk. 5. Identify and implement controls and recovery measures for hazards in the yellow area of the RAM to reduce risk to ALARP. 6. Identify and implement controls and recovery measures for hazards in the red and yellow A5 and B5 areas of the RAM (as stated above for yellow risk hazards) and in addition by a bow-tie or equivalent methodology. This methodology must include the following: a. Identify barriers to prevent a top event, to prevent escalation factors and to reduce the consequences should the top event occur b. Identify critical activities to maintain the barriers c. Identify critical equipment and performance criteria d. Identify criteria for ALARP determination e. Provide a documented demonstration of ALARP 7. Prepare a remedial action plan to close any identified gaps. Document # EP November 15, 2016

49 Figure 7.1 Hazard Identification System Risk Assessment Matrix (RAM) Hazard associated risks are assessed using the Risk Assessment Matrix (RAM) described in the Shell HSSE & SP CF and shown in Figure 7.2 below. The RAM s purpose is to establish a consistent process for assessing and characterizing HSSE risks and is used in association with HSSE risk assessments and incident classification. The Venture Leadership Team and the Front Line Managers are responsible to ensure competence of staff and/or contractors applying the RAM. Figure 7.2 provides a description of the RAM. Document # EP November 15, 2016

50 Figure 7.2 Risk Assessment Matrix Bow Tie Analysis Bow Tie analysis combines a fault tree with a consequence tree. Shell uses the Bow Tie exercise for the assessment of high HSSE risk hazards. High HSSE risk hazards are those shown in red on the RAM, plus A5 and B5, as outlined in Figure 7.2. An example of a Bow Tie Analysis Diagram is provided in Figure 7.3. The Bow Tie consists of: Threats Barriers Hazards Top Event Recovery Measures (Barriers) Escalating Factors Consequences Document # EP November 15, 2016

51 A top event is the loss of control or release of the hazard. When effectively in place: Barriers prevent hazards from becoming a top event by stopping the threat; and Recovery preparedness measures (or recovery measures) prevent the top event from becoming a severe consequence (i.e., cause harm, damage, or environmental impacts). Escalation factors are conditions that lead to increased risk due to loss of controls (barriers or recovery measures). Escalating factor controls (or escalating controls) are measures put in place to mitigate the effects of escalation factors. Increasing the number and/or quality of barriers reduces the probability of something occurring. Increasing the number and/or quality of recovery measures reduces the impact of something occurring. Reducing the probability and/or the impact reduces the risk. Figure 7.3 Bow-Tie Analysis Diagram Document # EP November 15, 2016

52 7.2 Environmental Assessment In addition to the Hazard and Risk assessment processes described above, Shell s HSSE & SP CF requires that an Impact Assessment (IA) be completed for all new Projects to further identify and assess the potential environmental, social and health impacts of a project and to implement mitigation measures to minimize negative impacts and optimize any potential positive impacts. Where external regulatory requirements for an IA exist, assurance is made that these external requirements allow compliance with the Shell HSSE & SP CF framework requirements and additional analysis and assessment are undertaken where gaps are noted. In line with internal and external requirements, the primary study undertaken to identify environmental hazards and evaluate environmental risks associated with the Project was an environmental assessment (EA) pursuant to CEAA, The associated EIS (Stantec 2014) documents the results of the EA, including a summary of baseline environmental conditions and Shell s commitments regarding mitigation measures to avoid, prevent, reduce or manage risks to the environment. Relevant operational mitigation measures and commitments to manage the potential environmental effects noted in the EIS have been incorporated into the EPP where relevant. Table 7.1 below provides a summary of the identified potential hazards (potential interaction) as well as the identified and assessed potential environmental effects from the EIS. Additionally Table 7.1 refers to the associated mitigations measure established as part of the EIS to reduce the risk of the associated hazard and environmental effect to occur. Refer to Appendix C for a full summary of the EIS mitigation commitments associated with the Project. Additional requirements are outlined in the EA Report conditions released by CEAA on June 15, 2015 and included as Appendix D. Table 7.1 EIS Assessment Summary Project Component/Activity Potential Hazard Environmental Effect Mitigation Measure Presence and Operation of MODU Vessel Strike (Marine mammal and Sea turtles) Acoustic Emissions (Marine Mammal, Sea Turtles, Fish, Marine birds, Commercial fisheries, Aboriginal Use) Light Attraction Mortality or Physical Injury Appendix C: No. 45 Mortality or Physical Injury (auditory injury) Change in Habitat Use and Quality (sensory disturbance) Change in Availability of Fisheries (avoidance- Fish) Change in Traditional Use (avoidance Fish) Mortality or Physical Injury (stranding, starvation, Appendix C: No. 53, 54 Appendix C: Document # EP November 15, 2016

53 Table 7.1 EIS Assessment Summary Project Component/Activity Potential Hazard Environmental Effect Mitigation Measure (Marine birds) collision, incineration) Change in Habitat Use and Quality (attraction to MODU) No. 4, 18 Discharge of Drill Muds and Cuttings Exclusion Zone (Commercial fisheries, Aboriginal Use) Cuttings Footprint (benthic species and habitat Fish, Commercial fisheries, Aboriginal Use) Change in Availability of Fisheries Resources (localized exclusion) Change in Traditional Use (avoidance Fish) Mortality or Physical Injury (smothering) Change in Availability of Fisheries Resources (direct loss) Appendix C: No. 53, 54 Appendix C: No. 21, 22 Direct or Indirect Exposure (Marine mammals, Sea turtles, Fish, Marine birds, Commercial fisheries, Aboriginal Use) Change in Habitat Use and Quality (reduction in water and sediment quality, impact to prey species) Change in Availability of Fisheries Resources (avoidance- Fish) Change in Traditional Use (avoidance Fish) Appendix C: No. 24, 25, 27, 28, 53, 54 Other Discharges and Emissions Indirect Exposure (Marine mammals, Sea turtles, Fish, Marin birds) Change in Habitat Use and Quality (reduction in water and sediment quality, impact to prey species, temporary avoidance) Change in Availability of Fisheries Resources (avoidance- Fish) Change in Traditional Use (avoidance Fish) Appendix C: No. 7, 26, 29, 35, 53, 54 Vertical Seismic Profiling Direct Exposure (Marine birds) Acoustic Emissions (Marine mammals, Sea Turtles, Fish, Marine birds, Mortality or Physical Injury (oiling, attraction to MODU) Change in Availability of Fisheries Resources (direct loss) Change in Traditional Use (direct loss) Mortality or Physical Injury (auditory injury) Change in Habitat Use and Quality (sensory Appendix C: No. 7, 26, 29, 35, 53, 54 Appendix C: No. 50, 51, 52, 53, 54 Document # EP November 15, 2016

54 Table 7.1 EIS Assessment Summary Project Component/Activity Helicopter Transport OSV Operations Well Abandonment Potential Hazard Commercial fisheries, Aboriginal Use) Acoustic Emissions (Marine mammals, Marine birds) Collision (Marine birds) Vessel Strike (Marine mammals and Sea turtles) Acoustic Emissions (Marine mammals, Sea turtles, Fish, Marine birds, Commercial fisheries, Aboriginal Use) Light Attraction (Marine birds) Physical Structure (Marine mammals, Sea turtles, Fish, Commercial fisheries, Aboriginal Use) Environmental Effect disturbance) Change in Availability of Fisheries (avoidance- Fish) Change in Traditional Use (avoidance Fish) Change in Habitat Use and Quality (sensory disturbance) Mitigation Measure Appendix C: No. 13, 14 Mortality or Physical Injury Appendix C: No. 13, 14, 15 Mortality or Physical Injury Appendix C: No. 8, 11, 12, 15, 45 Change in Habitat Use and Quality (sensory disturbance) Change in Availability of Fisheries (avoidance- Fish) Change in Traditional Use (avoidance Fish) Mortality or Physical Injury Change in Habitat Use and Quality Change in Habitat Use and Quality (Localized disturbance) Change in Availability of Fisheries Resources (direct loss) Change in Traditional Use Appendix C: No. 11, 12, 53,54 Appendix C: No. 4, 18 Appendix C: No. 54, 55 Abandonment Plans 7.3 HSSE Studies The following HSSE studies (Table 7.2) have been performed to comply with Shell s HSSE &SP CF requirements to identify Project hazards, evaluate the associated risks and determine appropriate controls and mitigations. Copies of these studies are available upon request via the Shell Halifax Office. Table 7.2 HSSE Studies Document # EP November 15, 2016

55 Study Environmental Impact Statement Hazard Identification (HAZID) / Hazard and Effects Register Date Completed June 2014 October 2014 Scope The Shelburne Basin Venture Exploration Drilling Project Environmental Impact Statement (EIS) (Stantec 2014) evaluates potential environmental effects from the Project and recommends mitigation and monitoring to manage adverse environmental effects. The EIS also assesses a number of accidental events including a subsea blowout. This register includes all hazards identified for Exploration Operations and their risk ratings. Environmental aspects are also identified and considered. Outputs of the HAZID will include hazard listing and all associated controls for those identified hazards. Bow-tie Assessments Health Risk Assessment (HRA) October 2014 February 2015 Bow-tie assessments are required to detail the mitigation strategy for hazards potentially having red risk, or yellow 5A or yellow 5B risk according to the Shell RAM. Shelburne Basin Health Risk Assessment takes every reasonable precaution in the circumstances to protect the employee s own health and safety that will minimize the effects of exposure to those health hazards most commonly encountered in offshore exploration drilling operations HSE Case June 2015 Major potential HSSE risks are documented in an HSSE Case to demonstrate the hazards and effects associated with an installation and its operation have been fully identified and risks managed within the principles of As Low As Reasonably Practicable (ALARP). For the Shelburne Basin Drilling activities there is a Stena Safety Case. Where applicable, the existing Aviation, Marine and Road Transport HSSE Cases will be relied upon for the Project. Document # EP November 15, 2016

56 7.3.1 HSSE Study Results Table 7.3 outlines the Major Hazards and top events/worst case scenarios that were identified as part of the HSSE studies conducted in association with the Project and that could result in associated environmental consequences/effects. As part of these hazard assessments, critical tasks and responsible positions have been identified and outlined to prevent such an event. The associated bow-tie analysis and identified critical tasks and roles to mitigate each hazard can be found in Section Table 8 of the OSP. Table 7.3 also identifies the associated response plans to be implemented to address the associated top event. Further information on these response plans is provided in Section Table 7.3 Identified and Assessed Project Hazards Potential Major Hazard Top Event Environmental Consequence Response Plan HAZID Reservoir Hydrocarbon under Pressure Shallow Gas Approaching Vessel Engine Room Combustibles Object at Height Air Transport Marine Bulk Transfers Vessel to Vessel Transfers Loss of Well Control Surface Loss of Well Control - Subsea Loss of Well Control- Shallow Gas Ship Collision Fire in Engine Room Dropped Object Helicopter Ditching at Sea Helicopter Ditching on the MODU Loss of Containment Environmental Impact Statement (Stantec 2014) Environmental Damage (product release to the marine environment) Environmental Damage (product release to the marine environment) Environmental Damage (fuel or drilling fluid release to the marine environment) Environmental Damage (resulting release of combustibles, bilge to marine environment) Environmental Damage (release or object loss to the marine environment) Environmental Damage (fuel and/or material release to the marine environment) Environmental Damage (release of product to the marine environment) ERP OSRP Source Control Contingency Plan Well Control Plan ERP ERP ERP ERP ERP ERP Document # EP November 15, 2016

57 Table 7.3 Accidental Event Subsea Blowout (30 day release) Operational Batch Spill (Instantaneous release) SBM whole Mud Spill (Instantaneous release) Vessel Spill (Instantaneous release) Identified and Assessed Project Hazards Worst Case Credible Scenario bbl/day bbl/day Environmental Effect Mortality or Physical Injury Change in Habitat Use and Quality 100 bbl Marine Diesel Mortality or Physical Injury Change in Habitat Use and Quality bbl (full tank release) bbl (full riser release) Mortality or Physical Injury Change in Habitat Use and Quality 100 bbl Marine Diesel Mortality or Physical Injury Change in Habitat Use and Quality Response Plan ERP OSRP Source Control Contingency Plan Well Control Plan ERP ERP ERP Document # EP November 15, 2016

58 8. AWARENESS, COMPETENCE AND TRAINING Training and competency management and assurance for the Project is detailed in the Shelburne Basin Venture Training and Competency Management Plan (EP ) currently under development. 8.1 Awareness All personnel are made aware of the existence of the EPP, Shell policies, plans and procedures and how it relates to their role on the Project, during kick-off orientation training. The EPP is described in the pre-start-up meetings to all workforce by the Venture Operations Manager and the Venture HSE Lead with support from the Environmental Lead. This meeting covers all aspects of the proposed drilling campaign, including health, safety and environmental aspects. The environmental component of this orientation will, among other things, address the environmental setting of the Project, regulatory context and expectations as well as requirements for environmental compliance. 8.2 Competence Shell employees and contractors are qualified and competent to perform the work required for the operations. The following processes are in place to provide competent resources (Figure 8.1): Figure 8.1 Onshore/Offshore Operations Interface Organizational Chart Document # EP November 15, 2016

59 Recruitment - Every level of employment has to meet or exceed job specific recruitment criteria such as experience in position, training and other qualifications or educational background. Recruitment is a responsibility of each contractor to validate any work experience and qualifications for the hiring of personnel. This requirement is mandated by contracts that are vetted through Shell Contracts and Procurement and CSMP process. Refer to the Shell Training Matrix, Stena Ice Max HSE Case & 2.3.6, and Stena Competence Assurance Scheme for further details. Each Shell Employee and Contractor that will be working offshore prior to being assigned to the project will have conducted and obtained a valid and full duty Medical Evaluation as per CAPP s - Atlantic Canada Medical Assessment for Fitness to Work Offshore. These evaluations will be maintained by each contractor at their respective location and will be available for assurance purposes as required. 8.3 Training Position specific training is provided to increase the knowledge and skill of workers. Refresher training is provided at appropriate intervals. Mandatory training is listed in each companies training plan or matrix and available on the MODU. The required professional, marine, and trade certifications will be determined for the relevant roles and maintained accordingly. All Shell personnel positioned in a HSSE Critical Roles performing any HSSE Critical Tasks will have been assessed against the Front Line Barrier Management Standard requirements that include Well Control Testing, Round 1 & Round 2 Well Diploma programs, and other standards that apply. These qualifications will be verified through the training profiles found on SOU and with Global Wells Training Coordinator. It is the responsibility of the Supervisor to ensure these requirements have been followed and met. For Stena personnel, it is the responsibility of the OIM to ensure that all employees assigned both Safety and Environmental Critical positions described in the Stena HSE Case Critical Task sheets (refer to Table 8 of the OSP), has met the training and qualification requirements outlined in the Stena HSE Training Matrix for Competency Assurance for each identified critical task. Verification Prior to starting work, each company must demonstrate that training of their staff and contractors has been completed, and they will maintain a training matrix and compliance status for their staff, including but not limited to safety leadership training, Basic Survival Training with HUEBA, and H2S awareness. This will be verified and audited through the Venture HSE Team Lead and the Shelburne Basin Training Coordinator for the Shelburne Basin Document # EP November 15, 2016

60 drilling program based on the Shelburne Basin Training and Competency Management Plan (EP ). Stena s policies and procedures relating to personnel competence are outlined in the Stena Training Manual for each position. Full details on these position requirements can be found through the Shelburne Basin Training and Competency Management Plan (EP ) which includes the training matrices. It is the Rig Manager s responsibility to ensure that personnel are trained accordingly. Statutory training is coordinated by the Stena Training Administrator who keeps records of all training completed. In-house and onboard training is recorded and records held onboard by the OIM. Periodic audits confirm programs are functioning and effective. 8.4 Contractor Management Shell utilizes a Contractor Management Program which identifies, early on in the contracting process if the Contractor s Management System is equivalent to Shell s. If after review, it is determined that the Contractor s Management System is not equivalent to Shell s, then Management System interfaces from key contractors will be included in the relevant Bridging Document(s). Each Bridging Document describes the contractor specific details/mapping or bridging documents which provided support on how the specific contractors are managing their risks to ALARP, if contractors are used for the execution of the scope of work. Contractor HSE management is performed in accordance with the UA Contractor HSSE Management Process (CSMP). Implementation of CSMP provides assurance that selected contractors are competent to perform the contracted work and that contractor performance will be monitored and recorded for future contractor appraisals. The Shell HSSE CF provides simple expectations for managing key HSSE risk. These expectations are mandatory across Shell and are delivered in the form of the Contractor HSSE Management Mandatory Manual. In order to support bid evaluation, potential contractors are required to provide the following for consideration : Past and current HSSE performance Demonstration of an existing HSSE MS that exhibits the same degree of application and assurance as the Shell HSSE CF. Demonstration of an existing Competence Assurance process for personnel Demonstration that training programs support the management of the associated HSSE risks Document # EP November 15, 2016

61 Existing fitness to work process for personnel Demonstration that tools and equipment are suitable and safe for use. This information is used to assess whether the chosen contractor has the capability and resources to manage the HSSE risks associated with the proposed work. HSSE performance will be a key consideration in determining a preferred contractor and the Shell Contractor HSSE Management Manual requires preferential selection of those companies that show good HSSE performance. During operations, Shell will continuously monitor and regularly assess the HSSE performance of the associated contractors to ensure compliance with the HSSE performance agreed in contract. The Shelburne Basin Venture will have an assurance plan which lists the various process level and worksite level audits and assurances that will be executed during operations. Document # EP November 15, 2016

62 9. EPP MANAGEMENT 9.1 EPP Review and Revision Shell and Stena have reviewed this EPP to ensure that the appropriate aspects of their HSE management systems and environmental policies are integrated and that the environmental protection and measures are consistent with company requirements and capabilities as well as established regulatory commitments. Once a quarter the EPP is to be reviewed for changes in all policies that could have an impact on the EPP. Additionally this EPP will be reviewed at the close of Project Operations to identify any required adjustments or revisions as a result of lessons learned from Project operations and in advance of any future operational activities. If changes are needed, they will made, reviewed by Shell Leadership and resubmitted to the CNSOPB for final approval. Once approved the changes will be distributed throughout the assets of the Shelburne Basin Venture. Changes to the EPP shall only be made in accordance to Shell Canada s Management of Change (MOC) process (Section 8.3) and with the engagement and approval of the CNSOPB. No changes to the outlined commitments of this plan shall be implemented until formal approval is provided by the CNSOPB and a revision has been issued. Any revisions to the EPP will be communicated to any affected stakeholders and revised version distributed to hardcopy holders and managed in accordance with Shell s document control system. 9.2 Document Control Shell has a Document Control system to identify, collect, store, retrieve, route and dispose of documentation to ensure operational integrity and regulatory compliance. The process used to manage these documents is described on the Shell UA Control Framework documents homepage. Printed documents are assumed to be uncontrolled, potentially out of date, and require latest version verification. For more information, refer to the Shelburne Basin Venture Document Management Plan (UAXSV-HSE0001- PR01). Document # EP November 15, 2016

63 Table 9.1 provides a sample list of controlling documents and identified storage locations. Table 9.1 Document Control Records and Storage Location Document/Record CNSOPB Regulatory Records and Submissions Environmental Regulatory Records and Reports (including EPP and EA materials) Legal Records Preventative / corrective maintenance records of HSE critical equipment Audit records and action items Incident reporting records HSE Training records Risk Management Documents Personnel records (GPAs, CBDs, IDPs) Storage Location Shelburne Venture Sharepoint (Intranet) Web Site Shelburne Venture Sharepoint (Intranet) Web Site Local files / UA Legal Calgary and Halifax Office PM Systems onboard Each Vessel Fountain Assurance (Intranet) Web Site Fountain IMPACT (Intranet) Web Site Shell Open University (Intranet) Web Site Shelburne Venture Sharepoint (Intranet) Web Site Shell People (Intranet) Web Site 9.3 EPP Communication and Distribution The contents of this EPP will be communicated, as appropriate, to all Shell and contractor personnel involved with Project activities and with responsibilities associated with the EPP. In addition, following finalization, Shell will disseminate hard copies to the relevant parties involved in implementation and management of the EPP. Table 9.2 identifies the proposed hard copy distribution for the EPP. In addition, all Shell and contract staff will have electronic access to the EPP through an established online document management system. Interested public and first nation stakeholders will be provided links to the document once finalized and posted on the CNSOPB public document registry. Hard copies will be sent by mail as requested. Table 9.2 EPP Distribution List Role Company Location Venture Manager Shell Shell Office - Calgary Operations Manager Shell Shell Office - Halifax Drilling Superintendent Shell Shell Office - Halifax Shell Senior Drilling Supervisor Shell Shell Office - Halifax Venture HSE Manager Shell Shell Office - Halifax Wells HSE Lead Shell Shell Office Houston Environment Lead Shell Shell Office - Calgary Document # EP November 15, 2016

64 Table 9.2 EPP Distribution List Role Company Location Logistics HSE Lead Shell Shell Office - Halifax Shell HSE Technician Shell Stena Ice Max Rig Manager Stena Stena Office - Halifax Offshore Installation Manager Stena Stena Ice Max Safety Officer Stena Stena Ice Max Environmental Advisor CNSOPB TD Centre, Halifax Public and stakeholder communication is addressed in Section 19. Document # EP November 15, 2016

65 10. OPERATIONAL CONTROL 10.1 Operations and Maintenance Procedures Shell Operations are managed according to a hierarchy of applicable plans and procedures starting with the Shell HSSE & SP Control Framework and associated HSSE &SP Mandatory Manuals as discussed in Section 4.3. These documents set the framework of control that subsequent operating activities and contractors are required to align with. In addition and as described in Section 4.1 and 4.2 a number of statutory and guidance documents are to be complied with and function to ensure environmental management practices in addition to the internal standards and manuals 10.2 Structures, Facilities, Equipment and Systems Critical to Environmental Protection An environmentally critical element (ECE) is a structure, facility, equipment or system whose failure will either cause or contribute to an environmental event, or the purpose of which is to prevent or limit the effect of an environmental event. Shell recognizes that there are various critical elements associated with the Project that contribute to environmental protection. For these elements to be effective, appropriate procedures for installation, operation, inspection, testing, and maintenance activities must be welldefined and executed. The equipment and installations that are to be used in the work or activity to be authorized are fit for the purposes for which they are to be used. ECEs as well as Safety Critical Elements (SCE), which are often one in the same, are identified during Bow Tie analyses and other studies as outlined in the respective HSE Case. Refer to Section of the OSP for a complete list of all structures, facilities, equipment and systems critical to environmental protection, which are noted on the Bowties and listed with each Hazard Sheet. A performance standard, the Technical Integrity Performance Standards (TIPS) exists for each ECE and SCE. Each performance standard specifies and describes the tasks necessary to validate that the ECE and SCE performs the function necessary for the barrier to be effective, and includes the acceptance criteria which the ECE and SCE must meet. The performance standard contains information on: System description, boundaries and function; Design and installation requirements; Operations and maintenance requirements; and Inspection and repair requirements. Document # EP November 15, 2016

66 Stena has an established procedure for Identifying and Managing Environmentally Critical Elements (Doc. No. L2-DOC-LPD-4996). In accordance with this procedure, the Stena OIM is responsible for ensuring that sufficient resources are available so that ECEs are identified, documented and managed onboard the MODU as well as to ensure that consideration is given to the minimum standards of ECE prior to purchasing any new, replacement or modified equipment for the MODU. Stena s Chief Engineer is responsible for ensuring that the planned maintenance schedule is adequate for the identified ECE, that maintenance schedules are adhered to, and that any ECE failures/deficiencies are risk assessed and recorded. Stena s Maintenance Superintendent is responsible for ensuring that any ECE is identified in the maintenance system and that History, Planning, and Outstanding Work Order reports are available. Stena Drilling inspects and maintains environmentally critical elements onboard the Stena IceMAX on a routine schedule which include the following systems: Bilge System Deck Drainage Drill Cuttings Cleaning System Sewage and Grey Water Systems Helifuel System Fire Control Systems Bulk Fuel and Fluid Transfer Systems Certificate of Fitness and Certification In accordance with CNSOPB requirements, the drilling vessel will possess a Certificate of Fitness that has been approved by the CNSOPB prior to starting operations. Equipment contractors interfacing with the Project must ensure that compliance with company, industry standards, and regulatory requirements are maintained. Stena will have an OA required Certificate of Fitness provided by Det Norske Veritas (DNV). Additionally, the equipment contractor must ensure that compliance with Class, other regulatory requirements and industry standards are maintained and Shell will conduct inspections and audits to ensure this compliance is maintained. Shell will ensure that all Contractor equipment is fit for purpose. Only appropriately certified equipment will be used. Any additional critical equipment requires appropriate certification prior to use (e.g., pressure vessels, materials handling equipment and lifting gear). It is the responsibility of the Contractor to ensure that any such additional equipment is fit for purpose and safe to use prior to entering service with Shell. Document # EP November 15, 2016

67 All lifting equipment (i.e., slings, shackles, pad-eyes, etc.) is visually inspected by a competent person from the contractor prior to use and certified by a qualified third party, annually, as a minimum. Certification certificates must be at the work site for review by Shell and Regulators if required. A colour coding system is in place for the purpose of identifying dates for inspection and/or testing. Additional information can be found at the sites. Shell and its contractors maintain Quality Management Systems to ensure that all equipment conforms to the specifications. These systems include procurement of materials, inspection and testing, witnessed by third parties where appropriate, and final inspections prior to installation Management of Change Figure 10.1 Management of Change HSSE & SP risks related to process, procedural or organizational changes are managed under Shell s Management of Change (MOC) procedures. Shelburne HSSE & SP procedures are reviewed whenever changes occur to relevant HSSE & SP CF manual sections, or when business risk profiles change and approved by the accountable leader. Shell uses the MOC process detailed in the Shell Global Wells Management System (GWMS) Manual (WS Gen Rev 1). Stena uses the MOC process detailed in Stena procedure Management of Change Principle L2-PR-OPS Shell and Stena are responsible to fully execute its respective MOC programs for changes that they are responsible. Completed MOCs will be made available upon request by either company. Any MOC needed outside this scope will have the procedures identified through the respective Bridging Documents. However, the minimum will be to follow Shell standards until this has been identified. At a minimum the MOC processes shall be used to manage permanent and temporary changes of the following types: Process (equipment, process control, and process condition) Document # EP November 15, 2016

68 Procedural (affecting HSSE &SP) Organizational change (changes in critical role compliment and/or roles and responsibilities) These requirements include the revision distribution and control of associated documents. MOC s are not required for the following changes: Procedural changes that do not affect HSSE critical content Like For Like Replacement (equipment or personnel) Organizational changes that do not involve transfer of HSSE &SP Critical Activities Ongoing changes will be managed through the MOC process to ensure that the integrity of the design is maintained throughout its life. All proposed changes covered by the MOC Process are screened for their impact to health, safety, environment or regulatory compliance, reviewed and approved. This EPP will be a controlled document and subject to Shell s MOC procedures. Document # EP November 15, 2016

69 11. MONITORING AND REPORTING 11.1 Performance Measurement and Compliance Monitoring Compliance with Shell HSSE & SP requirements is checked through Management site visits, onboard inspections, monitoring of proactive measures, and incident information, and other assurance processes as described below. EPP specific considerations will be added to these checks and observations prior to commencing operations. Specific environmental monitoring programs to be implemented as part of the Project are further discussed in Sections In association with Shell s own Performance Monitoring and Reporting (PMR) requirements under the HSSE CF, Shell measures and monitors performance of the following environmental parameters: Energy Use Greenhouse Gas (GHG) Emissions Flaring and Other Emissions Water Use Oil Discharged to Surface Water Waste Unintended Emissions and Discharges (i.e., hydrocarbon spills) Biodiversity These measures are recorded in Shell s online reporting tool. Overall effectiveness of the EPP and environmental performance of operations shall be measured against these parameters as well as inputs such as non-compliance reports and discussions during any of the above process activities. A formal project review will be carried out at the end of operations. Intermediate reviews may be initiated based on audit findings, site inspections and incident / accident reports Audits and Inspections Project activities will be subjected to planned inspections and audits to identify potential environmental and safety problems or non-compliances. The purpose of the inspection and audit process is to ensure continued compliance with regulations, operational plans, company plans and regulatory commitments. Audits are carried out in compliance with Shell Assurance as well as local assurance and self-assessments. The auditor s requirements are defined in the HSSE & SP Control Framework. Document # EP November 15, 2016

70 The following is a summary of various planned audits: Pre-Start Up Reviews e.g., including Drilling, Marine, and Aviation Vessels Internal Audits e.g., Shell HSE Audits, Self-Assessments / Inspections o LOD1 self-assurance is an asset or venture led assessment of all or part of the HSSE & SP CF within that asset. o LOD2 audits are performed by independent assurance providers from the Wells business, are integral to the LoB Audit Plan and requested by the business and/or business unit. o LOD3 are independent audits performed by Group and external assurance providers. LOD3 audits will include Group level assurance activities [e.g., Shell Internal Audit (SIA), Shell Maritime Business Review (SMBR) audits] o On an annual basis, each LoB will establish, maintain, and execute HSSE & SP self-assessments in support of the HSSE & SP Assurance Plan Independent and External audits (e.g., CNSOPB and Transport Canada Inspections, and Third Party Verifications) Contractor HSSE Audits All audits are tracked in Fountain Assurance All audit processes (local, internal, and external) are used to facilitate continuous improvement of HSSE &SP based on the lessons learned and experiences gained from the findings. The audit findings allow specific HSSE &SP issues to be identified early and corrective actions to be taken, as well as providing assurance that the management system remains current Managing Non-Conformities Inspections and audits document outcomes and any resulting non-conformances. Corrective actions are created and followed through completion. Noted nonconformances are prioritized, assigned action parties, corrective actions, targeted completion dates and then tracked to final close-out. Management regularly reviews the status of corrective actions and ensures that they are implemented. Stena Ice Max will follow Non-Conformance and Corrective Action Procedure (L2-DOC-LPD-0191) for compliance. Typical sources for corrective actions include: Audit and self-assessment results HSSE MS reviews operational monitoring activities adverse trends in performance indicators and reporting data incident investigations or inspections Document # EP November 15, 2016

71 non-completion of agreed and planned HSSE improvements failure to meet established targets/limits observations regulatory/environmental non-compliances Corrective actions generated during audit and assurance processes, and incident investigations are compiled and agreed with the affected discipline lead. The compiled actions are prioritized, responsible parties are assigned, and target completion dates are established and tracked to final closeout in Fountain Assurance. Outcomes of these activities will be reviewed and progressed against follow-up monitoring at various levels of management to ensure adequate actions have taken place in order to close the event out. Each location will maintain a Master Action List to track all audits, assurances, incident investigations, inspections, and preventative maintenance issues that could result in a problems associated with procedures and equipment. It is the responsibility of the person in command (PIC) at each location to ensure that the Master Action List are up to date and being addressed in a timely manner Records Management The management of Project records will be conducted in accordance with external requirements for record retention as well as Shell s Group Records Management guidelines. The following list provides examples of the types of records maintained to demonstrate environmental protection and conformity to the management system covered at different locations: Legally required records Preventative/corrective maintenance Records of HSE critical equipment and tasks HSE training records Results of audits, reviews, and inspections Results of emergency drills and exercises performance and compliance monitoring reports regulatory/environmental approvals inclusive of commitments Records of environmental incidents or non-compliance These records are stored at each site in such a way that they are readily retrievable by heads of departments. They are protected against loss or damage and are traceable to the work-site, activity, product or service involved. Document # EP November 15, 2016

72 11.5 Continual Improvement Shell uses feedback from all parts of the management system to provide for continual Improvement. The term Management Review is used to describe the process of reviewing the feedback and taking action to improve. Performance management is structured on the Continual Improvement Cycle shown in Figure 11.1 below and involves the following: Plan: Identify performance targets in accordance with the Shelburne Basin objectives or regulatory requirements/commitments Implement: Put performance management resources, processes and procedures into practice Check: Monitor and measure performance against targets and the effectiveness of the HSE Management system Review: take action to improve performance and if necessary the HSE Management system Figure 11.1 Shell s continual Improvement Cycle Document # EP November 15, 2016