Amendment of well completion status - slrconsulting.com · 1 It should be noted that the actual...

APPLICATION TO AMEND

ENVIRONMENTAL MANAGEMENT

PROGRAMME BLOCK 11B/12B

Amendment of well completion status

Prepared for: Total E&P South Africa B.V.

Authority Ref: 12/3/067

SLR Project No: 720.20047.00003

Revision No: 1:

12 November 2018

Total E&P South Africa B.V.

Application to Amend Environmental Management Programme Block 11B/12B

720.20047.00003

November 2018

i

DOCUMENT INFORMATION

Title Application to Amend Environmental Management Programme Block

11B/12B: Amendment of well completion status

Project Manager Jonathan Crowther

Project Manager e-mail [email protected]

Author Jonathan Crowther

Reviewer Jonathan Crowther

Keywords Block 11B/12B; Well Drilling; Amendment application

Status EIR for submission to DMR

Authority Reference No 12/3/067

SLR Project No 720.20047.00003

DOCUMENT REVISION RECORD

Rev No. Issue Date Description Issued By

A 9 November 2018 EMPR Amendment issued for client review Jonathan Crowther

B 12 November 2018 EMPR Amendment issued for I&AP review Jonathan Crowther

BASIS OF REPORT

This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales

and resources devoted to it by agreement with Total E&P South Africa B.V. (the Client) for part or all of the services it has been appointed by the Client to

carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any

person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement

or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client

and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

SLR disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the work.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report

remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements

which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any

documents referenced explicitly herein and should then only be used within the context of the appointment.



720.20047.00003

November 2018

ii



720.20047.00003

November 2018

iii

EXECUTIVE SUMMARY

INTRODUCTION 1

This Executive Summary provides a comprehensive synopsis of the Environmental Management Programme

(EMPR) Amendment prepared as part of an amendment application process being undertaken by Total E&P

South Africa B.V. (hereafter referred to as “TEPSA”).

1.1 PROJECT BACKGROUND

TEPSA is the holder of an Exploration Right to undertake seismic surveys and exploration well drilling in defined

areas within Block 11B/12B. The Exploration Right area has a total extent of approximately 18 773 km2

and is

situated approximately 130 km offshore of the south coast in water depths of between 500 m and 2 000 m.

The approved drilling area covers an area of approximately 4 066 km2 (see Figure A).

Experience gained in the initial drilling of the Brulpadda well in 2014, highlighted a number of technical

difficulties facing the well drilling operation. These relate to drilling a deepwater well in a high energy marine

environment and the strongly flowing Agulhas current passing through the area of drilling interest. Taking

cognisance of the technical issue learning points, TEPSA is now applying to amend its EMPR in order to leave

the wellhead on the seafloor on completion of the drilling operation

An application to amend an EMPR is provided for in Section 37 of the Environmental Impact Assessment (EIA)

Regulations 2014, as amended, promulgated in terms of Sections 24(5) and 44 of the National Environmental

Management Act, 1998 (No. 107 of 1998), as amended (NEMA). An EMPR Amendment application must be

subjected to a public participation process before it can be approved by the competent authority, which in this

case is the Petroleum Agency SA (PASA).

SLR Consulting (South Africa) (Pty) Ltd (hereafter referred to as SLR) has been appointed by TEPSA as the

independent environmental consultant to undertake the necessary amendment application process. The

outcome of the application process will be the submission an EMPr Amendment report to PASA.

1.2 OPPORTUNITY TO COMMENT

This EMPR Amendment has been distributed for a 30-day comment period from 13 November to

13 December 2018 in order to provide Interested and Affected Parties (I&APs) with an opportunity to

comment on any aspect of the proposed project and the findings of the EMPR amendment process. Copies of

the full report have been made available on the SLR website (at http://slrconsulting.com/za/).

Any comments should be forwarded to SLR at the address, telephone/fax numbers or e-mail address shown

below. For comments to be included in the updated EIR, comments should reach SLR by no later than

13 December 2018.



720.20047.00003

November 2018

iv

2. APPROACH AND METHODOLOGY TO THE AMENDMENT PROCESS

2.1 SPECIALISTS STUDIES

Two specialist studies were undertaken to address the key issues that required further investigation, namely

the impact on fishing and marine fauna. Specialist studies involved the gathering of data relevant to identifying

and assessing environmental impacts that may occur as a result of the proposed amendments to the project.

These impacts were then assessed according to pre-defined rating scales. Specialists also recommended

appropriate mitigation or optimisation measures to minimise potential impacts or enhance potential benefits,

respectively.

2.2 INTEGRATION AND ASSESSMENT

The above-mentioned specialist studies and other relevant information / assessments have been integrated

into the EMPR Amendment report. This report aims to present all information in a clear and understandable

format, suitable for easy interpretation by I&APs and authorities, and to provide an opportunity for I&APs to

comment on the proposed EMPR amendment and findings of the amendment process.

The following steps are envisaged for the remainder of the EMPR amendment process:

• After closure of the EMPR Amendment comment period, all comments received will be incorporated and

responded to in a Comments and Responses Report. The EMPR Amendment will then be updated into a

final report, to which the Comments and Responses Report will be appended.

• The final report will be submitted to PASA for consideration and decision-making by the Minister of

Mineral Resources (or delegated authority).

• After the competent authority has reached a decision, all I&APs on the project database will be notified

of the outcome of the application and the reasons for the decision.

• A statutory appeal period in terms of the National Appeal Regulations (GN No. R993) will follow the

issuing of the decision.

.

SLR Consulting (South Africa) (Pty) Ltd

Attention: Mandy Kula

PO Box 10145, CALEDON SQUARE, 7905

Unit 39 Roeland Square, 30 Drury Lane, CAPE TOWN, 8001

Tel: (021) 461 1118/9

Fax: (021) 461 1120

E-mail: [email protected]



720.20047.00003

November 2018

v

FIGURE A: LOCALITY OF BLOCK 11B/12B OFF THE SOUTH COAST OF SOUTH AFRICA. THE AREA OF INTEREST FOR DRILLING IS HIGHLIGHTED.



720.20047.00003

November 2018

vi

3. PROJECT DESCRIPTION

3.1 APPROVED WELL COMPLETION

The approved EMPr requires that once the well had been plugged to ensure well integrity1, the wellhead would

then be removed, with casing cut-off approximately 3 m below the seafloor and all sundry equipment removed

to leave the seafloor clear.

3.3 DESCRIPTION OF AMENDED WELL COMPLETION STATUS

As noted above, TEPSA is applying to amend its EMPr in order to leave the wellhead on the seafloor on

completion of the drilling operation. Detailed rationale for this approach is provided in the Risk Report that

TEPSA has compiled as part of the amendment application (see Appendix 4). A combination of the normal

challenges inherent in deepwater exploration together with the specific metocean challenges (harsh sea

conditions and strong currents) place a significant risk on the wellhead removal operation. Typical challenges

would include:

• The requirement to wait on an adequate weather window to perform the operation;

• Low reliability of the weather forecast in relation to the Agulhas Current behaviour and movement; and

• The risk of rig position loss due to current unpredictability.

Based on the perceived risk of conducting well removal under the specific metocean conditions associated with

the drilling area location, TEPSA is applying for an amendment to leave wellheads on the seafloor.

4. DESCRIPTION OF THE AFFECTED ENVIRONMENT

4.1 PHYSICAL OCEANOGRAPHY

The oceanography of the South Coast is almost totally dominated by the warm Agulhas Current which forms

between 25° and 30° S and flows southwards along the shelf edge of the southern African East Coast, as part of

the anticyclonic Indian Ocean gyre. It is a well-defined and intense jet some 100 km wide and 1 000 m deep

flowing in a south-west direction at a rapid rate, with current speeds of 2.5 m/s or more. On the eastern half of

the South Coast, the Agulhas Current flows along the shelf break at speeds of up to 3 m/sec, diverging inshore

of the shelf break south of Still Bay (before realigning to the shelf break off Cape Agulhas.

Westerly winds predominate along the South Coast in winter, frequently reaching gale force strengths. During

summer, easterly wind directions increase markedly resulting in roughly similar strength/frequency of east and

west winds during that season.

______________________

1 It should be noted that the actual wellhead has no impact on well integrity once a well has been plugged for abandonment. The well

integrity is guaranteed by plugging the well with two independent barriers provided by setting the cement plugs in the well. This

occurs irrespective of the wellhead completion status.



720.20047.00003

November 2018

vii

On the South Coast, the majority of waves arrive from the south-west quadrant, dominating wave patterns

during winter and spring. Waves from this direction frequently exceed 6 m and can reach up to 10 m. During

summer, easterly wind-generated ‘seas’ occur.

4.2 BIOLOGICAL OCEANOGRAPHY

The Block 11B/12B Exploration Right area falls within the Agulhas Inshore and West Indian Offshore bioregions.

The biological communities occurring in the Block 11B/12B area consist of many hundreds of species, often

displaying considerable temporal and spatial variability (even at small scales). The majority of the approved

well drilling area falls within an area that is defined as least threatened in terms of the ecosystem threat status.

A very small portion in the west coincides with a vulnerable area.

The ichthyofauna on the South Coast is diverse, comprising a mixture of temperate and tropical species. The

seabed of the Agulhas Bank substrate is also diverse comprising areas of sand, mud and coral thereby

contributing to increased benthic fauna and fish species. The fish most likely to be encountered on the shelf,

beyond the shelf break and in the offshore waters of Block 11B/12B are the large migratory pelagic species,

including various tunas, billfish and sharks.

Three species of turtle occur along the Southwest Coast, namely the leatherback (Vulnerable), and occasionally

the loggerhead (Endangered) and the green (Endangered) turtle. Juvenile leatherback and the loggerhead that

reach the sea after hatching, are carried south westward by the Agulhas Current. Green turtles are non-

breeding residents often found feeding on inshore reefs.

Of the 60 seabird species that are known, or thought likely to occur, along the South Coast, fifteen species

breed in southern Africa: Cape gannet, African penguin, four species of cormorant, white pelican, three gull

and four tern species. The breeding areas are distributed around the coast with islands being especially

important.

The marine mammal fauna occurring off the southern African coast includes several species of whales and

dolphins and one resident seal species. Thirty six species or sub species/populations of cetaceans (whales and

dolphins) are known (based on historic sightings or strandings records) or likely (based on habitat projections

of known species parameters) to occur in these waters. The most common species within Block 11B/12B (in

terms of likely encounter rate not total population sizes) are likely to be the long-finned pilot whale and

humpback whale

The Cape fur seal (Arctocephalus pusillus pusillus) is the only seal species that has breeding colonies along the

South Coast, namely at Seal Island in Mossel Bay, on the northern shore of the Robberg Peninsula in

Plettenberg Bay and at Black Rocks (Bird Island group) in Algoa Bay.

4.3 MARINE PROTECTED AREAS

Numerous coastal marine protected areas (MPAs) exist along the South Coast. Of these, the Goukamma,

Robberg and Tsitsikama MPAs are located inshore of Block 11B/12B. It is noted that a network of 20 MPAs was

approved by Cabinet on 24 October 2018, however there is no overlap with the area of interest for well drilling

and these recently approved MPAs.



720.20047.00003

November 2018

viii

5. IMPACT ASSESSMENT CONCLUSIONS

5.1 MARINE FAUNA

Considering the ecosystem threat status of ‘least threatened’ in the drilling area, and the negligible proportion

of the benthic habitat type and the wider South-west Indian Offshore Bioregion potentially affected by the

subsea infrastructure, the specialist marine fauna study assessed the impact of leaving wellheads on the

seafloor as being of Low significance and concluded that there is no reason in terms of marine fauna why the

wellheads should not be left in place on the seabed.

5.2 FISHERIES

The proposed TEPSA drilling area is located in a water depth of between 500 m and 2 000 m. In a fisheries

context, trawl fisheries have been confined to the “shelf” referring to the “continental shelf”. Historically

trawling in South African waters has been confined to depths shallower than 500 m. Generally, depths beyond

500 m are defined as being on “the shelf edge” and an area that drops off steeply and of rougher substrate

type. Currently no fisheries would be affected by leaving a wellhead on the seafloor within the drilling area.

Thus there would be no impact on any fisheries.

The fisheries specialist study concludes that possible future demersal trawling is the only likely fishery that

could present a problem related to fouling with a wellhead in the drilling area. This could mean loss of the

trawl gear, loss of trawl warps, and in extreme cases, loss of the vessel due to loss of stability resulting from the

fouling.

Historical records of research trawling in the vicinity of the approved drilling area provide support for the

future expansion of trawling into the area:

• Hake directed bottom trawling in the last decade has systematically targeted fish in increasing water

depths.

• There has in the past been interest in the shelf drop off for trawling for deep-water species, specifically

orange roughy (Hoplostehus sp.), deep-water dories (oreos), cardinal fish, alfonsino and various other

species. There are established trawl fisheries for these species in Namibia and on the South West Indian

Ocean Ridge that fish in depths of between 1 000 m and 2 000 m. All of these species occur off the

Agulhas Bank and there continues to be interest in their commercial potential.

• In the mid 1990’s South Africa did have an experimental fishery for Oreo Dorie extending from south of

Cape Point towards the tip of the Agulhas Bank and further east. The trawling industry lost interest in the

fishery due to low abundance of the target species and high risk to the trawl gear.

• In the early to mid 1990’s one operator undertook a comprehensive side scan sonar survey for orange

roughy along the edge of the Agulhas Bank. Although seamounts and other suitable habitat was found

for orange roughy, viable commercial quantities were not found.

• The Department of Agriculture Forestry and Fisheries (DAFF) has also undertaken deep-water

exploratory trawling for deep-water species in the TEPSA drilling area. The results of these trawls have

shown the area to be of high risk to trawling.



720.20047.00003

November 2018

ix

Factors inhibiting the expansion of trawling into the drilling area include the following:

• The combination of depth and strong currents is the greatest deterrent to trawling for deep-water

species off the south and south eastern Agulhas Bank. The risk of losing trawl gear at these depths is

high.

• The Agulhas Current can reach 5 kts in places, it is irregular (and retroflects from westward moving to

eastwards) and may reverse at depth i.e. surface flowing currents may flow in the opposite direction at

the bottom.

• Weather and sea conditions are more extreme in the area, increasing the risk of losing trawl gear.

• The shelf edge and substrate type is of a generally high profile and unless suitable flat trawling ground

can be found, is difficult to trawl.

• Evidence of commercial quantities of deep-water species have to date not been found.

• Currently, targeting deep-water species is not permitted – if a fishery at these depths is found, the

trawling industry will need to apply for experimental fishing licenses.

• The area extending from the tip of Agulhas Bank eastwards to East London in depths up to 2 000 m has

been shown to have unique cold water corals and have been classified in places as a “Vulnerable Marine

Ecosystem” of VMEs. There is scientific interest in the area related to VMEs, specific habitat types and

corals. While there are no current restrictions to fishing in the area, the possibility that some habitats

may be protected in the future cannot be ruled out.

The specialist study concludes that there is currently no active fishery that would be affected by the proposed

application to abandon a wellhead in the project area. The possibility that trawling may occur in the proposed

area in the future cannot be ruled out; however, and the trawl gear used would pose a risk of damage to the

trawler should snagging occur. This risk could be mitigated by providing an over-trawlable structure to the

wellhead. Making the structure over-trawlable would mitigate the risk of damage to the fishing operation as

well as to potential damage to the wellhead.

5.3 EAP RECOMMENDATION

The findings of both specialists studies conclude that in terms of marine biophysical environment and the

current extent of fisheries, that the impact of leaving a wellhead on the seafloor would of low to negligible

significance.

The critical issue that needs to be evaluated in the decision-making process, is the implication of wellhead

infrastructure on future fisheries, specifically demersal trawl. There are indications that the demersal trawl

fishery could extend into deeper waters in the area proposed for drilling (although there are a number of

mitigations factors that also suggest fishing in deepwater with the strong Agulhas current may itself pose

problems), and could thus be affected by any infrastructure left on the seafloor. Should such a future risk not

be considered acceptable – then mitigation in the form of an over-trawlable structure should be a requirement

for well completion status within the approved drilling area. Such structures are assessed to be adequate to

remove the residual risk to future fisheries.



720.20047.00003

November 2018

x



720.20047.00003

November 2018

xi

CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................... III

INTRODUCTION ................................................................................................................................. 1 1

PROJECT BACKGROUND ................................................................................................................................. 1 1.1

AUTHORISATION REQUIREMENTS ................................................................................................................. 1 1.2

PURPOSE OF THIS REPORT ............................................................................................................................. 3 1.3

STRUCTURE OF THIS REPORT ......................................................................................................................... 3 1.4

OPPORTUNITY TO COMMENT ........................................................................................................................ 4 1.5

LEGISLATIVE REQUIREMENTS ............................................................................................................. 5 2

OVERVIEW OF THE “ONE ENVIRONMENTAL SYSTEM” .................................................................................. 5 2.1

MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 ............................................................ 5 2.2

NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 .............................................................................. 5 2.3

APPROACH AND METHODOLOGY TO THE AMENDMENT PROCESS ....................................................... 7 3

DETAILS OF THE PROJECT TEAM .................................................................................................................... 7 3.1

3.1.1 QUALIFICATIONS AND EXPERIENCE OF THE EAP ................................................................................................................................ 7

ASSUMPTIONS ............................................................................................................................................... 7 3.2

OBJECTIVES .................................................................................................................................................... 8 3.3

SPECIALISTS STUDIES ..................................................................................................................................... 8 3.4

INTEGRATION AND ASSESSMENT .................................................................................................................. 8 3.5

3.5.1 COMPILATION AND REVIEW OF THE EMPR AMENDMENT ............................................................................................................... 8

3.5.2 COMPLETION OF THE AMENDMENT PROCESS .................................................................................................................................. 9

PROJECT DESCRIPTION ..................................................................................................................... 11 4

GENERAL PROJECT INFORMATION .............................................................................................................. 11 4.1

4.1.1 EXPLORATION RIGHT HOLDER ........................................................................................................................................................... 11

4.1.2 EXPLORATION RIGHT AREA ............................................................................................................................................................... 11

PROJECT DESCRIPTION ................................................................................................................................ 11 4.2

4.2.1 APPROVED WELL COMPLETION ........................................................................................................................................................ 11

4.2.2 DESCRIPTION OF AMENDED WELL COMPLETION STATUS .............................................................................................................. 13

DESCRIPTION OF THE AFFECTED ENVIRONMENT ............................................................................... 15 5

5.1 PHYSICAL OCEANOGRAPHY ......................................................................................................................... 15



720.20047.00003

November 2018

xii

BIOLOGICAL OCEANOGRAPHY ..................................................................................................................... 15 5.2

MARINE PROTECTED AREAS ........................................................................................................................ 17 5.3

HUMAN UTILISATION ................................................................................................................................... 17 5.4

5.4.1 COMMERCIAL FISHERIES ................................................................................................................................................................... 17

5.4.2 MARINE TRAFFIC AND INFRASTRUCTURE ......................................................................................................................................... 21

IMPACT DESCRIPTION AND ASSESSMENT ......................................................................................... 23 6

MARINE FAUNA ........................................................................................................................................... 23 6.1

FISHERIES ..................................................................................................................................................... 24 6.2

CONCLUSIONS AND RECOMMENDATIONS ........................................................................................ 29 7

MARINE FAUNA ........................................................................................................................................... 29 7.1

FISHERIES ..................................................................................................................................................... 29 7.2

ENVIRONMENTAL MANAGEMENT PROGRAMME .............................................................................. 31 8

REFERENCES .................................................................................................................................... 47 9

APPENDICES

APPENDIX 1: CONVENTION FOR ASSIGNING SIGNIFICANCE RATINGS TO IMPACTS

APPENDIX 2: MARINE FAUNAL ASSESSMENT

APPENDIX 3: FISHERIES ASSESSMENT

APPENDIX 4: RISK REPORT

APPENDIX 5: PUBIC PARTICIPATION PROCESS

APPENDIX 5.1: I&AP DATABASE

APPENDIX 5.2: I&AP NOTIFICATION OF EMPR AMENDMENT

LIST OF TABLES

TABLE 3-1: DETAILS OF THE EIA PROJECT TEAM .............................................................................................. 7

TABLE 3-2: SPECIALISTS STUDIES ..................................................................................................................... 8

TABLE 6-1: IMPACT ON MARINE BENTHOS OF LEAVING WELLHEADS ON THE SEAFLOOR ........................... 24

TABLE 6-2: FISHERIES AND THE LIKELY IMPACT THAT WELLHEADS WOULD HAVE ON THEM ...................... 25

TABLE 6-3: IMPACT ON DEMERSAL FISHING OF LEAVING WELLHEADS ON THE SEAFLOOR ......................... 26

LIST OF FIGURES

FIGURE 1-1: LOCALITY OF BLOCK 11B/12B OFF THE SOUTH COAST OF SOUTH AFRICA. THE AREA OF

INTEREST FOR DRILLING IS HIGHLIGHTED. .................................................................................... 2

FIGURE 4-1: PHOTOGRAPH OF WELLHEAD ON THE SEAFLOOR ...................................................................... 12

FIGURE 4-2: DIAGRAMATIC CROSS SECTION OF CASING HOUSING 3.5 METRES ABOVE SEAFLOOR .............. 12



720.20047.00003

November 2018

xiii

FIGURE 5-1: BLOCK 11B/12B IN RELATION TO THE EXISITNG MARINE PROTECTED AREAS (ALONG

THE COAST) AND OFFSHORE MARINE PROTECTED AREAS RECENTLY ACCEPTED BY

CABINET. AFTER PISCES 2018....................................................................................................... 17

FIGURE 5-2: BLOCK 11B/12B IS RELATION TO DEMERSAL TRAWL EFFORT. .................................................... 18

FIGURE 5-3: BLOCK 11B/12B IN RELATION TO DEMERSAL LONGLINE EFFORT ............................................... 19

FIGURE 5-4: BLOCK 11B/12B IN RELATION TO PELAGIC LONGLINE EFFORT ................................................... 19

FIGURE 5-5: BLOCK 11B/12B IN RELATION TO SOUTH COAST ROCK LOBSTER EFFORT .................................. 20

FIGURE 5-6: BLOCK 11B/12B IN RELATION TO DAFF RESEARCH TRAWING EFFORT ....................................... 20

FIGURE 5-7: BLOCK 11B/12B IN RELATION TO DAFF RESEARCH SIESMIC SURVEY LINES ................................ 21

FIGURE 6-1: EXAMPLE OF AN OVER-TRAWLABLE STRUCTURE ........................................................................ 27



720.20047.00003

November 2018

xiv

ACRONYMS AND ABBREVIATIONS

Acronym /

Abbreviation Definition

CITES Convention on International Trade in Endangered Species

cm centimetres

cm/s centimetres per second

CMS Convention on Migratory Species

CO Carbon monoxide

CO2 Carbon dioxide

COLREGS Convention on the International Regulations for Preventing Collisions at Sea

DAFF Department of Agriculture, Forestry and Fisheries

DEA Department of Environmental Affairs

DMR Department of Mineral Resources

EAP Environmental Assessment Practitioner

EEZ Exclusive Economic Zone

EIA Environmental Impact Assessment

EMPR Environmental Management Programme

g/m2 grams per square metre

g/m3 grams per cubic metre

GN Government Notice

I&APs Interested & Affected Parties

IUCN International Union for Conservation of Nature

km kilometres

km2 Square kilometres

m Metres

m2 Square metres

m3 Cubic metre

MARPOL International Convention for the Prevention of Pollution from Ships, 1973/1978

mg/l Milligrams per litre

mm Millimetres

MPA Marine Protected Area

MPRDA Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002)

NEMA National Environmental Management Act, 1998 (No. 107 of 1998)

PASA Petroleum Agency SA

SLR SLR Consulting (South Africa) (Pty) Ltd



720.20047.00003

November 2018

1

INTRODUCTION 1

This chapter provides a brief description of the project background, summarises the legislative authorisation

requirements, describes the purpose of this report and presents the structure of the report.

PROJECT BACKGROUND 1.1

Total E&P South Africa B.V. (hereafter referred to as “TEPSA”) is the holder of an Exploration Right to

undertake seismic surveys and exploration well drilling in defined areas within Block 11B/12B (see Figure 1-1).

An Environmental Authorisation approving a Basic Assessment (BA) for undertaking exploration well drilling

was granted on 17 January 2011 in terms of the National Environmental Management Act, 1998 (No. 107 of

1998), as amended (NEMA) and a Record of Decision (ROD) was issued by the Petroleum Agency SA (PASA) for

the approval of the Environmental Management Programme Report (EMPR) amendment on 18 May 2012 in

terms of the Minerals and Petroleum Resources Development Act, 2002 (No. 28 of 2002), as amended

(MPRDA).

In terms of the project description provided in the above approved BA and EMPr, completion of exploration

well drilling would include removal of the wellhead with casings cut-off 3 m below the seafloor and all sundry

wellhead equipment removed to leave the seafloor clean. At the same time the project description also stated

the following…” technical (deep well scenario) and weather conditions (high swells and wind) may dictate that a

wellhead cannot be removed on completion of the drilling operation. A technical report would subsequently be

compiled and submitted to PASA. The report would indicate the factors leading to the abandonment and

provide a rationale as to the future status of the wellhead”.

Experience gained in the initial drilling of the Brulpadda well in 2014, highlighted a number of technical

difficulties facing the well drilling operation. These relate to drilling a deepwater well in a high energy marine

environment and the strongly flowing Agulhas current passing through the area of drilling interest. Taking

cognisance of the technical issue learning points, TEPSA is now applying to amend its EMPR in order to leave

the wellhead on the seafloor on completion of the drilling operation.

SLR Consulting (South Africa) (Pty) Ltd (hereafter referred to as SLR) has been appointed by TEPSA as the

independent environmental consultant to undertake the necessary amendment application process. The

outcome of the application process will be the submission an EMPr Amendment report to PASA.

AUTHORISATION REQUIREMENTS 1.2

The proposed amendment to the EMPr requires approval in terms of both the MPRDA and NEMA. These two

regulatory processes are summarised below and presented in more detail in Chapter 2.

Section 102 of the MPRDA provides for the amendment of, amongst others, an Environmental Management

Programme (EMPr) and requires that any amendment be approved by the Minister of Minerals and Energy (or

delegated authority). This application is facilitated by the NEMA process described below.



720.20047.00003

November 2018

2

FIGURE 1-1: LOCALITY OF BLOCK 11B/12B OFF THE SOUTH COAST OF SOUTH AFRICA. THE AREA OF INTEREST FOR DRILLING IS HIGHLIGHTED.



720.20047.00003

November 2018

3

An application to amend an EMPr is provided for in Section 37 of the Environmental Impact Assessment (EIA)

Regulations 2014, as amended, promulgated in terms of Sections 24(5) and 44 of the National Environmental

Management Act, 1998 (No. 107 of 1998), as amended (NEMA). An EMPr Amendment application must be

subjected to a public participation process before it can be considered by the competent authority. In this case

PASA will review the amendment application and make a recommendation to DMR as to whether the

amendment application should be accepted or rejected.

PURPOSE OF THIS REPORT 1.3

This EMPr Amendment has been compiled and distributed for review and comment as part of the above-

mentioned amendment process that is being undertaken by TEPSA.

This report summarises the:

• legislative requirements;

• approach and methodology of the amendment process;

• a description of the proposed changes to well completion;

• a summary of the key characteristics of the receiving environment;

• findings of specialist studies; and

• amendments to the EMPr, which includes the mitigation and management measures necessary to avoid

or reduce potentially significant impacts.

Interested and Affected Parties (I&APs) are asked to comment on the EMPr Amendment (see Section 1.5). The

document will then be updated into a final report, giving due consideration to the comments received. The

final EMPR Amendment will be submitted to PASA for consideration and decision-making.

STRUCTURE OF THIS REPORT 1.4

This EMPr Amendment has been prepared in compliance with Section 37 of the EIA Regulations 2014 (as

amended) and is divided into various chapters and appendices, the contents of which are outlined below.

Section Contents

Executive Summary Provides a comprehensive synopsis of the EIR Amendment.

Chapter 1 Introduction

Provides a brief description of the project background, summarises the legislative authorisation

requirements, describes the purpose of this report and presents the structure of the report.

Chapter 2 Legislative requirements

Outlines the key legislative requirements applicable to the proposed project and associated

amendment process.

Chapter 3 Approach and methodology to the amendment process

Presents the project team, assumptions, and outlines the amendment process, including the

assessment methodology and I&AP consultation process.

Chapter 4 Project description

Provides a general description of the proposed project.

Chapter 5 Description of the affected environment

Describes the existing biophysical and social environment that could potentially be affected by the

proposed amendment.



720.20047.00003

November 2018

4

Section Contents

Chapter 6 Impact description and assessment

Describes and assesses the potential impacts related to the proposed amendments on the affected

environment. It also presents mitigation/management or optimisation measures that could be

used to reduce the significance of any negative impacts or enhance any benefits, respectively.

Chapter 7 Conclusion and recommendations

Provides conclusions to the amendment process and summarises the mitigation and monitoring

measures that would be implemented for the proposed project.

Chapter 8 Environmental management programme

Provides the EMPr Management Actions for the proposed EMPr Amendment. This includes all

measures outlined in the approved EMPr and any amended and / or additional management

actions identified, where relevant.

Chapter 9 References

Provides a list of the references used in compiling this report.

Appendices Appendix 1: Convention for assigning significance ratings to impacts

Appendix 2: Marine Faunal Assessment

Appendix 3: Fisheries Assessment

Appendix 4: Risk Report

Appendix 5: Public Participation Process

Appendix 4.1: I&AP database

Appendix 4.2: I&AP notification of EMPR Amendment

OPPORTUNITY TO COMMENT 1.5

This EMPr Amendment has been distributed for a 30-day comment period from 13 November to

13 December 2018 in order to provide I&APs with an opportunity to comment on any aspect of the

amendment application. Copies of the full report have been made available on the SLR website (at

http://slrconsulting.com/za/).

Any comments should be forwarded to SLR at the address, telephone/fax numbers or e-mail address shown

below. For comments to be included in the updated EMPr Amendment, comments should reach SLR by no

later than 12 December 2018.

SLR Consulting (South Africa) (Pty) Ltd

Attention: Mandy Kula

PO Box 10145, CALEDON SQUARE, 7905

Unit 39 Roeland Square, 30 Drury Lane, CAPE TOWN, 8001

Tel: (021) 461 1118/9

Fax: (021) 461 1120

E-mail: [email protected]



720.20047.00003

November 2018

5

LEGISLATIVE REQUIREMENTS 2

This chapter outlines the key legislative requirements applicable to the proposed EMPR amendment.

OVERVIEW OF THE “ONE ENVIRONMENTAL SYSTEM” 2.1

The “One Environmental System” commenced on 8 December 2014 removing the environmental regulation of

prospecting, mining, exploration and production and related activities from the MPRDA and transferring it to

NEMA. Under the “One Environmental System”, the Minister of Mineral Resources (or delegated authority) is

the competent authority responsible for issuing Environmental Authorisations and associated amendments in

terms of NEMA for mining and petroleum related activities. The Minister of Environmental Affairs, however,

remains the appeal authority for these authorisations.

MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 2.2

TEPSA holds an existing Exploration Right for Block 11B/12B. As part of the process of applying for the

Exploration Right, a BA and EMPr were compiled and approved for the undertaking of seismic surveys and

exploration drilling within the licence area. Both of these activities have subsequently been undertaken within

the licence area to date.

Section 102 of the MPRDA provides for the amendment of, amongst others, an EMPr and requires that any

amendment be approved by the Minister of Minerals and Energy (or delegated authority). This application is

facilitated by the NEMA process described below.

NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 2.3

The EIA Regulations 2014 promulgated in terms of Chapter 5 of NEMA, and published in Government Notice

(GN) No. R982 (as amended by GN No. 326 of 7 April 2017) control certain listed activities, which are prohibited

until Environmental Authorisation has been obtained from the competent authority (which is the Minister of

Mineral Resources for Mining Right applications). As noted previously TEPSA was granted Environmental

Authorisation on 17 January 2011 for the above-mentioned seismic surveying and exploration well drilling

exploration programmes.

As indicated in the introduction, Section 37 of the EIA Regulations 2014, as amended, provides for the

amendment of an approved EMPR. The holder of an environmental authorisation must notify the competent

authority of such intention to amend the EMPr at least 60 days prior to submitting such amendments. TEPSA

submitted a notice of intent in this regard to PASA on 4 October 2018.

The Regulations further require that the holder of the environmental authorisation must invite comments from

potentially interested and affected parties, including the competent authority (a 30-day comment period) on

the proposed amendments to the EMPr. On completion of the public participation process, the holder of the

environmental authorisation must submit the EMPr Amendment report to PASA.

In the event that no comments are received on the Amended EMPR, the holder of the environmental

authorisation may submit the EMPr amendment to the competent authority for approval within 60 days of

inviting comment.



720.20047.00003

November 2018

6

If comments are submitted to the holder of the environmental authorisation, the holder must submit such

comments including responses to such comments to the competent authority together with the EMPr. The

competent authority must, within 30-days of receipt EMPr Amendment (including comments and responses)

consider such information and issues a decision to approve or not.



720.20047.00003

November 2018

7

APPROACH AND METHODOLOGY TO THE AMENDMENT PROCESS 3

This chapter presents the EMPr Amendment project team, assumptions, and outlines the amendment process,

including the assessment methodology and I&AP consultation process.

DETAILS OF THE PROJECT TEAM 3.1

Details of the project team that was involved in the preparation of this amendment report are provided in

Table 3-1. SLR has no vested interest in the proposed project other than fair payment for consulting services

rendered as part of the amendment process.

TABLE 3-1: DETAILS OF THE EIA PROJECT TEAM

General

Organisation SLR Consulting (South Africa) (Pty) Ltd

Postal address PO Box 10145, CALEDON SQUARE, 7905

Tel No. +27 (0)21 461 1118 / 9

Fax No. +27 (0)21 461 1120

Name Qualifications Professional

registrations

Experience

(Years) Tasks and roles

Jonathan Crowther

M.Sc. (Env. Sci.).

University of

Cape Town

Pr.Sci.Nat.,

CEAPSA, Member

IAIAsa

30 Report and process review

Qualifications and Experience of the EAP 3.1.1

Jonathan Crowther is the SLR Operations Manager for the Environmental Management Planning and Approvals

team in Africa. He holds a Master’s Degree in Environmental Science and has 30 years of relevant experience.

He has expertise in a wide range of environmental disciplines, including EIAs, EMPs, Environmental Planning

and Review and Public Consultation. Jonathan is a Registered Professional Natural Scientists (Pr.Sci.Nat.) and a

Certified Environmental Practitioner of South Africa (CEAPSA).

ASSUMPTIONS 3.2

The assumptions pertaining to this EMPR Amendment are listed below:

• It is assumed that SLR has been provided with all relevant project information and that it was correct and

valid at the time it was provided.

• There will be no significant changes to the project description or surrounding environment between the

completion of the amendment process and implementation of the proposed project that could

substantially influence findings and recommendations with respect to mitigation and management, etc.



720.20047.00003

November 2018

8

OBJECTIVES 3.3

The overall objectives of this EMPr Amendment application process is to determine the likely impact

significance of the proposal by TEPSA to leave wellheads on the seafloor on completion of exploration well

drilling .

Specialist studies have been commissioned in order to assess the significance of the proposed change in the

project description and the findings of these studies evaluated in order to provide a reasoned conclusion on

the findings.

SPECIALISTS STUDIES 3.4

Two specialist studies were undertaken to address the key issues that required investigation, namely the

impact on fisheries and marine fauna. The details of the two specialist studies are provided in Table 3-2.

Specialist studies involved the gathering of data relevant to identifying and assessing environmental impacts

that may occur as a result of the proposed amendments to the project. These impacts were then assessed

according to pre-defined rating scales (see Appendix 1). Specialists also recommended appropriate mitigation

or optimisation measures to minimise potential impacts or enhance potential benefits, respectively.

TABLE 3-2: SPECIALISTS STUDIES

No. Tasks and roles organisation Name Qualifications

1

Marine Faunal

Assessment

(see Appendix 2)

Pisces Environmental

Services Andrea Pulfrich

PhD (Fisheries Biology), Christian-

Albrechts University, Kiel, Germany

2

Fisheries Assessment

(see Appendix 3) Capricorn Marine

Environmental

Dave Japp MSc (Ichthyology and Fisheries

Science), Rhodes University

Sarah Wilkinson BSc (Hons) (Botany), University of

Cape Town

In addition to the above specialist studies, TEPSA has prepared a Risk Report (see Appendix 4), which provides

a rationale for the proposal to leave the wellheads on the seafloor and provides a risk analysis of the option of

wellhead removal versus leaving wellheads on the seafloor.

INTEGRATION AND ASSESSMENT 3.5

Compilation and review of the EMPR Amendment 3.5.1

This EMPr Amendment has been prepared in compliance with Section 37 the EIA Regulations 2014 (as

amended). The specialist studies and other relevant information / assessments have been integrated into this

report. This report, therefore, contains the key information from each of the specialist studies, including the

description and assessment of impacts. Each impact is described and assessed in terms of the nature of the

effect, duration, extent, intensity and significance level, which is assigned according to pre-defined rating scales

(see Appendix 1).



720.20047.00003

November 2018

9

This report aims to present all information in a clear and understandable format, suitable for easy

interpretation by I&APs and authorities, and to provide an opportunity for I&APs to comment on the proposed

EMPR Amendments and findings of the amendment process (see Section 1.5 for details of the comment

period).

Steps that will be undertaken as part of the draft report review process are summarised below.

• A preliminary I&AP database of authorities, Non-Governmental Organisations, Community-based

Organisations and other key stakeholders was compiled using an update of the existing database for

Block 11B/12B (see Appendix 5.1). Additional I&APs will be added to the database based on the tasks

below.

• A notification letter was distributed to all registered I&APs; and

• A copy of the report has been made available on the SLR website for the duration of the comment

period.

Copies of the notification letter will be included on the final report.

Completion of the Amendment Process 3.5.2

The following steps are envisaged for the remainder of the amendment process:

• After closure of the comment period, all comments received will be incorporated and responded to in a

Comments and Responses Report. The EMPR Amendment will then be updated into a final report, to

which the Comments and Responses Report will be appended.

• The final EMPR Amendment will be submitted to PASA for consideration and decision-making by the

Minister of Mineral Resources (or delegated authority).

• After the Minister has reached a decision, all I&APs on the project database will be notified of the

outcome of the application and the reasons for the decision.

• A statutory appeal period in terms of the National Appeal Regulations (GN No. R993) will follow the

issuing of the decision.



720.20047.00003

November 2018

10



720.20047.00003

November 2018

11

PROJECT DESCRIPTION 4

This chapter, provides general information, describes the need and desirability for the proposed project,

provides a project overview/description and describes the project alternatives.

GENERAL PROJECT INFORMATION 4.1

Exploration Right Holder 4.1.1

TEPSA is the Exploration Right holder.

Address: 3rd

Floor

Tygervalley Chambers Two

Willie Van Schoor Avenue

Bellville, 7530

South Africa

Responsible Persons: Mr Eduard Groenewald

Telephone: +27 21 003 4077

Email: [email protected]

Exploration Right Area 4.1.2

The Exploration Right area includes Block 11B/12B (see Figure 1-1) and has a total extent of approximately

18 773 km2 and is situated approximately 130 km offshore of the south coast in water depths of between

500 m and 2 000 m. The approved drilling area (shaded green on Figure 1-1) covers an area of approximately

4 066 km2.

PROJECT DESCRIPTION 4.2

Approved well completion 4.2.1

The approved EMPr requires that once the well had been plugged to ensure well integrity2, the wellhead would

then be removed, with casing cut-off approximately 3 m below the seafloor and all sundry equipment removed

to leave the seafloor clear.

A typical wellhead is shown Figure 4-1 and a diagrammatic cross section in Figure 4-2.

______________________

2 It should be noted that the actual wellhead has no impact on well integrity once a well has been plugged for abandonment. The well

integrity is guaranteed by plugging the well with two independent barriers provided by setting the cement plugs in the well. This occurs

irrespective of the wellhead completion status.



720.20047.00003

November 2018

12

FIGURE 4-1: PHOTOGRAPH OF WELLHEAD ON THE SEAFLOOR

FIGURE 4-2: DIAGRAMATIC CROSS SECTION OF CASING HOUSING 3.5 METRES ABOVE SEAFLOOR



720.20047.00003

November 2018

13

Description of amended well completion status 4.2.2

As was indicted in the introduction, the description of the well completion status made reference to the fact

that if there were technical problems, that it may not be possible to remove the wellhead. The following is

extracted directly from the approved EMPr:

“technical (deep well scenario) and weather conditions (high swells and wind) may dictate that a wellhead

cannot be removed on completion of the drilling operation. A technical report would subsequently be compiled

and submitted to PASA. The report would indicate the factors leading to the abandonment and provide a

rationale as to the future status of the wellhead”.

TEPSA gained substantial experience of the local metocean conditions during the initial drilling of the

Brulpadda well in 2014. The strong Agulhas current that flows through the approved drilling area highlighted a

number of technical difficulties facing the well drilling operation. Taking cognisance of the technical learning

points, TEPSA is now applying to amend its EMPr in order to leave the wellhead on the seafloor on completion

of the drilling operation. Detailed rationale for this approach is provided in the Risk Report that TEPSA has

compiled as part of the amendment application (see Appendix 4). A brief summary of this is provided below.

A combination of the normal challenges inherent in deepwater exploration together with the specific

metocean challenges (harsh sea conditions and strong current) place a significant risk on wellhead removal

operations. Typical challenges would include:

• The requirement to wait on an adequate weather window to perform the operation;

• Low reliability of the weather forecast in relation to the Agulhas Current behaviour and movement; and

• The risk of rig position loss due to current unpredictability.

The casing cutting operations are performed in open water (riser and blow out preventer already removed)

and require that the cutting tools for the wellhead removal are anchored inside the casing strings. The high

current and its low forecast reliability, exposes the rig to increased risk of rig loss position which could lead to

the parting and loosing of the string. This is assessed to be a sever risk. Implications are:

• If the string parted close to the seabed, then access to the wellhead would be lost (e.g. in order to install

a corrosion cap) and there would be more equipment/debris left on the seabed;

• If the string parted on the rig side, then it could result in significant equipment damage and potential

impact on the safety of the drill rig and its crew. This would also result in drill string equipment/debris,

being left on the seafloor.

Thus, based on the perceived sever risk of conducting well removal under the specific metocean conditions

associated with the drilling area location, TEPSA is applying for an amendment to leave wellheads on the

seafloor.



720.20047.00003

November 2018

14



720.20047.00003

November 2018

15

DESCRIPTION OF THE AFFECTED ENVIRONMENT 5

A detailed update of the affected environment description provided in the approved EMPr has been prepared

as part of this amendment application process. The detailed description of the South Coast is provided in

Appendix 2. A summary of the key aspects are provided below.

5.1 PHYSICAL OCEANOGRAPHY

The oceanography of the South Coast is almost totally dominated by the warm Agulhas Current. The current

forms between 25° and 30° S, flowing southwards along the shelf edge of the southern African East Coast

(Schumann 1998) as part of the anticyclonic Indian Ocean gyre. It is a well-defined and intense jet some 100

km wide and 1 000 m deep flowing in a south-west direction at a rapid rate, with current speeds of 2.5 m/s or

more, and water transport rates of over 60 × 106 m

3/s have being recorded. On the eastern half of the South

Coast, the Agulhas Current flows along the shelf break at speeds of up to 3 m/sec, diverging inshore of the shelf

break south of Still Bay (34° 28'S, 21° 26'E) before realigning to the shelf break off Cape Agulhas. The Agulhas

Current may produce large meanders with cross shelf dimensions of approximately 130 km, which move

downstream at approximately 20 km per day It may also shed eddies, which travel at around 20 cm/s and

advect onto the Agulhas Bank.

The surface waters of the Agulhas Current may be over 25° C in summer and 21° C in winter.

Westerly winds predominate along the South Coast in winter, frequently reaching gale force strengths. During

summer, easterly wind directions increase markedly resulting in roughly similar strength/frequency of east and

west winds during that season. The strongest winds are observed at capes, including Agulhas, Infanta, Cape

Seal, Robberg and Cape Recife. Calm periods are most common in autumn.

On the South Coast, the majority of waves arrive from the south-west quadrant, dominating wave patterns

during winter and spring. Waves from this direction frequently exceed 6 m and can reach up to 10 m. During

summer, easterly wind-generated ‘seas’ occur.

BIOLOGICAL OCEANOGRAPHY 5.2

The Block 11B/12B Exploration Right area falls within the Agulhas Inshore and West Indian Offshore bioregions.

Communities within marine habitats are largely ubiquitous throughout the southern African South Coast

region, being particular only to substrate type or depth zone. The biological communities occurring in the

Block 11B/12B area consist of many hundreds of species, often displaying considerable temporal and spatial

variability (even at small scales).

The seabed benthic communities in the Block 11B/12B area lie within the Agulhas sub-photic and continental

slope biozones, which extend from a 30 m depth to the shelf edge, and beyond to the lower slope,

respectively. The majority of the approved well drilling area falls within an area that is defined as least

threatened in terms of the ecosystem threat status. A very small portion in the west coincides with a

vulnerable area.

The Agulhas Bank hosts a diversity of deep-water corals and sponges that have establish themselves below the

thermocline where there is a continuous and regular supply of concentrated particulate organic matter, caused

by the flow of a relatively strong current. Reef-building cold water corals have also been documented within

the Southwest Indian Upper Bathyal, Agulhas Sandy Shelf Edge and in association with deep reefs and

submarine canyons on the Agulhas Inner Shelf and Shelf Edge, respectively.



720.20047.00003

November 2018

16

The ichthyofauna on the South Coast is diverse, comprising a mixture of temperate and tropical species. As a

transition zone between the Agulhas and Benguela current systems, the South Coast ichthyofauna includes

many species occurring also along the West and/or East coasts. The seabed of the Agulhas Bank substrate is

also diverse comprising areas of sand, mud and coral thereby contributing to increased benthic fauna and fish

species.

Small pelagic shoaling species occurring along the South Coast include anchovy, pilchard, round herring, chub

mackerel and horse mackerel. The fish most likely to be encountered on the shelf, beyond the shelf break and

in the offshore waters of Block 11B/12B are the large migratory pelagic species, including various tunas, billfish

and sharks many of which are considered threatened by the International Union for the Conservation of Nature

(IUCN), primarily due to overfishing.

There is a high diversity of teleosts (bony fish) and chondrichthyans (cartilaginous fish) associated with the

inshore and shelf waters of the South Coast, many of which are endemic to the Southern African coastline and

form an important component of the demersal trawl and long-line fisheries. The Cape hake is distributed

widely on the Agulhas Bank, while the deep-water hake is found further offshore in deeper water. Apart from

the hakes, numerous other by-catch species are landed by the South Coast demersal trawling fishery including

panga, kob, gurnard, monkfish, John Dory and angel fish.

Three species of turtle occur along the Southwest Coast, namely the leatherback (Vulnerable), and occasionally

the loggerhead (Endangered) and the green (Endangered) turtle. Both the leatherback and the loggerhead

turtle nest on the beaches of the northern KwaZulu-Natal coastline in the summer months. After hatching

juvenile turtles that reach the sea, are carried south westward by the Agulhas Current. Green turtles are non-

breeding residents often found feeding on inshore reefs.

Fifteen species of seabirds breed in southern Africa: Cape gannet, African penguin, four species of cormorant,

white pelican, three gull and four tern species. The breeding areas are distributed around the coast with

islands being especially important. Overall, 60 seabird species are known, or thought likely to occur, along the

South Coast.

The marine mammal fauna occurring off the southern African coast includes several species of whales and

dolphins and one resident seal species. Thirty six species or sub species/populations of cetaceans (whales and

dolphins) are known (based on historic sightings or strandings records) or likely (based on habitat projections

of known species parameters) to occur in these waters. The distribution of cetaceans can largely be split into

those associated with the continental shelf and those that occur in deep, oceanic water. Importantly, species

from both environments may be found on the continental slope (from the shelf break - 200 m to ~2 000 m)

making this the most species rich area for cetaceans. Cetacean density on the continental shelf is usually

higher than in pelagic waters as species associated with the pelagic environment tend to be wide ranging

across 1 000s of kilometres. The most common species within Block 11B/12B (in terms of likely encounter rate

not total population sizes) are likely to be the long-finned pilot whale and humpback whale

The Cape fur seal (Arctocephalus pusillus pusillus) is the only seal species that has breeding colonies along the

South Coast, namely at Seal Island in Mossel Bay, on the northern shore of the Robberg Peninsula in

Plettenberg Bay and at Black Rocks (Bird Island group) in Algoa Bay.



720.20047.00003

November 2018

17

MARINE PROTECTED AREAS 5.3

Numerous coastal marine protected areas (MPAs) exist along the South Coast (see Figure 5-1). There are four

MPAs on the Western Cape coast east of Cape Agulhas namely De Hoop, Goukamma, Robberg, and Tsitsikama.

Of these, the Goukamma, Robberg and Tsitsikama MPAs are located inshore of Block 11B/12B.

Following an initiative that has long been in the developing, biodiversity data was used to identify numerous

focus areas for protection on the South Coast. These focus areas were carried forward during Operation

Phakisa, which identified potential offshore MPAs. A network of 20 MPAs was approved by Cabinet on

24 October 2018, thereby increasing the ocean protection within the South African Exclusive Economic Zone

(EEZ) to 5%. Those recently approved MPAs within the broad project area are shown in Figure 5-1. There is no

overlap with the area of interest for well drilling and recently approved MPAs.

FIGURE 5-1: BLOCK 11B/12B IN RELATION TO THE EXISITNG MARINE PROTECTED AREAS (ALONG THE

COAST) AND OFFSHORE MARINE PROTECTED AREAS RECENTLY ACCEPTED BY CABINET.

AFTER PISCES 2018

HUMAN UTILISATION 5.4

Commercial Fisheries 5.4.1

South Africa has a coastline that spans two ecosystems, extending from the Orange River in the west on the

border with Namibia, to Ponta do Ouro in the east on the Mozambique border. The western coastal shelf has

highly productive commercial fisheries similar to other upwelling ecosystems around the world, while the East

Coast is considerably less productive but has high species diversity, including both endemic and Indo-Pacific

species. South Africa’s fisheries are regulated and monitored by the Department of Agriculture, Forestry and

Fisheries (DAFF). All fisheries in South Africa, as well as the processing, sale in and trade of almost all marine

resources, are regulated under the Marine Living Resources Act, 1998 (No. 18 of 1998) (MLRA).

Approximately 14 different commercial fisheries sectors currently operate within South African waters. These

are described in more detail in the fisheries specialist report (see Appendix 3). However, it should be noted

here, and it will be discussed further in Chapter 6, that only future demersal trawling and demersal is likely to

be affected by wellheads being left on the seafloor.



720.20047.00003

November 2018

18

FIGURE 5-2: BLOCK 11B/12B IS RELATION TO DEMERSAL TRAWL EFFORT.

FIGURE 5-3: BLOCK 11B/12B IN RELATION TO MIDWATER TRAWL EFFORT



720.20047.00003

November 2018

19

FIGURE 5-3: BLOCK 11B/12B IN RELATION TO DEMERSAL LONGLINE EFFORT

FIGURE 5-4: BLOCK 11B/12B IN RELATION TO PELAGIC LONGLINE EFFORT



720.20047.00003

November 2018

20

FIGURE 5-5: BLOCK 11B/12B IN RELATION TO SOUTH COAST ROCK LOBSTER EFFORT

FIGURE 5-6: BLOCK 11B/12B IN RELATION TO DAFF RESEARCH TRAWING EFFORT



720.20047.00003

November 2018

21

FIGURE 5-7: BLOCK 11B/12B IN RELATION TO DAFF RESEARCH SIESMIC SURVEY LINES

Marine traffic and infrastructure 5.4.2

A large number of vessels navigate along the South Coast on their way around the southern African

subcontinent. The majority of this vessel traffic, including commercial and fishing vessels, remains relatively

close inshore and is, therefore, expected to pass through inshore areas of the proposed survey area.

PetroSA operates the F-A production platform, which was brought into production in 1992. The F-A platform is

located 85 km south of Mossel Bay and roughly mid-way between Block 11B/12B and Mossel Bay. Gas and

associated condensate from the gas fields (F-A, F-A Satellite, E-M and E-M Satellite) are processed through the

platform. The produced gas and condensate are exported through two separate 90 km pipelines to the PetroSA

Gas-to-Liquid (GTL) plant in Mossel Bay.



720.20047.00003

November 2018

22



720.20047.00003

November 2018

23

IMPACT DESCRIPTION AND ASSESSMENT 6

This chapter describes and assesses the significance of the potential impacts associated with the application by

TEPSA to leave wellheads on the seafloor on completion of each of the approved 10 exploration well drilling

operation within the approved drilling area.

All impacts are systematically assessed and presented according to a predefined impact assessment protocol.

Mitigation or optimisation measures are proposed which could ameliorate negative impacts or enhance

potential benefits. The status of all impacts should be considered to be negative unless otherwise indicated.

The significance of the impacts with and without mitigation is also assessed.

MARINE FAUNA 6.1

Description of impact

A detailed discussion of the effects of oil and gas infrastructure on the seabed is provided in the Marine Faunal

Assessment (see Appendix2). Various studies (e.g. Hall 2001) have shown that infrastructure provided by

platforms can support a rich diversity of marine species, including rare and slow growing cold water corals.

Studies on the effects of platforms on the behaviour and abundance of certain fish species showed that the

presence of oil and gas infrastructure appeared to provide a sheltering habitat for fish usually associated with

complex reef habitats (Love et al. 2005; Love & York 2006).

The changes in biodiversity discussed in these various studies, however, are primarily associated with

permanent production rigs, and any alterations to community structure resulting from potentially up to 10

wellheads would occur at a much smaller scale than that reported on production infrastructure. For the

current project, the drilling area is located in between 500 m to 2 000 m depth, in Southwest Indian upper

bathyal seabed habitat, which has been assigned an ecosystem threat status of ‘least threatened’ (Sink et al.

2012). The physical presence of remaining subsea infrastructure would effectively introduce hard substratum

in an otherwise uniform area dominated by unconsolidated sediments. The infrastructure remaining on the

seabed would be available for colonisation by sessile benthic organisms typically associated with heard

substrata, and would provide shelter for demersal fish and mobile invertebrates thereby potentially increasing

the benthic biodiversity and biomass in the continental slope region. The benthic fauna inhabiting islands of

hard substrata in otherwise unconsolidated sediments of the outer shelf and continental slope are very poorly

known. Likely taxa would include urchins, anemones, sponges, gorgonians, bryozoans and octocorals, many of

which could potentially be sensitive to disturbance. Considering the close proximity of the newly discovered

biogenic coral reef structure known as Secret Reef to the drilling area, it is not unlikely that some of the fragile

and sensitive deep water corals (scleractinian corals, stylasterine corals) and byrozoans occurring there may

colonise the abandoned wellheads, although establishment of mature communities would only be expected

over the medium to long-term. Due to the water depths in the drilling area, colonisation by invasive species is

unlikely to pose a significant threat to natural biodiversity in the deep sea habitats.

Assessment

The impacts associated with the presence of subsea infrastructure (up to ten wellheads) and potential

alteration of community structure, biodiversity and biomass would be highly localised, affecting no more than

approximately 8 m2 of seabed in total. This represents a negligible proportion of Block 11B/12B (0.04 x10

-6 %),

the Southwest Indian Upper Bathyal habitat type (0.009 x 10-7

%) and of the wider South-west Indian Offshore



720.20047.00003

November 2018

24

Bioregion (0.3 x 10-8

%). As most wells drilled to date (some of which will have been abandoned) are located in

waters shallower than 500 m depth, the cumulative impacts associated with abandoning subsea infrastructure

beyond 500 m depth is considered negligible, and any impact on benthic species, habitats or ecosystem

processes would most likely remain undetectable. The drilling area also lies beyond the depths typically

targeted by the demersal fishery, so cumulative effects of other users would likewise be negligible.

The increase in biodiversity (neutral impact) due to the presence of abandoned subsea structures would be

considered a secondary impact of low intensity. As TEPSA has indicated that the wellhead(s) would be

abandoned, the impact is irreversible but is considered to be of LOW significance without mitigation (see Table

6-1).

Should over-trawlable structures be installed above the wellhead to mitigate potential impacts to the trawl

fishery of leaving the wellheads in place, each structure would impact an area of approximately 25 m2. The

impacts associated with placing up to 10 structure on the seabed would thus likewise be highly localised

(250 m2) and be considered to be of LOW significance without mitigation.

Mitigation

No mitigation is recommended or deemed necessary.

TABLE 6-1: IMPACT ON MARINE BENTHOS OF LEAVING WELLHEADS ON THE SEAFLOOR

Impacts of petroleum infrastructure on marine biodiversity: wellhead remains on the seafloor during abandonment

Without Mitigation Assuming Mitigation

Intensity Low

No mitigation is proposed

Duration Permanent

Extent Local: limited to drilling area

Consequence Low

Probability Definite

Significance Low

Status Neutral

Confidence High

Nature of Cumulative impact Cumulative impacts at depths beyond 500 m are considered negligible.

Degree to which impact can be

reversed

Irreversible – wellheads will be permanently abandoned and changes in seabed structure

would thus also be permanent.

Degree to which impact may cause

irreplaceable loss resources

Negligible


mitigated

Medium

FISHERIES 6.2

Description of impact

As indicated in the affected environment section, five fisheries that operate within immediate or immediately

adjacent to the approved drilling including: demersal trawl, midwater trawl, demersal longline, large pelagic

longline and south coast rock lobster. Fisheries research cruises also occur near to the approved drilling area.



720.20047.00003

November 2018

25

Of these fisheries and research surveys, only the likely future expansion of demersal trawl operations are

expected to be affected by leaving wellheads on the seafloor within the drilling area. A summary of the likely

impact of wellheads left on the seabed within the drilling area is provided in Table 6-2.

TABLE 6-2: FISHERIES AND THE LIKELY IMPACT THAT WELLHEADS WOULD HAVE ON THEM

Fishery Description of likelihood of fisheries

interaction with wellhead on the seafloor

Impact Description

Demersal trawl Evidence of trawling up to a depth of 600 m, just

adjacent to the northern edge of the drilling area.

Currently no trawling in drilling area.

Based on current fishery operation

locations there would be NO IMPACT.

Possible future expansion of the fishery into the

drilling area cannot be ruled out.

Medium intensity but LOW significance

due to low probability of expansion.

INSIGNIFICANT IMPACT with mitigation

of over-trawlable structure in place.

Mid-water trawl Isolated trawls up to 650 m depth. No overlap with

drilling area. Also by definition mid-water trawl

nets mostly do not touch the seabed

As there is no overlap NO IMPACT is

expected.

Demersal longline Fishing area lies adjacent to the drilling area to the

north, but does not coincide with the area.

The nature of this fishery is such that equipment

can get caught on seabed obtrusions. Thus lines

could get entangled on either a wellhead or over-

trawlable structure.

As there is no overlap there would be NO

IMPACT.

In highly unlikely event that the fishery

was to expand into the drilling area,

entanglement of lines on a wellhead

could occur. However, in comparison to

demersal trawl there would be no

resultant safety issue – rather the issue

would be one of equipment damage only.

Although infrequent, there are various

records of entanglement with reefs and

corals.

Large pelagic longline Although the drilling area coincides with the

extensive area of this fishery, the targeted fishing

depth is approximately 40 m, and thus seabed

infrastructure is unlikely to pose a threat.

As this is effectively a surface fishery, NO

IMPACT on this sector is anticipated.

South Coast Rock Lobster The drilling area does not coincide with the lobster

trap grounds as the area is deeper than the depth

range of rock lobster species

As the areas do not coincide there is no

impact NO IMPACT.

Fisheries

Research

Trawling Research trawls mostly between the coast and

1 000 m depth, with occasional trawls of up to

1 300 m.

As the areas do not coincide there is no

impact NO IMPACT.

Seismic Seismic surveys have extended into the north-

western extent of the drilling area. Acoustic survey

techniques use surface equipment.

NO IMPACT as surveys are surface based.

Assessment

An abandoned wellhead may pose an obstruction to any fishing activity directed towards the seabed (namely

any demersal fishery). The potential impact is the loss of catch as a result of preclusion from fishing grounds

around the abandoned wellhead(s). The risk of the impact of up to 10 abandoned wellheads within the

approved well-drilling area in Licence Block 11B/12B is low, as currently the only fishery identified as being

operational within the area is pelagic in nature rather than demersal.



720.20047.00003

November 2018

26

The risk of impact on future demersal trawling activities can only relate to the opening of new fisheries based

on the discovery of additional stocks for exploitation in the affected area. The probability of this occurring is

considered to be possible.

The proposed abandonment of wellheads within the approved drilling area would likely affect future demersal

trawl operations through exclusion from localised areas of fishing grounds. The impact of exclusion from fishing

grounds is assessed to be of medium intensity (causing a moderate change to normal fishing processes). The

medium rating is given with consideration to the advanced navigational capacity of deepsea trawlers, where

often the trawl net can be accurately guided over subsea obstacles when the position of such obstacles is

charted. The overall consequence of the impact is likely to be medium but of low overall significance due to the

relatively low probability of expansion of fishing activity into the area (see Table 6-3).

Mitigation

The impact on future fishing activities could be reduced to overall insignificance if the wellhead were fitted

with an over-trawlable structure (see Figure 6-1), to minimise the risk of damage to trawl gear and vessels.

TABLE 6-3: IMPACT ON DEMERSAL FISHING OF LEAVING WELLHEADS ON THE SEAFLOOR

Impacts of demersal fishing: wellhead remains on the seafloor during abandonment

Without Mitigation Assuming Mitigation

Intensity Medium Very Low

Duration Permanent Permanent

Extent Local Local

Consequence Medium Very Low

Probability Possible Possible

Significance Low INSIGNIFICANT

Status Negative Negative

Confidence Medium Medium

Nature of Cumulative impact Cumulative impacts at depths beyond 500 m are considered negligible.


reversed

Irreversible – wellheads will be permanently abandoned and changes in seabed structure

would thus also be permanent.

Degree to which impact may cause

irreplaceable loss resources

Low


mitigated

Medium



720.20047.00003

November 2018

27

FIGURE 6-1: EXAMPLE OF AN OVER-TRAWLABLE STRUCTURE

Risk Considerations

The fisheries specialist study provided a snag risk assessment related to leaving a wellhead on the seafloor.

The risk scale ranges from zero for pelagic fisheries too low for mesopelagic fisheries to medium for demersal

longline and high for demersal trawl sectors. The risk only applies when the wellhead is in a fishing ground. The

snag risk assessment is shown below:

Definition of snag-risk ratings:

High Risk – Incorporate risk reduction measures. A major potential accident event is probable based on the

intensity of fishing and associated gear type. Fishing operations are altered to the extent that they temporarily

or permanently cease.

Medium Risk – Incorporate risk reduction measures

A major potential accident event is possible based on the intensity of fishing and associated gear type. Fishing

operations continue, albeit in a modified way.

Low Risk – Manage for continuous improvement.

A major potential accident event is improbable based on the intensity of fishing and associated gear type.

Fishing operations continue, albeit in a slightly modified way.

No Risk

A major potential accident event is improbable based on the intensity of fishing and associated gear type.

Fishing operations continue, albeit in a slightly modified way.

Demersal trawlers regularly snag obstructions of many forms and systematically use GPS to record new or

known snags and then alter course to avoid them in future. Snagging of trawl gear is a major risk. By way of

example, a South African deepsea trawler snagged a wreck on the south coast during adverse sea conditions

which resulted in the flooding of the aft deck and engine room and the sinking of the vessel with loss of crew

within minutes.



720.20047.00003

November 2018

28

Midwater nets are not equipped to run on the seabed; however, gear does approach close to the bottom and

there are records of midwater gear occasionally making contact with the seabed, either accidentally or

deliberately. A midwater net close to the bottom could foul a raised obstruction e.g. wreck, wellhead,

seamount, large boulder.

Demersal longlines that are used to target hake comprise a double line which allows for gear recovery using a

top line when the bottom line snags and parts. Skippers will, however, avoid known snag areas. In strong

current, gear can lift and move and drag onto snags. Gear will not be set in areas when the risk of total loss is

high. Demersal longlines can fish as deep as 2 000 m. These bottom-set lines are, however, difficult to set in

deep water and in strong currents and require specialised vessels with winches and with sufficient power and

line length to set at these depths.

Gear types associated with both midwater and demersal longlining are not expected to pose any risk to a well

or similar structure on the sea floor, although fouling on any hydrocarbon structure may result in loss of the

line gear.



720.20047.00003

November 2018

29

CONCLUSIONS AND RECOMMENDATIONS 7

This chapter draws conclusion to the EMPr Amendment and recommends a suggested way forward regarding

the application by TEPSA to leave wellheads on the seafloor in the drilling area.

MARINE FAUNA 7.1

Considering the ecosystem threat status of ‘least threatened’ in the drilling area, and the negligible proportion

of the benthic habitat type and the wider South-west Indian Offshore Bioregion potentially affected by the

subsea infrastructure, the specialist marine fauna study concluded that there is no reason why the wellheads

should not be left in place on the seabed.

FISHERIES 7.2

The proposed TEPSA drilling area is located in a water depth of between 500 m and 2 000 m. In a fisheries

context, trawl fisheries have been confined to the “shelf” referring to the “continental shelf”. Historically

trawling in South African waters has been confined to depths shallower than 500 m. Generally, depths beyond

500 m are defined as being on “the shelf edge” and an area that drops off steeply and of rougher substrate

type.

The fisheries specialist study concludes that possible future demersal trawling is the only likely fishery that

could present a problem related to fouling with a wellhead in the drilling area. This could mean loss of the

trawl gear, loss of trawl warps, and in extreme cases, loss of the vessel due to loss of stability resulting from the

fouling.

Historical records of research trawling in the vicinity of the approved drilling area provide support for the

future expansion of trawling into the area:

• Hake directed bottom trawling in the last decade has systematically targeted fish in increasing water

depths.

• There has in the past been interest in the shelf drop off for trawling for deep-water species, specifically

orange roughy (Hoplostehus sp.), deep-water dories (oreos), cardinal fish, alfonsino and various other

species. There are established trawl fisheries for these species in Namibia and on the South West Indian

Ocean Ridge that fish in depths of between 1 000 m and 2 000 m. All of these species occur off the

Agulhas Bank and there continues to be interest in their commercial potential.

• In the mid 1990’s South Africa did have an experimental fishery for Oreo Dorie extending from south of

Cape Point towards the tip of the Agulhas Bank and further east. The trawling industry lost interest in the

fishery due to low abundance of the target species and high risk to the trawl gear.

• In the early to mid 1990’s one operator undertook a comprehensive side scan sonar survey for orange

roughy along the edge of the Agulhas Bank. Although seamounts and other suitable habitat was found

for orange roughy, viable commercial quantities were not found.



720.20047.00003

November 2018

30

• The Department of Agriculture Forestry and Fisheries (DAFF) has also undertaken deep-water

exploratory trawling for deep-water species in the TEPSA drilling area. The results of these trawls have

shown the area to be of high risk to trawling.

Factors inhibiting the expansion of trawling into the drilling area include the following:

• The combination of depth and strong currents is the greatest deterrent to trawling for deep-water

species off the south and south eastern Agulhas Bank. The risk of losing trawl gear at these depths is

high.

• The Agulhas Current can reach 5 kts in places, it is irregular (and retroflects from westward moving to

eastwards) and may reverse at depth i.e. surface flowing currents may flow in the opposite direction at

the bottom.

• Weather and sea conditions are more extreme in the area, increasing the risk of losing trawl gear.

• The shelf edge and substrate type is of a generally high profile and unless suitable flat trawling ground

can be found, is difficult to trawl.

• Evidence of commercial quantities of deep-water species have to date not been found.

• Currently, targeting deep-water species is not permitted – if a fishery at these depths is found, the

trawling industry will need to apply for experimental fishing licenses.

• The area extending from the tip of Agulhas Bank eastwards to East London in depths up to 2 000 m has

been shown to have unique cold water corals and have been classified in places as a “Vulnerable Marine

Ecosystem” of VMEs. There is scientific interest in the area related to VMEs, specific habitat types and

corals. While there are no current restrictions to fishing in the area, the possibility that some habitats

may be protected in the future cannot be ruled out.

The specialist study concludes that there is currently no active fishery that would be affected by the proposed

application to abandon a wellhead in the project area. The possibility that trawling may occur in the proposed

area in the future cannot be ruled out; however, and the trawl gear used would pose a risk of damage to the

trawler should snagging occur. This risk could be mitigated by providing an over-trawlable structure to the

wellhead. Making the structure over-trawlable would mitigate the risk of damage to the fishing operation as

well as to potential damage to the wellhead.

EAP RECOMMENDATION 7.3

The findings of both specialists studies conclude that in terms of marine biophysical environment and the

current extent of fisheries, that the impact of leaving a wellhead on the seafloor would of low to negligible

significance.

The critical issue that needs to be evaluated in the decision-making process, is the implication of wellhead

infrastructure on future fisheries, specifically demersal trawl. There are indications that the demersal trawl

fishery could extend into deeper waters in the area proposed for drilling (although there are a number of

mitigations factors that also suggest fishing in deepwater with the strong Agulhas current may itself pose

problems), and could thus be affected by any infrastructure left on the seafloor. Should such a future risk not

be considered acceptable – then mitigation in the form of an over-trawlable structure should be a requirement

for well completion status within the approved drilling area. Such structures are assessed to be adequate to

remove the residual risk to future fisheries.



720.20047.00003

November 2018

31

EMPR MANAGEMENT ACTIONS 8

This chapter lists the specific environmental management actions and procedures required to avoid or

minimise impacts on the environment from the proposed exploration well drilling programme. It also indicates

who is the responsible party and includes a compliance audit column for auditing purposes and the

requirements for closure. The specific environmental protection activities and procedures are addressed under

each of the project life cycle phases listed below.

8.1 PRE-ESTABLISHMENT PHASE

8.1.1 Pre-drilling planning

8.1.2 Preparation for emergencies

8.1.3 Financial provision

8.1.4 Approval of EMP

8.2 ESTABLISHMENT PHASE

8.2.1 Compliance with the environmental management plan

8.2.2 Notifying other users of the sea

8.2.3 Well / anchor position to avoid sea obstacles /

installations

8.2.4 Ensure integrity of anchor system

8.3 OPERATIONAL PHASE

8.3.1 Adherence to the EMP and Environmental Awareness

8.3.2 Continue to communicate with other users of the sea and

resource managers

8.3.3 Prevention of emergencies

8.3.4 Dealing with emergencies including major oil spills

8.3.5 Blow out prevention during well drilling

8.3.6 Disposal of drilling muds and cuttings

8.3.7 Disposal of ballast water

8.3.8 Well testing

8.3.9 Rig installation, anchor laying and well infrastructure

installation

8.3.10 Transport, storage and handling of radioactive devices

8.3.11 Pollution control and waste management of products

disposed of: into the air

8.3.12 Exclusion of other marine users from access to the

operational area for safety reasons

8.3.13 Equipment loss



720.20047.00003

November 2018

32

8.3.14 Use of helicopters

8.3.15 Oil bunkering / refuelling at sea

8.3.16 Drill Rig lighting

8.3.17 Benthic fauna

8.4 DECOMMISSIONING AND CLOSURE

PHASE

8.4.1 Completion of wells

8.4.2 Drilling unit / vessels to leave area

8.4.3 Inform key stakeholders of survey completion

8.4.4 Final waste disposal

8.5

MONITORING, COMPLIANCE

AUDITING AND THE SUBMISSION

OF INFORMATION PHASE

8.5.1 Performance assessment / monitoring activities and

effects

8.5.2 Compile well drilling “close-out” report



720.20047.00003

November 2018

33

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES

AUDITABLE MANAGEMENT ACTIONS TO BE TAKEN TO MEET THE EMP

REPORT OBJECTIVES (WELL DRILLING)

COMPLIANCE RESPONSI-

BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

PRE-ESTABLISHMENT PHASE 8.1

8.1.1

Pre-drilling

planning

Accommodation of

needs for

environmental

monitoring and

liaison with fishing,

mining and other

industries

In order to minimise disruption to the drilling programme and 8.1.1.1

other users of the sea:

a) Communicate with fishing operators and the marine diamond

mining industry, as well as other vessels, regarding (1) safety

zone around the drilling unit, and (2) the timing and duration

of drilling in order to minimise disruption to the drilling

programme and other activities in the area.

TEPSA and

Contractor

Prior to

commencemen

t of operations

Provide records

of meetings

held and copies

of all

correspondence

8.1.2

Preparation for

emergencies

Preparation for any

emergency that

could result in an

environmental

impact

Have the following emergency plans, equipment and personnel in 8.1.2.1

place to deal with all emergencies:

a) Company (or representative) Emergency Response Plan. (all

contractors ER Plans to be bridged with Company plan)

b) Drilling unit contractor Emergency Response Plan (including

MEDIVAC plan).

c) Support vessel contractor Emergency Response Plan

(including MEDIVAC plan).

d) Helicopter Operator Emergency Response Plan.

e) South African Search and Rescue (SASAR) Manual.

f) Oil Spill Contingency Plan (OSCP) approved by the South

African Maritime Safety Authority (SAMSA). Note that in case

of a major oil spill, emergency responses and/or Oil Pollution

Contingency Plan(s) refer to the coastal oil spill contingency

plan(s) of DEA:MCM.

In addition to the above, ensure that: 8.1.2.2

a) Drilling unit must have Pollution Safety Certificate(s) issued

by SAMSA.

b) There is adequate protection and indemnity insurance cover

for oil pollution incidents.

c) There is a record of the drilling units and support vessel’s

seaworthiness certificate and/or classification stamp.

TEPSA and

Contractor

Prior to

commencemen

t of operation

Confirm

compliance and

maintain copies



720.20047.00003

November 2018

34

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

8.1.3

Financial provision

Compliance with

legislative

requirements

Ensure that financial provision is in place for the rehabilitation 8.1.3.1

and management of negative environmental impacts associated

with exploration drilling in Block 11B/12B. Such Financial

provision must be approved by PASA.

TEPSA and

Contractor

Prior to

commencemen

t of operations

Confirm that

financial

provision has

been put in

place

8.1.4

Approval of EMP

Compliance with

legislative

requirements

Ensure that the EMP has been approved by the Minister. 8.1.4.1 TEPSA and

Contractor

Prior to

commencemen

t of operations

Authorisation

letter

ESTABLISHMENT PHASE 8.2

8.2.1

Compliance with

environmental

management plan

Operator and

contractor to

commit to

adherence to EMP

Ensure that a copy of the approved EMP report and all 8.2.1.1

Authorisations is supplied to all Contractors and is on board the

drilling unit and support vessels during the operation and:

a) Ensure procedures and systems for compliance are in place.

b) Appropriately inform the drilling unit’s and support vessel’s

personnel of the purpose and requirements of the EMP.

c) Ensure correct equipment and personnel are available to

meet the requirements of the EMP.

d) Ensure responsibilities are allocated to personnel.

e) Contractor complies to the requirements of the EMP.

TEPSA and

Contractor

Prior to

commencemen

t of operation

Ensure that a

copy of the

EMP report is

provided to the

Drilling

contractor and

that an

acknowledgme

nt of receipt

form is signed

by the

Contractor

8.2.2

Notifying other

users of the sea

Ensure that other

users are aware of

the drilling

programme

TEPSA and its contractors must notify key stakeholders of the 8.2.2.1

navigational co-ordinates of the well drilling site/s and keep them

updated on the well drilling programme. The following

stakeholders shall be notified:

a) Overlapping and neighbouring users with delineated

boundaries in the oil and gas exploration and production

industries and any mining industries.

b) SAN Hydrographic Office. (Silvermine).

c) South African and foreign fishing vessels including:

Association of Small Hake Industries, SA Deep Sea Trawling

Industry Association, SA Inshore Fishing Industry Association,

South East Coast Inshore Fishing Association, SA Midwater

TEPSA and

Contractor

30 days prior to

start

Confirm that

notices were

sent to relevant

parties

Provide copy of

standard notice

and list of those

to whom it was

sent



720.20047.00003

November 2018

35

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

Trawling Association, SA Tuna Association, Fresh Tuna

Exporters Association, South Coast Rock Lobster Association,

Shark Longline Association, SA Pelagic Fishing Industry

Association, SA Commercial Linefish Association, and SA

Squid Management Industrial Association.

d) Fisheries and Mariculture Development Association.

e) Government departments with jurisdiction over marine

activities, particularly DEA, DEA: MCM and PASA.

f) SAMSA and local Port Captains.

TEPSA must request, in writing, the SAN Hydrographic Office 8.2.2.2

(Silvermine) to release Radio Navigation Warnings and Notices to

Mariners throughout the drilling period. The Notice to Mariners

should give notice of (1) ordinates of the well drilling activity, (2)

500 m safety zone around drilling unit, (3) well drilling

timeframes, and (4) a special note on the hazard posed by the

anchor chains and anchors.

8.2.3

Well / anchor

position to avoid

sea obstacles /

installations

Ensure that well

and anchor

positions will not

affect obstacles /

installations on the

seabed

Ensure that 8.2.3.1

a) no other mining / exploration activity, pipeline or

telecommunication cable will be affected by the drilling

activities.

b) Ensure known ammunition dumps are avoided.

c) Wells to avoid any shipwrecks and any other cultural heritage

/ archaeological material.

Notify the South African Heritage Resource Agency (SAHRA) 8.2.3.2

regarding requirements to disturb any such wrecks or any cultural

heritage / archaeological material.

TEPSA Prior to drilling

or as required

Copy of permit

from SAHRA (if

required)

8.2.4

Ensure integrity of

anchor system

Reduce

environmental risk

by minimising risk

of failures during

operation

Undertake and/or have in place the following in order to minimise 8.2.4.1

environmental risk:

a) A hazard identification and risk assessment document;

b) The Contractor must apply relevant national codes and

standards in accordance with good oil / gas field practice;

c) The Contractor must operate in accordance with procedures

Contractor

Prior to and

throughout

drilling

operations



720.20047.00003

November 2018

36

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

laid down in the vessel’s marine operations manual as

approved by the relevant classification society;

d) All anchor chains and anchors must be certified; and

e) The drilling unit(s) / vessel(s) must be maintained to class

standard throughout the project.

OPERATIONAL PHASE 8.3

8.3.1

Adherence to the

EMP and

Environmental

awareness

Operate in an

environmentally

responsible manner

Comply fully with the EMP (compliance would mean that all 8.3.1.1

activities were undertaken successfully and details recorded and

included in the Close-out Report).

Subscribe to the principles of an internationally acceptable 8.3.1.2

Environmental Management System onboard the drilling unit and

support vessels. This includes environmental awareness training,

waste management and environmental monitoring, record

keeping and continuous improvement.

TEPSA and

Contractor

Throughout

programme

Before

deployment to

site

Provide copies

of records

Certificate of

training

8.3.2

Continue to

communicate with

other users of the

sea and resource

managers

Promote co-

operation and

successful multiple

use of the sea,

including promotion

of safe navigation

Through normal communication channels, Radio Navigation 8.3.2.1

Warnings and Notices to Mariners, keep the following interested

and affected parties updated on the drilling programme:

a) Overlapping and neighbouring users with delineated

boundaries in the oil and gas exploration and production

industries and any mining industries.

b) SAN Hydrographic Office (Silvermine).

c) South African and foreign fishing vessels including:

Association of Small Hake Industries, SA Deep Sea Trawling

Industry Association, SA Inshore Fishing Industry Association,

South East Coast Inshore Fishing Association, SA Midwater

Trawling Association, SA Tuna Association, Fresh Tuna

Exporters Association, South Coast Rock Lobster Association,

Shark Longline Association, SA Pelagic Fishing Industry

Association, SA Commercial Linefish Association, and SA

Squid Management Industrial Association.

d) Fisheries and Mariculture Development Association.

e) Government departments with jurisdiction over marine

activities, particularly DEA, DEA:MCM and PASA.

TEPSA and

Contractor

During

operations as

required

and on

completion of

drilling

Provide copies

of written

notices and list

of those to

whom it was

sent



720.20047.00003

November 2018

37

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

f) SAMSA and local Port Captains.

Keep constant watch for approaching vessels during the drilling 8.3.2.2

programme and warn by radio and standby vessel, if required.

Take steps to share information and co-operate with other 8.3.2.3

marine users and resource managers in the marine environment

generally, to their mutual benefit.

8.3.3

Prevention of

emergencies

Minimise the

chance of

emergency and

subsequent

damage to the

environment

occurring

Prevent collisions by ensuring that the drilling unit and support 8.3.3.1

vessels display correct signals by day and lights by night (including

twilight), by visual radar watch and standby vessel(s).

Ensure that all well locations are surveyed and accurately charted 8.3.3.2

with the SA Navy Hydrographer.

The law also requires equipment and training to ensure the safety 8.3.3.3

and survival of the crew in the event of an accident.

Service equipment regularly and practice weekly emergency 8.3.3.4

response drills, etc. (refer to Mine Health and Safety Act and

regulations).

Establish lines of communication with the following emergency 8.3.3.5

response agencies / facilities: SAN Hydrographic Office

(Silvermine), SAMSA, DEA (Directorate of Marine Pollution), PASA

and DEA: MCM, MRCC

Ensure all hazardous materials are correctly labelled, stored, 8.3.3.6

packed and sealed with proper markings for shipping.

TEPSA and

Contractor

Throughout

operation

Provide copies

8.3.4

Dealing with

emergencies

including major oil

spills (owing to

collision, vessel

break-up,

refuelling etc.)

Minimise damage

to the environment

by implementing

response

procedures

efficiently

Adhere to obligations regarding other vessels in distress. 8.3.4.1

Implement health and safety procedures 8.3.4.2

Notify SAMSA about wrecked vessels (safety and pollution) and 8.3.4.3

the Department of Finance (salvage, customs, royalties). Give

location details to SAN Hydrographer.

In the event of an oil spill immediately implement emergency 8.3.4.4

plans and notify (a) the Principal Officer of the nearest SAMSA

office, (b) the DEA's Chief Directorate of Marine Pollution in Cape

Town and (c) PASA. Information that should be supplied when

reporting a spill includes:

TEPSA and

Contractor

In event of spill Record of all

spills (Spill

Record Book),

including spill

reports;

emergency

exercise

reports; audit

reports.

Incident log



720.20047.00003

November 2018

38

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

a) The type and circumstances of incident, ship type, port of

registry, nearest agent representing the ships company;

b) Geographic location of the incident, distance off-shore and

extent of oil spill;

c) Prevailing weather conditions, sea state in affected area

(wind direction and speed, weather and swell); and

d) Persons and authorities already informed of the spill.

Where diesel, which evaporates relatively quickly, has been 8.3.4.5

spilled, the water should be agitated or mixed using a propeller

boat/dinghy to aid dispersal and evaporation.

Dispersants should not be used without authorisation of DEA. 8.3.4.6

Dispersants should not be used:

a) On diesel or light fuel oil.

b) On heavy fuel oil.

c) On slicks > 0.5 cm thick.

d) On any oil spills within 5 nautical miles off-shore or in depths

less than 30 metres.

e) In areas far offshore where there is little likelihood of oil

reaching the shore.

Dispersants are most effective: 8.3.4.7

a) On fresh crude oils; under turbulent sea conditions (as

effective use of dispersants requires mixing).

b) When applied within 12 hours or at a maximum of 24 hours.

The volume of dispersant application should not exceed 20-30% 8.3.4.8

of the oil volume.

In the unlikely event of an uncontrolled gas or oil blow-out the 8.3.4.9

first objective is to ensure the safety of personnel followed by

efforts to move the drilling unit from the pool of upwelling gas

into safe waters. Once the safety of lives and equipment has been

assured the well can be brought under control using

internationally established procedures.



720.20047.00003

November 2018

39

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

8.3.5

Blow out

prevention during

well drilling

Ensure that the

necessary

safeguards are in

place and avoid any

uncontrolled

release of drilling

fluids, oil and/or

gas

Blow out preventers (BOPs) installed on wells during drilling must 8.3.5.1

be “fit for purpose” (i.e. appropriate for intended use,

dependable and effective when required and able to perform as

intended).

Undertake a shallow hazards analysis to address shallow gas and 8.3.5.2

shallow water flows.

Fully inspect the BOPs on the drilling unit(s) in accordance with 8.3.5.3

the American Petroleum Industries recommended practices (or

equivalent) prior to well drilling.

Ensure that all responsible personnel are qualified in accordance 8.3.5.4

with International Well Control Forum requirements or equal and

are adequately trained in both accident prevention and

immediate response.

Follow written and internationally established procedures for well 8.3.5.5

control.

Identify hazards and put risk control systems in place. 8.3.5.6

Implement monitoring and management to assist in the detection 8.3.5.7

of uncontrolled gas or oil releases.

TEPSA and

Contractor

Prior to and

during drilling

8.3.6

Disposal of drilling

muds and cuttings

Minimise

discharges into the

sea

The following mitigation measures should be implemented when 8.3.6.1

using NADF:

a) NADF should not be used in the upper part of a well (with the

exception in cases of geological or safety reasons) as specific

by the OSPAR Convention.

b) The drilling fluid should be centrifuged to remove as much of

the finer particles as possible.

c) Only Synthetic Based Drilling Fluid (OGP Type III) should be

used with a low polycyclic aromatic hydrocarbon content.

d) All recovered NADF should be stored on board and taken to

shore for treatment and reuse.

e) NADF cuttings should be treated to reduce oil-content on

cuttings to < 5% of weight before discharge to the sea.

f) NADF cuttings should be discharged 10 m below the sea

Contractor

During drilling

operation

Provide

estimates of

actual volumes

of muds and

cuttings

disposed.



720.20047.00003

November 2018

40

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

surface.

Optimally recycle the mud for use downhole to minimise mud 8.3.6.2

disposal overboard and reduce concentrations of mud chemicals

released.

Where they are used ROV’s should obtain video footage of the 8.3.6.3

seabed before and after drilling operations to assess the status of

cuttings disposal on the benthos.

8.3.7

Disposal of Ballast

water

Minimise the

discharge of ballast

water into the sea

and reduce the

possibility of an

impact

Avoid the unnecessary discharge of ballast water. 8.3.7.1

Adhere to the guidelines for management of ballast water 8.3.7.2

provided by the International Maritime Organisation (Guideline

A.868(20)).

Ensure that the drilling vessel has in place a ballast water 8.3.7.3

management plan.

Whenever possible, conduct the exchange of ballast water at 8.3.7.4

least 200 nautical miles from the nearest land and in water at

least 200 m in depth. Where this is not possible, the exchange

should be as far from the nearest land as possible, and in all cases

a minimum of 50 nautical miles from the nearest land and in

water at least 200 m in depth.

During the loading of ballast, every effort should be made to 8.3.7.5

avoid the uptake of potentially harmful aquatic organisms,

pathogens and sediment that may contain invasive organisms,

through adequate filtration procedures.

Where practicable, routine cleaning of the ballast tank to remove 8.3.7.6

sediments should be carried out in mid-ocean or under controlled

arrangements in port or dry dock.

Contractor

Throughout

drilling

operation

Provide

estimates of

actual volumes

of ballast water

disposed,

distance and

water depth

ballast water

was disposed.

8.3.8

Well testing

Ensure that there

are minimal

discharges into the

sea and minimise

product burned

Use high efficiency flare to maximise combustion of 8.3.8.1

hydrocarbons.

Use well control procedures to ensure that there are no 8.3.8.2

discharges to the sea.

For each drillstem flow test, provide an estimate of the volume of 8.3.8.3

any oily discharge into the sea and the size of the resulting slick /

sheen.

Contractor During well

testing

Quantity of gas

burned



720.20047.00003

November 2018

41

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

8.3.9

Rig installation,

anchor laying and

well infrastructure

installation

Minimise

disturbance to the

sea floor

Pre-drilling site surveys should ensure that drilling and anchoring 8.3.9.1

locations are not located within a 1 km radius of any vulnerable

habitats (e.g. hard grounds), species (e.g. cold corals, sponges) or

structural features (e.g. rocky outcrops).

Dynamically positioned vessels should be used in preference to 8.3.9.2

vessels requiring anchorage, if possible.

TEPSA and

Contractor

During pre-

drilling surveys

Throughout

drilling

operations

8.3.10

Transport, storage

and handling of

radioactive devices

Avoid human and

environmental

exposure to radio-

active material

Comply with necessary regulations for the transport, storage and 8.3.10.1

handling of radioactive devices. Transport and store radioactive

devices in specially designed secured (locked) storage containers.

Designate competent person/s in charge and to handle the 8.3.10.2

radioactive devices. Follow strict approved procedures when

handling the devices. Wear personal monitoring devices to

measure any unusual exposure.

Follow radioactive sources procedure. When radioactive sources 8.3.10.3

are to be used, secure the area between and around the storage

containers and the floor and only allowed key personnel in the

area.

Set up incident and emergency reporting procedures for actual or 8.3.10.4

suspected individual over-exposure, theft or loss, logging tools

stuck downhole in wells, and release or spillage into the

environment.

Test the sources every three to six months to document leak 8.3.10.5

levels.

TEPSA and

Contractor

Throughout

drilling

operations

Provide results

from routine

tests on

radioactive

sources to

determine leak

levels

8.3.11

Pollution control

and waste

management of

products disposed

of: into the air

(exhausts, cfcs and

incinerators), to

sea (sewage, food,

Minimise pollution,

and maximise

recycling by

implementing and

maintain pollution

control and waste

management

procedures at all

times

Comply with legal requirements for waste management and 8.3.11.1

pollution control (for air and water quality levels at sea) and

employ “good housekeeping” and monitoring practices.

a) General waste: Initiate a waste minimisation system. No

disposal overboard.

b) Galley (food) waste: Dispose overboard after macerating

according to MARPOL standard (less than 25 mm size) –

prohibited if distance to nearest land is < 3 nautical miles.

Disposal overboard without macerating – vessel must be 12

nautical miles from coast.

Contractor

Throughout

drilling

operations

Provide

summary of

waste record

book / schedule

and receipts

Report

occurrence of

minor oil spills

and destination



720.20047.00003

November 2018

42

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

oils), to land (used

oils etc, metals,

plastics, glass, etc.)

c) Medical waste: Seal in aseptic containers for appropriate

disposal onshore.

d) Metal: Send to shore for recycling or disposal.

e) Other waste: Send remaining waste to a licensed waste site.

Ensure waste disposal is carried out in accordance with

appropriate laws and ordinances.

f) Waste oil: Return used oil to a port with a registered facility

for processing or disposal.

g) Wastewater: Comply with MARPOL.

h) Minor oil spill: Use oil absorbent.

i) Emissions to the atmosphere: Properly tune and maintain all

engines, motors, generators and all auxiliary power to

contain the minimum of soot and unburned diesel.

j) Deck drainage: Deck drainage should be collected in oily

water separator systems. Ensure that weather decks are kept

free of spillage. Mop up any spills immediately with

biodegradable low toxicity detergents. Ensure compliance

with MARPOL standard.

k) Machinery space drainage: Drilling unit and supply vessels

must comply with international agreed standards regulated

under MARPOL.

l) Sewage - use approved treatment plants to the MARPOL

standard.

Ensure all crew is trained in spill management. 8.3.11.2

Record types and volumes of chemical and hazardous substances 8.3.11.3

brought on board (e.g. radioactive devices/materials, neon lights,

toner cartridges, etc.) and destination of wastes.

Ensure that a waste disposal contractor disposes of waste 8.3.11.4

returned to port at a licensed landfill site.

of wastes

8.3.12

Exclusion of other

marine users from

Minimise disruption

to other legitimate

users of the sea by

respecting their

Co-operate with other legitimate users of the sea to minimise 8.3.12.1

disruption to other marine activities and marine fauna.

Use effective communication channels (see Section 3.2) to inform 8.3.12.2

all other potential users about the drilling location, timing,

Contractor Throughout

drilling

operations

Confirm that

notices were

sent to relevant

parties



720.20047.00003

November 2018

43

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

access to the

operational area

for safety reasons

(shipping,

including fishing

and mining

vessels)

rights. priority of passage safety, 500 m exclusion zone and general

safety distances. To avoid any interference with anchors and

anchor chains it is suggested that the Notice to Mariners advises

of a stay clear area of 1 500 m from the corners of the drilling

unit(s), if applicable.

Provide copy of

standard notice

and list of those

to whom it was

sent

Record any

incidents

outside of

normal

occurrence

8.3.13

Equipment loss

Minimise hazards

left on the seabed

or floating in the

water column, and

inform relevant

parties

Keep a record of lost equipment and all items lost overboard and 8.3.13.1

not recovered.

When any items that constitute a seafloor or navigational hazard 8.3.13.2

are lost on the seabed, or in the sea, complete a standard form /

record sheet, which records the date and cause of loss, details of

equipment type, etc.

Pass information to PASA and SAMSA. Notify SAN Hydrographer, 8.3.13.3

relevant mining companies and fishing associations. SAN

Hydrographer will send out Notice to Mariners with this

information.

Contractor

Throughout

drilling

operation

Provide a list of

lost equipment

and a copy of

record sheet

8.3.14

Use of helicopters

for crew changes,

servicing, etc.

Minimise

disturbance /

damage to marine

and coastal fauna.

Establish, with pilots, flight paths that do not over-pass Ramsar 8.3.14.1

sites, islands, coastal reserves, bird and seal breeding or bird

breeding colonies / sanctuaries on the coast (minimum altitudes

of 2 000 feet above ground level over nature conservation areas).

Extensive coastal flights (parallel to the coast within 1 nautical 8.3.14.2

mile of the shore) should also be avoided. There is a restriction of

coastal flight on the South Coast between June and November in

order to avoid Southern Right Whale breeding areas.

Aircraft may not approach to within 300 m of whales. 8.3.14.3

Deviations from set flight plans must be reported. 8.3.14.4

Brief all pilots on the ecological risks associated with over flights 8.3.14.5

of seabird and seal colonies.

TEPSA and

Contractor

As required Submit copy of

set flight path.

Report

deviations from

set flight paths.



720.20047.00003

November 2018

44

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

8.3.15

Oil bunkering /

refuelling at sea

Minimise

disturbance /

damage to marine

life.

No discharge of any oil whatsoever is permitted within 50 nautical 8.3.15.1

miles of the coast.

Transfer of oil at sea is not permitted within the economic zone 8.3.15.2

(i.e. 200 miles from the coast) without the permission of the

Minister. In terms of the Marine Pollution (Control and Civil

Liability) Act (1981) a Pollution Safety Certificate must be

obtained before commencement of operations.

Submit an application in terms of Regulation 14 (Regulation under 8.3.15.3

the Prevention and Combating of Pollution of the Sea by Oil Act,

1984) to the Principal Officer at the port nearest, should

bunkering of oil be undertaken. Permission would cover the

duration of the drilling period.

Contractor Before

commencemen

t of operations

8.3.16

Drill Rig lighting

Minimise attraction

of marine fauna to

drilling unit(s)

Consider light shielding in order to reduce seabird mortalities. 8.3.16.1

Minimise non-essential lighting to reduce nocturnal attraction. 8.3.16.2

However, such measures should not undermine work safety

aspects or concerns.

Minimise the discharge of waste material should obvious 8.3.16.3

attraction of fauna be observed.

Contractor

8.3.17

Benthic fauna

Improve knowledge

of offshore benthic

environment.

Identify any foreign

organisms

Any underwater inspections of infrastructure (ROV and SAT diver) 8.3.17.1

should be used as opportunities to acquire footage (close-ups and

stills) of marine life associated with the infrastructure. Where

possible, samples of any dense colonies of marine life should be

captured / collected and identified by a qualified marine

ecologist.

All visual footage of infrastructure should be inspected by marine 8.3.17.2

ecologists to detect any potential invasive species.

TEPSA and

Contractor

During

operations

DECOMMISSIONING AND CLOSURE PHASE 8.4

8.4.1

Completion of

wells

Ensure that there

are no leakages and

wherever possible

ensure that nothing

is left on the

seafloor

Seal the well by inserting concrete plugs in the well bore at 8.4.1.1

various levels according to good oilfield practice. Test well

integrity.

Remove BOP stack and any other equipment that may have been 8.4.1.2

dropped on the seafloor.

Contractor On completion

of well drilling

Confirmation of

activity

completed.

Provide

photographic

evidence or



720.20047.00003

November 2018

45

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

Place an over-trawlable structure/cap over the wellhead if left on 8.4.1.3

the seafloor. Ensure that seafloor is clear of any debris on

completion of placement of structure.

written receipt

from waste

disposal

contractor.

8.4.2

Drilling unit /

vessels to leave

area

Leave area as it

was prior to

operation

Ensure that no construction debris or dropped equipment that 8.4.2.1

may be detrimental to the environment or other users of the sea

is left on the seafloor.

Contractor On completion

of well drilling

Confirm, where

possible,

through seabed

scan and/or

video.

Provide log of

lost objects

8.4.3

Inform relevant

parties of drilling

completion

Ensure that

relevant parties are

aware that the

drilling operation is

complete

Inform all key stakeholders (see Section 2.2) that the drilling unit 8.4.3.1

and support vessels are off location.

8.4.3.2 Notify SAN Hydrographic Office of the location of the over-

trawlable structure and request that this be recorded on the

necessary hydrographic charts

TEPSA and

Contractor

Within one

weeks after

completion of

drilling

Copies of

notification

documentation

required.

8.4.4

Final waste

disposal

Minimise pollution

and ensure correct

disposal of waste

Dispose all waste retained onboard at a licensed waste site using 8.4.4.1

a licensed waste disposal contractor.

Contractor When vessel is

in port

Receipt

required from

contractor

MONITORING, COMPLIANCE AUDITING AND THE SUBMISSION OF INFORMATION PHASE 8.5

8.5.1

Performance

assessment /

monitoring

activities and

effects

Implement the

ongoing monitoring

programmes (in

conjunction with

government if

required)

Compile monitoring programme and EMP Performance 8.5.1.1

Assessments and submit to PASA.

Undertake appropriate monitoring (as per specific topics) and 8.5.1.2

track performance against objectives and targets. Document all

activities and results for internal and external auditing.

Ensure monitoring/observation of marine fauna from drilling unit, 8.5.1.3

including:

b) Record actual bird reaction to lights and real incidents of

injury or death. Ringed or banded birds should be reported to

the appropriate scheme (details on ring); and

c) Interaction with other vessels.

TEPSA and

Contractor

Daily

throughout

operations

The frequency

of performance

assessments

shall be as

recommended

by PASA

Provide all

recorded

information



720.20047.00003

November 2018

46

PROJECT PHASE

AND ACTIVITIES

ENVIRONMENTAL

OBJECTIVES




BILITY Timing

REQUIREMENT

FOR “CLOSE-

OUT” REPORT

8.5.2

Compile well

drilling “close-out”

report

Ensure corrective

action and

compliance and

contribute towards

improvement of

EMP

implementation

Compile a well drilling “Close-out” report for each well. 8.5.2.1

“Close–out” Report must be based on requirements of the 8.5.2.2

monitoring and EMP Performance Assessment.

Provide information / records as indicated in the “Close-out” 8.5.2.3

Report column of the EMP within 90-days of the drilling

operation.

Provide copy of report to PASA and DEA. 8.5.2.4

Provide a copy of any video footage that was shot during the 8.5.2.5

course of the drilling operation to PASA.

TEPSA On completion

of each well



720.20047.00003

November 2018

47

REFERENCES 9

Please refer to the specialist studies for a list of the references.

AFRICAN OFFICES

South Africa

CAPE TOWN

T: +27 21 461 1118

FOURWAYS

T: +27 11 467 0945

SOMERSET WEST

T: +27 21 851 3348

Namibia

WINDHOEK

T: + 264 61 231 287

SWAKOPMUND

T: + 264 64 402 317

Amendment of well completion status - slrconsulting.com · 1 It should be noted that the actual...

Documents

Transcript of Amendment of well completion status - slrconsulting.com · 1 It should be noted that the actual...