Shelburne Basin Venture Exploration Drilling Project Oil Spill Response Plan

Transcription

1 Project Document Title Document Number Shelburne Basin Venture Exploration EP Document Revision 04.5A Document Status Owner / Author Scott Jardine/KC Sullivan Issue Date Expiry Date Security Classification Disclosure None Unrestricted None Revision History shown on next page

2 Unrestricted Revision History REVISION STATUS APPROVAL Rev. Date Description Originator Reviewer Approver Initial review KC Sullivan Melinda N/A Watts Draft Preliminary Draft Scott Jardine Various N/A Draft Final Draft Scott Jardine Various N/A Final Scott Jardine Various Christine Pagan Redacted Final Scott Jardine Various Christine Pagan Removal of Jones Tide Update re. STA Regulation Lexy Dalton Greg Krauss Scott Jardine/ Rob van Scherpenseel Scott Jardine/ Rob van Scherpenseel Update to vessel fleet Lexy Dalton Scott Jardine/Ben Martell Stéphane Labonté Stéphane Labonté Stéphane Labonté All signed originals will be retained by the P&T Document Control Center and an electronic copy will be stored in the Shelburne Venture SharePoint site Signatures for this revision Date Role DCAF Authority Role 11/24/ /25/ /30/2016 Name Reviewer HSSE Manager Scott Jardine Reviewer Approver Operations Manager Exploration Manager Ben Martell Stéphane Labonté Signature or electronic reference ( ) Distribution List Canada-Nova Scotia Offshore Petroleum Board, Halifax Environment Canada National Environmental Emergencies Centre (NEEC), Montreal Canadian Coast Guard, Environmental Response Maritimes, Halifax Joint Rescue Coordination Centre, Halifax Eastern Canada Response Corporation, Dartmouth Oil Spill Response Limited, Houston

3 Unrestricted TABLE OF CONTENTS 1. INTRODUCTION AND PLAN OVERVIEW Purpose and Scope Shell HSSE Management System HSSE & SP Commitment and Policy Objectives Plan Structure and Use Regulatory Background Associated Plans Shell Canada Crisis Management (CM) Shelburne Basin Emergency Response Plan (ERP) Source Control Contingency Plan (SCCP) OIL SPILL RESPONSE STRATEGY Strategy Considerations Tiered Response Summary Response Priorities Sensitive Receptors RESPONSE ACTIONS Initial Response Procedures Initial Actions Check List OIL SPILL RESPONSE MANAGEMENT Transition of Command Response Organization Incident Management Team Incident Command Post National Level Americas Level (International) International Level Crisis Management Notifications Internal Notifications External Notifications Assessment and Escalation Tier Assessment Incident Escalation Remote Sensing and Trajectory Modelling Documentation OIL SPILL RESPONSE RESOURCES Tier Tier Eastern Canada Response Corporation (ECRC) Other Regional Primary Areas of Response (PAR)... 38

4 Unrestricted 5.3. Tier Oil Spill Response Limited Global Response Network Subsea Well Intervention Services Global Dispersant Stockpile Contractor Response Readiness OIL SPILL RESPONSE PLAN IMPLEMENTATION Scenario Matrix Operational Communications Simultaneous Operations (SIMOPS) Assessment and Surveillance Aerial Support Offshore Containment and Recovery Surface Dispersant Operations In-Situ Burn (ISB) Operations Shoreline Protection and Recovery Subsea Response Spill Waste Management and Disposal Spill Waste Management Spill Waste Products and Materials Transportation Incident Specific Waste Management Plan Federal and Provincial Legislation Relevant for Spill Waste Management Spill Waste Storage and Segregation Spill Waste Oil Accounting / Tracking Decanting Treatment and Disposal Decontamination Procedures WILDLIFE RESPONSE ENVIRONMENTAL Sampling Incident-Specific Net Environmental Benefit Analysis (NEBA) Environmental Effects Monitoring Monitoring Levels Marine Birds Pelagic Marine Mammals and Sea Turtles Contamination and Taint of Fish and Shellfish Shoreline Habitats Termination of Monitoring Activities HEALTH, SAFETY AND SECURITY Safety Life Saving Rules, Permits and Derivations... 65

5 Unrestricted 9.2. Medical Security COMMUNICATIONS Public Information Common Operating Picture Stakeholder Engagement FINANCE, CLAIMS AND COMPENSATION Process Key Contact Information Canada Claims Number RICM Focal Point DEMOBILISATION AND TERMINATION OF RESPONSE Demobilisation Return to Normal Operations PREPAREDNESS OSR Program Management Training Drills Appendix A: Contact Information Appendix B: External Reference List Appendix C: Regulatory Reference Table Appendix D: Emergency Response Documentation Schematic Appendix E: IMT Roles and Responsibilities Appendix F: Forms Appendix G: Shell Spill Response Dedicated Equipment Inventory Appendix H: ECRC Background Information Appendix I: ECRC Spill Response Equipment Inventory Appendix J: Map Depicting Primary Areas of Response Appendix K: Acronyms and Abbreviations List of Figures Figure 1-1: Exploratory Drilling in the Project Area... 7 Figure 1-2: Shell HSSE & SP Commitment and Policy... 9 Figure 1-3: Regulatory Overview Figure 1-4: Incident Management System Figure 2-1: Tier Level Overview Figure 2-2: Response Priorities Figure 3-1: Initial Response Procedures Figure 4-1: Incident Management Team... 24

6 Unrestricted Figure 4-2: Spill Tier Assessment Figure 4-3: Escalation Process Figure 5-1: ECRC Facility Locations Figure 8-1: EEM Flow Chart Figure 10-1: COP Data Integration List of Tables Table 1-1: Key Relevant Legislation or Guidelines with Potential Relevance to Spills Table 1-2: Key Relevant Legislation or Guidelines with Potential Relevance to Spills Table 2-1: Well Details and Potential Oil Properties Table 4-1: Reporting Notification Requirements and Contacts Table 5-1: Tier 2 Response Contractors Table 5-2: OSRL SLA Summary Table 5-3: OSRL Response Times Table 6-1: Categories and Examples of Spill Waste Table 8-1: Spill Monitoring Level Criteria and Activities Table 13-1: Typical Drill Schedule... 70

7 - 6 - Unrestricted 1. INTRODUCTION AND PLAN OVERVIEW 1.1. Purpose and Scope This (OSRP) provides guidance regarding response management, capabilities and resources in the unlikely event of an oil spill release during the Shelburne Basin Venture Exploration (the Project). The OSRP follows international good practice and the Canadian National OSRP, ISO and the International Maritime Organization (IMO) Manual on Assessment of Oil Spill Risk and Preparedness. The tiered preparedness and response in this OSRP is consistent with the International Convention on Oil Pollution Preparedness, Response and Co-operation 1990 (OPRC 90). Shell notes that it has referenced three Spill Treating Agents (STAs) in this and associated contingency plans submitted to the CNSOPB for review in support of obtaining its authorizations for the Project. On June 15, 2016 the Regulations Establishing a List of Spill Treating Agents (the STA Regulation) came into force, which enables the use of Corexit EC9500A and Corexit EC9580A once the conditions described in the Accord Act have been met, which includes obtaining approval from the CNSOPB. Shell continues to include Dasic and Finasol in its contingency plans for a number of important reasons: a) OSRL, Shell s oil spill response provider, maintains stockpiles of each of these STAs that would be available to Shell in the unlikely event of an incident. b) The STA Regulation may also be amended in the future (and potentially during Shell s drilling program) to add STAs. c) Inclusion of STAs in the spill contingency plans does not constitute approval of their use during an incident. If the use of dispersants is appropriate, approval will be sought through the CNSOPB. STAs excluded from the Regulation at that time would be precluded from receiving approval for use. d) In order for an STA to be considered for use at the time of incident, its use must be outlined in the operator s response plans. As such, Shell must describe their use in this plan for their use to be considered at the time of an incident. Shell will ensure sufficient quantities of Corexit would be available to respond efficiently and effectively in the unlikely event of a spill during the Shelburne Project. Statements in the contingency plans make it clear to incident command that approval for the use of an STA must be sought through the CNSOPB at the time of an incident. STAs are hereafter referred to as an Approved STA. The Project will consist of up to seven exploration wells drilled over a four-year period from 2015 to 2019 in accordance with the exploration periods and licenses. The overall drilling campaign will be phased and divided into two separate drilling campaigns. Each phase of the campaign will be contingent upon results from Shell s 2013 Shelburne Basin 3D Seismic Survey and the previous phase of drilling survey results. Specific drilling locations will be determined using the data gathered as part of the 2013 Shelburne Basin 3D Seismic Survey. These drilling locations will also consider the seabed and geotechnical survey undertaken in Initially, two exploration wells will be drilled in the Project Area commencing in Q4

8 - 7 - Unrestricted The Project Area is located approximately 250 km offshore Nova Scotia in water depths between 2000 m and 3000 m. The specific technical details for the wells will be outlined in the drilling programs, and will be submitted to the Canada-Nova Scotia Offshore Petroleum Board (CNSOPB). Figure 1-1 below highlights the Project location and proposed drilling area Shell HSSE Management System Figure 1-1: Exploratory Drilling in the Project Area Shell is committed to protecting the environment while actively managing its environmental performance. This is reflected in Shell s Business Principles and Health, Security, Safety, the Environment and Social Performance (HSSE & SP) Control Framework. Well design features and mitigation measures have been incorporated into the Project to prevent an incident from occurring in the first instance, and to reduce potential environmental effects should an incident occur. Shell s 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 company standards, multiple safety barriers to prevent incidents from occurring and ongoing attention to the ability to mobilize an efficient and effective incident response should it be required. Shell s safety standards also include extensive competence assurance and a culture that requires workers, contractors and visitors to stop any unsafe activities. As a result of these safety standards and practices, Shell is recognized internationally as a safe and responsible operator. Such recognition was clearly demonstrated when Shell became the first offshore operator in the Gulf of Mexico to receive an approval for a new deepwater exploration plan and drilling permit following the Deepwater Horizon incident. As part of Shell s commitment to safe operations, spill prevention and incident response preparedness are of critical importance in Shell s project planning and operations.

9 - 8 - Unrestricted All operations relating to the Project will be required to comply with Shell s corporate standards and regulatory requirements as a minimum. Utilizing their HSSE management systems, Shell and its Contractors will institute appropriate health and safety programs to provide a safe working environment for all personnel and will conduct operations in a responsible manner in compliance with all applicable regulatory requirements HSSE & SP Commitment and Policy Shell is committed to meeting the operational requirements of the Project, and ensuring it is prepared to respond efficiently and effectively in the unlikely event of an oil spill to reduce potential impacts. The following section highlights key points illustrating Shell s commitment to the prevention and mitigation of oil spills. The Shell HSSE & SP Commitment and Policy (refer to Figure 1-2) 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 regularly communicated to employees and contractors, as well as being displayed in office and work locations and underpins Shell s HSSE & SP Management System.

10 - 9 - Unrestricted 1.3. Objectives Figure 1-2: Shell HSSE & SP Commitment and Policy This OSRP outlines Shell s comprehensive program for spill preparedness and response. It includes details of Tier 1 equipment and trained operators that are kept at or near the areas of operation and are ready

11 Unrestricted to immediately respond. This includes reference to SOPEPs, which all vessels are required to have in place. Should the response escalate to Tiers 2 / 3, Shell has contracts and service level agreements in place with local, national and international response organizations to assist in providing the necessary equipment, personnel, and response (refer to Section 2.2 Tiered Response Summary and Chapter 5 Oil Spill Response Resources). Shell has produced this OSRP to minimize the potential environmental impacts and risk to human health and safety that may result from an oil spill, through spill preparedness. This means having measures in place that ensure an efficient and effective response Plan Structure and Use The OSRP provides specific guidance to personnel who may be involved in a spill response related to Shell s exploration drilling operations. Specifically, it supplies Shell s Response Teams and Incident Management Team (IMT) with tactical and strategic response guidance, procedures and information required during an oil spill response operation. This OSRP provides guidance regarding response management, capabilities and resources in the unlikely event of an oil spill from the Project. The plan also provides references to external and supporting materials to be utilized during a response (noted as External Reference throughout the plan). Refer to Appendix A: Contact Information and Appendix B: External Reference List for contacts and a list and guidance to access external reference documents. Please note that the OSRP is only one aspect of Shell s overall program for managing oil spill response and has been developed for use by trained and competent personnel. This OSRP is not designed to be prescriptive as it is expected that the target audience has undergone applicable training, are familiar with OSR principles and participate in regular exercises. The OSRP contains the following thirteen (13) Chapters.

12 Unrestricted Table 1-1: Key Relevant Legislation or Guidelines with Potential Relevance to Spills Chapter 1: Introduction And Plan Overview 2: Oil Spill Response Strategy Description Sets the scene for the document and describes the OSRP s scope and objectives Highlights the regulatory framework that outlines the expectations for response operations Describes how to use the document and how it aligns with other plans Describes factors that contribute to strategy decisions, such as: o spill probability analysis (including probability of shoreline impact) o types of operations covered by the OSRP o oil properties o spill scenarios and potential impacts Defines the Tier Levels Provides a hierarchy of response priorities Identifies sensitive receptors 3: Response Actions Details the initial response actions to be carried out in the early stages of an oil spill response operation. Provides an initial actions checklist. 4: Oil Spill Response Management 5: Oil Spill Response Resources 6: Oil Spill Response Plan Implementation Provides guidance on managing the ongoing response, including incident escalation considerations, and the incident management process. Describes how strategies, techniques and resources will be implemented. Details internal and external notification requirements, processes and contacts, including regulatory and response contractor notifications. Provides tools for spill assessment and tracking. Describes by Tier level the internal Shell and external spill response resources that would be available in the event of a spill. Provides a scenario flowchart to assist in implementing response. Describes communication processes and procedures between response teams. Gives an overview of the techniques available to Shell. Gives reference to specific guidance on response techniques available to Shell. Describes spill waste management and disposal processes and considerations, including decontamination. 7: Wildlife Response Details measures to avoid and / or mitigate impact on wildlife. Describes processes, procedures and resources for rescuing and rehabilitating affected or injured wildlife. Describes procedure for developing an incident-specific wildlife response plan. 8: Environmental Considerations And Tools 9: Health, Safety And Security Describes environmental considerations and tools such as sampling and Net Environmental Benefit Analysis. Details, by Tier Level, Environmental Effects Monitoring program requirements and considerations. Describes where to locate information on health and safety, medical emergencies, and security threats or breaches. 10: Communications Provides an overview for public information and stakeholder communications. 11: Finance, Claims And Compensation 12: Demobilisation And Termination Of Response Describes processes and provides contact information in the event of oil spill related claims. Describes considerations, processes and requirements for demobilisation and response termination. 13: Preparedness Provides an overview of training, exercises and drills.

13 Unrestricted 1.5. Regulatory Background The Nova Scotia Offshore Petroleum Drilling and Production Regulations require operators in the Nova Scotia Offshore Area to have a spill contingency plan as well as other emergency response plans in place and included in their application for an Authorization from the CNSOPB. Figure 1-3 below shows the relationships between agencies, regulator, operators and response contractors. Other Agencies Lead Regulatory Agency Offshore Operators Response Contractors Environment Canada Atlantic Emergency Response Team Inc (ALERT) Canadian Coast Guard (CCG) Fisheries and Oceans Canada Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) Shell Point Tupper Marine Services Ltd Eastern Canada Response Corporation (ECRC) Provincial Government Departments Oil Spill Response Limited (OSRL) Figure 1-3: Regulatory Overview

14 Unrestricted The following are the major departments and agencies with key roles in marine oil spill response for the Project: Canada Nova Scotia Offshore Petroleum Board (CNSOPB) Canadian Coast Guard (CCG), including CANUSLANT for USA trans-boundary spills Transport Canada (TC) Environment Canada (EC) Department of Fisheries and Oceans (DFO) Canadian Wildlife Service (CWS) Department of National Defence (DND), including JRCC for any related SAR issues Royal Canadian Mounted Police (RCMP) Port Authorities Department of Justice Nova Scotia government Industry, including response organizations such as ECRC Petroleum activities in Nova Scotia s offshore area are regulated by the CNSOPB, a joint federalprovincial agency reporting to the federal Minister of Natural Resources and the provincial Minister of Energy. The Nova Scotia Offshore Petroleum Drilling and Production Regulations (the Regulations) pursuant to the Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act require that oil spill response plans are in place for any offshore petroleum-related activities that occur in the waters off Nova Scotia. The Project OSRP includes response procedures for mitigating the effects caused by any reasonably foreseeable event that might compromise safety or environmental protection. In responding to any such event, Shell will appoint an on-scene Incident Commander (IC) who will take responsibility for directing all response activities according to the approved OSRP. The CNSOPB is the lead regulatory agency for the spill response, with EC the CCG, DFO, TC acting as resource agencies available to the CNSOPB. NEEC is the advisory focal point between EC and the CNSOPB in the event of a polluting incident that requires Environment Canada s involvement, and provides scientific advice for activities such as establishing clean-up priorities and techniques, and protecting sensitive ecosystems and wildlife. NEEC s Environmental Emergencies Science Table (the Science Table ) can be convened to provide advice to the lead agency during the response to an environmental emergency requiring multi-agency cooperation. Science Table experts include representatives from response agencies, government (e.g., DFO, CCG, TC), Aboriginal representatives, local communities, industries, environmental non-government organizations, and academic institutions. These representatives develop consensus on protection and clean-up priorities, and provide a forum for rapidly moving information to minimize potential impacts while maximizing the effective implementation of response resources. The Canada Shipping Act (CSA) governs the control of pollution from the MODU and Offshore Support Vessels. These vessels must have a Shipboard Oil Pollution Emergency Plan (SOPEP) in place. Shell s marine assurance process ensures that all vessels meet or exceed these requirements. The CCG is the

15 Unrestricted lead regulatory agency for oil spills from vessel or MODUs while in transit. TC also has compliance, enforcement and implementation responsibilities of regulations relating to response organizations. The key legislation, regulations, guidelines and memoranda of understanding relevant to operations within the scope of this OSRP are summarized below in Table 1-2. These are not exhaustive and all parties are to be fully compliant with flag, port state, local, national, international laws, codes and standards. More detail on regulatory agencies, applicable acts, regulations and guidelines is provided in the regulatory reference table in Appendix C: Regulatory Reference Table. Table 1-2: Key Relevant Legislation or Guidelines with Potential Relevance to Spills Legislation or Guidelines 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 (and associated Guidelines) Nova Scotia Offshore Marine Installations and Structures Occupational Health and Safety Transitional Regulations Nova Scotia Offshore Petroleum Installations Regulations Nova Scotia Offshore Area Petroleum Geophysical Operations Regulations (and associated Guidelines) Nova Scotia Offshore Certificate of Fitness Regulations Environmental Protection Plan Guidelines (EPPG) Safety Plan Guidelines Offshore Waste Treatment Guidelines (OWTG) Offshore Chemical Selection Guidelines (OCSG) Compensation Guidelines Respecting Damage Relating to Offshore Petroleum Activity (Compensation Guidelines) Guidelines for Reporting and Investigation of Incidents Canadian Environmental Assessment Act, 2012 Canadian Environmental Protection Act and Regulations Migratory Birds Convention Act Species at Risk Act Canadian Oceans Act Fisheries Act and Regulations Canada Shipping Act Hazardous Products Act and Regulations Navigation Protection Act and Regulations Transportation of Dangerous Goods Act and Regulations Responsible Regulatory Authority CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CNSOPB CEAA EC EC EC, DFO DFO Fisheries and Oceans Canada / EC Transport Canada Health Canada Transport Canada Transport Canada

16 Unrestricted The CNSOPB has active MOUs in place with numerous agencies describing their mutual roles and responsibilities in administering relevant legislation. These detailed MOUs can be found at: Associated Plans In the event of a spill, effective preparedness measures can ensure a timely and coordinated response, thereby limiting the potential adverse environmental effects or other consequences. In addition to the OSRP, Shell requires all sites and assets including the MODU, supply vessels and shore bases to implement appropriate tier 1 local spill response arrangements, such as SOPEPS to ensure a timely and effective response in the event of any localized or small-scale incident. Additionally, a Source Control Contingency Plan and Dispersant Preparedness and Operations have been developed for use in support of oil spill response operations. Although Shell maintains its own capabilities to respond to an incident, broader spill response coordination may also be employed depending upon the particular circumstances of the incident. Spill response coordination allows industry participants, including Shell, to access additional relevant technical assistance and response resources in the event of a spill, which includes regional, national and international capacity to prepare for, and respond to, incidents. It also establishes a framework for the exchange of information related to new research, best practices and practical experience. Shell s Incident Management System (IMS) is divided into 3 coordinated and independent areas: Crisis Management, Business Continuity and Emergency Response. The IMS includes a coordinated system of plans that may be required pursuant to legislation, regulatory or corporate requirements. Figure 1-4 is a visual representation of the IMS. Figure 1-4: Incident Management System

17 Unrestricted In addition to the IMS schematic above, Appendix D: Emergency Response Documentation Schematic depicts the detailed organization diagram of how the various emergency related plans and resources inter-relate to one another, under the umbrella of the ERP. Further information regarding these associated plans is provided in the subsections below Shell Canada Crisis Management (CM) Shell Canada Crisis Management is the overarching framework through which Shell addresses a major event, issue, or incident that threatens to disrupt business or license to operate, creates stakeholder concern, and has the potential to impact Shell s reputation. Crisis Management is maintained at a country level with the Country Chair responsible to assess a situation and activate the Crisis Management Team (CMT). The CMT is made up of separate personnel with distinct responsibilities outside of that which falls under the purview of the IMT for emergency response. Depending on the type of issue or incident, the CMT will work in coordination with the IMT to address potential impacts to the Shell Shelburne Basin Emergency Response Plan (ERP) Shell s Shelburne Basin Emergency Response Plan (ERP) for the Project comprises one of the main response documents that Shell will utilize during an emergency response. The ERP defines Shell s organizational structure, response process and tools that will be employed to facilitate an effective, efficient and safe response, regardless of the size, type or complexity of an incident. The ERP provides coordinated guidance for all emergency response aspects of Shelburne Basin exploration operations, including shore base facilities and contractors. External Reference: Shelburne Basin Emergency Response Plan Source Control Contingency Plan (SCCP) The Shelburne Basin Source Control Contingency Plan (SCCP) details the technical procedures and operations involved with subsea source control in the event of a well control incident. The SCCP addresses cap and containment plan (outlining the initiation, mobilisation and deployment of a capping stack); and a relief well plan describing the process for mobilizing and drilling a relief well, and subsea dispersant operations in the unlikely event of a well control incident. Because of the complexity and technical nature of the SCCP, it links to numerous supporting procedural documents and has been designed to be used in conjunction with the plan. External Reference: Shelburne Basin Source Control Contingency Plan

18 Unrestricted 2. OIL SPILL RESPONSE STRATEGY 2.1. Strategy Considerations In the event of an oil spill, decisions will be made quickly as to the best, most effective strategy to employ in the response. Several factors must be considered in response strategy decisions, the foremost of which is always safety. Sensitive receptors such as wildlife, socio-economic, and cultural resources, and potential impacts to sensitive areas must also be evaluated during a spill to determine appropriate strategies and tactics. Shell has taken into consideration a number of factors when establishing its incident specific tiered response capability and related strategies for operations in offshore Nova Scotia, including applicable local legislation, and more specifically the Petroleum Industry Environmental Conservation Association (IPIECA) guidelines and the CNSOPB requirements. The Spill Probability Analysis conducted for the Project indicates a very low probability of a well blowout or other accidental release. Detailed analysis also shows that should an incident occur, it would be a small volume, low consequence incident rather that a large event with major consequences. The most likely spill scenario is one of a smaller spill from equipment or process failure, a small scale incident that can be mitigated easily and effectively. For further details refer to the Spill Probability Analysis, and the Spill Fate and Behaviour Modelling report. Given the distance of the Project offshore and the prevailing metocean conditions in the area, it is unlikely a significant spill or blowout would impact the shoreline (1.88% likelihood). However, due to its physical properties (viscosity, pour point, etc.) the crude oil may potentially be persistent in the marine environment. An information gathering and analysis operation may be required following an incident for evaluation of response measures that may need to be implemented. Shell has carried out extensive oil spill modelling to explore the possible impact on environmental sensitivities, including biological resources (fish, marine mammals, sensitive areas, birds). In the event of a spill, incident-specific modelling may also be conducted to assess the trajectory of the spill and potential areas of impact. External Reference: EIS Appendix F, EIS Appendix G Risk and Spill Types This OSRP covers the following Shell operations: Drilling: Oil spills arising from exploration drilling activities Ports and Harbours: Oil spills arising from activities associated with ports and harbours Field Support: Oil spills arising from activities involving support vessels The details of the planned wells and hydrocarbons that may be expected from those wells are given in Table 2-1.

19 Unrestricted Table 2-1: Well Details and Potential Oil Properties The Shelburne Basin EIS (EIS Section 8.2) identified and described potential impacts of the following spill risk accidental event scenarios: Operational batch spill (100 bbl and 10 bbl) SBM whole mud spill Vessel spill (offshore and near shore) Subsurface blowout Subsurface blowout scenarios (Site 1 and Site 2) were developed based on the expected water depths that may be drilled within the Project area and have considered estimated well parameters for the various depths. Analysis of these scenarios in the EIS included consideration of spill risk and probabilities (likelihood analysis) (EIS Section 8.3) and spill fate and behaviour (EIS Section 8.4), including a description of reasonable and practical worst case scenarios. The EIS also assessed potential impacts of spills on fish and fish habitat, marine mammals and sea turtles, marine birds, special areas, commercial fisheries and current Aboriginal use of lands and resources for traditional purposes (EIS Section 8.5). The following sections define Tier spill levels, present a hierarchy of oil spill response priorities, and discuss receptors that are particularly sensitive to impacts of oil Tiered Response Summary The definitions of the Tier Levels are primarily focused around the location relative to the respective operational activity and complexity of an incident. They are defined as: Tier 1 spills are relatively small and operational in terms of volume, with the incident only affecting the immediate or local area. The recommended resources to address this would normally consist of modest amounts of equipment held on-site (e.g. SOPEP) or available from local contractors. Tier 2 spills are more complex, larger in scale and more on a regional level. The potential impacts from a Tier 2 spill would be greater than Tier 1, a diverse range of response resources would be required, and a greater number of stakeholders involved. The resources may include regional mutual aid, regional industry funded cooperatives, and local governmental or port authorities.

20 Unrestricted Tier 3 spills are those that due to their scale, complexity and potential to cause significant impacts, call for substantial resources from a range of national and international sources. An overview of the Tiered Levels, including operational and setting factors, is shown in Figure 2-1 below. Figure 2-1: Tier Level Overview The Canadian and United States governments are both signatory to OPRC 1990 and thereby have adopted the Tier Level approach to managing oil spills. CANUSLANT has been developed pursuant to the Canada-United States Joint Marine Pollution Contingency Plan, a cooperative bridge mechanism between the two countries for preparedness and response in continuous waters of interest to spills of harmful substances Response Priorities The key priorities and objectives during oil spill response should include, but are not limited to, those outlined in Figure 2-2.

21 Unrestricted P People Preserve safety of human life. Consider the safety of all people in the immediate area including your own. E Environment Minimize adverse effects to the environment and property conservation. A Asset Integrity Protect Shell s assets. Stabilize the situation to prevent the event from worsening. R Reputation Figure 2-2: Response Priorities As part of the overall response, Shell is committed to developing incident-specific objectives and strategies to address these priorities as well as developing incident-specific response objectives that minimize further spill impacts and protect resources at risk. Response objectives will be clearly communicated, measurable and achievable. Effective planning and execution of response operations is based upon coordination with authorities and response partners to allocate response resources (i.e., people, equipment, time) effectively Sensitive Receptors Sensitive receptors may include but not be limited to: Biological resources (wildlife, etc.) Natural / environmental resources (shoreline, etc.) Socioeconomic and Human-use resources

22 Unrestricted To establish priorities for protection and response in the event of an oil spill, information about the existing environment needs to be considered. Valuable information to support this process will include information about the biological sensitivity of various flora and fauna, habitats and areas of special significance and human uses that could be impacted in the event of an oil spill. Such information for the Shelburne Project is available through ECRC and in the Shelburne Basin EIS prepared for this Project. The ECRC maintains a highly detailed GIS mapping data base of all shoreline sensitivity classifications throughout Atlantic Canada. This data base includes mainland Nova Scotia, as well as islands such as Sable Island, Cape Sable Island and others, some of which are highly sensitive environmental areas. This ECRC database is available to Shell for reference and planning purposes during a spill response (including the overlay of spill trajectories), and will provide detailed information needed to prioritize protection and response measures. The Shelburne Basin EIS, developed with support from Stantec, provides substantial information regarding the existing environment and potentially sensitive receptors. Species of conservation interest are summarized in EIS Section 5.2.7, and EIS Section focuses on environmentally sensitive areas such as national, provincial and regional parks, ecological reserves, estuaries, Important Bird Areas, Migratory Bird Sanctuaries and habitats of federally or provincially listed species at risk and other sensitive areas that are within the Project s area. Information regarding human uses that could potentially be impacted in the event of an oil spill, including land and near shore ocean use, offshore ocean uses, offshore commercial fisheries, aboriginal fisheries, and cultural resources, is also provided in EIS Section 5.3. Stantec is identified to provide addition support for identification of sensitive receptors should an incident occur as part of the Environmental Unit.

23 Unrestricted 3. RESPONSE ACTIONS 3.1. Initial Response Procedures Key initial actions and notifications to be undertaken in an oil spill are illustrated in Figure 3-1. HYDROCARBON SPILL Initial Actions Spill Observer Notify Control Room (CR) (if Observer is on a vessel then the Vessel Master is to provide this notification) Collect relevant information injuries, hazards, location, estimate quantity and type of oil, cause of spill, etc. If safe attempt to stop hydrocarbon spill/release MODU Control Room (CR) Notify Offshore Installation Manager (OIM) Notify Standby Vessel Master (for potential assessment of the spill) Notify vessels/adjacent installations within 500m exclusion zone (if appropriate) Log information Injuries, hazards, location, type of oil, and cause of spill, etc. Standby Vessel Master Ensure safety of personnel and installation If safe, following communications with OIM, assess the spill Inform the Port Authority (if appropriate) Emergency Response Team (ERT) (Offshore) On-scene Commander (OSC) (OIM) Ensure safety of installations and personnel Alert crew to cease all hot work (if appropriate) Activate OSRP If safe attempt to stop hydrocarbon spill/release Notify and liaise with the Shell on-call Duty Manager Mobilise Tier 1 resources (if appropriate) Liaise with Standby Vessel Master (potential assessment of the spill) Request additional resources if required through ERT Carry out assessment of spill tier with ERT Lead Inform Statutory Authorities refer to Section 4.3 Notifications On-Call Duty Manager or Duty Engineer (onshore) Assess the situation with the OSC (and ERT Lead if appropriate) conduct a Tier response assessment refer to Section 4.4 Assessment and Escalation Alert and mobilise the Incident Management Team (IMT). Depending on Tier, alert Oil Spill Response Limited (OSRL) to access resources (e.g. Technical Advisor, Aerial Surveillance) Liaise with regulators and statutory authorities as appropriate refer to Section 4.3 Notifications Figure 3-1: Initial Response Procedures

24 Unrestricted 3.2. Initial Actions Check List SPILL OBSERVER Person who first sees the oil spill and takes instant action. Make safety your first priority. Stop all hot work and separate ignition sources. SAFETY If safe, take instant action to stop the spill. ONLY approach the spill from downwind of the source with a gas monitor. If monitor alarm sounds exit the area across wind. If area is unsafe, leave and tell others to. People near the spill. ALERT Control Room/Offshore Installation Manager (OIM) or Vessel Master, give information on: Safety and status of personnel Location Source and cause Extent of spill, if its ongoing or under control Time and length of spill Hydrocarbon type Potential hazards Estimated size/extent of spill Other useful information Initiate the oil spill tier assessment if requested to do so. If needed, help the OSC with the completion of the Incident Notification Form. Direct the Emergency Response Team (ERT) to the spill. If trained, required and safe to do so, assist the ERT in their response. RESPONSE ACTIONS Complete demobilisation procedures. Attend and take part in the debrief. Offer support to the incident investigation. Restart normal operations as told.

25 Unrestricted 4. OIL SPILL RESPONSE MANAGEMENT 4.1. Transition of Command For larger spills requiring the mobilisation of the full IMT, command will be transitioned from the On Scene Commander (OSC) to the Incident Commander (IC). The OSC will be required to notify and provide the IC a full briefing using the applicable Shell procedures as detailed in Section Response Organization Shell Canada has adopted the Incident Command System (ICS) as its national incident management system. The ICS is described in detail in the Shelburne ERP, and an organizational chart of the IMT is provided in Figure 4-1: Incident Management Team. Safety Officer Legal Officer Information Officer Incident Commander Liaison Officer Staging Area Manager Operations Section Planning Section Logistics Section Finance Section Recovery and Protection Branch Source Control Branch Wildlife Branch Situation Unit Support Branch Service Branch Time Unit Shoreside Recovery Group On-water Recovery Group Protection Group Decon Group Capping & Subsea Group Capping Stack Subsea Dispersant Site Assessment/ Debris Removal Well Control Group Relief Well Well Control Air Operations Branch Dispersant Operations Branch Resource Unit Documentation Unit Environmental Unit Technical Specialists Supply Unit Facilities Unit Vessel Support Unit Ground Support Unit Food Unit Medical Unit Communications Unit Cost Unit Compensation/ Claims Unit Procurement Unit Disposal Group Figure 4-1: Incident Management Team Several levels of organization (international, national, regional and local) exist and are applicable to Shell Americas preparedness and response activities. All levels operate under the concept of ICS. The following section describes these organizations Incident Management Team The strategic response will be managed by the Incident Management Team (IMT). The Incident Commander (IC) will be notified of the incident by On Scene Commander (OSC). On notification of the incident the IC will mobilize the IMT as required. For any incident, the IMT will be based in Halifax, Nova

26 Unrestricted Scotia. The Incident Command Post (ICP) has all the necessary communication tools essential for an effective emergency response. The IMT is structured in line with the Incident Command System model. The IMT structure permits: Clear definition of roles and responsibilities amongst response personnel Procedures from controlling personnel, facilities, equipment and communications Manageable span of control and lines of authority during a response Integration of the IMT with response teams from other companies or authorities that have adopted the ICS model The IMT will be led by the Incident Commander (IC) who is responsible for directing and coordinating the response to the incident. The critical response functions conducted by the IMT are broken down into four Roles: Operations Planning Logistics Finance The IMT s primary responsibilities are to: Develop and execute appropriate strategies to protect people, environment, assets and reputation Manage all aspects of the response Work in cooperation with all agencies, authorities and governments involved in the response Notify employees and third party Emergency Management Teams Notify and liaise with the CMT Leader Provide and co-ordinate specialist support Co-ordinate Shell, country operational recovery from the incident Establish and implement an appropriate media response strategy Refer to Appendix E: IMT Roles and Responsibilities for roles and responsibilities of the IMT. External Reference: Incident Management Handbook (IMH), Position Specific Job Aids Incident Command Post There will be one Incident Command Post (ICP) and this will be established by the IC at the time of an oil spill. The ICP: is the location where primary command functions are performed; may be located with other facilities; is large enough to provide adequate working room for assigned personnel; contains situation and resource status displays necessary for the incident; and is where arriving agency / stakeholder representatives are normally located.

27 Unrestricted The ICP for the Shelburne Project has been pre-designated and is ready for use at all times. It contains easy access (e.g., wall charts, handouts) to pertinent information including, but not limited to, the following: ICS 201 Incident Briefing Form Emergency Classification Criteria (as specified by the local regulator) The Planning P Area map The primary ICP for the Shelburne Project has been pre-designated in the Shell Canada Limited Halifax Office. Should the incident exceed the size of primary ICP (e.g., Tier 2 / 3), an alternate ICP has been predesignated in Halifax, NS National Level Shell Canada National Response Team (SCAN NRT) The Shell Canada National Response Team (SCAN NRT) consists of Shell personnel from the different Canadian upstream and downstream businesses that have been trained to assist in responding to a Tier 2 and Tier 3 emergency or oil spill. When requested by the Incident Commander, the SCAN NRT will be mobilized to Halifax to facilitate a coordinated response to a Tier 2 or 3 incident by managing any or all aspects of the response throughout the incident. The SCAN NRT applies the ICS to manage the incident. Some members of the SCAN NRT are also identified as Away Team members of SART that will mobilize quickly to provide assistance to the IMT while additional SART personnel are activated and mobilized. Further detail about the Away Team can be found in Section Shell Canada Downstream Emergency & Crisis Management (SCAN ER & CM) Manager, assisted by their counterpart for Upstream are responsible for coordinating training, exercising and maintaining a roster of qualified personnel that form the SCAN NRT. External Reference: Shell Canada National Response Plan Americas Level (International) Shell Americas Emergency Management The Shell Americas Emergency Management (SAEM) provides a functional centre of expertise for all operational emergencies and crisis situations with the coverage and depth to support Shell s businesses and ventures across all of the Americas including Canada. Provision of response capabilities include: oil spills, fires and explosions, well blowouts, transportation events, search and rescue, medical response and evacuations, security related incidents and natural disasters (all-hazard). It provides oversight, advisory

28 Unrestricted services and will respond and coordinate as necessary to significant oil spills, hazardous material release and to any other emergencies. SAEM is responsible for overseeing, managing, coordinating and activating the Shell Americas Response Team (SART). Shell Americas Response Team (SART) The SART is organized to provide a robust Shell managed response to oil spills and other emergencies that potentially have National and International significance (Tier 3 Incident) in the Americas. The SART consist of Shell personnel from the different upstream and downstream businesses within the Americas region that are members of their respective National Response Teams who are trained and identified as competent Shell Staff to assist in responding to a Tier 3 emergency or oil spill event that requires significant support from personnel throughout the region. The SART per se is not a standing team but a broad group of trained responders and subject matter experts that make up a pool of resources available to the IMT. The SART is not the direct Project IMT or Crisis Management Team (CMT) in the event of a major incident. SART provides experienced and trained personnel to support the response effort as needed based upon the nature, magnitude and type of incident. SART members are fully trained and competent in the ICS. SAEM is responsible for coordinating, training, exercising and maintaining a roster of qualified personnel that form the SART. The SART is activated by notifying the SART activation phone number, as described in the Canada National Response Plan (NRP). External Reference: Shell Canada National Response Plan When activated, an initial component of the SART (known as the Away Team ) will be immediately mobilized to provide assistance to the local response effort while additional SART personnel are activated and mobilized. The Away Team may include personnel qualified in the roles of IC, Operations, Communications/Public Affairs, Legal, Security and Safety International Level Shell Global Response Support Network (GRSN) The Shell Global Response Support Network (GRSN) for Tier 3 oil spills is a network of Shell staff, employed in a wide range of positions within Shell s global businesses who have received specific training related to oil spill response and can be called upon to support the Shelburne Basin exploration drilling venture in the unlikely event of Tier 3 Oil Spill incident. The Shell GRSN consists of 3 regional teams: The Americas: North America, South America and the Caribbean Team SART Europe, Middle East, Africa Team (EMEAT) Asia, Russia, Australia Team (ARAT)

29 Unrestricted Overall responsibility for coordinating the organization and activity of the GRSN lies with the Oil Spill Expertise Centre (OSEC) and OSEC GRSN focal point. SAEM will facilitate requests for support or resources with the OSEC GRSN focal point for the IMT Crisis Management The Canada Country Chair, trained in crisis management, is responsible to make an assessment of an incident and determine if it falls under the criteria of a crisis. The Shell IC should notify the Country Chair of any incident that could potentially become a crisis. If the incident is deemed a crisis, the Country Chair will activate the CMT. Indicators of a potential crisis include: National authorities have been alerted of a problem Shell receives calls and/or coverage from national media or local branches of national media Potential impact to local communities The IC and Planning Section Chief will coordinate with CMT members as necessary following the protocol detailed in the Shell Canada Crisis Management Manual. External Reference: Shell Canada Crisis Management Manual 4.3. Notifications In the event of a spill, Shell will follow all required notification and reporting obligations necessitated by the incident. The notification and reporting requirements may vary with the size and severity of the spill. Specific personnel responsible for notifications are identified below. The CNSOPB Incident Reporting and Investigation Guidelines (November 30, 2012) are the primary source for reporting and notification requirements. The Guidelines are provided to assist operators in complying with the requirements of the Accord Acts, the regulations, and the terms and conditions of Board approvals and authorizations for the reporting and investigation of incidents that occur in the offshore area. The Guidelines provide detail on information requirements for each type of notification, including for spills. In the event of any incident, Shell employees and Contractors are expected to immediately report details of the incident to their supervisor, who will report to Shell management. The following process is followed for notifications, activation and mobilisation of resources for a Tier 2 or Tier 3 response. External Reference: CNSOPB Incident Reporting and Investigation Guidelines (November 30, 2012) Internal Notifications The Shelburne Basin ERP describes actions to be taken by the Emergency Response Teams and Incident Management Team during, and immediately after an emergency to mitigate the impact to people, the environment, and the company s reputation and assets. The actions include internal notifications as required, and external notifications to various stakeholders including, but not limited to, agencies, regulators and authorities.

30 Unrestricted SAEM must be notified immediately in the event of a spill to water from maritime transportation operations or a spill / incident that could result in a Tier 3 response by calling the SART activation phone number. Escalation to a Tier 2 level is a decision that may include consultation with SCAN Emergency Response and Crisis Management Managers. If the IC requires assistance from the SCAN NRT or SART, they can activate the process by contacting one of the SCAN ER & CM Managers directly or by calling the SART activation phone number. Escalation to a Tier 3 level follows the same process as described above, and will be conducted in consultation with SCAN ER & CM Managers and SAEM. Shell s Emergency Response philosophy is to prudently over-respond and mobilize resources immediately. Prompt notification of emergencies to Shell management is critical for initiating response actions and in meeting legal requirements. Prompt notification facilitates the alert, activation of mobilisation of equipment and personnel if needed to support the response efforts. The IC is required to make notifications as soon as possible to the SCAN ER & CM Managers who are an integral part of SAEM whenever there is a potential for escalation External Notifications External notifications should be made as early as possible. The following sets out the regulatory and spill response contractors requirements for notification. Depending on the nature of the incident, notification may be required to multiple agencies. Regulatory Notifications The following key regulators will be notified as follows: CNSOPB (24 hours) as per the CNSOPB Incident Reporting and Investigation Guidelines CCG , , VHF Channel 16 immediate verbal notification is required for any spill incident Halifax Port Authority immediate verbal notification for spill in the Halifax Harbour Table 4-1 provides a listing of the agencies and authorities to be contacted in the event of a spill.

31 Unrestricted Reporting / Notification Reason Any discharge of petroleum (including but not limited to crude oil, natural gas, condensate, lubricants, hydraulic oils, fuels, petroleum based synthetic drilling fluids, or any other refined petroleum product) that enters the sea shall be reported as a spill. Spill Incident or any other marine pollution incident *Note: CCG will initiate notification of TC, EC and the DFO these government departments do not need to be notified separately. Spill incident if it has the potential to involve marine search and rescue or medevac Aviation emergency or incident in association with a spill or spill response (guidelines: Worker injuries and illnesses and accidental explosions Death, injury that may prove fatal, or accidental explosion with or without injury: within 24 hours Injuries caused by fire or accident that needed treatment by a doctor or paramedic: within 7 days Collision during spill response that results in an injury or major damage / impairment Collision during spill response that does not result in an injury or major damage / impairment Leak of hazardous substance Table 4-1: Reporting Notification Requirements and Contacts Timing of Reporting / Notification Greater than 25 L: Immediate verbal 25L or less: Immediate written Immediate verbal Who should be contacted? CNSOPB Duty Officer (24h/7d) CNSOPB CCG Regional Operations Centre Contact Information (24 hours) incident@cnsopb.ns.ca Immediate verbal JRCC Immediate verbal Within 24 hours or 7 days depending on injury / illness type. Consult Immediate verbal 24-hour written using Incident Notification Form available at 24-hour written using Incident Notification Form available at Transport Canada Aviation (24 hours) WCB CNSOPB Duty Officer CNSOPB CNSOPB Spill in or near Halifax Harbour Immediate verbal Halifax Port Authority Or fax report form available from website to (24 hours) incident@cnsopb.ns.ca incident@cnsopb.ns.ca

32 Unrestricted Response Contractor Notifications Shell requires that the following response contractors must be notified in the event of a spill as described below: Eastern Canada Response Corporation (ECRC) o Phone <Redacted> requires notification immediately upon escalation to Tier 2 OSRL Southampton, UK o Phone <Redacted> notification required on escalation or potential escalation to Tier Assessment and Escalation Tier Assessment The tier assessment (Figure 4-2) will be used to help assess the severity of the oil spill and determine the Tier Level. The worst-case scenario should be assumed based on the criteria listed for the operational and setting factors. By identifying the Tier Level, the IC and IMT can mobilize the appropriate response technique resources to combat the spill, based on the oil type released, location and available resources. Establish the tier level of the oil spill Tier 1 Tier 1 oil spills are likely to be small and effect a localised area. The spill can be managed by using the local resources Characteristics of a Tier 1 oil spill: Spill occurs within immediate site proximity Minor environmental impact Spill can be easily managed using oil spill response resources available locally The spill source has been secured Little media interest Tier 2 An incident in which national and regional resources and support are required to control the spill Characteristics of a Tier 2 oil spill: Spill extends beyond the immediate site proximity Tier 1 resources are overwhelmed, additional regional resources are required Potential impact to sensitive areas and/or local communities Spill source cannot be immediately secured Local / national media attention Tier 3 An incident for which assistance is required from national and international resources Characteristics of a Tier 3 oil spill: UNCONTROLLED WELL BLOW OUT/ LOSS OF WELL CONTROL Spill has crossed international maritime boundaries Tier 1 and 2 resources are overwhelmed requiring international Tier 3 resources to be mobilised (e.g. OSRL) Significant impact to sensitive areas and or local communities International media attention Figure 4-2: Spill Tier Assessment

33 Unrestricted Incident Escalation Depending on the type of emergency and level (Tier 2 or 3), the SCAN ER & CM Managers will coordinate with the IC and identify needed personnel to support the emergency response. The SCAN ER & CM Managers with the IC will determine the following: Available personnel to deploy SCAN NRT activation and mobilisation, if required SART activation (actual or stand by) as needed, including needs for immediate mobilisation of SART Away Team Aviation contacts for corporate transportation Point of contacts in route Point of contacts at destination Transportation mode (charter flight, commercial or other) Reporting time and date Reported location Estimated time of deployment (initiate identification / notification of relief personnel) Role, as applicable Activation and mobilisation of the SCAN NRT and SART is a flexible process that is incident-specific and dependant on the situation. Activation and mobilisation will vary from a small handful of people to the entire response team. In some situations, activation will not be necessary, but appropriate members of the NRT or SART may provide assistance and guidance to the local responders from remote locations. Figure 4-3 outlines the escalation process.

34 Unrestricted TIER I TIER II TIER III Operations IMT Contractors Authorities ACTIATE Mutual Aid Industry Association bhtlcy ACTIATE IMT Business / Management Logistics / Wells bhtlcy bhtlcy ACTIATE Business Wells SCAN ER&CM Mgr Emergency Response Manager bhtlcy bhtlcy Country Chair Business EP ACTIATE SCAN NRT Team Members Emergency Response Manager CX If the incident has any potential to solicit media attraction ACTIATE bhtlcy Response Organizations SART Lead ACTIATE SART Team Members CANADIAN RESPONSE MODEL ESCALATION PROCESS Remote Sensing and Trajectory Modelling Figure 4-3: Escalation Process Remote sensing and trajectory modelling will be an integral component of the response and will be used to assist in the characterization and surveillance of a spill. Numerous oil spill detection devices including but not limited to visual, satellite, infra-red and radar sensors are available to be activated should an incident occur. The data collected through remote sensing will provide important information required to model an oil spill and maintain situational awareness. Depending on the severity of the incident, Satellite imagery can be requested internally within Shell by activating the Oil Spill Tracking Service through Shell Geomatics. This is done by following the Work Instruction Remote Sensing Oil Spill Tracking Service, which outlines the activation procedure.

35 Unrestricted Post-incident trajectories can be obtained to increase the effectiveness of the real-time response. Running incident specific models or trajectories which incorporate real time data and observations, will be used for strategic planning of the spill response. Depending on the size and complexity of the incident, trajectories can be requested from OSRL and / or RPS ASA. Imagery and trajectories obtained must be thoroughly reviewed within the Situation Unit prior to distribution or added to the Common Operating Picture (COP). Additional information on the COP can be found in Section Refer to Appendix F: Forms for the OSRL modelling request form. External Reference: Work Instruction - Remote Sensing Oil Spill Tracking Service Incident Management Process The Shell incident management system uses the ICS model, which is described in detail in the Shell Shelburne ERP. The ICS provides the structure with which to implement the emergency response measures and deliver guidance to response personnel. The structure applies to any type of emergency. The ICS acts to capture emergency response principles, procedures and processes in an effective way for use in all incidents, including oil spills. ICS follows an operational planning cycle with associated meetings to prepare, plan and execute a response. This planning cycle is show below in Figure 4 4. Figure 4-4: ICS Operational Planning Cycle

36 Unrestricted All forms are located in an appendix to this plan (refer to Appendix F: Forms). The OSRP also contains forms to be used in the reactive stages of an incident. The effective implementation of ICS for the Project has been established and will be maintained through training and exercises. Refer to Chapter 13 for detailed information on training and exercises. ICS is interdisciplinary and organizationally flexible to meet the following management challenges: The needs of an organization to cope with incidents of any kind or complexity (i.e., it expands or contracts as needed). Allows personnel from a wide variety of agencies to merge rapidly into a common management structure with common terminology. Provides logistical and administrative support to operational staff. Provides cost-effectiveness by avoiding duplication of efforts, and continuing overhead. Provides a unified, centrally authorized emergency organization Documentation Documentation generated during any incident will be managed by the IMT Documentation Unit with guidance from the Planning Section and Shell Legal. Documentation procedures and retention requirements will be defined during an incident based on the scale and complexity. External Reference: Documentation Unit Lead Job Aid

37 Unrestricted 5. OIL SPILL RESPONSE RESOURCES The following sections describe, by Tier level, internal Shell and external spill response resources that would be available in the event of a spill. Depending on the severity of the incident, out-of-region resources may be required to support the spill response operation Tier 1 Refer to Appendix G: Shell Spill Response Dedicated Equipment Inventory for Tier 1 resources that are owned and immediately available to Shell. The offshore support vessels and Stena IceMax will have additional site-specific Tier 1 resources available, which will be listed in their SOPEPs. Nothing in this plan is intended to prevent the OIM or vessel master to initiate the necessary actions outlined in contractor plans and SOPEPs, applicable to the particular circumstances of the issue or incident. External Reference: Vessel SOPEP, Stena IceMax SOPEP 5.2. Tier 2 The Tier 2 response contractors available to Shell are shown in Table 5-1. Table 5-1: Tier 2 Response Contractors Resource Eastern Canada Response Corporation (ECRC) Witt O Brien s The Response Group (TRG) Tri-State Bird Rescue Crawford`s Wayne Manning Cobequid Wildlife Rehabilitation Center Marine Animal Response Society Capability Oil spill response organization Emergency management, Incident Action Plan preparation and disaster response and recovery Emergency Management, Incident Action Plan preparation Wildlife Response Claims and Compensation Wildlife rehabilitation Marine mammal rescue For a complete list of wildlife response contacts, please refer to Appendix 2 of the Shell Wildlife Protection Plan (EP ) Eastern Canada Response Corporation (ECRC) ECRC is certified by TC Marine Safety, as a Response Organization under the Canada Shipping Act (CSA), with locations shown in Figure 5-1. As a certified Response Organization, ECRC is available to provide assistance to the Shelburne venture as needed via an Offshore Operator s Agreement between ECRC and Shell. Certified under the Canadian Shipping Act, the ECRC s mandate is to maintain a professional marine oil spill response capability for its member base, and Shell is a member for the purposes of this and other projects. It is acknowledged that, similar to other OSROs, the deployment of ECRC personnel and resources is dependent upon availability at the time of an incident.

38 Unrestricted ECRC offers a Subscriber Agreement to organizations including the oil exploration and production facilities operating off Canada s east coast. These specific types of organizations are identified by ECRC as Offshore Operators, including Shell Canada. With the Subscriber Agreement, the Subscribers (Offshore Operators/Shell) are entitled: to identify ECRC as the response organization with which Shell has an agreement to receive Marine Spill Response Services in ECRC s Geographic Area of Response (GAR); and upon the occurrence of a spill of oil on water within ECRC s GAR, to request ECRC to respond and provide Marine Spill Response Services. The ECRC GAR includes all waters off Atlantic Canada out to the EEZ. Further information regarding ECRC coverage is provided in Appendix H: ECRC Background Information. Figure 5-1: ECRC Facility Locations Shell will have a contract in place, by time of spud, with ECRC who will be called upon at some level in all spills. As the Shell oil spill contractor, ECRC may be responsible for the direction of resources provided by other contractors and offshore operators. ECRC will provide comprehensive response management services, equipment, and trained field personnel to implement technical operations in the field. If ECRC are mobilized by the IMT, Shell will still be responsible for managing the response using ECRC s services. The activation procedure is as follows:

39 Unrestricted Contact the ECRC Call Centre at <Redacted> and provide the operator with the following information: o Contact name o Call-back number The ECRC Atlantic Region Duty Officer will then call back to obtain the following information: o Description or material safety data sheet (MSDS) for the product spilled o Position of the spill release or initial sighting The ECRC response manager will then initiate an internal notification process that will result in a call back from an ECRC Nova Scotia Representative. Once the ECRC response manager has confirmed the information about the spill and receives more information from Shell, the ECRC response manager will initiate a network of activation calls that escalate to a level required by the size and circumstances of the spill. This includes alerting ECRC managers in Ottawa, Corunna, Quebec and Dartmouth as well as local response contractors who are engaged to initiate a response within minutes of a call. The ECRC manager also makes an initial evaluation of the spill information and uses a code to alert other ECRC personnel of the expected level of response required. ECRC maintains a complete spill response inventory equipment list, which is updated internally each quarter. Shell will verify the availability and degree of readiness of ECRC equipment regularly. An excerpt of equipment immediately available in Nova Scotia from ECRC is provided in Appendix I: ECRC Spill Response Equipment Inventory. If requested by Shell, ECRC may mobilise additional equipment and resources from any of their locations in Canada Other Regional Primary Areas of Response (PAR) Additional oil spill response providers that Shell can seek assistance from and make arrangements with, if necessary during a Tier 3 incident include; Point Tupper, Nova Scotia Point Tupper Marine Services Ltd. (PTMS) All the waters between an arc having a 50 nautical mile radius about Bear Head Light, 45 33'N, 61 17'W but not extending north of the Canso Causeway into the Saint Georges Bay and the contiguous land mass. Saint John, New Brunswick Atlantic Emergency Response Team (ALERT) All the Canadian Waters between the western boundary consisting of an arc having a 50 nautical mile radius about the point 45 08'03"N, 66 17'12"W, and the eastern boundary consisting of an arc having a 50 nautical mile radius about a point, centred on Cape Spencer Light.

40 Unrestricted A map depicting the PARs noted above is shown in Appendix J: Map Depicting Primary Areas of Response Tier Oil Spill Response Limited Shell is a Participant member with OSRL, therefore has immediate access to Tier 3 technical advice, resources (including personnel and equipment) and expertise. Table 5-2 summarizes the OSRL service level agreement (SLA) available to Shell and Table 5-3 provides the OSRL response times to Halifax, Nova Scotia. Table 5-2: OSRL SLA Summary Service Service Standard Shell Membership Type: Participant Notification of a spill should be placed to one of the following locations: OSRL BASE Southampton, UK Loyang, Singapore Fort Lauderdale, USA Response notification, mobilisation, service and advice TELEPHONE <Redacted> <Redacted> <Redacted> FAX <Redacted> <Redacted> <Redacted> <Redacted> FORMS Refer to Appendix F: Forms The Duty Manager will speak and advise Shell immediately, or call Shell back within 10 minutes. Nominated Contact OSRL must receive an official mobilisation authorisation from one of Shell s Nominated Call-Out Authorities (anyone can notify OSRL). Shell Nominated Authority Spill response equipment SLA response equipment is housed in secure facilities in Southampton, Fort Lauderdale, Bahrain and Singapore. Response equipment is customs cleared response ready. Refer to: OSRL Yearbook for a complete list of equipment available, and refer to the equipment stockpile status report As per the SLA, Shell can mobilize up to 50% of the global stockpile. If there is more than one spill Shell can mobilize 50% of what remains. Dispersant stockpile If there was an incident, Shell is entitled to 50% of the 785 m 3 of dispersant/sta located in Southampton, Singapore, Fort Lauderdale and Bahrain. OSRL may be able to obtain further dispersant/sta through the Global Response Network (GRN) and

41 Unrestricted Service World-wide transportation of equipment Oil spill trajectory and tracking Service Shell Membership Type: Participant Standard other organizations, if required. Note 1: There is also an additional 5000 m 3 of Global Dispersant/STA Stockpile, available through a separate Subscriber Agreement described in Section Note 2: In response to an incident, Shell would mobilize sufficient quantities of approved STAs through the GRN and through the Dispersant/STA manufacturer. Use of an approved STA would only commence once approval for their use has been obtained. Global Aerial dispersant coverage provided by aerial platforms and application systems. Aerial dispersant coverage is mobilized within a six hour notice period. Logistics support including: Own fleet of vehicles for local mobilisation of equipment 24-hour-a-day access to global network of cargo and passenger charter services through a dedicated broker with specially negotiated payment terms Trajectory and stochastic services for surface or subsurface oil spills on request, and backtrack services for surface oil spills using commercial modelling software including: Oil Spill Information System (OSIS) OILMAP Oil Spill Contingency and Response Model (OSCAR) Satellite imagery services can be provided on request Response Personnel OSRL will provide the following response personnel on a first come, first serve basis: One senior oil spill response manager One oil spill response manager 15 Spill response specialists / responders One Logistics Service branch coordinators A Technical Advisor can be dispatched to offer support to Shell when they have an oil spill incident or the potential for an incident to occur. This is provided free of charge for the initial assessment period of up to 48 hours. If a full response team is then mobilized, the Technical Advisor will form part of the available team headcount.

42 Unrestricted Table 5-3: OSRL Response Times Resource Tier 3 aerial dispersant (UK to Halifax, Canada) Dispersant re-supply by air (based B747F) Tier 3 containment and recovery equipment (based on B747F) Mobilisation 6 hrs 48 hrs 48 hrs Transit 4.5 hrs 4.5 hrs 4.5 hrs Total 10.5 hrs 52.5 hrs 52.5 hrs Comment Shell will be responsible for obtaining the relevant permissions for the aircraft to fly into Canada. Payload and mobilisation time is dependent upon aircraft availability. Payload and mobilisation time is dependent upon aircraft availability Global Response Network If required, OSRL will facilitate the mobilisation of further resources through the GRN. The GRN is a collaboration of six major oil industry funded spill response organizations and national or regional oil spill response organizations, whose mission is to harness cooperation and maximise the effectiveness of oil spill response services worldwide. This network includes the following relevant organizations: ECRC Western Canada Marine Response Corporation (WCMRC) Oil Spill Response Limited (OSRL) (America, Europe, Middle East, Africa, Asia and Pacific) Marine Spill Response Corporation (MSRC) Alaska Clean Seas (ACS) Subsea Well Intervention Services If a loss of well control occurs during drilling, the IMT will coordinate with OSRL to mobilize the subsea well intervention services (SWIS) and associated resources as needed. Shell is a founding member and active subscriber to the SWIS program. The detailed SWIS planning specifically for this project is described in the Shelburne Basin Source Control Contingency Plan (SCCP). General SWIS information can be found at: External Reference: Shelburne Basin Source Control Contingency Plan In the event of a loss of well control, Shell would mobilize SWIS via OSRL:

43 Unrestricted Emergency Contact (24 hours) UK: <Redacted> Singapore: <Redacted> 15k PSI capping stack - Norway 15k PSI capping stack - Brazil 10k PSI capping stack - South Africa 10k PSI capping stack - Singapore Subsea intervention toolkit - Norway Subsea intervention toolkit - Brazil In addition to the OSRL notification and mobilisation forms, a further Subsea Well Response Equipment Identification and Configuration Form will also need to be completed by Shell. This will be completed in cooperation and assistance with the OSRL Duty Manager (DM). Refer to Appendix F: Forms. The Shelburne Basin SCCP provides a detailed equipment listing of the SWIS packages and additional equipment that Shell would need to activate. Contracts are in place to ensure that the applicable equipment can be mobilized when needed Global Dispersant Stockpile The Global Dispersant Stockpile (GDS) is a strategic and easily accessed dispersant stockpile of 5000m³. The GDS is located across the OSRL bases plus at a further location in Vatry, France. The GDS can be used for aerial, vessel or subsea application. Details regarding the planning for dispersants can be found in the Venture Dispersant Preparedness and Operations Plan and the Source Control Contingency Plan. Mobilisation and logistics arrangements for the Global Dispersant Stockpile and equipment can be found in the OSRL Global Dispersant Stockpile Logistics Execution Plan. The GDS is split into different regions globally for quick access. Unlike the SLA, all 5000 m³ of the dispersant can be mobilized for any one incident. 5000m³ has been estimated to support both a subsea and/or surface response for 30 days and the expected worst case release rate for the Shelburne Project. This would also allow for time to procure additional dispersant if required. Membership to the GDS is via a supplementary agreement to the OSRL SLA plus indemnity agreements with the dispersant manufacturers. At present, 21 operators including Shell are members of the GDS. Through indemnity agreements, Shell has access to sufficient quantities of approved STAs for use in an incident. Additionally, Shell can commission the manufacture of additional quantities of approved STAs, as needed, which is supported by an ER logistics plan to ensure that mobilisation and delivery of approved STAs can be deployed to Nova Scotia in response to an OSR incident. External Reference: OSRL Global Dispersant Stockpile Logistics Execution Plan 5.4. Contractor Response Readiness All response contractors are regularly tested by Shell to ensure they are response ready at all times. The contracts in place with these response providers define that the response resources and services are available 24 hours a day, 365 days of the year.

44 Unrestricted 6. OIL SPILL RESPONSE PLAN IMPLEMENTATION 6.1. Scenario Matrix OIL SPILL Site s Emergency Response Plans take precedence YES IS THERE A RISK TO LIFE? NO Spill contained (e.g. on deck)? NO YES Onboard cleanup Refer to SOPEP Continue to monitor Assessment & Surveillance Section 6.3 RESPONSE REQUIRED AND SAFE? NO Continue to monitor and provide assistance if required. YES Diesel/Fuel Oil Crude Assessment & Surveillance Section 6.3 Containment & Recovery Section 6.4 Consider the need for Wildlife Response Section 7 Assessment & Surveillance Section 6.3 NO Subsea Response Section 6.8 Dispersant Operations Section 6.5 Offshore Containment and Recovery, Section 6.4 In Situ Burn Operations Section 6.6 Shoreline impact anticipated? YES Ensure permission is granted and test spray conducted Ensure permission is granted Shoreline Response & Recovery Section 6.7 Assess Dispersant Efficacy Section 6.5 Waste Management Section 6.9 Figure 6-1: Scenario Matrix

45 Unrestricted 6.2. Operational Communications Shell recognizes that effective communication during any spill response require that all parties understand and use the assigned radio frequencies and telephone numbers. The use of satellite for communications with deployed OSR assets and the use of pre-programmed and designated frequencies will ensure that emergency communications are immediately established for a response. As spill response efforts potentially grow, additional frequencies and telephone numbers may be added to complete the incident Communications Plan that will be distributed to all response participants. The ICS Communications Unit Leader is responsible for establishing a tactical communications plan that provides coverage in the field, and between the field and a command post. Communication requirements are determined by many factors, the most important of which are the location and nature of the spill response activities and the number of staff placed in the field. Specific requirements include: The Communications systems will be self-contained, compact, highly portable and capable of providing all on-site and off-site communication links for the duration of the response. The Communication equipment used in the immediate vicinity of spilled or recovered product must be intrinsically safe (explosion-proof). Vessel and aircraft operations will be conducted in coordination with the CNSOPB, CCG, and the JRCC. At a minimum, the communications plan will document and include: Names of assets deployed, call signs, operational areas, and radio communications frequencies Emergency contacts Refer to Appendix F: Forms Simultaneous Operations (SIMOPS) Should simultaneous response operations (SIMOPS) occur, the probability of a hazardous or conflicting event is increased as numerous assets can be working at the same time in close proximity. Coordination of SIMOPS and effective communications are necessary to ensure all activities are performed in a safe and controlled manner. Shell has established SIMOPS procedures which will be followed during a spill response, and an incident-specific SIMOPS plan will be developed if required commensurate with the scale of the spill Assessment and Surveillance Aerial Support Depending on the size and complexity of an incident, the IMT may assign an Air Operations Branch as part of the Operations Section. The Air Operations Branch is tasked to coordinate aerial support based on operational needs. There are four key missions that aerial support can be tasked with: Verification of oil spill Monitoring Quantification of amount spilled Supporting Operations (e.g., Application of an approved STA, Wildlife Monitoring)

46 Unrestricted The Air Operations Branch Director is responsible addressing response considerations including flight authorisations and restrictions, air clearances, government support, aerial logistics and operational constraints (e.g., weather, visibility). Operational assignments will be documented in an ICS-220 Air Operations Summary form and included in the IAP. All air operations must follow the Site Safety Plan and additional emergency procedures specific to the operation. Communications for aerial support should be coordinated with the Logistics Section / Communications Unit and documented in the Communications Plan. Shell Aviation personnel are identified and assigned as part of the SART for escalated incidents and will be mobilized as needed. Refer to the OSRL Aerial Surveillance Field Guide for additional guidance Offshore Containment and Recovery Offshore containment and recovery operations will be utilized depending on the size and nature of a spill and operating conditions. For Shelburne Basin operations, all offshore support vessels will have skimming systems and containment boom for Tier 1 spills and crews will be verified as competent to respond as part of the overall internal Shell RFO and assurance process. Should further resources be required, ECRC will be called upon for Tier 2 spills and additionally, OSRL will provide further resources in the event of a Tier 3 spill. Vessels of Oportunity (VOOs) will be sourced at the time of the incident, as needed, to provide platforms for the containment and recovery systems. Additionally, barges to store and transport recovered waste in accordance with the Waste Management Plan will be utilized. The Recovery and Protection Branch Director is responsible for offshore containment operations. All operations will be conducted in accordance with the Site Safety Plan and IAP. Communications methods will be documented in the ICS 205 Communications Plan. Refer to Appendix F: Forms for the associated form Surface Dispersant Operations The Shelburne Basin Dispersant Operations Plan is referenced for guidance on the following: Decision and approval process Summary of available approved dispersants and effectiveness NEBA based decision and approval processes Resources and mobilisation information Test application guidance Application methods (vessel, aerial) Surveillance, monitoring and effectiveness Termination of dispersant operations Refer to the Aerial and Surface Dispersant Operations Plan for additional guidance.

47 Unrestricted 6.6. In-Situ Burn (ISB) Operations In-situ burning involves the controlled burning of oil that has been spilled on land or water. Oil is typically contained by physical means (e.g., containment boom) to provide a collected thickness sufficient for the oil to ignite and sustain burning. In-situ burn operations on water require specific conditions that must be evaluated for the development of an incident specific operations plan. Seasonal conditions have been evaluated for operational pre-planning. Industry best practice and operational guidance will be utilized to develop the necessary incident specific tactical instruction. The reference documents below provide additional guidance for in-situ burn operations. Shell maintains internal expertise for managing in-situ burn operations that are part of the SART and can be deployed in direct support of an incident. In certain circumstances, a Net Environmental Benefit Analysis (NEBA) may be undertaken as part of the evaluation of effectiveness and applicability of ISB operations. External Reference: API Decision Maker s Guide to In-Situ Burning and the OSRL Field Guide Shoreline Protection and Recovery The ECRC maintains a highly detailed GIS mapping data base of all shoreline sensitivity classifications throughout Atlantic Canada. As outlined in the Sensitive Receptors section, this data base includes mainland Nova Scotia, as well as Islands such as Sable Island, Cape Sable Island and others, some of which are highly sensitive environmental areas. This ECRC database, along with input from local stakeholders will be used for planning purposes during a spill response (including the overlay of spill trajectories), and will provide significant information needed to prioritize protection and response measures. The Operations Section, in coordination with the Environmental Unit will develop incident-specific protection and recovery strategies that will be incorporated into the Incident Action Plan. The Science Table can be convened by the Lead Agency to assess and comment on incident-specific protection and recovery strategies. Pre-Shoreline Cleanup Assessment Technique and Shoreline Cleanup Assessment Technique will be utilized for pre-impact assessment, planning for response operations, survey /document the affected area and determination of appropriate shoreline treatment and cleanup operations. Shoreline Cleanup Assessment Technique will be utilized for pre-impact assessment, planning for response operations, and determination of appropriate cleanup methods. External Reference: IPIECA Guide to Oiled Shoreline Surveys and the OSRL Shoreline Operations Field Guide Subsea Response For details regarding subsea response, refer to the Shelburne Basin Source Control Contingency Plan (SCCP). The SCCP addresses management of source control incidents including capping stack, relief well, and subsea dispersants. External Reference: Source Control Contingency Plan.

48 Unrestricted 6.9. Spill Waste Management and Disposal Clean-up activities following an oil spill will result in hazardous waste that must be carefully managed and ultimately disposed of in an appropriate manner. Large spills can result in a significant amount of waste, substantially more waste than the original spill volume, as some liquid products may emulsify, materials are used in the spill response, and secondary contamination may occur (i.e., previously uncontaminated material becomes contaminated through contact with spill waste). Accordingly, minimizing spill waste is an important factor in managing any oil spill response. The use of approved STAs and in-situ burning of oil may help limit the amount of oil reaching potential receptors, and may help to reduce the amount of spill waste generated. In the event of a spill, the Logistics Section and Environmental Unit will dedicate resources to identify, evaluate and select storage and disposal facilities based on the size of the spill and the amount of anticipated waste. An incident-specific waste management plan would be developed, based upon the guidance provided in the venture waste management plan, according to the oil type and spill severity, and with consideration for any external parties contracted to assist with spill clean-up. Shell will require chain of custody documentation with all contractors for the storage and transfer of spill waste material from origin to final disposition. ECRC will provide local spill waste management support, including local resources and hazardous material contractor networks, in line with their well-established Recovered Materials Management Procedures. External Reference: IPIECA Guidelines for Oil Spill Waste Minimization and Management Spill Waste Management Management of waste generated during a potential oil spill will include the following: Waste recovery spill location and extent of potential oil contamination Waste storage temporary on site at spill location and later onshore Waste transport to shore facilities, and later to disposal facilities Waste disposal

49 Unrestricted Figure 6-2: Typical Spill Waste Management Different types of wastes have different characteristics, necessitating specific equipment (including PPE) and/or techniques for proper handling. In particular, oil wastes have volatile fractions that may be potentially flammable and/or toxic. All personnel handling such wastes must use appropriate PPE, and be made aware of safety considerations before they commence work or join the response effort. This includes participation in a formal safety and incident-specific orientation/induction delivered by a qualified supervisor. A priority in any incident is minimizing the potential risk for additional environmental issues caused by waste storage and/or disposal. For this reason, commensurate with the type and extent of the spill cleanup, the selection of proper storage, transport and disposal methods and facilities is of critical importance. In the unlikely event of an incident, an incident-specific waste management plan would be created to detail the type of wastes to be disposed of, recommended handling procedures, approved manner of disposal in line with legislation and regulations and licensed waste facilities approved to receive the various waste streams. External Reference: Waste Management Plan (Operational Authorization) Spill Waste Products and Materials Two primary types of products and materials result from oil spill clean-up: liquid and solid. Each type must be recovered and stored in appropriately. Proper waste segregation and management is imperative in order to reduce the potential for secondary contamination and ensure the most efficient disposal for each type of waste.

50 Unrestricted Table 6-1: Categories and Examples of Spill Waste Liquid Solid Recovered or skimmed oily liquids Emulsified oil / water Vessel wastes Decontamination liquids (Non-oily) Grey and black waters Sand, gravel / rocks, tar balls Sludge and asphalt patches Sorbent Booms, Pads, Sheets Oiled personal protective equipment and gear Contaminated Shoreline Materials (vegetation, seaweed, driftwood, beach debris, flotsam) Empty drums and containers (Non-oily) trash and garbage (Non-oily) human wastes Transportation All transportation of oil and oily waste will be conducted in accordance with applicable Nova Scotian provincial legislation, the federal Transportation of Dangerous Goods Act (TDG) and attendant regulations, as applicable. To determine the applicable requirements for transportation of oil spill waste, the materials being transported must be characterized in accordance with applicable hazard classifications established by the legislation. All hazardous wastes must be shipped in appropriate containers. Both solid and liquid wastes from an offshore oil spill will almost always be transported to shore for disposal, with the exception of burning oil in-situ offshore. The chain of custody for managing wastes includes offshore and onshore storage, transportation by various means, and ultimate disposal. Liquid waste collected at sea is typically stored on a supply vessel, and may be transferred for temporary storage to a larger vessel such as a tanker or barge. When the vessel is full or the clean-up effort is complete, the vessel will transport the liquid materials to an onshore temporary storage facility. Liquid waste is typically transported onshore by a tanker truck, which will deliver the waste to a disposal site such as an oil refinery. In the event of a spill, Shell will make arrangements with appropriate vessels, storage facilities, onshore transportation services and disposal facilities in order to ensure that all waste from the spill is properly transported and stored at all times from collection through to ultimate disposal. Interprovincial transportation of waste dangerous goods destined for disposal must comply with the requirements of the Interprovincial Transport Regulations under the Canadian Environmental Protection Act (CEPA) and the hazard classifications under the TDG Regulations. These requirements will generally be restricted to transportation of waste oil between provinces which meets the TDG hazard classification

51 Unrestricted as a flammable liquid. Transportation of these products will be completed by Certified Used Oil Collectors who have the vehicles, staff and facilities for management of such wastes. It is not expected that large volumes of oiled solid waste would be moved between provinces for the purposes of disposal. There is also no specific classification for these materials under provincial or federal legislation. It is common practice that solid materials (e.g., soils) are transported within provinces without regulatory manifests. However, in Nova Scotia any site receiving wastes for treatment and/or disposal requires a manifest tracking system as a condition of their environmental approval issued by NSE Incident Specific Waste Management Plan As noted above, in the unlikely event of a spill requiring the recovery and handling of waste material, Shell will develop an incident specific Waste Management Plan taking into consideration the type of oil and extent of the spill event. The incident-specific Waste Management Plan at a minimum will outline permitting requirements, hazard assessment, safety and waste handling procedures. This plan will be developed by the Environmental Unit with input from Logistics and Operations, in close coordination with the ECRC and applicable local authorities and waste management contractors. This incident specific plan will incorporate guidance and leverage existing contractual agreements outlined in the Project Waste Management Plan Federal and Provincial Legislation Relevant for Spill Waste Management The CNSOPB is the lead agency responsible for pollution response with respect to incidents related to offshore Nova Scotia petroleum exploration or production installations, including a MODU while on station at a well location. In the event of such an incident, the CCG has an MOU to provide assistance as a resource agency. In the event of a significant oil spill requiring federal environmental involvement, the multi-agency Science Table (chaired by EC) as well as Nova Scotia Environment will be engaged to provide information and support to Shell and the CNSOPB regarding materials recovery, waste minimization and storage, transport and disposal. The following sections identify and summarize federal and provincial legislation potentially related to management and disposal of waste.

52 Unrestricted Federal Roles and Legislation Canadian Environmental Protection Act (CEPA) Within the federal government, CEPA is the primary element of the legislative framework for the protection of human health and the environment, and includes the prevention and management of risks posed by toxic and other harmful substances, impacts of marine pollution, disposal at sea, interprovincial and international movements of hazardous wastes and environmental emergencies involving CEPA regulated substances and other sources of pollution not regulated by provincial jurisdictions. The Disposal at Sea Regulations pursuant to CEPA prohibit the disposal of wastes and other matter at sea within Canadian jurisdiction and by Canadian ships in international waters and waters under foreign jurisdiction, unless conducted under a permit issued by the Minister. Incineration at sea is also prohibited, except under emergency situations or if it is waste generated on board the ship or structure. The Interprovincial Movement of Hazardous Waste Regulations pursuant to CEPA aim to ensure that the Canadian manifest tracking and hazards classification conditions for waste, formerly set out in the Transportation of Dangerous Goods Regulations, are maintained for the interprovincial movement of hazardous wastes. EC enforces requirements for transboundary shipments of hazardous waste or hazardous recyclable materials. Fisheries Act Selected sections of the Fisheries Act are also administered by the Federal Minister of the Environment on behalf of the Minister of Fisheries and Oceans Canada, including provisions to prevent pollution of waters inhabited by fish. Canada Shipping Act The Canada Shipping Act addresses a broad range of issues related to ships and oil handling facilities, both of which are required to have oil pollution emergency plans and arrangements in place with response organizations. Transportation of Dangerous Goods Act The Transportation of Dangerous Goods Act promotes public safety in the handling, transporting and offering for transport of dangerous goods. Oil and oily waste resulting from spill events falls under the TDGA classification for hazardous waste and will be handled in accordance with TDGA guidelines. Specific standards apply to the containment of such goods, as well as labelling, placarding and shipping document requirements. Migratory Birds Convention Act (MBCA) The MBCA addresses migratory birds, their habitat, and their harvest and management. It is an offense under the MBCA to deposit oil or oily waste into water that is inhabited by migratory birds.

53 Unrestricted Species at Risk Act (SARA) SARA seeks to prevent species from being extirpated or becoming extinct; to provide for the recovery of species that are extirpated, endangered or threatened as a result of human activity; and to manage species of special concern to prevent them from becoming endangered or threatened. No person shall kill, harm, harass, capture or take an individual of a wildlife species that is listed as an extirpated species, an endangered species or a threatened species. Additional Legislation The following federal legislation also has potential relevance to offshore oil spill emergency response, depending on the circumstances of the spill: Canada Water Act Canada Wildlife Act International Boundary Waters Treaty Act Energy Supplies Emergency Act Hazardous Products Act National Energy Board Act National Transportation Safety Act Provincial Roles and Legislation Nova Scotia Environment Act Industrial facilities that treat oily waste require approval under the Activity Designation Regulations pursuant to the Environment Act. Any facilities storing recovered oil will be required to have tanks which are in compliance with the Petroleum Management Regulations. Under the Petroleum Management Regulations, petroleum products are designated as dangerous goods. The Dangerous Goods Management Regulations establish the standards and requirements for the storage and handling of dangerous goods. Licenses for the Transportation of Dangerous Goods Nova Scotia does not require manifesting or carrier numbers for persons involved in the transportation of dangerous goods within the province. However, companies involved in the transportation of dangerous goods must maintain valid driver training and insurance. Manifesting requirements are generally reflected in the Approval requirements for facilities accepting waste from third parties Spill Waste Storage and Segregation The amount of liquid waste generated in a Tier 3 oil spill can be considerable. Insufficient storage can be a potential bottleneck in clean-up operations, therefore ensuring sufficient storage is a top priority during any clean-up operation.

54 Unrestricted The storage of liquid waste on vessels requires that the vessel is equipped with large volume internal tanks or on-deck tanks from small to moderate volume. Portable deck tanks for storage are available from ECRC. Additional resources will be identified and procured as required and identified in the incidentspecific Waste Management Plan (including OSRL). The use of decanting may also improve the efficiency of storage. Individual collection vessels often have a small storage capacity, requiring that waste is regularly transferred to a tanker during any spill response operation. Solid waste from the spill must be properly segregated to avoid contamination by materials that would require more expensive forms of waste disposal. Proper solid waste containment includes the use of industrial-grade plastic garbage bags, folding tote sacks, or lined steel garbage containers. Ideally, material will be packed at the spill site so that repacking onshore is not necessary prior to shipment for disposal. Onshore storage of solid waste must be at government-approved locations. An overview of waste disposal resources is included in Appendix I: ECRC Spill Response Equipment Inventory and Appendix G: Shell Spill Response Dedicated Equipment Inventory Spill Waste Oil Accounting / Tracking The proper management of any waste generated by a spill includes careful documentation and recording of all oily liquids and contaminated materials. Careful Chain of Custody records will be maintained of waste storage, waste transportation, and waste disposal. As waste materials are moved, each step in the transfer of the material will be recorded and manifested Decanting During containment and mechanical recovery operations, oily liquids including water and emulsions will be recovered. Temporary storage capacity can become limited depending on size and complexity of an incident. Decanting may be appropriate in a low-energy environment allowing the oil to separate into layers through gravity separation. Retention and settling time may vary dependent on the viscosity of the oil. Free water is then discharged within the apex of containment boom in the path of mechanical recovery equipment. Visual monitoring will be conducted during decanting operations to ensure only water is released. This separation and decanting of excess water can be an effective method to maximise the use of storage capacity. An incident-specific decanting operations plan will be developed as the decanting plan requires acceptance from the CNSOPB with guidance sought from the Science Table. No formal permits are required to authorize decanting. External Reference: IPIECA JIP 17 Decanting Treatment and Disposal Liquid wastes from oil spill clean-up are generally disposed of through recycling or other disposal methods. In some cases, recovered oil can be mixed into a refining stream following dewatering. Shell will identify the appropriate method for disposal of liquid waste in the spill-specific plan based on the classification of oil spilled and the condition and volume of the recovered oil.

55 Unrestricted Solid wastes generated from spill clean-up will include contaminated sediments, sorbent booms, pads and sheets. Shell will identify the appropriate method for disposal of solid waste in the spill-specific plan for based on the type of solid waste that needs to be disposed of, as well as the amount of waste Decontamination Procedures In the event of a spill, an incident-specific Decontamination Plan will be developed by Shell to be commensurate with the nature and extent of the spill. Decontamination must be coordinated with Site Safety Plan requirements. Prior to implementation of the decontamination plan, Shell will engage with the relevant regulatory agencies dependant on where decontamination activities will occur to ensure acceptance of the proposed plan (e.g. CNSOPB and Nova Scotia Department of Environment). The Planning Section will support development of the Decontamination Plan with input from Operations and Logistics. The decontamination procedures will depend on the type and volume of oil that has been spilled, and the type of equipment used during the clean-up operation. Regular decontamination during the response is necessary for the personnel involved with direct clean-up efforts, the vessels involved in the response, and a wide range of spill-related equipment. Shell s spill response contractors will follow guidance (such as available through OSRL) for decontamination operations in order to facilitate proper decontamination through the duration of the clean-up effort. The establishment of a field decontamination process is a priority. Regular decontamination will occur in the field, particularly during a large-scale response, so all personnel must be briefed on the decontamination requirements at the beginning of the spill response in ensure functioning of decontamination operations. Supervisory personnel are responsible for ensuring that all decontamination activities are occurring according to the guidelines. At the end of the response effort, all the vessels and equipment that have been used at the site will undergo a more thorough cleaning to ensure their suitability for future use as part of the demobilisation process. The incident specific Decontamination and Demobilisation plans will outline such expectations. Personnel Decontamination Procedures Personnel who are involved in clean-up activities that have direct contact with oil will be equipped with appropriate personal protective equipment to protect them from contamination. Specific areas that are designated dirty and clean will be established in order to organize personnel who are in the process of suiting up or decontaminating. A sequential decontamination process will be established for all personnel to follow. Fluids generated during the decontamination process must be collected as oily waste and will be added to the spill waste management storage. Any solid waste generated must be segregated and disposed of per approved procedures. Personnel may reuse PPE, but dirty PPE must be kept in a specific area where it can be recovered when personnel returned to cleaning tasks. Any discarded PPE must be put in the segregated garbage bags.

56 Unrestricted Equipment Decontamination Procedures The decontamination of equipment must take place in designated areas. A dry cleaning of equipment may take place depending on the level of oiling and potential reuse of equipment. If equipment is washed with fluids, the fluid must be collected because it is classified as oily waste, and specific regulations apply to its disposal. For this reason, pressure washing and steam cleaning should generally be avoided because these processes generate significant amounts of oily waste. Equipment such as skimmers and hoses that are not being used and are awaiting decontamination, should be stored in such a way that any oil dripping from the equipment is captured. This can be achieved by storing such equipment in dedicated containers designed for this purpose, which are stored on the deck of the vessel. Upon completion of the clean-up effort, all equipment must be cleaned thoroughly so that the equipment is ready for subsequent use. Following dry-cleaning on deck of the vessel, equipment is typically transported to shore. Equipment may need to be wrapped or otherwise protected during transportation to prevent secondary oiling. Onshore, equipment will typically be steam cleaned or pressure washed, and all fluids will be collected and handled appropriately. It is important to minimize the potential for secondary oiling and secondary waste, so cleaning should be undertaken as close as possible to the receiving onshore area. Vessel Decontamination Procedures Vessels involved in the spill response will be exposed to oil in varying degrees, depending on the role of the vessel in the clean-up effort. Vessels may receive an initial decontamination (pre-wash) in the field if the oil poses a hazard or the vessel must return to port. Criteria for varying levels of decontamination procedures will be identified based on operational needs. As vessels complete operations or are identified for demobilisation, they must be thoroughly cleaned in accordance with regulatory requirements set forth by Environment Canada and the Nova Scotia Department of Environment. When clean-up takes place in a harbour, contaminated vessel(s) will be managed based on a number of factors including severity of contamination, economic impact. Vessel decontamination procedures will be outlined in the Decontamination Plan generated by the Environmental Unit, with input from Operations and Logistics, during an incident. External Reference: Shelburne Waste Management Plan

57 Unrestricted 7. WILDLIFE RESPONSE The Wildlife Response Plan (WRP) has been developed to allow for timely, coordinated, and effective protection, rescue, and rehabilitation of wildlife resources to minimize any negative impacts that may be resultant of a spill associated with the Project. The WRP is an independent document prepared to outline the measures to avoid and mitigate impacts on wildlife, as well as rescue and rehabilitation of affected or injured wildlife should such measures be required. The principal objectives of the WRP are to: provide appropriate and achievable protection to wildlife resources and habitats; minimize impacts to wildlife resources and habitats; provide appropriate and achievable rehabilitation and rescue to impacted wildlife resources; document and record wildlife rescue operational activities associated with spill response and cleanup; and prevent injuries to responders and the public. The WRP consists of three key sections which provide management and operational guidance for the following: Assessment Reconnaissance Hazing and Pre-emptive Capture Recovery and Care Response Strategies The Shelburne Basin Venture Exploratory Drilling EIS provides extensive information regarding the wildlife and habitat that could be affected in the event of an oil spill. Species of conservation interest and environmentally sensitive areas (national, provincial and regional parks, federally or provincially listed habitat, ecological reserves, estuaries, Important Bird Areas, Migratory Bird Sanctuaries) within the Project s potential zone of influence are summarized in EIS Section and EIS Section Potential effects of oil on relevant marine species and sensitive regions are also described and assessed in the EIS Sections 7.3 Marine Mammals and Sea Turtles, 7.4 Marine Birds, and 7.5 Special Areas. In addition to the Environment Canada database, ECRC maintains a detailed GIS database of marine and shoreline sensitivity mapping, including important wildlife areas. This information, along with aerial and vessel monitoring, shoreline surveys and advice received through the Emergency Science Table and other government departments will be used by Shell to identify potentially affected resources and areas, and to inform the response effort. External Reference: Shelburne Basin Wildlife Response Plan & Shelburne Basin Venture Exploratory Drilling EIS (Stantec, 2014)

58 Unrestricted 8. ENVIRONMENTAL 8.1. Sampling Safe, effective and standardized sampling is an important component of the documentation and record keeping process associated with an oil spill response. Shell will ensure that sampling activities will be conducted and managed by certified and experienced consulting companies and laboratories. An incident specific Sampling Plan will be developed by the Environmental Unit to be commensurate with the nature and extent of the spill. This plan and the outlined procedures will be submitted to the CNSOPB for review and consideration by the Science Table in order to ensure appropriateness of the proposed approach as well as to consider opportunities for coordination with other regulatory agencies conducting sampling in association with the incident Incident-Specific Net Environmental Benefit Analysis (NEBA) A NEBA has been prepared for the Shelburne drilling Project titled Net Environmental Benefit Analysis Support for the Shelburne Basin Venture Exploration (the Shelburne NEBA ). The Shelburne NEBA has been submitted to the CNSOPB as part of the Operations Authorization process, and for review by the Science Table in support of potential dispersant operations. More specifically during an incident, the CNSOPB will request that EC convene a Science Table to provide the CNSOPB with the incident specific guidance needed for CNSOPB to consider the NEBA and determine whether there is a Net Environmental Benefit to using an approved STA in response to the incident. This NEBA would then be utilized during an incident to help make strategic decision on the appropriate dispersant deployment response techniques to implement. It may also form the foundation for the development of an incident specific analysis. In the unlikely event of an oil spill, the existing NEBA may be utilized to develop an incident-specific analysis to weigh the positive environmental impacts of removing oil from the environment against the impact of potential cleanup techniques and the impact of leaving the oil in environment to naturally attenuate. The NEBA will provide key decisions, factors involved and the trade-offs being evaluated. The development of the NEBA and associated discussions will be coordinated by the Environmental Unit in consultation with the appropriate stakeholders and authorities. The use of NEBA will ensure that strategic decisions and response actions will be taken to minimize impact to the environment based on the current conditions and sensitivities involved. In certain circumstances, the NEBA approach may also be used to inform decisions related to In-situ Burning or other alternative response techniques being considered at the time of the incident. The NEBA will be submitted to the CNSOPB, and CNSOPB will request EC to convene a Science Table. The Science Table will provide comments and recommendations to CNSOPB. The NEBA developed in support for this OSRP should be utilized as a base for development of an incident-specific analysis for operations such as STA application, in-situ burn and shoreline techniques. External Reference: Net Environmental Benefit Analysis Support for the Shelburne Basin Venture Exploration

59 Unrestricted 8.3. Environmental Effects Monitoring The implementation of an effective EEM program is an important component any incident that has potential for environmental impacts. EEM is necessary to provide appropriate identification and characterization of threats and potential impacts on marine resources as well as shoreline areas. The EEM program includes activities such as sample collection, analysis and reporting, all of which contribute to an understanding of how the environment may be affected by an incident, and allows for further consideration of how those effects can be addressed and resolved. The program will monitor the behaviour, fate and effects of the incident in the environment. This section provides a high-level description of what the EEM may include / consider. Depending on the incident and its severity, detailed follow-up programs may be required. Such programs may involve monitoring the effects of oiling on components of the marine environment until specific endpoints are identified in consultation with expert government departments are achieved and residual hydrocarbons reach acceptable levels. These programs may be developed in consultation with applicable regulatory agencies, Aboriginal groups, fisheries representatives, and other stakeholders. As applicable, objectives of the EEM may include the following: Fingerprint oil samples collected as necessary for verification of source. Determine the effect of the incident on receptor populations or ecosystems. Measure hydrocarbon concentrations in water or sediment samples, including the decline of hydrocarbon concentrations over time following an incident. Sensory testing seafood for taint, and chemical analysis for oil concentrations and any other substances, as applicable Measure levels of contamination in recreational and commercial fish species with results integrated into a human health risk assessment to determine the fishing area closure status Monitor for marine mammals, sea turtles, and birds with indicative signs of oiling and reporting results to the CNSOPB. Demonstrate a commitment to the environment and appropriate recovery efforts in the event of an incident. A further benefit of the EEM program is the potential ability to use collected data to modify practices or procedures to reduce the impact of future incidents. Records of marine birds, mammals and sea turtles encountered will be maintained and provided to the relevant regulatory agencies at a frequency dependent on the size and scale of the incident. A quality assurance process would be established to ensure that the recording, monitoring and sampling procedures are properly conducted and recorded, and to ensure that the program is delivering on the intended objectives. The EEM program provides a structured plan for data collection and interpretation, allowing the monitoring of specific wildlife populations in the potential areas that may be affected by a spill. In the case of the Project, four specific monitoring receptors have been identified. The EEM plan provides guidance for the monitoring of the following receptors:

60 Unrestricted Marine bird populations Pelagic marine mammal populations Fish and shellfish populations Shoreline environment, including Sable Island Receptors may be modified at the time of an incident based on the situation-specific temporal or spatial considerations. Monitoring seeks to identify whether the oil spill has actually reached the population or location, and if so, whether the exposure has had any adverse effects. The severity of the effects can be assessed and measured, while taking into account any observed effects that have causes other than the oil spill. The monitoring process also allows for estimates on the expected duration of any exposure and its associated impacts to receptors. The size and severity of an oil spill, along with other environmental factors, will substantially influence the potential for the spill to affect specific receptors. The intensity of the monitoring effort is directly related to the magnitude of the spill. As a result, the proposed level of monitoring will correspond to the size of the spill. Assigning a specific monitoring level allows for streamlining of efforts and ensuring appropriate resources can be put into place to manage any ongoing monitoring Monitoring Levels Appropriate monitoring activities depend on the type and size of spill that has occurred. A spill-specific EEM plan will be developed in the event of a spill. The first step in any monitoring effort, regardless of level, is to determine the best estimate of spill volume, as well as the type of oil that has been spilled. The three monitoring levels outlined in Table 8-1 provide a guideline of the level of response effort in accordance with spill size. Table 8-1: Spill Monitoring Level Criteria and Activities Monitoring Level 1 2 Spill Size / Type Tier 1 spills Small spills which are expected to naturally dissipate and cause little to no impact to receptors. Batch spills with slicks that do not persist beyond the immediate area of the spill site. Tier 2 spills Medium to large spills that persist beyond the spill site and which may result in impacts. Batch spills with slicks that persist beyond the spill site. Monitoring Activities Record spill observations. Monitor oil slick from platform or from an aircraft / vessel if possible. Monitor and record any affected receptor population and/or location. All Level 1 activities. Oil slick monitoring and surveillance, including trajectory modelling of expected spill behaviour. Collecting oil samples for source identification purposes. Systematic surveying of potentially affected receptors, including testing of fish and/or shellfish species for contamination.

61 Unrestricted 3 Tier 3 spills Very large spills which are likely to travel long distances and have potentially significant effects on receptors. Large batch spills with large slicks that persist well beyond 1 km from the spill site. Blowout spills of any duration. All Level 1 and 2 activities. Extensive surveying of potentially-affected receptors. Chemical analysis for human health risks. Assessment of cause and effect relationships between the spill and its impacts. While the above table provides general guidelines, the necessary monitoring activities and resources may vary for different receptors based on the size and type of spill. Figure 8-1 provides a flowchart decision tree to assist in determining the appropriate EEM level. The spill-specific EEM plan that is developed will take into consideration trajectory modelling and aerial surveillance (including DFO and / or CCG spill monitoring flights) as described in EIS Section 6.3 and Section 4.4.3, respectively.

62 Unrestricted Figure 8-1: EEM Flow Chart

63 Unrestricted The sections below outline requirements for each potential receptor group and provide further detail on associated monitoring activities Marine Birds Marine birds are those birds typically found at sea whose populations can be potentially affected by oil spills. Monitoring the oil slick is particularly important because of its potential impact on such birds. Specific activities required for marine bird impact monitoring include the following: Table 8-2 Required Activities for Marine Birds Level Required Activities 1 Monitor and record any affected receptor population and / or location 2 Conduct surveys to identify and confirm the presence and abundance of bird populations as well as to identify any impacted individuals (i.e. oiled birds) Collect oiled birds, where feasible, and test for source identification purposes 3 All Level 2 activities Where observed bird populations are at risk, assess any impacts and test for source identification to determine whether these result from the spill or another cause Conduct a necropsy of dead birds to determine cause of death Existing CWS standardized bird survey protocols would be utilized in developing any associated bird monitoring program during a Level 2 or 3 response. CWS would also be consulted during a response in regards to any proposed marine bird monitoring to ensure the appropriate protocols and approaches were implemented Pelagic Marine Mammals and Sea Turtles Pelagic marine mammals include a variety of whale and dolphin species. Specific activities required for pelagic marine mammal and Sea Turtle monitoring include the following: Table 8-3 Required Activities for Marine Birds Level Required Activities 1 Monitor and record any affected receptor population and / or location 2 Conduct surveys of mammal distribution in the local area Extensive assessment and monitoring of oil slicks using computer modelling 3 All Level 2 activities Should one (or more) mammal population is observed to be affected by oiling, a postincident, species-specific monitoring program may be developed in association with subject matter experts - the program will seek to identify any behaviours in the population that differ from pre-spill behaviours, as well as assess the impact of the spill on survivorship in the population Contamination and Taint of Fish and Shellfish The monitoring of Commercial, Recreational and Aboriginal (CRA) fisheries is particularly important because of the potential for human health impacts, impacts to fish health and population levels as well as

64 Unrestricted the potential for fisheries closures to have significant economic impacts. In the event of a significant spill, fish and shellfish will be monitored in coordination with DFO, EC, and the Canadian Food Inspection Agency (CFIA) and results will be integrated into a human health risk assessment to determine whether the closure of any commercial fishing operation is necessary, and the timing of its subsequent re-opening. Specific activities required for fish and shellfish monitoring include the following: Table 8-3 Required Activities for Marine Birds Level Required Activities 1 Not applicable 2 Conduct surveys to determine the movement of oil in all zones (surface, water column, seabed) and the fate of the oil in these zones Determine whether any commercial fishery is impacted by the spill Conduct in-situ fluorescence assessment of hydrocarbons in all zones Obtain seabed sediment samples for analysis Sample receptor benthic / demersal species for contamination testing Provide information on the extent of the spill (spatial and temporal) in order to determine whether any commercial fishery should be closed, and also timing of re-opening 3 All Level 2 activities When contamination has been found in one or more species of fish or shellfish, use oil fingerprinting to determine whether the contamination is a direct result of the spill Continue monitoring to determine when contamination levels are reduced to acceptable and safe level Shoreline Habitats Spill trajectory modelling conducted as part of the EIS showed very remote probability of shoreline oil impact on the southern shoreline of Nova Scotia as well as Sable Island. Due to the fragile and delicate ecosystem present on the Sable Island shoreline, it is an area that should be considered for monitoring in the event of an oil spill with potential to impact the shoreline, which may also affect wildlife that live on or frequent the island. The objective of any monitoring associated with the Sable Island shoreline or any other potentially impacted shoreline is to acquire information to assist with preparations for managing any impact. Useful information will include the location of the oil slick, the extent of the slick, and the expected level of impact, as well as any estimates on the persistence of the oil. The information can assist with the determination of appropriate clean-up techniques and activities to minimize harm to wildlife. The assessment of the oil slick in the event of a spill is the first step in assessing any impact on shoreline habitats. Level 2 and 3 monitoring include the assessment of slicks that extend beyond 1 km from the site, both of which should also assess any potential impact on Sable Island or other shoreline habitats. Careful monitoring of the slick and its persistence and direction of movement must be conducted. When any slick is observed to be within 10 km of Sable Island or the Nova Scotia shoreline, Level 3 monitoring of the island shoreline must commence as follows:

65 Unrestricted Level Required Activities 1 and 2 Not applicable 3 Conduct shoreline surveys for purposes of assessing oil contamination (ASTM Standard F 1686 (ASTM 1998) Collect oil samples for source identification purposes Consult with lead regulatory agency for the escalation of monitoring efforts and decisions on when monitoring efforts will cease Consult with lead regulatory agency for any requirement to conduct shoreline clean-up efforts or wildlife rehabilitation effort Termination of Monitoring Activities The duration of any monitoring activities is correlated with the severity and magnitude of the spill. In general, the results of monitoring activities, including environmental sample results, will provide guidance on whether the monitoring effort must continue and, if so, the appropriate scale of the effort. Small spills that quickly disperse in the environment will result in short-term monitoring activities, while larger spills may require monitoring for months or years into the future. The decision to terminate any monitoring activities will be made in conjunction with regulatory agencies and stakeholders, once the results of monitoring indicate that the risks are low to negligible. Criteria for termination of monitoring will be developed with input from the Environmental Unit and Science Table and addressed in the spill-specific EEM plan.

66 Unrestricted 9. HEALTH, SAFETY AND SECURITY In responding to any oil spill, the primary focus of Shell s actions will be on the health, safety and security of Shell personnel, other responding personnel involved in the spill response, and the general public who may be affected by the spill. This is reflected in Shell s Business Principles and the HSSE & SP Control Framework Safety All spill response operations are required to comply with Shell s HSSE & SP Control Framework, Life Saving Rules and regulatory OHS standards as a minimum. Shell and its contractors will institute appropriate health and safety programs to provide a safe working environment for all personnel and to conduct operations responsibly. Shell requirements for HSSE apply to all persons conducting work for Shell irrespective of whether they are Shell employees, contractor staff, third parties or occasional visitors. A Site Safety and Health Plan (SSHP) is an incident-specific document required by Shell and developed by the IMT. The SSHP, at minimum addresses, includes, or contains the following elements: job safety analysis requirements, PPE guidance, site-specific medical monitoring requirements, air monitoring plan, site control measures, confined space entry procedures (if needed), pre-entry briefings (tailgate meetings), incident reporting requirements, and quality assurance of SSHP effectiveness. The incident Safety Officer will prepare the SSHP with input from Operations, the Medical Unit Leader and subject matter expertise such as an Industrial Hygienist. The SSHP will be distributed to the Operations Section Chief for implementation and promulgation to all operational groups and responding authorities Life Saving Rules, Permits and Derivations The Shell Life Saving Rules will apply in the event of any oil spill and must be adhered to by all persons participating in the spill response effort, regardless of whether they are Shell employees, contractors, third parties, or other personnel. In the event of an emergency situation that requires deviation from a regulation, authorization, permit or approval, the CNSOPB Regulatory Query (RQ) process will be followed Medical The Shelburne Basin ERP addresses response and recovery activities related to potential emergencies. This plan covers medical emergencies and outlines procedures and protocols to be followed. Aspects of these procedures will be incorporated into an incident-specific Medical Plan. The Safety Officer and Medical Unit will prepare guidance to be implemented by all response personnel and organizations Security A Shelburne Basin Security Plan has been developed as part of the ERP to prevent potential security breaches. This plan should be adhered to at all times by all personnel. In the event of a spill, an incidentspecific Security Plan may be developed commensurate with the scale and conditions of the spill event. As part of the initial response, key security-based requests must be submitted to the relevant authorities as needed, such as the RCMP and JRCC. The Security Plan should also address security precautions and procedures covering personnel access and incident facilities including the command post, staging areas and other locations.

67 Unrestricted 10. COMMUNICATIONS Public Information A Public Information Officer (PIO) will be activated depending on size and complexity of an incident. The PIO role is staffed by a Shell Communications lead who will manage communications and media relations throughout the incident. The PIO will collaborate with the communications personnel from the lead regulatory agency and associated authorities for media statements or releases as necessary and appropriate. The PIO may manage additional staff to support response operations including functions for community relations and speaker support. The Shelburne Basin Environmental Protection Plan and ERP also provides detailed guidelines on public communication regarding environmental or general impacts and issues arising from any incident. An Information Center may be established near the ICP or an off-site location to manage public information needs. The Information Center will provide a location for effective information management during an incident by having a functional space with adequate communications capability (e.g., phones, computers, internet) and work space to support a potential escalating incident. If necessary, an additional call center may be set up to appropriately manage large call volumes during an incident. An incident website will be set up utilizing PIER system as part of efforts to manage public information and social media. The media will be addressed in the event of a significant oil spill emergency as per the applicable communication procedures described in the Shelburne Basin ERP Common Operating Picture A Common Operating Picture (COP) is Geographical Information System (GIS) technology that provides a single source of data and information for situational awareness, coordination, communication and data archival to support emergency management and response personnel and other stakeholders involved in or affected should an incident occur. A COP integrates and synthesizes various types of information, provides a map interface to all individuals involved in an incident, improves communication and coordination among responders and stakeholders, and provides resource managers with the information necessary to make faster and better informed decisions. It can also provide for different views for different responders stakeholders (e.g., Incident Command, regulators, public), based upon the most current data available. The Situation Unit with support from Shell Geomatics will manage the COP during an incident. Figure 10-1 illustrates COP data integration. The Situation Unit (responsible for coordinating with external agencies for mapping and data verification, QA/QC) ensures a fully validated and correlated operating (maritime) picture between all parties generating maps and materials for operational and external distribution.

68 Unrestricted Stakeholder Engagement Figure 10-1: COP Data Integration A Liaison Officer is responsible for coordination and information management with external stakeholders (e.g., agencies, authorities, environmental groups, and government officials) who have a vested interest and will be expected to provide input into the response process. These stakeholders will expect situation reports throughout the course of an incident and the Liaison Officer will be responsible for coordinating with Situation Unit to receive up to date information. The Shelburne Basin Environmental Protection Plan also provides guidelines on stakeholder communication regarding environmental impacts of any incident, with particular focus on communicating with Commercial and Aboriginal Fisheries representatives as well as Regulatory Agencies. A specific Stakeholder Coordination or Outreach Plan may be developed depending on size and complexity of an incident.

69 Unrestricted 11. FINANCE, CLAIMS AND COMPENSATION Process If a spill occurs, the Finance Section Chief or delegate must activate the emergency response claims management service by contacting the Canada Claims number or the global Risk and Insurance Crisis Management Focal Point (RICM Focal Point). Shell has a global claims management process coordinated through Crawford (see Key Contact Information below for the RICM Focal Point and Alternates). The Canada claims number is the initial number to call for any event where the number of third party claims is expected to be ten (10) or fewer. For an incident that may have more than 10 claims, Crawford must be instructed to establish a dedicated incident claims number. The Finance Section Chief should provide the following information: Provide details of incident to include: o Date and time of the incident o Business and location (country, state / province / territory, and / or city) o Description of incident, parties impacted, and extent of impact to parties impacted Provide contact information for the Finance Section Chief and/or Deputy The RICM Focal Point or Alternate will: Initiate the process to establish a toll-free claims reporting telephone number for the incident Establish a Claims Call Center for to manage claims reporting Provide claims handling, management and reimbursement processes Manage information requests and reporting, including distribution and frequency The Finance Section Chief or Deputy should communicate the telephone number to be utilized to report claims to the Situation Unit. This number should be prominently displayed in the Incident Command Post. The Finance Section Chief or Deputy should coordinate with the RICM Focal Point, Information Officer, Liaison Officer and Legal to determine procedures for publication of the claims reporting telephone number to the general public, if necessary. The Finance Section Chief or Deputy will facilitate establishment of an incident specific Third Party Liability Claims Management Operational Response Plan (ORP) Key Contact Information Canada Claims Number <Redacted> RICM Focal Point <Redacted> Alternates: <Redacted> <Redacted> Head of Claims Team, Risk & Insurance

70 Unrestricted 12. DEMOBILISATION AND TERMINATION OF RESPONSE Demobilisation Once an incident has stabilised and operations are being completed, a decision will be made to commence demobilisation of resources (personnel and equipment) as appropriate. An incident specific demobilisation plan will be developed incorporating guidance from regulatory authorities and the Resource Unit Lead, Operations, Logistics and Legal. The Resource Unit will then coordinate demobilisation of resources in accordance with the approved Demobilisation Plan Return to Normal Operations Depending on the size and complexity of an incident, normal operations may be significantly impacted. As incident response operations are completed, consideration and planning must occur around final activities and authorizations necessary to return to normal operations. As appropriate, a Transition Plan may be developed to outline the agreed upon steps and approvals needed to complete this.

71 Unrestricted 13. PREPAREDNESS OSR Program Management To maintain Shell spill preparedness, the company provides its employees with ongoing training in spill prevention, environmental protection and spill response. Exercises and drills will be conducted to confirm preparedness for responding to incidents and the competency of response team members Training Individual / team training and competencies are integral to their ability to respond effectively to an incident. Emergency response training can take the form of formal classroom training, computer-based training (CBT), on-the-job training, and lessons learned during exercises and drills. This training will be designed and instructed to meet the requirements of the members of the IMT. Shell will: review training requirements for all personnel involved in the operation of a facility; review the contents of the applicable emergency response plan with all appropriate personnel to familiarize them with their duties and responsibilities; and conduct drills to train personnel and ensure responsibilities are understood for carrying out the correct response to an emergency condition Drills Drills are training events that test at least one component of a plan, process or procedure, and are used to maintain a high level of readiness. Exercises are comprehensive training events that involve several of the functional elements of a plan and test communications, coordination, resource availability and response. Additionally, these may involve response partners and regulatory agencies to allow responders to practice their roles and identify opportunities to improve preparedness. Exercises and drills will be scheduled and conducted in accordance with regulatory requirements and / or internal requirements. A multi-year training and exercise plan will be developed and refined yearly to ensure that requirements are met. An example of a typical drill schedule, based upon control framework requirements is shown in Table Table 13-1: Typical Drill Schedule Drill Type Tier 1 Tier 2 Tier 3 Notification 6 months 12 months 12 months Table top 12 months 24 months 36 months Equipment Deployment 12 months 24 months 36 months Country/Multi-country (trans-boundary) N/A N/A 36 months

72 Unrestricted APPENDIX A: CONTACT INFORMATION EMERGENCY RESPONSE PHONE Shelburne Duty Line 24/7 <Redacted> Cell <Redacted> EMERGENCY RESPONSE COORDINATOR Shell Venture HSSE Manager (Halifax) Office <Redacted> INCIDENT COMMANDER Shell Wells Operations Manager (Halifax) Office <Redacted> STENA ICEMAX OIM Phone <Redacted> Shell Representative Phone <Redacted> Scotian Sea Phone <Redacted> Maersk Nexus Phone <Redacted> Skandi Flora Phone <Redacted> OIL SPILL RESPONSE ORGANISATIONS Eastern Canada Response Corporation (ECRC) Phone <Redacted> Oil Spill Response Limited (OSRL) Phone <Redacted> Subsea Well Intervention Services (SWIS) Phone <Redacted> SHELL NATIONAL /INTERNATIONAL CONTACTS Shell Americas Response Team (SART) 24/7 <Redacted> Canada ER Manager (West) Phone <Redacted> Canada ER Manager (East) Phone <Redacted> SHELL INTERNAL CONTACT LIST (not included) AGENCY and EXTERNAL NOTIFICATIONS CNSOPB Canadian Coast Guard Environment Canada

73 Unrestricted APPENDIX B: EXTERNAL REFERENCE LIST The list below is a summary of key external references utilized throughout the OSRP. This list is not exhaustive as additional resources will also become available for use during an incident. These resources are, however, regularly used in training, exercises and incidents and form a basic library of guidance documents that will be available, to the Shell IMT in the immediate first hours following an incident: Shelburne Basin Source Control Contingency Plan Spill Probability Analysis, and the Spill Fate and Behaviour Modelling Report Shelburne Basin Venture Exploratory Drilling EIS (Stantec, 2014) Net Environmental Benefit Analysis Support for the Shelburne Basin Venture Dispersant Preparedness and Operations Plan Incident Management Handbook (IMH), Position Specific Job Aids. Shell Canada National Response Plan SART Activation and Mobilisation Guidance Shell Canada Crisis Management Manual CNSOPB Incident Reporting and Investigation Guidelines (November 30, 2012) Work Instruction - Remote Sensing Oil Spill Tracking Service Documentation Unit Lead Job Aid Vessel SOPEP Stena Icemax SOPEP API Decision Maker s Guide to In-Situ Burning IPIECA Guide to Oiled Shoreline Surveys OSRL Aerial Surveillance Field Guide OSRL Shoreline Operations Field Guide OSRL In-situ Burn Field Guide. IPIECA Guidelines for Oil Spill Waste Minimization and Management IPIECA JIP 17 Decanting Waste Management Plan (Operational Authorization)

74 Unrestricted APPENDIX C: REGULATORY REFERENCE TABLE FEDERAL Canada-Nova Scotia Offshore Petroleum Board Jurisdiction Expertise / Advisory Role All offshore petroleum-related facilities in the waters off Nova Scotia, including pipelines, PFC, subsea systems, petroleum production activities, petroleum development activities. Responsibilities in the areas of: Reservoir management Health, Safety, Environment Construction and design Drilling, diving Geophysical activities Vessel inspection Authority under the Canada - Nova Scotia Offshore Petroleum Resources Accord Implementation Act Sub-section 166(4) to take direct action that is necessary to clean up a spill. Lead agency for regulating activities associated with the exploration, development and production of offshore oil and gas. Lead agency for requesting and following-up on spill information from the polluter. Responsible for the investigation of spill events that emanate from offshore installations while on location. Legislated authority regarding the use of approved STAs for mitigating spills. Legislation, Acts & Regulations Environment Canada (EC) CNSOPB is responsible for the administration of the following Acts, Regulations and Guidelines and related pieces of legislation: Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act NS Offshore Petroleum Drilling & Production Regulations NS Offshore Petroleum Installations Regulations NS Offshore Area Petroleum Diving Regulations NS Offshore Certificate of Fitness Regulations NS Offshore Area Petroleum Geophysical Operations Regulations Canada-NS Oil and Gas Spills and Debris Liability Regulations NS Offshore Petroleum Occupational Health & Safety Requirements Drilling and Production Guidelines Safety Plan Guidelines Environmental Protection Plan Guidelines Offshore Waste Treatment Guidelines Chemical Selection Guidelines for Drilling and Production Activities on Frontier Lands Offshore Physical Environment Guidelines Measurement Guidelines Data Acquisition and Reporting Guidelines Compensation Guidelines Respecting Damage Relating to Offshore Petroleum Activity Atlantic Canada Offshore Petroleum Industry Standard Practice for the Training and Qualifications of Personnel Guideline for the Reporting and Investigation of Incidents Guidelines Respecting Financial Responsibility for Work or Activity in the Newfoundland and Nova Scotia Offshore Areas CAPP Safe Lifting Practices Statement of Canadian Practice with Respect to the Mitigation of Seismic Sound in the Marine Environment Safety/Environmental Notices and Directives Notices to Operators

75 Unrestricted Jurisdiction Responsible for environmental subject areas related to petroleum operations such as: Disposal at sea Air quality (air emission reporting, GHGs, halocarbons) Species at risk, migratory birds Chemical management (substances lists) Wetlands Pollution prevention provisions dealing with the deposit of deleterious substances (under Fisheries Act ) Will advise CNSOPB as soon as possible of the application of federal legislation/regulations in relation to offshore petroleum operations. Expertise / Advisory Role Federal authority for environmental and scientific advice during a marine pollution incident, largely under the regulations of the Canadian Environmental Protection Act (CEPA) and the Fisheries Act. Key aspects of CEPA include the prevention and management of risks posed by toxic and other harmful substances, marine pollution, disposal at sea, interprovincial and international movements of hazardous wastes, environmental emergencies involving CEPAregulated substances, and other sources of pollution not regulated by provincial jurisdictions. Environment Canada has been assigned responsibility for administration and enforcement of the Fisheries Act pollution prevention provisions dealing with the deposit of deleterious substances (including oil) into water frequented by fish. Conducts inspection, monitoring and investigation or may conduct joint program with CNSOPB. May convene the Environmental Emergencies Science Table (the Sciences Table ) (formerly REET), to provide advice to the lead agency. The Science Table brings together relevant experts in the field of environmental protection such as response agencies, all levels of government, Aboriginal representatives, local communities, industries, environmental non-government organizations, and academic institutions. The Science Table develops consensus on protection and clean-up priorities, brings expertise, is able to adapt the scale of response to a particular environmental emergency, and provides a forum for rapidly moving information to minimize damage to human life or health, or the environment, while maximizing the use of limited response resources. Interprovincial transportation of waste and dangerous goods destined for disposal must comply with the requirements of the Interprovincial Movement of Hazardous Waste Regulations under the Canadian Environmental Protection Act (CEPA) and the hazard classifications under the Transportation of Dangerous Goods (TDG) Regulations (see Transport Canada). Legislation, Acts & Regulations EC is responsible for the administration of all or selected parts of the following Acts and Regulations, as well as related regulations, guidelines, and other pieces of legislation: Canadian Environmental Protection Act & Regulations Canada Water Act Disposal at Sea Regulations Environmental Emergency Regulations Environmental Enforcement Act Fisheries Act (pollution prevention provisions) Federal Halocarbon Regulations Species at Risk Act Migratory Birds Convention Act (MBCA) & Regulations Canadian Wildlife Service (directorate within EC) Jurisdiction Administration of the MBCA. There will be an additional responsibility for the federal government under SARA for all listed species at risk under its jurisdiction. The Canada Wildlife

76 Unrestricted Act, also administered by CWS, broadens responsibility providing enabling mechanisms for habitat and all wildlife conservation. Expertise / Advisory Role Responsible for issuing permits for wildlife recovery and care as well as taking over a wildlife response if that initiated by a polluter is determined to be inadequate. CWS has a role in oil spill response in three main areas as outlined within the EC document National Policy on Oiled Birds and Oiled Species at Risk January 2000: 1. Knowing and providing information on the migratory bird resource and species at risk (under CWS jurisdiction) in the area of a spill (this includes damage assessment and restoration planning after the event); 2.Minimizing the damage to birds by deterring unoiled birds from becoming oiled; and, 3.Ensuring the humane treatment of captured migratory birds and species at risk by determining the appropriate response and treatment strategies which may include euthanization or cleaning and rehabilitation. CWS also provides information and advice on marine birds monitoring. CWS also assesses damages caused by oil spills to wildlife and habitats to help determine whether responsible parties should be prosecuted and the costs that they should bear, and conducts studies to determine the status of recovery efforts. In association with this expertise and advisory role, CWS will be consulted in regards to any marine bird monitoring or recovery efforts to ensure appropriate protocols and approaches are proposed and agreed upon. Legislation, Acts & Regulations MBCA Canada Wildlife Act National Energy Board (NEB) Jurisdiction Expertise / Advisory Role Legislation, Acts & Regulations NEB jurisdiction it defined under the Canada Oil and Gas Operations Act and certain provisions of the Canada Petroleum Resources Act. Lead agency for spills that occur at offshore and near shore oil and gas exploration and production facilities on frontier lands. Independent federal agency that reports to the Minister of Natural Resources and regulates international and interprovincial aspects of the oil, gas and electric utility industries. They may be included in the Science Table for expertise in this field. Canada Labour Code, Part II and applicable regulations, including but not limited to the Oil and Gas Occupational Health and Safety Regulations Transport Canada (TC) Jurisdiction Regulatory responsibility for marine safety, including Canada s marine oil spill response regime in the case of spills from ships, but does not have any responsibility to respond to spills from offshore facilities. Responsibilities in the areas of: Marine safety, training and certification Vessel inspection Transportation of dangerous goods Aviation Ballast waters Establishment of Safety Zone Navigable waters protection

77 Unrestricted Expertise / Advisory Role Responsible for the Environmental Prevention and Response National Preparedness Plan and the Canadian Marine Oil Spill Preparedness and Response Regime for safety oversight, pollution prevention, monitoring of compliance with regulations and enforcement action. Conducts investigations of ship-source pollution occurrences aboard polluting vessels, and provides technical expertise about the ship and the ship s on-board activities, which can help mitigate ship-source spills. The Federal Transportation of Dangerous Goods Act (TDG) and Regulations provide a national classification system based on nine hazard types. It is important to note that generally, the classification and shipping requirements of TDG are applied to dangerous goods which are shipped as commercial products (pure products such as bulk fuel) and not as waste. Waste generated as a result of a marine oil spill is generally not classifiable under the regulations. Legislation, Acts & Regulations Fisheries and Oceans Canada TC is responsible for the administration of all or selected parts of the following Acts and Regulations, as well as related regulations, guidelines, and other pieces of legislation: Aeronautics Act Canada Shipping Act Canadian Aviation Regulations Ballast Water Control and Management Regulations Classed Ships Inspection Regulations Collision Regulations Crew Accommodation Regulations Environmental Response Arrangements Regulation Fire and Boat Drills Regulations Fire Detection and Extinguishing Equipment Regulations Life Saving Equipment Regulations Load Line Regulations Marine Occupational Health & Safety Regulations (under the Canada Labour Code) Marine Personnel Regulations Navigation Protection Act Navigation Safety Regulations Pollutant Discharge Reporting Regulations Regulations for the Prevention of Pollution from Ships and for Dangerous Chemicals Response Organizations and Oil Handling Facilities Regulations Safe Working Practices Regulations Safety Management Regulations Ship Station (Radio) Regulations and Technical Regulations Transportation of Dangerous Goods Act Vessel Certificates Regulations VHF Radiotelephone Practices and Procedures Regulations Jurisdiction Lead federal government authority that oversees the management of Canada s fisheries and oceans. Under the fisheries power, the federal government has jurisdiction to regulate not only fish and fisheries, but also fish habitat and the quality of fish-bearing waters, as well as marine plants and marine mammals, such as whales, walruses and seals. Additional responsibilities under the Fisheries Act,which are administered by EC, include pollution prevention provisions dealing with the deposit of deleterious substances (including oil) into water frequented by fish; marine mammals, turtles and fish under the Species at Risk Act, and the Canada Oceans Act. Powers, duties and functions pursuant to Section 678 of the Canada Shipping Act and therefore is the support for the lead response agency, CCG in the case of ship-source pollution spills.

78 Unrestricted Expertise / Advisory Role Legislation, Acts and Regulations As a participant of the Science Table, DFO provides scientific and technical advice respecting the location of critical fisheries resources and their habitat, the timing and location of fishing activities, oceanographic information, support in spill tracking and trajectory modelling, general advice in support of clean-up operations and strategies, the impact of pollutants on sensitive resources, monitoring the potential impact of response strategies, and priorities for environmental protection related to the fisheries. Canada Shipping Act Fisheries Act Species at Risk Act The Canada Oceans Act Marine Mammal Regulations Canadian Coast Guard (CCG) (An operating agency of Fisheries and Oceans Canada) Jurisdiction Mandate to respond to spills from ships (supply and support vessels or rigs/platforms during transit), but not from offshore facilities in Canadian waters (under the CNSOPB). The CCG s Environmental Response (ER) program s mission is to ensure an appropriate level of preparedness and response capability for all ship-source and mystery source pollution incidents in waters under Canadian jurisdiction. ER s specific mission objectives are to: Expertise / Advisory Role Legislation, Acts and Regulations minimize the impact of marine pollution incidents on public safety; minimize the environmental impact of marine pollution incidents; and minimize the economic impact of marine pollution incidents. Lead federal agency for the response component of Canada s Marine Oil Spill Preparedness Response Regime. The Environmental Response program monitors or manages the clean-up efforts for any ship-source or mystery source pollution incident in waters under Canadian jurisdiction, with support from DFO. Responsible for monitoring an oil spill response and of taking over the response if it is seen not to be appropriate or sufficient. Marine Spills Contingency Plan Canada-US Joint Marine Spills Contingency Plan Canada Shipping Act Part 8 Department of National Defence Jurisdiction Expertise / Advisory Role Legislation, Acts and Regulations Government of Canada Provide people, facilities, logistics, naval and airborne support and other resources during a marine pollution incident. The availability of these resources is dependent upon National Defence established priorities and operational requirements National Defence Act Aboriginal Affairs and Northern Development Jurisdiction Expertise / Advisory Role Land, royalty and benefit matters Aboriginal Affairs and Northern Development can provide advice to the CCG regarding pollution incidents near Aboriginal lands regarding land claims agreements, cultural and other issues. They may participate in the Sciences Table, provide expertise in specific areas and/or act as a

79 Unrestricted community liaison to Aboriginal groups. Legislation, Acts and Regulations First National Land Management Act Natural Resources Canada Jurisdiction Expertise / Advisory Role Legislation, Acts and Regulations In the case of a spill in an offshore area under joint federal/provincial management, the Chief Conservation Officer must first consult with the federal Minister of Natural Resources and the minister s provincial counterpart, and the Minister of Natural Resources must consult with the Minister of the Environment. Work together with the CNSOPB to review roles and responsibilities related to the response to a major oil spill. Review will take into consideration the legal authority, mandate, and available resources of each organization, and identify gaps, while acknowledging the primary role of the operator in spill response. In addition, Natural Resources Canada commits to hosting an annual simulation exercise with its partners. Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act Canada Oil and Gas Operations Act Canada Petroleum Resources Act Canada-Nova Scotia Oil and Gas Spills and Debris Liability Regulations Nova Scotia Offshore Area Petroleum Diving Regulations Nova Scotia Offshore Area Petroleum Geophysical Operations Regulations Nova Scotia Offshore Petroleum Drilling and Production Regulations Public Safety Canada Jurisdiction Expertise / Advisory Role Legislation, Acts and Regulations Government of Canada Responsible for the Federal ERP and can provide support for a large-scale incident requiring additional coordination of federal resources to support CCG s role of lead federal agency. Federal Emergency Response Plan

80 Unrestricted PROVINCIAL Nova Scotia Environment Jurisdiction Lead agency under the Nova Scotia Environment Act Expertise / Advisory Role Legislation, Acts & Regulations Lead agency for regulatory activities involving the onshore storage, treatment, or disposal of oily waste. In addition, expertise and advisory capacity regarding the following subjects, which may be affected by spills and / or clean-up activities. Air Quality Wetlands Environment Act (Nova Scotia) and applicable regulations and guidelines including, but not limited to: Activities Designation Regulations (Water Approvals) Air Quality Regulations Dangerous Goods Management Regulations Emergency Spill Regulations Environmental Assessment Regulations Greenhouse Gas Emissions Regulations Solid Waste-Resource Management Regulations Sulphide Bearing Material Disposal Regulations Used Oil Regulations Nova Scotia Wetland Conservation Policy Nova Scotia Labour & Advanced Education Jurisdiction Expertise / Advisory Role Legislation, Acts & Regulations Safe and healthy workplaces, and work practices, and safety standards protecting the general public. Onshore Occupational Health & Safety Occupational Health & Safety Act (Nova Scotia) and applicable regulations including, but not limited to: Occupational Health and Safety First Aid Regulations Occupational Safety General Regulations Workplace Hazardous Materials Information System Regulations Nova Scotia Technical Safety Act (Nova Scotia)

81 Unrestricted APPENDIX D: EMERGENCY RESPONSE DOCUMENTATION SCHEMATIC Global HSSE&SP Control Framework Shelburne Basin Emergency Management Schematic Shell Americas Emergency Management Shell Americas Emergency Management NRT/SART Training & Exercise Strategy May 2015 Shell Canad a Shell Canada Crisis Management Plan Shell Canada Core Emergency Response Plan Shell Canada National Response Plan Nova Scotia - Shelburne Basin Emergency Response Plan ***OA 15 Contractor ER Plans Medical Emergency Response Plan ***OA 15 Security Plan Oil Spill Response Plan ***OA 19i Shorebase / Facility ER Plan Canadian Helicopters HNZ Stena Vessel ERP Cap & Contain ***OA 19H Subsea Dispersant ***OA 19H Source Control Contingency Plan Relief Well ***OA 19J NEBA Vessel / Stena SOPEP Shorebase / Air Base OSR Plan Dispersant Operations Shoreline Cleanup Assessment Environmental Effects Monitoring Sampling Plan Waste Management Wildlife Response Decanting Decontamination

82 Unrestricted APPENDIX E: IMT ROLES AND RESPONSIBILITIES POSITION Incident Commander Liaison Officer Information Officer Safety Officer Legal Officer RESPONSIBILITIES Fill in Spill Report Form Assemble Spill Response Team - Brief team - Assign duties (org. chart) - Remind team to keep logs Establish objectives (chart) Name Incident Determine response strategies Conduct air surveillance Establish meeting times (chart) Notify agencies (chart) Status of incident, facility, and personnel Evaluate level of response required and activate IMT support as required Conduct internal / external notifications as required Authorize the use of response resources Participate in Incident Command briefings Notify / call CNSOPB Notify appropriate state agencies Notify federal agencies Request safety zones air / water Request Notice to Mariners Prepare written reports to agencies Notify corporate executives Notify partners Notify company personnel Prepare for media interest Keep the public informed Set up Information Center Coordinate media efforts through an Information Center Coordinate efforts with CNSOPB Identify community concerns Evaluate / monitor hazards Notify offset operators Obtain MSDS / Prepare Site Safety Plan Conduct air monitoring as may be needed Establish initial site safety plan Ensure regulatory compliance Investigate safety related accidents and report to Incident Commander Conduct safety inspections Advise the IC on legal issues associated with response operations Establish documentation guidelines; review of press releases / contracts Advise IMT Sections when requested Participate in incident investigations and damage assessments Participate in ICS meetings and other meetings as requested

83 Unrestricted Operations Section Chief Logistics Section Chief Direct surveillance operations Mobilize Response Contractors as needed and other equipment that is deemed necessary to response efforts by the UC. - Equipment / operators / supervisors - Take air monitoring equipment - Obtain samples of spilled material - Prepare shoreline for impact (pre-clean) - Contact ECRC / OSRL - Spray / Spotter aircraft and personnel - Vessel for SMART Team - Prepare for in-situ burn operations Consider night time spill tracking Establish Section Branch / Groups (e.g., Wildlife, Source Control) Commence source control operations, mobilize specialist Contact wildlife specialist for information Activate resources for wildlife protection Locate utility / crew boats, helicopters Prepare Air Operations Plan Set up decontamination stations Identify / set up staging areas Ensure temporary storage-recovered oil capacity Request mechanics / parts trailers Prepare medical plan, source EMTs Prepare communications plan (ICS 205) Obtain security at ICP / staging areas Establish services Housing Catering Parts trailers / mechanics Fueling facilities Planning Section Chief Finance Section Chief Activate Subject Matter Experts / Contractors Request trajectories Prepare approved STA / in situ burning request form Submit approved STA use request to CNSOPB Show approved STA application timeline Update with weather forecasts / surveillance Submit in situ Burn request to CNSOPB Post / Update charts in ICP Commence sampling operations Determine Sensitive Areas and Resources at Risk Call out technical specialists as needed Coordinate IAP development Set up secured filing system Develop Waste Management Plan Obtain CNSOPB approval for decanting Issue WBS Element Implement process to handle claims and insurance issues Review contracts with Logistics / vendors

84 Unrestrcited APPENDIX F: FORMS Incident Name: Incident Date: Prepared by (name): Prepared Date: Prepared Time: Alert Level 1 Level 2 Level 3 The ERCB/OGC must be notified to confirm the Emergency Level MAP / SKETCH And/or attach marked up ERP Map Include sketch showing the area of operations, the incident site/area, hazard zones, landmarks, impacted residences or other graphics depicting situation and response status INCIDENT SUMMARY ICS 201 Page 1 of 5

85 Unrestrcited Summary of Current Actions Priorities (P E A R ) 1. People (Workers, responders and public nearby, downwind and in rest of EPZ) Workers/ Responder Priority Priority Public Protection 2. Environment 3. Asset Integrity 4. Reputation OBJECTIVES (Non-prioritized) Current Actions Planned Actions Incident Potential Limitations and Constraints ICS 201 Page 2 of 5

86 Unrestrcited Current Organization (Example) INCIDENT COMMANDER Legend 1 White Vest Bold Thick Border Boxes = primary ICS functions to be assigned White Vest SAFETY OFFICER Solid connect lines = represent organizational authority Dotted connect lines = communications/support information White Vest DEPUTY IC White Vest LIAISON OFFICER Note: It is not mandatory to assign all positions. Assign positions only as necessary. Some positions may not require activation depending on the actual emergency. PUBLIC INFORMATION OFFICER OPERATIONS SECTION CHIEF PLANNING SECTION CHIEF LOGISTICS SECTION CHIEF FINANCE/ADMIN SECTION CHIEF Red Vest Blue Vest Orange Vest Green Vest White Vest STAGING AREA MANAGER DOCUMENTATION UNIT SITUATION UNIT Add Title Add Title Single Resources Add Title (eg. Helicopter) Add Title ENVIRONMENTAL UNIT RESOURCES UNIT Add Title Add Title Add Title Add Title Add Title SOURCE CONTROL GROUP SUPERVISOR Add Title Add Title Add Title Add Title Add Title Add Title Add Title Add Title ICS 201 Page 3 of 5

87 Unrestrcited Resource Type (Equipment/People) Description Total Quantity Available Out ICS 201 Page 4 of 5

88 Unrestrcited DESCRIPTION OF INCIDENT: Location: Additional Incident Information (Optional) What Happened: Fire Explosion Spill Medical Other Comments: WEATHER: Wind Speed: Wind Direction (winds from): Temperature: Precipitation (rain, snow, etc.): Sunrise: Sunset: IMPACTS: People Environment / Land / Water o Property o Sensitive Areas Impacted or Threatened? Location? Incident Will Require Additional Resources (e.g., contractors, mutual aid) Incident Will Likely Generate Significant Public Affairs/Community Relations Issues Explain: SAFETY CONSIDERATIONS: refer to Site Safety Plan (ICS 208) Injuries/Casualties/Unaccounted Oil Hazards Physical Hazards Other ( PPE / Equipment or Training / Competency) Explain: ICS 201 Page 5 of 5

89 Unrestrcited APPENDIX G: SHELL SPILL RESPONSE DEDICATED EQUIPMENT INVENTORY Name Description Details Operations Standby Vessel Offshore containment and recovery package Dispersant Application System 200 m Offshore side sweep system boom, Offshore skimmer 20 m³ inflatable storage barge, daughter craft Dispersant spray unit 4 m³ type 2 / 3 approved STA Sorbent pads Surveillance Assisted Natural Dispersion Containment & Recovery Dispersant delivery Vessel Crew Trained in oil spill response operations 200 m Offshore boom Support Vessel 1 Support Vessel 2 Offshore containment and recovery package Dispersant Application System Offshore skimmer 20 m³ inflatable storage barge Dispersant spray unit 4 m³ type 2 / 3 approved STA Sorbent pads Surveillance Assisted Natural Dispersion Containment & Recovery Dispersant delivery Vessel Crew Trained in oil spill response operations Vessel of Opportunity May be tasked in support of OSR activity as required. Aerial platform Canadian Helicopters Helicopters with trained crew / personnel in Oil Spill Observation and monitoring Aerial Surveillance and Monitoring Aerial Dispersant Application Support

90 Unrestrcited APPENDIX H: ECRC BACKGROUND INFORMATION

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95 Unrestrcited APPENDIX I: ECRC SPILL RESPONSE EQUIPMENT INVENTORY ECRC Equipment List ATL: Atlantic Region QUE: Quebec GL: Great Lakes Item Application and Description Available ATL QUE GL BOATS Boston Whalers ft Inflatables ft Patrol Boat 49 ft Patrol Boats ft Rigid Hull Inflatables Seatrucks ft Versatile platform for response operations. Used for towing, setting boom, transportation, and general duties near shore water operations. Fiberglass, unsinkable boat with unique Boston Whaler hull design offers exceptional seaworthiness. Outfitted with twin outboard motors (90 hp to 100 hp) providing power for towing and manoeuvrability. Various uses as a workboat, such as: surveillance, boom maintenance or transportation. Suitable for use in near shore environments. Inflatable boats with a fabric, air filled flotation collar that makes up the bow and sides (gunnels) of the boat. The flotation collar supplies buoyancy (with reserve), stability, and absorbs wave energy to soften the ride in rough conditions. Equipped with outboard motor and either a centre steering console or tiller control. Used to assist in boom deployment and towing operations, for transportation of equipment and responders and as a support vessel for surveillance and safety activities. Can be used in unsheltered water. Built of aluminium and equipped with two 350 hp diesel engines. Carries a crew of six. Open flat deck provides a working area of 28 m 2 (300 ft 2 ) at the rear of the vessel. Used to assist in boom deployment and towing operations, for transportation of equipment and responders and as a support vessel for surveillance and safety activities. Built of aluminium and equipped with outboard gasoline motors, 115 hp or 135 hp. Inflatable boats provide versatility in response operations for both transportation and active duty in sheltered water operations. Rigid hull inflatable boats equipped with outboard motor (15 hp to 70 hp); molded fibreglass, plastic or metal hulls (including floor) with a fabric air filled flotation collar that makes up the bow and sides of the boat. The rigid hull provides stability for operation of the boat in most sea conditions. The flotation collar supplies buoyancy (with reserve), stability and absorbs wave energy to soften the ride in rough conditions. Used mainly for deployment of boom in sheltered water or close to shoreline and for skimming operation. Also used for transportation of personnel and equipment during shoreline cleanup operations. Having a shallow draft, they permit access to almost any shoreline. Units are road transportable, each unit

96 Unrestrcited Item Small Boats ft BOOMS Kepner Boom Application and Description having a dedicated trailer. Description - Built of aluminium, the vessels vary in size from 30 ft x 10 ft to 36 ft x 12 ft. They are equipped with two outboard motors (135 hp to 200 hp). These boats are primarily used for spill observation, transporting equipment, small material and personnel, for tending shoreline skimming and for shoreline treatment operations. For stability purposes these boats are typically flat bottom with slanted square bow, unsinkable, filled with polyfoam at bow and under the seat. Oil containment boom suitable for shoreline, sheltered and open water usage. Can be deployed from a dock, from shore or from a vessel. Mounted on a deployment reel, the boom self-inflates as it comes off the reel, allowing quick deployment. Self-inflating, selfcompacting reel able boom constructed of heavy-duty polyurethane-coated polyester fabric. Each reel contains three sections of 150 m each (500 ft), for a total of 450 m (1,500 ft) per reel. Available ATL QUE GL Lamor Autoboom Oil containment boom suitable for shoreline, sheltered and open water usage. Can be deployed from a dock, from shore or from a vessel. Mounted on a dedicated trailer, the boom can be sent on scene quickly. Single point air inflatable boom constructed of heavy-duty urethane-coated polyester fabric. Each reel contains 250 m (825 ft) of boom. 1 (250 m) 1 0 RO Boom 1500 Oil containment boom for offshore applications. Synthetic, woven fabric and oil resistant rubber, fitted with galvanized ballast chain and stainless steel connectors. 500 m 0 0 Vikoma Boom Oil containment boom for offshore applications. Single point inflation, oil resistant rubber, fitted with galvanized ballast chain and ASTM connectors m m Shore Seal Boom Mainly used in area where there is tidal effect, it provides seal to the bottom when the tide goes out. It joins to conventional booms in deeper water. Useful when doing shoreline cleaning, using water flooding method. Uses two water-filled lower chambers for ballast and stability. The top chamber is air inflated for buoyancy. It is made of a rugged urethane coated fabric for maximum abrasion and puncture resistance Solid Flotation Boom Oil containment boom suitable for shoreline and sheltered water. It is stored in trailers, containers and on deck of seatrucks and pontoons. General purpose boom with a solid flotation core and made of polyurethane-coated polyester fabric. 16, ,76 2 7,9 70 Zoom Boom Oil containment boom suitable for shoreline and sheltered water. It is stored in racks. General purpose self-inflating containment boom. Design allows for compact storage and very rapid deployment

97 Unrestrcited Item BOOM SWEEP SYSTEMS Application and Description Available ATL QUE GL NOFI Sweep Systems NOFI Buster COMMUNICATION Field Operations Centre Mobile Unit Base Station The NOFI Sweep System is a wide-swath oil containment system suitable for use in unsheltered waters. The sweep system is deployed from a vessel or large recovery barge, used as the platform for the operation of the skimmer and for storage of recovered liquid. A second vessel is required to pull the lead arm of the sweep. The system is comprised of two boom sections: 1) the v-shaped boom section that provides an oil collection point; and, 2) the guide boom section that deflects oil into the v-section. The NOFI system utilizes a cross bridle line and a trawl net in the v-section to control the shape of the sweep. The small area created by the v-section, results in a thicker layer of oil accumulating at the apex. The NOFI 600 is single container system that can be deployed from offshore support vessels, barges or tugs. The NOFI 1000 is designed as a two-container system that must be deployed from offshore support vessels that are large enough to accommodate 20 ISO containers. The NOFI Harbour/Current/Ocean Busters are unique products for containing and recovering oil, with increased skimming efficiency due to low oil-layer turbulence in the separator at the end of the system. They can be operated in sheltered as well as unsheltered water. They are capable of containing and collecting oil at towing speeds up to 3.0 knots 4 knots. These units can be deployed from a dock, a floating platform or the deck of a service tug. Two vessels are required to tow a unit. The NOFI Current Buster is also expected to be well suited for fast running rivers and in narrow, high current straits. Consists of a Front Sweep guiding or herding oil into the combined Collector / Skimming device and then into the Separator Tank from where the oil is recovered by a simple pump or a conventional skimmer. In addition to containing oil in high towing speeds (and / or currents), it also separates the oil from the water and positively controls the oil for uncomplicated and highly efficient oil recovery replacing the need for conventional skimmers (by applying pumps instead). Used as a temporary Field Operations Centre / Communications Centre, equipped with communication equipment, including an 800 MHz repeater and mast antenna. Also utilised as a field division office deployed at/near the spill site. Fifth wheel trailer or motor home modified to support Spill Management Team. Units are equipped with heating / air conditioning units. This type of unit is used to enhance the coverage area given its transmitting power is stronger than a typical handheld (portable) unit. It is utilized as a mobile unit (in truck, boats or field operation centre) or as a base station in the management centre. The MOTOTRBO XPR 4580 is a digital mobile radio that operates

98 Unrestrcited Item Portable Radio Repeaters FLEXIBLE STORAGE Barges Application and Description in the UHF-800MHz frequency range. The radios have a number of operating channels to provide for greater flexibility when establishing a communication network with a lot of different teams. The radios can be used in a simplex mode (radio to radio) or through a repeater system. Dedicated transportation cases, meeting air transportation specifications, are available for the transportation of radios. The portable radio is a main communication tool for ECRC, both in the field and within operational management. These radios are intrinsically safe and can be used in all environments. Response Centres maintain an inventory of radios that may be cascaded to any region and operated without having to be reprogrammed. The Motorola MOTOTRBO XPR 6580 IS digital portable radio operates in the UHF-800MHz frequency range. The radios have a number of operating channels to provide for greater flexibility when stablishing a communication network with a lot of different teams. The radios can be used in a simplex mode (radio to radio) or through a repeater system. Dedicated transportation cases, meeting air transportation specifications, are available for the transportation of radios. The 800 MHz radio repeater units are used to expand the operating range of portable and mobile radios unit. Repeaters simultaneously receive and then retransmit a radio signal at a much higher power. ECRC has the ability to cascade 6 repeaters to a spill site to create a larger area of radio coverage. The Repeater units are paired with the Dispatch Station to provide full monitoring and control of all radio assets. The Dispatch Station utilizes two mobile radios connected to a laptop computer running TRBOnet software. The TRBOnet software provides a map display showing the location of each radio unit. The Repeater unit are housed in weatherproof enclosures allowing them to be set up in remote areas. The MOTOTRBO XPR MHz repeater operates on one of four sets of dedicated ECRC frequencies. These units can also be configured to create a trunked radio system with fleeting and sub-fleeting capabilities to satisfy major communications requirements. Dedicated transportation cases, meeting air transportation specifications, are available for the transportation of repeaters. Flexible temporary oil storage container capable of being towed or moored. Zodiac style inflation chambers provide buoyancy and shape of the tank. A pocket shaped expandable tank hanging below the water level provides the storage capacity. The boat shape bow allows easy towing operation whether empty or loaded to 36 ft x 12 ft. Made from Hypalon outer and neoprene inner fabric. Available ATL QUE GL

99 Unrestrcited Item Floating Tanks Unitor Bag MISC. EQUIPMENT Cleanfire Incinerator Gas Detection Equipment Oil Slick Tracking Devices PUMPS Air Pumps Desmi Dop 160 Application and Description Flexible temporary oil storage container capable of being towed or moored. Can also be used for temporary oil storage on land. The RO tank comprises a main chamber for storage of oil or other liquids. It is supplied with a pillow float air chamber for additional buoyancy. A bolted on cross bar closes the tanks ends so that it can be opened for cleaning. Flexible temporary oil storage container capable of being towed or moored. Made of an oil and salt water resistant fabric with a tear shaped front and stern section. A nose cone houses the towing arrangement, as well as the connection for filling / discharge. Portable incinerator used for burning oiled debris and rubbish. Consists of a double wall, forced air combustion chamber with an external (diesel driven) high-volume air blower. The unit is capable of holding 2.5 m 3 of debris at a time and will incinerate up to one ton of debris per hour. The exterior walls of the incinerator are kept cool by the combustion air blowing between the walls before it is deflected down into the combustion chamber. The unit can measure LEL and concentration of O 2, CO and H 2 S. It is also used during spill response operation to assess air quality where responders will have to work. Also used to assess environment before confined space entry or hot work. A rugged gas detector equipped with four cells. Can be used with different accessories: air pump, remote alarm, visual alarm, etc. Oil slick tracking devices providing valuable information about the extent, speed and direction of oil slick movement. When deployed, each buoy can be tracked using a receiver. Once the receiver locates the buoy s position, it can then be plotted and its speed and drift trajectory calculated. The tracker system consists of three radio frequency transmitter buoys that are weighted and profiled to drift with the oil. Suitable for the recovery and transfer of oil, water and oily water mixture. It can also be used during shoreline treatment operations requiring water washing. Air driven pumps, equipped with camlock connections. A submersible cargo offloading pump system, designed to pump high viscosity products (0 cst to > 1,000,000 cst). The system is used for transferring product from temporary storage devices or can be deployed directly into areas where large volumes of oil may be collected for recovery. The Desmi DOP-160 system is a modified design of the traditional Archimedes screw pump. Unlike traditional Archimedes screw pumps, the DOP-160 is self-feeding. Fluid is forced into the pump housing by the rotation of the screw. This self-feeding feature combined with the benefits of screw pump Available ATL QUE GL

100 Unrestrcited Item Desmi Dop 250 Peristaltic Pumps Salaroll Pump Small Size Pumps Application and Description design enables the DOP-160 to operate as an effective offloading and transfer pump for products with higher viscosity ratings. The unit can be run with hot water injection on the inlet and / or outlet side of the pump. This lubricates the pump and / or product hose in order to handle the most viscous products. A submersible cargo offloading pump system, designed to pump high viscosity products (0 cst to > 1,000,000 cst). The system is used for transferring product from temporary storage devices or can be deployed directly into areas where large volumes of oil may be collected for recovery. The Desmi DOP-250 system is a modified design of the traditional Archimedes screw pump. Unlike traditional Archimedes screw pumps, the DOP-250 is selffeeding. Fluid is forced into the pump housing by the rotation of the screw. This self-feeding feature combined with the benefits of screw pump design enables the DOP-250 to operate as an effective offloading and transfer pump for products with higher viscosity ratings. Suitable for the recovery and transfer of oil, water and oily water mixture, including viscous mixture. Can also be used during shoreline treatment operation (e.g., water washing or flushing). Gasoline driven pumps, equipped with camlock connection. Suitable for the recovery and transfer of oil, water and oily water mixture, including viscous and debris (up to 1.5 inch) laden mixtures. Hydraulic driven pumps, equipped with camlock connection. Suitable for the recovery and transfer of oil, water and oily water mixture. Can also be used during shoreline treatment operations requiring water washing. Gasoline or diesel driven pumps, equipped with camlock connection. Inlet / outlet connections varying in size from 4 inch to 1.5 inch. Available ATL QUE GL SHORELINE CLEANUP Bird Hazing Devices Decontamination Unit Bird scaring devices are used to help move birds away from oiled areas to reduce the risk of contamination to the birds. The bird scaring devices all use sound as the deterrent mechanism. The sounds are generated by electronic speakers, controlled gas explosion, and 6 mm pistol blanks and whizzers. The range and effectiveness varies with each device. The electronic devices use a random sequence of sounds to reduce the habituation of the birds to the sounds. Each of the devices is designed to be operated on land or on a boat. The Breco Buoy is also a free floating unit designed to drift with an oil slick. The decontamination unit is utilized for the cleaning of personnel and equipment during spill responses. It provides for the removal, storage and potential cleaning/reuse of personal protective equipment and tools. It is the point of entry/departure to and from the spill site by shoreline workers. The unit consists of one 45-ft

101 Unrestrcited Item High Pressure Washing Unit Shoreline Deck Barge Smart Ash Burner Sorbents Tent-Shelter SKIMMERS Application and Description van trailer, four tents, wash trays, sorbents, deck matting, storage drums and porter tanks. It is set up near or adjacent to the spill site as a component of the field camp. Trailer is to be moved to other regions when needed. Portable high pressure washing unit, providing cold or warm water or steam. Can be used during shoreline cleanup operations to clean man-made structures. Can be transported by road or on a seatruck to access remote shoreline areas. Mounted on a trailer, the unit is equipped with a diesel heater, diesel pump, a 500 gallon reservoir for the water and two high pressure pistols. Used as a working platform during shoreline and dock face cleanup operations. Can be used to store equipment and material on deck. Built in steel or heavy-grade aluminium to allow usage at close proximity of shoreline and in tidal zone areas. Used to burn oiled debris recovered in remote access areas. An electrical blower is installed on a steel barrel, providing oxygen inside the barrel to ensure a clean burn. Sorbents are used for several tasks such as recovery of oil on the surface of water, the reduction of the secondary contamination by workers by protecting the operating areas, the cleaning of the rocks and other structures soiled by oils. The principal uses, according to the type of absorbing product, are: Pads: recovery of oils on the surface of water, on the shore and for the cleaning of solid surfaces Rolls: protection of the ground under the equipment (portable pumps, tanks) to prevent any contamination at the time of the operations Boom: to contain and recover oil on the surface of water in the places with weak current Pom-Poms: recovery of oils with high viscosity (heavy fuel oil, the crude cold water oil) Mat: protection of the operating areas to prevent any secondary contamination. Made from 100% spun blown melted polypropylene, the sorbents retained are selective to hydrocarbons, absorb only the liquids based on oils, will not absorb water, water-based or water-soluble fluids and float indefinitely on water, even when saturated with oil. They can be incinerated and will generate only 0.02% of ashes. They are available in various formats (pads, rolls, booms, pompom, mat) and selected according to their intended application. Tents are used for many purposes. For example, equipment storage, communications centres, food and rest shelter for workers in decontamination centres for workers. They consist of a metal frame attached to two plastic pivots. Onto this structure, a poly mesh shell, fire retardant, UV rated, is fastened and the protection unit is complete. Units are stored pre-assembled. When folded, they can be transported on the back of a half-ton truck. Two people can erect a unit in about 10 minutes. They can be used at any time of the year. Available ATL QUE GL Full invent ory

102 Unrestrcited Item Axiom Belt Skimmer Disc Skimmers Elastec Skimmer GT Skimmers Lamor LRB 40 Libra Belt Skimmer Application and Description Suitable for the recovery of heavy oils and emulsions and sheltered marine environments. Can be deployed from shoreline, seatruck or recovery barge. Heavy oil belt skimmer on marine grade aluminium frame with stainless steel hardware. Portable and versatile for use on a variety of platforms. Hydraulically driven by an external power pack utilized in conjunction with an Archimedes screw pump as the transfer mechanism. Suitable for the recovery of light to medium viscosity oil. Suitable for shoreline and sheltered use. Can be deployed from shoreline, dock or small boat. An oleophilic disc skimmer, equipped with a diaphragm pump installed in the middle section, or using an external pumping mechanism. Hydraulically driven by an external power pack. The RPM of the disc is adjusted according to the viscosity of the oil in order to minimize water pickup. Suitable for the recovery of light to high viscosity oil, but most useful in heavy oil recovery. Suitable for shoreline and sheltered water usage. Can be deployed from shoreline, vessel or recovery barge. And oleophilic drum skimmer, built of aluminium frame and moulded polyethylene drums. The oil is picked off the water by the rotating drum and scraped off into a sump. The 188G features a grooved drum providing improved recovery rate. An integrated or external pump moves the recovered oil to an external storage unit. Suitable for the recovery of light too high viscosity oil. Suitable for shoreline, sheltered and open water usage. Can be deployed from shoreline, dock, vessel of opportunity or recovery barge. Used in conjunction with the NOFI sweep system from a large recovery barge. A weir skimmer, equipped with an Archimedean screw pump, installed in the middle section. Hydraulically driven by an external power pack. The height of the weir is adjusted by varying the pumping rate to maximize the recovery of product with a minimum quantity of water. Suitable for the recovery of light to high viscosity oil. Suitable for shoreline and on water usage. Suitable for use where debris is present or in broken ice conditions. Can be deployed from an excavator on a shoreline or by crane on a vessel or recovery barge. An oleophilic brush wheel capable of operating in both directions depending on the type of oil. The oil is picked off the water by the rotating brushes and scraped off into a sump. An external pump moves the recovered oil to an external storage unit. Suitable for the recovery of medium to heavy oils from shoreline and in sheltered marine environments. Can be deployed from shoreline, dock, seatruck or recovery barge. An oleophilic skimmer, using a porous belt allowing water decanting. Three different types of belt can be used depending on the viscosity of the product to be recovered. Two small propellers, located underneath the front of the belt, pull oil toward the belt when the unit is not advancing on the water. Available ATL QUE GL

103 Unrestrcited Item Lori Brush Skimmers Minimax 60 W Brush Skimmer Desmi-Helix 160 Oil Mop Skimmers Pedco Skimmer SOLID BARGES Application and Description Suitable for the recovery of medium to high viscosity oil. Suitable for shoreline, sheltered and open water usage. Depending on model, can be deployed from shoreline, dock, vessel and recovery barge. Suitable to be used in cold water. An oleophilic skimmer, equipped with brushes mounted on a rotating chain. Oil is scraped off as the bristles pass through a comb-type cleaner located at the top. Units have 2 to 6 brushes. Suitable for the recovery of light to high viscosity oil. Suitable for shoreline and sheltered water usage. Can be deployed from shoreline, vessel or recovery barge. An oleophilic brush wheel, built of fiberglass with aluminium reinforcing. The oil is picked off the water by the rotating bristles in scraped off into a sump. An external pump moves the recovered oil to external storage units. Suitable for the recovery of light to high viscosity oils. Suitable for shoreline, sheltered and open water usage. Can be deployed from the shoreline, dock and vessel of opportunity or recovery barge and may be used in conjunction with the NOFI buster system. Equipped with a circular set of hydraulically driven brushes enabling the brushes to grab the oil from any side of the skimmer and pull it into the pump. The HELIX brush set enables the skimmer to operate at high pickup rates even with the heaviest oils with very little water content. Suitable for the recovery of medium viscosity oils. Can also be used with light and heavy oils with acceptable results, depending of conditions. Suitable for shoreline and shallow water. Can also be used in the presence of ice and debris. This oleophilic skimmer is composed of an endless rope mop, a pulley and an electric roller wringer. The rope mop is pulled through the oil slick and returned through the roller where the oil is extracted and collected in a 45-gallon drum. Suitable for the recovery of light to heavy oil. Suitable for shoreline and shallow water. A weir skimmer. The depth of the weir is adjusted by controlling the pumping rate of the pump. The recovery rate is dependant of the pumping capacity of the pump connected to it. Available ATL QUE GL Ton Storage Barge Barge Petite Basques Used to store recovered liquid and solid materials during on-water recovery or shoreline cleanup operations. Can be used as a platform to support shoreline cleanup operations. Some units, mounted with a power pack and Hiab crane, are equipped with a skimmer unit. All units are road-transportable. Built in aluminium, the barges have eight compartments, for a total storage capacity of 50 m³. Units in Québec region are equipped with pontoons, giving a working area of 6 m x 12 m (20 ft x 40 ft). The barge Petite Basque is specially designed for the transportation and deployment of the Ocean Buster and other dynamic sweep systems. It can also be used as a working

104 Unrestrcited Item Barge Dover Light Barge ECRC 200 Barge John P Oxley Barge Orleans Application and Description platform for recovery operations using a NOFI Vee sweep system in conjunction with a GT-185 skimmer. It can also serve as a simple deck working platform to carry material and equipment, supporting shoreline cleanup operations. It is equipped with 225 kw generators able to power the lighting system and the anchor winch. Ballast compartments allow the barge to operate in various sea states and to be inclined by the stern to facilitate deployment of sweep systems through an inclined ramp. Used as a primary and / or secondary storage unit during or recovery operation. It can also be used as a working platform for recovery operations using NOFI Vee Sweep boom in conjunction with a GT-185 skimmer. It can also serve as a simple deck working platform to carry material and equipment, supporting shoreline cleanup operations. The Dover Light is a single-hull steel barge. It has four storage compartments for the oily water, allowing for natural decanting of water, with a total storage capacity of 1600 m³. Two compartments are equipped with heating coils. It is a dedicated response vessel fitted with one diesel generator, one crane, one winch, one anchoring system, two cargo pumps and one cargo heating system. Used as a primary and / or secondary storage unit during all recovery operations. It can also be used as a working platform for recovery operations using a NOFI Vee Sweep system in conjunction with a GT-185 skimmer. It can also serve as a simple deck working platform to carry material and equipment, supporting shoreline cleanup operations. The ECRC 200 is a single-hull steel barge. It has eight storage compartments for the oily water, allowing for natural decanting of water, with a total storage capacity of 1900 m³. It is a dedicated response vessel fitted with one diesel generator, one crane, and anchor system, and a mid-ship tugger winch. The barge is mounted for sweep and recovery operation using a NOFI Vee Sweep and a GT-185 skimmer. Used as a primary and / or secondary storage unit during oil recovery operation. It can also be used as a working platform for the recovery operations using a NOFI Vee Sweep system in conjunction with a GT-185 skimmer. It can also serve as a simple deck working platform to carry material and equipment, supporting shoreline cleanup operations. The John P. Oxley is a double- hull steel barge, built in It has eight storage compartments for the oily water, allowing for natural decanting of water, with a total storage capacity of 2,000 m 3. It is a dedicated response vessel fitted with two diesel generators, one crane, a bilge/ballast system, an anchor system, and a deck winch (for NOFI 600 cross-bridle). The barge is configured for sweep and recovery operation using a NOFI Vee Sweep and GT-185 skimmer. Used as a primary and/or secondary storage unit during oil recovery operation. It can also be used as a working platform for recovery operations using a NOFI Vee Sweep system, in Available ATL QUE GL

105 Unrestrcited Item Barge SMTB 7 TRAILERS Application and Description conjunction with a GT-185 skimmer. It can also serve as a simple deck working platform to carry material and equipment, supporting shoreline cleanup operations. The Orleans is a singlehull steel barge. It has eight storage compartments for the oily water, allowing for natural decanting of water, with a total storage capacity of 2,100 m 3. It also has fore and afterward trim compartments. It is a dedicated response vessel fitted with two diesel generators, one crane and a deck winch (for NOFI 600 cross-bridle). The barge is configured for sweep and recovery operation using a NOFI Vee Sweep and GT-185 skimmer. Used as a primary and-or secondary storage unit during or recovery operations. It can also be used as a working platform for recovery operation using a Vikoma boom sweep in conjunction with a GT-185 skimmer. It can also serve as a simple deck working platform to carry material and equipment, supporting shoreline cleanup operations. The SMBT 7 is a singlehull steel barge. It has three storage compartments for the oily water, allowing for natural decanting of water, with a total storage capacity of 1200 m³. It is a dedicated response vessel fitted with one diesel generator, one crane and three cargo pumps. The barge is configured for sweep and recovery operation using a Vikoma boom and GT-185 skimmer. Available ATL QUE GL Boat-Barge Trailers Response Trailers Small Trailers Used for the transportation of seatrucks and 50-ton barges. Each vessel has its own dedicated trailer. Can also be used to transport other spill response equipment. Fifth wheel trailer, constructed of galvanized steel. Designed to be backed down ramps to allow boat launch and retrieval. Quick deployment trailer, containing response equipment to start shoreline cleanup operations or to bring different response equipment on-site. Can be used as a field store when on-site. The box trailers vary in size from 10 ft to 48 ft. One unit per response centre is configured as a shoreline cleanup unit containing booms, skimmer, pumps, hoses, portable storage, sorbents, generators, lights, etc. Other units carry boom, sorbents or are configured as field stores. Used for transportation of small boats and other response equipment. Ball hitch trailers constructed of steel, galvanized steel or aluminium. Boat trailer designed to be backed down ramps to allow boat launching and retrieval Note: ECRC maintains this list with regular updates quarterly and keeps the list internal for use during a spill.

106 Unrestrcited APPENDIX J: MAP DEPICTING PRIMARY AREAS OF RESPONSE