Maurel & Prom Namibia (Pty) Ltdeia.met.gov.na/screening/407_app_00407_emp_vol_3_of_3_m_p_nam… · Document ID: EMP Vol. 3 of 3 Report December 2019 Version.Final Owner: Maurel &

Document ID: EMP Vol. 3 of 3 Report December 2019 Version. Final Owner: Maurel & Prom (M & P) Namibia (Pty) Ltd

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MET ECC APPLICATION No. APP-00407

Maurel & Prom Namibia (Pty) Ltd

Final Environmental Management Plan (EMP) Vol. 3 of 3 Report to Support the Application for Environmental Clearance Certificate (ECC) for Proposed Multiple

Wells Drilling Operations in the Petroleum Exploration License (PEL) No. 44, Block 2212B, Offshore, Walvis Basin and Logistic Support Port of Walvis Bay (Shore

Base) and Walvis Bay International Airport / Arandis Airport (Aviation Base) CENTRAL OFFSHORE NAMIBIA

Maurel & Prom Namibia (Pty) Ltd 12, rue Volney, 75002 Paris

FRANCE

December 2019

Maurel & Prom Namibia (Pty) Ltd 8th Floor Channel Life Towers,

Post Street Mall, Windhoek P.O. Box 27544,

WINDHOEK, NAMIBIA


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CITATION: Risk-Based Solutions (RBS), 2019. Final Environmental Management Plan (EMP) Vol.

3 of 3 Report to Support the Application for Environmental Clearance Certificate (ECC) for all activities the Proposed Multiple wells Drilling Operations in the Petroleum Exploration License (PEL) No. 44, Block 2212B, Offshore, Walvis Basin Central Offshore Namibia

Environmental Management Plan (EMP) Vol. 3 of 3 Report

Date Issued Version Comments Prepared by Reviewed by Approved by

December 2019 Final ECC Application Risk-Based Solutions (RBS) CC

Maurel & Prom Maurel & Prom


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PROPOSED PROJECT SUMMARY INFORMATION

Petroleum Exploration License (PEL No.) PEL No. 44 covering 5,122 km2

Operator Maurel & Prom (M&P) Namibia (Pty) Ltd

Project Partners M & P 42.5% (Operator)

AziNam 42.5% National Petroleum Corporation of Namibia (Namcor) 8%

Livingstone Mining Resource Development 4% Frontier Mineral Resources 3%

Block No. Block 2212B

Initial No. Wells and Names Five (5) - Godmother, Aurora, Serenade

Harmony, Diapason and Diapason

M&P Namibia (Pty) Ltd Oversees Address 12, rue Volney 75002 Paris

FRANCE

M&P Namibia (Pty) Ltd Namibian Address Channel Life Towers,

8th Floor, Post Street Mall, Windhoek P.O. Box 27544, Windhoek

NAMIBIA

Environmental Consultants Risk-Based Solutions (RBS) CC

(Consulting Arm of Foresight Group Namibia (FGN) (Pty) Ltd) 41 Feld Street Ausspannplatz

Cnr of Lazarett and Feld Street P. O. Box 1839, WINDHOEK, NAMIBIA

Tel: +264 - 61- 306058; FaxMail: +264-886561821 Mobile: +264-811413229 /812772546

Email: [email protected] Global Office / URL: www.rbs.com.na

Environmental Assessment Practitioner (EAP)

Dr Sindila Mwiya PhD, PG Cert, MPhil, BEng (Hons), Pr Eng

mailto:[email protected]

http://www.rbs.com.na/


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Summary Profile and Qualification of the Environmental Assessment Practitioner (EAP) / International Consultant Projects Director – Dr Sindila Mwiya

Dr Sindila Mwiya has more than eighteen (18) years of direct technical industry experience in Environmental Assessment (SEA, EIA, EMP, EMS), Energy (Renewable and Non-renewable energy sources), onshore and offshore resources (minerals, oil, gas and water) exploration / prospecting, recovery and utilisation, covering general and specialist technical exploration and recovery support, Health, Safety and Environment (HSE) permitting for Geophysical Surveys such as 2D and 3D Seismic and Gravity Surveys for mining and petroleum (oil and gas) operations support, through to engineering planning, layout, designing, logistical support, recovery, production / operations, compliance monitoring, rehabilitation, closure and aftercare projects lifecycles. Through his companies, Risk-Based Solutions (RBS) CC and Foresight Group Namibia (FGN) (Pty) Ltd which he founded, he has undertaken more than 200 projects for local, regional (SADC) and international clients. Dr Sindila Mwiya has been responsible for permitting and technical support and continue to provide Health Safety and Environmental (HSE) monitoring for several renewable energy projects in Namibia including, the Omburu 5MW Solar PV Park, Osona 5MW Solar PV Park, Okahandja 10MW Solar PV Park, Otjiwarongo 5MW Solar PV Park, Grootfontein 10MW Solar PV Park, Tsumeb 5MW Solar PV Park, Otavi 3/5MW Solar PV Parks, Usakos 10MW Solar PV Park, Arandis 3MW Solar PV Park, Mariental 5MW Solar PV Park, Keetmanshoop 5MW Solar PV Park, Aussenkehr 5MW Solar PV Park, Elizabeth Bay Mine 10MW Wind Farm, Lüderitz 10MW Wind Farm and Tsau //Khaeb (Sperrgebiet) National Park near Lüderitz 50MW Wind Farm. On the non-renewable resources front, Dr Sindila Mwiya continue to work for global reputable resources (petroleum and mining / minerals) and energy companies such as CGG Services UK Limited (UK/ France), BW Offshore (Singapore), Shell Namibia B. V. Limited (Namibia/ the Netherlands), Maurel & Prom Namibia (Pty) Ltd Oil (UK), Debmarine (DBMN) (Namibia), Reconnaissance Energy Africa Ltd (ReconAfrica) (UK/Canada), Osino Resource Corporation (Canada/Germany/ Namibia), Desert Lion Energy Corporation (Canada/ Australia), Petrobras Oil and Gas (Brazil) / BP (UK), REPSOL (Spain), ACREP (Namibia/Angola), Preview Energy Resources (UK), HRT Africa (Brazil / USA), Chariot Oil and Gas Exploration (UK), Serica Energy (UK), Eco (Atlantic) Oil and Gas (Canada / USA), ION GeoVentures (USA), PGS UK Exploration (UK), TGS-Nopec (UK), Maurel & Prom (France), GeoPartners (UK), PetroSA Equatorial Guinea (South Africa / Equatorial Guinea), Preview Energy Resources (Namibia / UK), Sintezneftegaz Namibia LTD (Russia), INA Namibia (INA INDUSTRIJA NAFTE d.d) (Croatia) and Namibia Underwater Technologies (NUTAM) (Namibia). Dr Sindila Mwiya is highly qualified with extensive experience in petroleum, mining, renewable energy (Solar, Wind, Biomass, Geothermal and Hydropower), Non Renewable energy (Coal, Petroleum and Natural Gas), applied environmental assessment, management and monitoring (Scoping, EIA, EMP, EMP, EMS) and overall industry specific HSE, Cleaner Production programmes, Geoenvironmental, Geological and Geotechnical Engineering specialist fields. He has undertaken and continue to undertake and manage high value projects on behalf of global and local resources and energy companies. Currently, (2019-2021) Dr Sindila Mwiya is responsible for permitting planning through to operational and completion compliance monitoring, HSE and engineering technical support for multiple major upstream petroleum, minerals, mining and manufacturing operations in different parts of the World including Namibia. He continue to worked as an International Resources Consultant, national Environmental Assessment Practitioner (EAP), Engineering / Technical Consultant (RBS / FGN), Project Manager, Programme Advisor for the Department of Natural and Applied Sciences, Namibia University of Science and Technology (NUST) and has worked as a Lecturer, University of Namibia (UNAM), External Examiner/ Moderator, NUST, National (Namibia) Technical Advisor (Directorate of Environmental Affairs, Ministry of Environment and Tourism / DANIDA – Cleaner Production Component) and Chief Geologist for Engineering and Environment Division, Geological Survey of Namibia, Ministry of Mines and Energy and a Field-Based Geotechnician (Specialised in Magnetics, Seismic, Gravity and Electromagnetics Exploration and Survey Methods) under the Federal Institute for Geoscience and Natural Resources (BGR) German Mineral Exploration Promotion Project to Namibia, Geophysics Division, Geological Survey of Namibia, Ministry of Mines and Energy. He has supervised and continue to support a number of MScs and PhDs research programmes and has been a reviewer on international, national and regional researches, plans, programmes and projects with the objective to ensure substantial local skills development pivotal to the national socioeconomic development through the promotion of sustainable natural resources coexistence developmental and resources recovery approaches, utilisation, management and for development policies, plans, programmes and projects financed by governments, private investors and donor organisations. Since 2006 until 2017, he has provided extensive technical support to the Department of Environmental Affairs (DEA), Ministry of Environment and Tourism (MET) through GIZ and continued to play a significant role in the amendments of the Namibian Environmental Management Act, 2007, (Act No. 7 of 2007), preparation of new Strategic Environmental Assessment (SEA) Regulations, preparation of the updated Environmental Impact Assessment (EIA) Regulations as well as the preparation of the new SEA and EIA Guidelines and Procedures all aimed at promoting effective environmental assessment and management practices in Namibia. Among his academic achievements, Dr Sindila Mwiya is a holder of a PhD (Geoenvironmental Engineering and Artificial Intelligence) – Research Thesis: Development of a Knowledge-Based System Methodology (KBSM) for the Design of Solid Waste Disposal Sites in Arid and Semiarid Environments focusing on Namibia, MPhil/PG Cert and BEng (Hons) (Engineering Geology and Geotechnics), qualifications from the University of Portsmouth, School of Earth and Environmental Sciences, United Kingdom. During the 2004 Namibia National Science Awards, organised by the Namibian Ministry of Education, and held in Windhoek, Dr Sindila Mwiya was awarded the Geologist of the Year for 2004, in the professional category. Furthermore, as part of his professional career recognition, Dr Sindila Mwiya is a life member of the Geological Society of Namibia, Consulting member of the Hydrogeological Society of Namibia and a Professional Engineer registered with the Engineering Council of Namibia.

WINDHOEK DECEMBER 2019


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Content List

NON-TECHNICAL SUMMARY ............................................................................................................................. XI

1. INTRODUCTION............................................................................................................................................ XII 2. SUMMARY OF THE PROPOSED PROJECT DESCRIPTION .................................................................................. XII 3. REGULATORY REQUIREMENTS .................................................................................................................... XIII 4. OBJECTIVES OF THE EMP VOL 3 OF 3 REPORT ........................................................................................... XIII 5. SUMMARY OF THE EIA FINDINGS ................................................................................................................ XIII 6. THE EMP FRAMEWORK ............................................................................................................................. XVII

1. BACKGROUND ............................................................................................................................................. 1

1.1 OVERVIEW ................................................................................................................................................... 1 1.2 PURPOSE AND OBJECTIVES OF THIS EMP REPORT ........................................................................................ 1 1.3 SCOPE AND EXTENT OF THE ENVIRONMENTAL ASSESSMENT (EA) ................................................................ 2 1.4 PROJECT PARTNERS CORPORATE PROFILES ................................................................................................. 7

1.4.1 Overview ........................................................................................................................................... 7 1.4.2 Maurel & Prom Namibia (Pty) Ltd ..................................................................................................... 7 1.4.3 AziNam Limited ................................................................................................................................. 7 1.4.4 National Petroleum Corporation of Namibia (NAMCOR) .................................................................. 7 1.4.5 Other Partner .................................................................................................................................... 8

1.5 PROPOSED PROJECT ................................................................................................................................... 8 1.5.1 Overview ........................................................................................................................................... 8 1.5.2 Project Implementation ..................................................................................................................... 9 1.5.3 Logistical Arrangements ................................................................................................................... 9 1.5.4 Drilling Rig ....................................................................................................................................... 10

2. SUMMARY OF THE EIA FINDINGS .......................................................................................................... 17

2.1 OVERVIEW OF THE FINDINGS ..................................................................................................................... 17 2.2 SUMMARY OF THE EIA RESULTS ................................................................................................................. 17

2.2.1 Summary Impacts During Logistics and Mobilisation Phase .......................................................... 17 2.2.2 Overall Summary Spudding and Drilling Operations ...................................................................... 24

2.2.2.1 Summary of Impacts .............................................................................................................................. 24 2.2.2.2 Summary of Impact Assessment Results .............................................................................................. 24

2.2.3 Summary Assessment of Impacts During Decommissioning ......................................................... 31 2.2.4 Risk-Assessment Approach ............................................................................................................ 38

3. REGULATORY REGISTER ........................................................................................................................ 42

3.1 CONSTITUTIONALITY OF THE ENVIRONMENTAL ASSESSMENT ........................................................................ 42 3.2 DRILLING PERMIT REQUIREMENTS REGISTER .............................................................................................. 42 3.3 PETROLEUM EXPLORATION AND PRODUCTION LEGISLATION REGISTER ........................................................ 43 3.4 ENVIRONMENTAL LEGISLATION AND REGULATIONS REGISTER ...................................................................... 43 3.5 OTHER KEY NATIONAL LEGAL INSTRUMENTS REGISTER ............................................................................... 44 3.6 REGIONAL FRAMEWORKS AND PROTOCOLS REGISTER................................................................................. 45 3.7 INTERNATIONAL OBLIGATIONS REGISTER .................................................................................................... 46

4. EMP AND MONITORING FRAMEWORK ................................................................................................... 47

4.1 INTRODUCTION........................................................................................................................................... 47 4.2 EMP PROVISIONS ...................................................................................................................................... 47

4.2.1 Objectives ....................................................................................................................................... 47 4.2.2 EMP Requirements and Standards ................................................................................................ 48 4.2.3 EMP Roles and Responsibilities ..................................................................................................... 49

4.2.3.1 Proponent (M &P Namibia (Pty) Ltd)...................................................................................................... 49 4.2.3.2 Drilling Contractor and Support Vessel Contractors............................................................................... 50

4.3 EMP FRAMEWORK ..................................................................................................................................... 51 4.3.1 EMP Mitigation Measures, Monitoring and Reporting .................................................................... 51

5. HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT GUIDANCE ............................................. 70


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5.1 HEALTH, SAFETY AND ENVIRONMENTAL COMPLIANCES ................................................................................ 70 5.2. OIL / DIESEL SPILL RESPONSES ............................................................................................................. 73

5.2.1 Oil Spill Contingency Plan (OSCP) ................................................................................................. 73 5.2.2 OSCP and the National Marine Pollution Contingency Plan (NMPCP) .......................................... 74 5.2.3 Guidelines to Appropriate Response Strategies ............................................................................. 75

5.3 EMERGENCY PREPAREDNESS GUIDANCE .................................................................................................... 77 5.3.1 Emergency Response Plans (ERP) ................................................................................................ 77 5.3.2 Purpose of the ERP and Organisational Framework ...................................................................... 80 5.3.3 ERP Organizational Response Structure (ORS) ............................................................................ 81 5.4.4 Emergency Response Principles .................................................................................................... 82

5.4 USEFUL CONTACTS TO BE INCLUDED IN THE ERP AND OSCP ...................................................................... 83

6. CONCLUSIONS AND RECOMMENDATIONS ............................................................................................ 86

6.1 EMP CONCLUSIONS................................................................................................................................... 86 6.2 RECOMMENDATIONS .................................................................................................................................. 86

6.2.1 EMP and Environmental Clearance Certificate (ECC) ................................................................... 86 6.2.2 Other Permits Requirements .......................................................................................................... 86 6.2.3 Notification for Project Implementation ........................................................................................... 87 6.2.4 Project Communications Protocols ................................................................................................. 87 6.4.5 Safety Exclusion Zone .................................................................................................................... 87 6.4.6 Other Project Operational Related Control Safety Measures ......................................................... 88 6.2.7 Safety Health and Environmental Awareness (SHEA) and Monitoring .......................................... 89


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List of Figures

Figure 1.1: Regional location of Petroleum Exploration License (PEL) No. 44 covering Block 2012B, offshore, Walvis Basin. ....................................................................... 3

Figure 1.2: Detailed bathometry around PEL No. 44 (Block 2012B) showing the location of the initial multiple wells to be drilled starting April 2020. ....................................... 4

Figure 1.3: Proposed initial multiple wells drilling location distances from the nearest coastline (Pelican Point Walvis Bay). ....................................................................... 5

Figure 1.4: Proposed initial multiple wells drilling locations distances from the Port of Walvis Bay) .............................................................................................................. 6

Figure 1.5: Envisaged logistical arrangements ......................................................................... 11 Figure 5.1: Characteristics of Tier 1, 2 and 3 oil spills. ............................................................. 74 Figure 5.2: National Marie Pollution Contingency Plan (NMPCP) Governance structure ......... 75 Figure 5.3: National Marine Pollution Contingency Plan (NMPCP) legal, administrative

and planning framework showing the link to other plans including the Offshore Petroleum Industry Marine Pollution Plan to be developed specifically for PEL 44. ........................................................................................... 75

Figure 5.4: Deciding on an appropriate response strategy. ...................................................... 77 Figure 5.5: Tier 1, 2 and 3 ERP response organisation. ........................................................... 78 Figure 5.6: Emergency Response Plan (ERP) organisational notification / response

structure. ................................................................................................................ 82

List of Tables

Table 2.1: Sensitivity of receptors with respect to the routine and accidental logistics

and mobilisation related activities. .......................................................................... 18 Table 2.2: Impact magnitude with respect to the routine and accidental logistics and

mobilisation related activities. ................................................................................ 19 Table 2.3: Duration of impact with respect to the routine and accidental logistics and

mobilisation related activities. ................................................................................ 20 Table 2.4: Geographical extent of impacts with respect to the routine and accidental

logistics and mobilisation related activities. ............................................................ 21 Table 2.5: Probability, likelihood of occurrence of impacts with respect to the routine

and accidental logistics and mobilisation related activities. .................................... 22 Table 2.6: Significance of impacts with respect to the routine and accidental logistics

and mobilisation related activities. .......................................................................... 23 Table 2.7: Sensitivity of receptors with respect to the routine and accidental spudding

and drilling operations related activities. ................................................................. 25 Table 2.8: Impact magnitude with respect to the routine and accidental spudding and

drilling operations related activities. ....................................................................... 26 Table 2.9: Duration of impact with respect to the routine and accidental spudding and

drilling operations related activities. ....................................................................... 27 Table 2.10: Geographical extent of impacts with respect to the routine and accidental

spudding and drilling operations related activities. ................................................. 28 Table 2.11: Probability, likelihood of occurrence of impacts with respect to the routine

and accidental spudding and drilling operations related activities. .......................... 29 Table 2.12: Significance of impacts with respect to the routine and accidental spudding

and drilling operations related activities. ................................................................. 30 Table 2.13: Sensitivity of receptors with respect to decommissioning / abandonment

phase. .................................................................................................................... 32


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Table 2.14: Impact magnitude with respect to the decommissioning / abandonment phase. .................................................................................................................... 33

Table 2.15: Duration of impact with respect to the decommissioning / abandonment phase. .................................................................................................................... 34

Table 2.16: Geographical extent of impacts with respect to the decommissioning / abandonment phase. ............................................................................................. 35

Table 2.17: Probability, likelihood of occurrence of impacts with respect to the decommissioning / abandonment phase. ............................................................... 36

Table 2.18: Significance of impacts with respect to the decommissioning / abandonment phase. .................................................................................................................... 37

Table 2.19: Level of likely impacts. ........................................................................................... 38 Table 2.20: Likelihood of occurrence. ....................................................................................... 38 Table 2.21: Risk Assessment results. ....................................................................................... 39 Table 4.1: Other International Standards. ............................................................................... 48 Table 4.2: American Petroleum Institute (API) Standards. ...................................................... 49 Table 4.3: Mitigation measures, monitoring and reporting for physical presence of

drillship and support vessels mitigation measures and monitoring provisions .............................................................................................................. 53

Table 4.4: Mitigation measures, monitoring and reporting for physical disturbance from drilling activity. ....................................................................................................... 54

Table 4.5: Mitigation measures, monitoring and reporting for increased light levels from routine vessel and drillship operations. .................................................................. 55

Table 4.6: Mitigation measures, monitoring and reporting for sound generation from drilling, support vessel and VSP activities. ............................................................. 56

Table 4.7: Mitigation measures, monitoring and reporting for increased sound from fixed wing aircraft and helicopters during take- off, landing and overflight. ............. 57

Table 4.8: Mitigation measures, monitoring and reporting for atmospheric emissions from routine drillship, support vessels and helicopter operations............................ 58

Table 4.9: Mitigation measures, monitoring and reporting for onshore support operations and waste management. ...................................................................... 59

Table 4.10: Mitigation measures, monitoring and reporting for discharge of Water Based Mud (WBM) and drill cuttings to the sea. ................................................................ 60

Table 4.11: Mitigation measures, monitoring and reporting for discharge of Synthetic Based Mud (SBM) and drill cuttings to the sea. ...................................................... 61

Table 4.12: Mitigation measures, monitoring and reporting for discharge of cement to the seabed. .................................................................................................................. 62

Table 4.13: Mitigation measures, monitoring and reporting for planned marine discharges. ............................................................................................................ 63

Table 4.14: Mitigation measures, monitoring and reporting for unplanned marine discharges (e.g. minor spillages of fuel, lubricants / maintenance oils)................... 64

Table 4.15: Mitigation measures and monitoring activities for accidental event: Loss of vessel, equipment or material. ............................................................................... 65

Table 4.16: Mitigation measures, monitoring and reporting for accidental event: Collision with marine wildlife during vessel operations.......................................................... 66

Table 4.17: Mitigation measures, monitoring and reporting for accidental Event: Loss of MGO containment on the drillship or support vessels due to ship collision or other major event. .................................................................................................. 67

Table 4.18: Mitigation measures, monitoring and reporting for accidental event: Loss of drilling mud during drilling. ..................................................................................... 68

Table 4.19: Mitigation measures, monitoring and reporting for accidental event: well blowout following loss of well control. ..................................................................... 69

Table 5.1: Summary of the emergency scenarios and operational response procedure ......... 79 Table 5.2: Coastal area covering Walvis Bay and Swakopmund emergency numbers

and facilities. .......................................................................................................... 84 Table 5.3: Government of Namibia (GRN) in-Country emergency response focal

points ..................................................................................................................... 85


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List of Plates

Plate 1.1: Example of a dynamic positioned (no anchors) drillship type of rig that may

be used for the proposed multiple well drilling operations in PEL 44 ...................... 12 Plate 1.2: Example of a dynamic positioned (no anchors) semisubmersible rig that may

be used as an alternative to a drillship for the proposed multiple wells drilling operations in PEL 44 .......................................................................................... - 13 -

Plate 1.3: Typical supply vessels that will be used to supply drilling materials from Walvis Bay to the rig in PEL 44 .......................................................................... - 14 -

Plate 1.4: Example of the fixed wing aircraft that will link Walvis Bay (Shore/Operations/supply base) to Windhoek (Headquarters) and the helicopter that will link Walvis Bay to the Rig offshore in PEL 44............................ 15

Plate 1.5: Walvis Bay International Airport (top) and Arandis Airport (bottom), the support base for the Windhoek link fixed wing aircraft and helicopter support link to the rig offshore ............................................................................................. 16


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Abbreviations and Acronyms AET Apparent Effects Threshold API American Petroleum Institute. Barrel or BBL A stock tank barrel, a standard measure of volume for petroleum corresponding

to 159 litters. Bpd Barrels per day BCC Benguela Current Commission Bcf Billion cubic feet. Bcfpd Billion cubic feet per day. BOE Barrels of oil equivalent, with volumes of natural gas converted to barrels of oil

using a conversion factor of 5,650 cf of natural gas to one bbl, in accordance with BP Statistical Review of World Energy of 2010.

Boepd Barrels of oil equivalent per day. Bcfg Billion cubic feet of gas Bopd Barrels of oil per day BOP Blowout Prevention BSI British Standards Institute BTEX Benzene, toluene, ethylbenzene, and xylenes BU Business Unit CRM Certified Reference Materials CRP Community Relations Plan CTD Conductivity Temperature and Depth DBT Dibenzothiophene DCM Dichloromethane DECC Department of Energy and Climate Change DGNSS Differential Global Navigation Satellite System DO Dissolved Oxygen DSDP Deep Sea Drilling Project EA Environmental Assessment EBS Environmental Baseline Survey EIA Environmental Impact Assessment EMP Environmental Management Plan EPZ Export Processing Zone ERL Effects Range Low ERM Effects Range Median ESG Environmental Scientifics Group EIA Environmental Impact Assessment E&P Exploration and production. FGN Foresight Group Namibia FPSO Floating production, storage, and offloading FPU Floating Production Unit FSO Floating Storage and Offloading Unit FSGS Fish Spawning Ground Survey FTIR GC Gas Chromatography GC-FID Gas Chromatography Flame Ionisation Detection GC-MS Gas Chromatography Mass Spectrometry HMW High Molecular Weight HSE Health, Safety and Environment I &AP Interested and Affected Parties (Stakeholders) ICP-OES Inductively Coupled Plasma Optical Emission Spectrometry ICP-MS Inductively Coupled Plasma Mass Spectrometry IMO International Maritime Organisation IPIECA International Petroleum Industry Environment Conservation Association KgOE Kilogram of oil equivalent LAT Lowest Astronomical Tide LGC Laboratory of Government Chemists LMW Low Molecular Weight


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LoD Limit of Detection LoI Loss on Ignition LPG Liquefied petroleum products LVI Large Volume Injection Mbbl Million barrels. Mbpd Million barrels per day. Mboe Million barrels of oil equivalent. MME Ministry of Mines and Energy MET Ministry of Environment and Tourism MFMR Ministry of Fisheries and Marine Resources MWT Ministry of Works and Transport Mmbo Millions of barrels of oil Mmcf Millions of cubic feet Mmcm Millions of cubic meters MME Ministry of Mines and Energy MMOs Marine Mammal Observers MPA Model Petroleum Agreement NAMCOR National Petroleum Corporation of Namibia NOGAPS U.S. Navy Operational Global Atmospheric Prediction System OBM Oil-Based Mud OECD Organisation for Economic Cooperation and Development OEC Office of the Environmental Commissioner PAH(s) Polycyclic aromatic hydrocarbon(s) PAM Passive Acoustic Monitoring POB Persons on board RBS Risk-Based Solutions ROV Remote Operated Vehicle SADC Southern African Development Community SBM’s Synthetic Based Mud’s SEP Stakeholders Engagement Plan SANCCOB Southern African Foundation for the Conservation of Coastal Birds SD Standard deviation SoW Scope of Work Tcf Trillion cubic feet. THC(s) Total Hydrocarbon Concentration(s) TOC Total Organic Carbon TOM Total Organic Matter TON Total Oxidised Nitrogen UTM Universal Transverse Mercator USEPA United States Environment al Protection Agency WBM’s Water-Based Muds WI Working Interest

NON-TECHNICAL SUMMARY


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1. Introduction

Maurel & Prom Group through its wholly owned subsidiary Maurel & Prom (“M &P”) Namibia (Pty) Ltd, (the proponent) holds 42.5% operatorship interest in the Petroleum Exploration License (PEL) No. 44. PEL No. 44 covers Block 2212B with a total area of 5,122 km2 and situated in the central Walvis Basin offshore Namibia. M & P Namibia (Pty) Ltd is the operator of PEL No. 44 and the other partners in the license are:

❖ AziNam 42.5%;

❖ National Petroleum Corporation of Namibia 8%;

❖ Livingstone Mining Resource Development 4%, and;

❖ Frontier Mineral Resources 3%.

2. Summary of the Proposed Project Description

M & P Namibia (Pty) Ltd and partners intends to drill multiple wells within PEL No. 44 starting with an initial five (5) wells drilling programme. The decision to drill all the proposed initial five (5) wells as well as the drilling of additional more wells will be subject to the positive outcomes of the first two (2) wells that will be drilled. The names, locations in Universal Transverse Mercator (UTM) coordinate system and water depths of the initial proposed five (5) wells are:

(i) Aurora 1: X (m) 254481, Y(m) 7487126 and water depth -1272 m;

(ii) Aurora 2: X (m) 254481, Y(m) 7487126 and water depth -1225 m;

(iii) Serenade 1: X (m) 265826, Y(m) 7488567 and water depth -926 m;

(iv) Serenade 2: X (m) 265959, Y(m) 7487732 and water depth -930 m; and

(v) Harmony 1: X (m) 262656, Y (m) 7486971 and water depth -1030 m. The logistical arrangements will use Windhoek as the local headquarters, Walvis Bay Port as the shore / operations base and Walvis Bay International Airport or Arandis Airport as the Aviation support base. The distances from the proposed well locations to the Port of Walvis Bay are: Aurora-1X (196 km), Aurora-2X (195 km), Harmony-1X (188 km), Serenade-1X (185 km) and Serenade-2X (185 km). Distance from the proposed well locations within the Area of Interest (AOI) to the nearest Namibian coastline (Pelican Point, Walvis Bay) are: Aurora-1X (188 km), Aurora-2X (187 km), Harmony-1X (180 km), Serenade-1X (177 km) and Serenade-2X (177 km). The drilling operations is estimated to last between 30 – 50 days per well and will be undertaken using either a dynamically positioned drillship or semisubmersible rig. The drilling operations will use seawater at beginning of the drilling process, Water Based Mud in shallow sections and Synthetic Based Mud (SBM) in the deeper sections and once the Blowout Preventer (BOP) has been installed. The estimated Total Depths (TD) for each well in meters below mean sea level (mbmsl) are: Aurora-1X: 4450 m, Aurora-2X: 4410 m, Serenade-1X: 4390 m, Serenade-2X, 4390 m and Harmony-1X, 3530 m. Each well is estimated to yield drill cuttings volume of between 550-650 m3. Approximately 300 – 400 m3 of cuttings per well will be generated in the top holes sections that will be drilled with seawater and water-based mud sweeps. As these sections are drilled without a riser, approximately 300 – 400 m3 of cuttings will be discharged from each well directly to the seabed. After the riser is run the remainder of the well will be drilled with a closed circulating


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system and cuttings will be filtered from the mud system on the rig floor.

3. Regulatory Requirements

The proposed offshore multiple wells drilling operations (activities) are listed in the Environmental Impact Assessment (EIA) Regulations, 2012 promulgated under the Environmental Management Act (EMA), 2007, (Act No. 7 of 2007) and cannot be undertaken without an Environmental Clearance Certificate (ECC). M & P Namibia (Pty) Ltd is required to have undertaken Environmental Impact Assessment (EIA) and Environmental Management Plan (EMP) in order to support the application for ECC for the proposed multiple offshore wells drilling operations in PEL No. 44. The Scoping Vol. 1 of 3 Report, the Environmental Impact Assessment (EIA) Vol. 2 of 3 Report and this Environmental Management Plan (EMP) Vol. 3 of 3 Report have all been prepared in order to support the application for ECC and all the other predrilling, drilling and post-drilling consents, endorsements, permits, authorisations and certifications for the proposed well drilling operation.

4. Objectives of the EMP Vol 3 of 3 Report This Environmental Management Plan (EMP) Vol. 3 of 3 Report for the proposed multiple wells drilling operations in PEL 44 provides a detailed plan of actions required for the implementation of the mitigation measures for minimising and maximising the identified significant negative and positive impacts, respectively. M & P Namibia (Pty) Ltd shall ensure adequate provision of the necessary resources towards good environmental and social management throughout the proposed multiple wells drilling operations. Overall, the environmental assessment covering the Environmental Scoping (Vol. 1 of 3), the Environmental Impact Assessment (EIA) (Vol. 2 of 3) and this Environmental Management Plan (EMP) (Vol. 3 of 3) for the proposed drilling operations in PEL 44 have all been undertaken in accordance with the provisions and environmental principles of the national, regional and international legislations and regulations as well as good practices for offshore oil and gas exploration operations.

5. Summary of the EIA Findings

The overall severity of potential environmental impacts of the proposed project activities (multiple Wells Drilling Operations in PEL 44) on the receiving environment will be of low significant impact with respect to magnitude, temporally duration and localised extent for planned or routine events, and medium severity and low probability of occurrence for unplanned or non-routine (accidental) events. However, it’s highly vital that all key mitigations measure as detailed in the EMP Vol. 3 of 3 Report and based on good international oil and gas industry practice are integrated into the project operational and design procedures to ensure all requirements of environmental standards are met. Activities of the proposed multiple wells drilling operations that have low or no risk and low or no significance environmental impact include: (i) Waste disposal which is governed by MARPOL regulations so as not to damage the

environment;

(ii) Vessel lighting if orientated downwards onto work space and shielded, combined with the scarcity of birds at the drilling locality contribute to a low impact status;

(iii) Vessel lighting not directed onto the sea surface will limit impacts on cephalopods and fish;

(iv) As long as helicopter flight paths and altitudes avoid breeding and nesting colonies no

impact is anticipated;


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(v) There is a potential risk of the support vessels encountering dolphins in nearshore waters

while entering Walvis Bay Harbour during port calls. Concentrated visual observation will limit interaction. It has been noted that injury from commercial vessel strikes and the effects of urban pollution have greater reported impact on marine mammals than any exploration or support vessels (OSPAR, 2009). Impacts on marine mammals are assessed as being of minor environmental significance as long as mitigation measures are adhered to;

(vi) Impact to the commercial fishing industry is low because the proposed multiple wells

locations do not directly overlap with any fishing grounds and the drilling exclusion zone will not affect the neighbouring commercial fishing grounds;

(vii) Angling, recreational and mariculture activities fishery are located along the coast and

shallow waters about 180 km east of the proposed multiple well drilling locations and no impact is anticipated from drilling operations on these industries, and;

(viii) Given the small scale and open ocean locality of the proposed drilling, and the remoteness

of operations in relation to other west coast marine operations no cumulative impacts are expected to occur.

Other activities associated with well drilling that have a slightly higher risk and are assessed as having low to moderate significance impacts include:

(i) Contamination of local Namibian marine waters and ecosystems by organisms transported

in from other countries in ballast water can cause significant impact. The EMP Report Vol. 2 of 3 addressed how ballast water management will be undertaken and monitored and controlled. While ballast water can pose significant risk, if internationally accepted procedures are adhered to the environmental impact is assessed as being low. It should be borne in mind that ballast water management is a pre-requisite of all international vessels visiting Namibia and is not solely restricted to these proposed oils well drilling operations. Therefore, ballast water management it is a well-established practice;

(ii) Drilling muds and cuttings, cement and BOP fluids are discharged into the water column.

These discharges will be effectively managed and volumes are small, but they do create temporally plumes and can smother benthos in the immediate vicinity of the well head especially in shallow water. In summary, the impact is assessed as being moderately low because of the very small area likely to be disturbed and the effects are not capable of impacting the environment on a population or ecosystem scale due to deep-water (~ -1000 m) environment with likely highly dilution;

(iii) Drill operation noise has the potential to impact marine mammals, birds and fish. However,

noise levels associated with oil well drilling operations are relatively low (<170 dB re 1 μPa at 1 m) and below levels that will do harm or seriously impact the environment. Localised disturbance and possible avoidance behaviour of marine mammals, birds and fish is probable during operations. These effects are of short duration and therefore a moderate impact can be assessed in the immediate vicinity of the drilling, but overall noise disturbance is considered to be of low impact within the open ocean setting. The migration routes of Blue and Sei whales may intersect the proposed exploration areas, but generally these migration corridors are broad and drilling operations including the VSP survey activities can easily be circumvented by these animals;

(iv) By far the greatest environmental risk associated with exploration oil well drilling activities

is an oil blow-out. It should be stressed that the likelihood of an oil or gas blow-out is very rare. Though, as was shown in the Deepwater Horizons disaster in the Gulf of Mexico, it is possible and can result in significant environmental impact. For this reason, oil well drilling contractors employ safety measures (Blow-out preventer) to minimize the possibility of such an event. These are discussed in detail in the body of this report, together with some measures that can be employed to contain a spill should it occur. Potential impacts on


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marine mammals, birds, commercial fishing, fisheries and organisms are also addressed in this report. In summary, the risk of occurrence is low, but should it occur impact is assessed to be moderate for these drilling operations. The reason that a higher impact level impact is not assessed is because the proposed multiple wells locations are about 181 km offshore and based on the oil spill modelling results, in an event of an oil spill the oil slick trajectories will follow the predominant wind and current directions are to the north-northwest, well in the deep sea offshore, thus minimising any chance of oil slicks reaching the key sensitive coastal zones or breeding areas or commercial fishing grounds. The oil slick is highly unlikely to reach the high biodiversity shoreline zones, which are most sensitive to spill impacts, and where most environmental damage occurs from the oil;

(v) General indications are that, apart from a catastrophic oil spill from an oil blow-out or vessel

collision, which will only result from an accidental or extreme incident where human lives are also at risk, exploration oil well drilling in offshore Namibian waters will have a low impact on the long-term sustainability of the environment and the Benguela ecosystem, and;

(vi) The summary results of significant negative impacts that the proposed drilling operation in

PEL 44 may have on the receiving environment is outlined in Tables 1 and 2. A combination of the magnitude of the impact under consideration and the sensitivity of the receptor determined the significance of the impact. Detailed mitigation measures, management and monitoring requirements as well as roles and responsibilities are detailed in the EMP Vol. 3 of 3 Report.


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Table 1: Overall significance negative impact summary matrix for the proposed drilling activities and sensitivity of the receiving environment.

RECEPTORS / TARGETS THAT MAY BE IMPACTED (RESOURCES) PHYSICAL ENVIRONMENT BIOLOGICAL ENVIRONMENT SOCIAL

ENVIRONMENT

Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l H

abitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) 1/2 1/2 2/2 1/2 1/2 1/2 2/2 2/2 2/2 2/2 1/2 1/2 1/2 2/2 -

2 Walvis Bay International Airport / Arandis Airport (Aviation Support Base Activities)

1/2 1/2 - - - - - - - - 1/2 1/2 1/2 - -

3 Windhoek Office 1/1 1/1 - - - - - - - - - - - - -

OFFSHORE

4 Physical presence rig and support vessel including the exclusion zone

- - 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

5 Physical disturbance from drilling activity 1/1 1/1 1/1 1/1 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1 6 Planned discharge of drill cuttings, drilling mud and

cementing --- - 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

7 Planned discharge of wastes (deck drainage, galley waste, bilge water, sewage, detergents etc.)

- 1/1 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

8 Noise / sound emissions (drilling, support vessels, helicopter and VSP activities

- - - - - 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

9 Light emissions from rig and support vessel - - - - - - 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1 10 Unplanned marine discharge (incl. spills of fuel, oils,

chemicals, wastes) - - 2/2 - - - 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

11 Cumulative effects 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

AC

CID

EN

TA

L

12

Major Accidental Diesel / Oil Spill

1/2 1/2

2/2

1/2 1/2 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1

Document ID: EMP Vol. 3 of 3 Report November 2019 Version. Final Owner: Maurel & Prom (M & P) Namibia (Pty) Ltd

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Table 2: Summary results of the significance impact assessment likely to be associated with routine, physical presence and accidental operational activities.

Activity / Event Description of Impact Significance of

Impact

Physical Presence of the Drillship and Support Vessels

Disruption to commercial fishing activity Low

Disruption to marine navigation None

Drill cuttings and Water Based Mud (WBM) discharged directly to the seabed

Direct chemical toxicity to benthic fauna due to seabed drilling discharges None

Burial and smothering of benthic fauna due to seabed drilling discharges Low

Reduction in sediment quality (e.g. changes in grain size, organic and oxygen content) due to seabed drilling discharges

None

Discharge of treated Synthetic Based Mud (SBM) and cuttings from the drillship to the water column; and seabed

Direct chemical toxicity to water column fauna from drilling discharges from drillship to water column

Low

Reduction in primary production of phytoplankton due to drilling discharges to water column from the drillship

Low

Disruption to feeding or behaviour in zooplankton and fish due to increased suspended sediments in the water column from drilling discharges from the drillship

Low

Disruption to feeding or behaviour in cetaceans, turtles and diving birds due to increased suspended sediments in the water column from drilling discharges from the drillship

Low

Direct chemical toxicity to benthic fauna due to deposition of treated cuttings discharged to the water column from the drillship

Low

Discharge of Cement to the Water Column

and Seabed

Damage or mortality in plankton due to discharge of cement washout to the water column from the drillship

Low

Damage or mortality in benthic fauna from cement discharged at the seabed Low

Underwater Sound Emissions from Drilling, Vessel Movements and related Activities

Disturbance in sea turtles Low

Disturbance in cetaceans Low

Disturbance in fish Low

Disturbance in diving seabirds Low

6. The EMP Framework

6.1 Meeting all the Permitting Requirements

Implementation of the proposed drilling programme can only be undertaken once the following permits / endorsements have been obtained including the following:

1. Environmental Clearance Letter / Certificate issued by the Office of the Environmental

Commissioner, Ministry of Environment and Tourism (MET);

2. Oil Spill Contingency Plan (OSCP) Approved / Endorsed by the Department of Maritime Affairs, Ministry of Works and Transport (MWT);

3. Emergency Response Plan (ERP) Approved / Endorsed by the Petroleum Commissioner,

Ministry of Mines and Energy (MME);

4. Radioactive Authorisation (Import and Export Permits) for the use of radioactive sources for logging Issued by the Radiation Authority, Ministry of Health and Social Services (MHSS);

5. Pollution Safety Certificate for the rig to be used issued by the Department of Maritime

Affairs, Ministry of Works and Transport (MWT);

6. Explosive Permit Registration (Import and Export Permits) as a consumer and importation of explosives into Namibia for the use of explosive materials in the drilling process issued the Ministry of Safety and Security (MSS);

7. Preapproval for the use of dispersants in an event of an oil spill issued by the Ministry of

Fisheries and Marine Resources (MFMR) and;


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8. Letter of consent to drilling or permit to drill, Drilling Reporting and Notification of well

abandonment and drilling completion issued by the Office of the Petroleum Commissioner, Ministry of Mines and Energy (MME).

6.2 Mitigation Measures, Monitoring Frequency, Reporting, Roles and Responsibilities

The following is the quick summary reference to the mitigation measures, monitoring frequency and reporting as well as roles and responsibilities tables of the of the EMP framework as detailed outlined in this EMP Vol. 3 of 3 Report:

1. Physical presence of drillship and support vessels mitigation measures and monitoring

provisions;

2. Physical disturbance from drilling activity;

3. Increased light levels from routine vessel and drillship operations;

4. Sound generation from drilling, support vessel and VSP activities;

5. Increased sound from fixed wing aircraft and helicopters during take- off, landing and overflight;

6. Atmospheric emissions from routine drillship, support vessels and helicopter operation;

7. Onshore support operations and waste management;

8. Discharge of Water Based Mud (WBM) and drill cuttings to the sea;

9. Discharge of treated Synthetic Based Mud (SBM) and drill cuttings to the sea;

10. Discharge of cement to the seabed;

11. Planned marine discharges;

12. Unplanned marine discharges (e.g. minor spillages of fuel, lubricants / maintenance oils;

13. Accidental event: Loss of vessel, equipment or material;

14. Accidental event: Collision with marine wildlife during vessel operations;

15. Accidental Event: Loss of MGO containment on the drillship or support vessels due to ship

collision or another major event;

16. Accidental event: Loss of drilling mud during drilling, and;

17. Accidental event: well blowout following loss of well control. 6.3 EMP Recommendations

The following is the summary of the key recommendations and actions to be implemented by M & P Namibia (Pty) Ltd as a part of the management of the impacts through implementations of this EMP is:

(i) Key stakeholders have been informed through the Ministry of Mines and Energy and in particular, other marine users around the proposed drilling sites with respect to the required exclusive zone around the rig;


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(ii) The drilling crew on the rig shall try to reduce any likely cumulative impacts through coordinating their activities with other operators and must adhere to the recommendations contained in this EIA (Vol. 2 of 3) and EMP (Vol. 3 of 3) reports as well as all other relevant operational manuals and M & P Namibia (Pty) Ltd Environmental Policy concerning conservation and preservation of natural features;

(iii) Develop a simplified environmental induction and awareness programme for all the

workforce, contractors and sub-contractors. All crew members shall be informed and reminded of good environmental management and protection of the marine environment shall be part of the daily briefings/ meetings by the HSE Team at the following points:

❖ On board the rig;

❖ At the operations base Walvis Bay Port;

❖ At Windhoek transfer point to Walvis Bay International Airport, and;

❖ At Walvis Bay International Airport / Arandis Airport before boarding the helicopter for

the rig.

(iv) All communications (public relations) with the stakeholders must be channelled through one communication channel. The Managing Direction of M & P Namibia (Pty) Ltd should play a significant role in this regard and contractor's personnel must be courteous and considerate when dealing with other marine users and members of the general public;

(i) Provide management support, human and financial resources for the implementation of the proposed mitigations and effective environmental management throughout the drilling period;

(ii) Where contracted service providers are likely to cause environmental impacts, they need

to be identified and contract agreements need to be developed with costing provisions for environmental liabilities;

(iii) Develop and implement a monitoring programme that will fit into the overall company’s

Environmental Management System (EMS) as well as for any future EIA for drilling and production phases within the License Area.

6.4 Oil Spill Contingency Plan (OSCP) and Emergency Response Plan (ERP)

In accordance with the national requirements and international best practices for petroleum exploration, an Oil Spill Contingency Plan (OSCP) and an Emergency Response Plan (ERP) for an Operator / Contractor must be prepared and approved / endorsed by the relevant Government Ministries in Namibia. Such plans shall define the response organisation, responsibilities and procedures to be followed in the event of an emergency including uncontrolled oil spill situation during exploration drilling operations. Such plans (OSCP and ERP) prepared by M & P Namibia (Pty) Ltd include:

(i) M & P Namibia (Pty) Ltd Health, Safety and Environment (HSE) Policy, emergency and

spill response organisation and duties;

(ii) Procedures for the notification and reporting of an emergency including large oil / chemical spills;

(iii) Contact details of all relevant organisations requiring notification of an emergency

including tier 3 spill;

(iv) Emergency response strategies and oil spill clean-up guidelines for most probable and worst-case emergency /spill scenarios;


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(v) Procedures for clean-up during the alert and action phase;

(vi) Environmental sensitivity information in the vicinity the proposed well location;

(vii) Prediction of hydrocarbon slick movement, and;

(viii) Available resources / facilities for an emergency / spill response.

In addition, a list of contact details of key persons to be contacted in event of an oil spill is provided in this report.

6.5 Environmental Monitoring and Coordination

It is highly recommended that ongoing environmental monitoring activities be undertaken for the duration of the proposed drilling programme through the appointment of an in-house Environmental Coordinator / Subcontractor to M & P Namibia (Pty) Ltd. The duties of the HSE / Environmental Coordinators shall be to:

(i) Oversee and coordinate the implementation of the EMP and SHEA activities;

(ii) Undertake overall environmental coordination activities through the preparation of monthly

progress reports on the coordination of ecological activities including results of any incidences associated with the rig (offshore) and the operational (Shore) base (Walvis Bay);

(iii) A trained HSE personnel on-board the rig to observe marine mammals especially during the

performance of Vertical Seismic Profile (VSP) activities. The HSE crew will be train so that if they observe a marine mammal, they will immediately inform the HSE Team Leader to perform implement the appropriate actions and registration of the incidence;

(iv) Prepare monthly reports on the awareness training and activities undertaken for personnel

on board the drill rig (offshore), the operations base Walvis Bay and the aviation base Walvis Bay International Airport / Arandis Airport as well as any other stakeholders interactions, and;

(v) Prepare final Health, Safety and Environment Environmental Monitoring (HSEEM) or

Closure Report at the end of each of the proposed wells drilled to be submitted to the Ministry of Environment and Tourism, National Petroleum Corporation of Namibia (Namcor), Ministry of Mines and Energy, NamPort, Ministry of Fisheries and Marine Resources and Ministry of Works and Transport. The closure report for each well drilled shall be prepared within three (3) months after the drilling operations have been completed for each well and shall present the environmental monitoring performances and activities undertaken and achievements made throughout the duration of each well drilled.

All the environmental, social and health liabilities associated with the proposed project rests with M & P Namibia (Pty) Ltd. Hence, all the responsibilities to ensure that the findings and recommendations of the environmental assessment covering Scoping, EIA and this EMP are executed accordingly rest with M & P Namibia (Pty) Ltd. The company shall make sure that all appropriate resources are put in place and that all members of the workforce including contractor and subcontractors are aware and familiar with the content and requirements of this EMP for the proposed multiple wells drilling operations in PEL 44, Walvis Basin, central offshore Namibia.


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1. BACKGROUND

1.1 Overview

Maurel & Prom (“M &P”) Namibia (Pty) Ltd, the Proponent and partners intend to drill up to five (5) offshore wells in its Petroleum Exploration License (PEL) No. 44 covering Block 2212B. PEL No. 44 has a total area of 5,122 km2 and is situated in the central Walvis Basin offshore Namibia (Figs. 1.1 – 1.4). In accordance with the provisions of the Environmental Impact Assessment (EIA) Regulations, 2012 promulgated under the Environmental Management Act (EMA), 2007, (Act No. 7 of 2007), the proposed offshore multiple wells drilling operations (activities) cannot be undertaken without an Environmental Clearance Certificate (ECC) and in addition to the other applicable predrilling, drilling and post-drilling consents, endorsements, permits, authorisations and certifications for the proposed well drilling operation. M & P Namibia (Pty) Ltd is required to have undertaken Environmental Impact Assessment (EIA) and Environmental Management Plan (EMP) in order to support the application for ECC and other consents, endorsements, permits, authorisations and certifications for the proposed multiple offshore wells drilling operations in PEL No. 44 (Figs. 1.1 -1.4).

1.2 Purpose and Objectives of this EMP Report This Environmental Management Plan (EMP) Vol. 3 of 3 has been prepared together with the Scoping Vol. 1 of 3 and EIA Vol. 2 of 3 Report in order to support the application for ECC and all the other predrilling, drilling and post-drilling consents, endorsements, permits, authorisations and certifications for the proposed well drilling operation. The following is summary of all the required consents, endorsements, permits, authorisations and certificates:

1. Environmental Clearance Letter / Certificate issued by the Office of the Environmental

Commissioner, Ministry of Environment and Tourism (MET);

2. Oil Spill Contingency Plan (OSCP) Approved / Endorsed by the Department of Maritime Affairs, Ministry of Works and Transport (MWT);

3. Emergency Response Plan (ERP) Approved / Endorsed by the Petroleum Commissioner,

Ministry of Mines and Energy (MME);

4. Radioactive Authorisation (Import and Export Permits) for the use of radioactive sources for logging Issued by the Radiation Authority, Ministry of Health and Social Services (MHSS);

5. Pollution Safety Certificate for the rig to be used issued by the Department of Maritime Affairs,

Ministry of Works and Transport (MWT);

6. Explosive Permit Registration (Import and Export Permits) as a consumer and importation of explosives into Namibia for the use of explosive materials in the drilling process issued the Ministry of Safety and Security (MSS);

7. Preapproval for the use of dispersants in an event of an oil spill issued by the Ministry of

Fisheries and Marine Resources (MFMR) and; 8. Letter of consent to drilling or permit to drill, Drilling Reporting and Notification of well

abandonment and drilling completion issued by the Office of the Petroleum Commissioner, Ministry of Mines and Energy (MME).



This Environmental Management Plan (EMP) Vol. 3 of 3 Report for the proposed multiple wells drilling operations in PEL 44 has been prepared based on the findings and recommendations of the impact assessment process as detailed in the Environmental Impact Assessment (EIA) Vol. 2 of 3 Report. The EMP Report provides an action plan with respect to the implementation of the mitigation measures aimed at minimising and maximising the identified significant negative and positive impacts, respectively. Management actions including roles and responsibility requirements for implementation of this EMP by M & P Namibia (Pty) Ltd throughout the duration of the proposed drilling operations are also provided. The EMP requirements shall be implemented by the Operator (M & P Namibia (Pty) Ltd) as well as all the contractors and subcontractors who will undertaking the various activities of the proposed drilling operations. This EMP gives commitments including financial, equipment and human resources provisions for effective implementation of the mitigation measures and management of the likely environmental liabilities during the proposed multiple wells drilling operations in PEL 44. Monthly environmental monitoring, review, assessments and evaluation of the environmental performances covering the rig offshore (PEL 44), helicopter support Walvis Bay International Airport / Arandis and the operations (Shore) base Walvis Bay Port shall be undertaken for the duration of the proposed drilling operations.

1.3 Scope and Extent of the Environmental Assessment (EA)

Scope and extent of the Environmental Assessment (EA) as presented in the Environmental Scoping (Vol. 1 of 3), Environmental Impact Assessment (EIA) (Vol. 2 of 3 and this Environmental Management Plan (EMP) Vol. 3 of 3 Reports covers the entire PEL No. 44 licensed area as granted by the Competent Authority (CA), the Ministry of Mines and Energy (MME). Although the initial proposed five (5) wells drilling operations covers a specific Area of Interest (AOI) within PEL No. 44, the Scoping (Vol. 1 of 3), the EIA Vol 2 of 3 and this EMP Vol. 3 of 3 Reports, all took into considerations the likelihood of drilling of additional wells anywhere within the authorised license area (PEL No. 44) as granted by MME the CA. This EMP is valid for the entire licensed area (PEL 44).



Figure 1.1: Regional location of Petroleum Exploration License (PEL) No. 44 covering Block 2012B, offshore, Walvis Basin (Prepared by

RBS, 2019, data source from the Geological Survey of Namibia, 2003).



Figure 1.2: Detailed bathometry around PEL No. 44 (Block 2012B) showing the location of the initial multiple wells to be drilled starting April 2020 (Source: M & P Namibia (Pty) Ltd, 2019).



Figure 1.3: Proposed initial multiple wells drilling location distances from the nearest coastline (Pelican Point Walvis Bay) (Source: M & P Namibia (Pty) Ltd, 2019).



Figure 1.4: Proposed initial multiple wells drilling locations distances from the Port of Walvis Bay) (Source: M & P Namibia (Pty) Ltd, 2019).



1.4 Project Partners Corporate Profiles

1.4.1 Overview

Maurel & Prom Group through its wholly owned subsidiary of M & P Namibia (Pty) Ltd, (the proponent) holds 42.5% operatorship interest in PEL No. 44 and the other partners are: ❖ AziNam 42.5%;

❖ National Petroleum Corporation of Namibia 8%;

❖ Livingstone Mining Resource Development 4%, and;

❖ Frontier Mineral Resources 3%.

1.4.2 Maurel & Prom Namibia (Pty) Ltd

Maurel & Prom Namibia (Pty) Ltd is a subsidiary of the Maurel & Prom Group which is an oil and gas exploration and production company listed on the regulated market of Euronext, Paris, France (www.maureletprom.fr/en/). The international development platform of IndonEIAn oil corporation Pertamina since 2017, Maurel & Prom has more than 650 employees worldwide. The Group has extensive technical and operational experience in both gas and oil projects. Over the past 20 years, Maurel & Prom has made several significant discoveries, particularly in the Congo Basin, and has successfully participated as an operator in the development or redevelopment of a large number of assets in Congo, Colombia, Gabon, Tanzania and Nigeria. Currently, the Group has a portfolio of high- potential assets focused on Africa and Latin America, consisting of both producing assets (Gabon, Tanzania and Venezuela) and opportunities currently in the exploration or appraisal phase (Gabon, Namibia, Colombia, France, Italy and Canada). The Group also holds a 20.46% stake in Seplat, one of Nigeria’s main operators that is listed on the London (main market London stock exchange) and Lagos (Nigerian stock exchange) stock exchanges. Maurel & Prom constantly strives to meet and improve the industry’s strictest standards in terms of health, safety and environmental protection. The Group also relies on constant dialogue with host countries and local communities to ensure long- term commitment from stakeholders.

1.4.3 AziNam Limited

AziNam Ltd., is an exploration and production company focused on leveraging its strengths in seismic acquisition, processing, interpretation and geoscience to create value for shareholders and partners (www.azinam.com). AziNam is focused on rapidly progressing the exciting opportunities in Namibia by applying advanced geoscience technology to its extensive acreage position. AziNam is backed by the Bermuda-based energy investment group Seacrest Capital Ltd. and partners.

1.4.4 National Petroleum Corporation of Namibia (NAMCOR)

National Petroleum Corporation of Namibia (NAMCOR) is a legally enacted entity with limited liability under the Namibian Companies Act of 1973 (www.namcor.com.na/). The Government of the Republic of Namibia is its sole shareholder. Under the Petroleum (Exploration and Production) Act of 1991, NAMCOR (Pty) Ltd has the right to carry out reconnaissance, exploration and production operations either on its own or in partnership with other organisations in the industry. NAMCOR's main business is to ensure the optimum exploitation of Namibia’s petroleum resources and meaningful Namibian participation in resulting business developments

http://www.maureletprom.fr/en/

http://www.azinam.com/

http://www.namcor.com.na/



in petroleum related exploration activities. The company also acts as advisor to the Ministry of Mines and Energy and assists it in monitoring the exploration activities of licensees. The institutional role of NAMCOR is to actively promote the hydrocarbon potential of Namibia. In exercising this role, the company is tasked with advising the Ministry of Mines and Energy on policy issues regarding the upstream petroleum industry and monitoring the petroleum activities of oil companies operating within Namibia. NAMCOR has since independence facilitated the signing of several petroleum agreements with international oil companies. NAMCOR holds extensive modern data room comprising both onshore and offshore seismic and well data sets.

1.4.5 Other Partner

Livingstone Mining Resource Development and Frontier Mineral Resources are both local empowerment companies participating in PEL No. 44 covering Block 2212B.

1.5 Proposed Project

1.5.1 Overview

The following is the summary of the initial project information that will continuously be updated as part of the ongoing Environmental Assessment (EA) process covering this Scoping, Environmental Impact Assessment (EIA) and Environmental Management Plan (EMP) reports (Figs. 1.1 – 1.4):

1. Petroleum Exploration License (PEL) No.: 44;

2. Block: 2012B;

3. Location: Offshore, Walvis Basin, Central Namibia;

4. Names of the Initial Wells to be Drilled First: Aurora 1X, Aurora 2X, Serenade 1X,

Serenade 2X and Harmony 1X;

5. Coordinates of the Initial Wells Locations in UTM, Water depths, Drill Well Depth from Seafloor (Total Depth –TD) in meters below mean sea level (mbmsl):

(i) Aurora 1: X (m) 254481, Y(m) 7487126, water depth -1272 m and drilled well Total

Depth (TD) 4450 m bmsl;

(ii) Aurora 2: X (m) 254481, Y(m) 7487126, water depth -1225 m and drilled well Total Depth (TD) 4410 m bmsl;

(iii) Serenade 1: X (m) 265826, Y(m) 7488567, water depth -926 m and drilled well

Total Depth (TD) 4390 m bmsl;

(iv) Serenade 2: X (m) 265959, Y(m) 7487732, water depth -930 m and drilled well Total Depth (TD) 4390 m bmsl; and

(v) Harmony 1: X (m) 262656, Y (m) 7486971, water depth -1030 m and drilled well

Total Depth (TD) 3530 m bmsl.

6. Initial Wells Distance from the Namibian Coastline: Pelican Point, Walvis Bay, Aurora-1X (188 km), Aurora-2X (187 km), Harmony-1X (180 km), Serenade-1X (177 km) and Serenade-2X (177 km);



7. Initial Wells Operations/ Support/ Shore Base/ Distance: Walvis Bay with distance from well location: Aurora-1X (196 km), Aurora-2X (195 km), Harmony-1X (188 km), Serenade-1X (185 km) and Serenade-2X (185 km);

8. Logistic Arrangements: Walvis Bay Port (Shore Base) and Walvis Bay International

Airport / Arandis Airport (Aviation Base) (Fig. 1.5);

9. Type and Name of Rig: Dynamically positioned Drillship or Semisubmersible, name to be confirmed (Plates 1.1 and 1.2);

10. No. of Supply Boats: Will be provided by up to four (4) vessels and all to operate from

Walvis Bay with one (1) vessel being around the rig at any given time (Plate 1.3);

11. Planned Spud Date of the 1st Well: 3rd / 4th Quarter (Q3/Q4) 2020; 12. Estimated Drilling Duration per Well: Depending on final well depths and downtime but

may be between 30 – 50 days per well, and; 13. Envisage Type of Drilling Fluids: Seawater, Water Based Mud and Synthetic Based

Mud (SBM) to be used for 17-1/2" section onwards (once the BOP is on) and as may be required.

1.5.2 Project Implementation

M & P Namibia (Pty) Ltd plans to drill the first well in Q3/Q4 2020 and to continue the drilling campaign with the second well, following the study of the first well results. The drilling of the other proposed subsequent wells is subject to the positive results of the initial drilling operations of the first three (3) wells. The drilling operations of each well has been subdivided into three (3) stages and each stage has been evaluated in detailed during the preparation of the EIA and EMP Reports. The following three (3) project stages applicable for each well are also likely to be the sources of impacts linked to routine and accidental operational discharges:

(i) Mobilisation and Logistics;

(ii) Spudding and Drilling Operations, and;

(iii) Demobilisation and Abandonment.

The estimated drilling time per well is thought to be 30 – 50 days. However, due to unforeseen circumstances including possible downtime due to weather condition or equipment failure, the drilling permit for each well shall assume a maximum of up to 90 days

1.5.3 Logistical Arrangements

The envisaged logistical arrangements for the proposed drilling operation in PEL No. 44 are summarised in Fig. 1.5. In accordance with Fig. 1.5, the following is the summary of the envisaged logistic arrangements as evaluated during the EIA and EMP processes:

(i) Windhoek – Will serve as the local headquarters for the entire project development with

linkages to Paris, France (Fig. 1.5). Arrival of international and regional drilling crew will also take place in Windhoek. Local air transport from Windhoek to the Walvis Bay / Arandis Airport where a helicopter will take the crew on to the rig will be provided through a private charter for improved operational efficiency and Emergency Response Support (Plates 1.4



and 1.5). In the absences of air transport from Windhoek to Walvis Bay / Arandis or from Walvis Bay / Arandis to Windhoek on to their final destination, suitable and comfortable accommodation will be provided in Windhoek, Walvis Bay or Arandis to all the crew associated with the proposed drilling operations;

(ii) Walvis Bay – Will serve as the shore operations base for the supply of all the required materials (Fig. 1.5). Supply boats are envisaged to provide alternating link to the rig with at least one (1) supply being present around the rig at all times (Plate 1.2), and;

(iii) Walvis Bay International Airport or Arandis Airport–Will serve as the aviation base

(Plates 1.4 and 1.5).

All the likely negative and positive impacts associated with the envisaged logistical arrangements in support of the proposed multiple wells drilling operations in PEL No. 44 have been evaluated and the impact assessment results are described in the EIA Vol. 2 of 3 Report with the management and mitigation measures contained in this Environmental Management Plan (EMP) Vol. 3 of 3 Report. Based on the impact assessment undertaken as well as the results from previous similar projects undertaken by RBS between 2008 -2018, no major issues are anticipated with respect to the proposed logistical arrangements as outlined in Fig. 1.5 (Risk-Based Solutions (RBS), 2018a, 2018b, 2017, 2014, 2013a, 2013b, 2013c, 2012a, 2012b and 2008).

1.5.4 Drilling Rig

The proposed multiple wells drilling operations will be undertaken using a dynamically positioned (DP), drillship or semisubmersible (Plates 1.1 and 1.2). A drillship is a ship-shaped maritime vessel which has been fitted with all the necessary equipment required for drilling operations (Plate 1.1). A semisubmersible rig is a floating platform that is supported primarily on large pontoon-like structures submerged below the sea surface with operating decks elevated above the pontoons on large steel columns (Plate 1.2). Drill ships and semisubmersible rigs can both operate in a wide range of water depths, including deep water environments similar to the water depths for the proposed multiple wells drilling operations in PEL No. 44.



Figure 1.5: Envisaged logistical arrangements (Base map Source:

http://portals.flexicadastre.com/ Namibia, Accessed July 2019 and photos by RBS, 2019).

http://portals.flexicadastre.com/



Plate 1.1: Example of a dynamic positioned (no anchors) drillship type of rig that may be used for the proposed multiple well drilling

operations in PEL 44 (RBS Geotagged Image Series 2019).


Monitoring: Printed copies not uncontrolled Page: - 13 - of

110

Project: PEL 44, Block 2212B Walvis Basin Offshore Namibia

Plate 1.2: Example of a dynamic positioned (no anchors) semisubmersible rig that

may be used as an alternative to a drillship for the proposed multiple wells drilling operations in PEL 44 (Source: Chariots Oil and Gas Limited, 2018).


Monitoring: Printed copies not uncontrolled Page: - 14 - of

110

Project: PEL 44, Block 2212B Walvis Basin Offshore Namibia

Plate 1.3: Typical supply vessels that will be used to supply drilling materials from

Walvis Bay to the rig in PEL 44 (RBS Geotagged Image Series 2019).



Plate 1.4: Example of the fixed wing aircraft that will link Walvis Bay (Shore/Operations/supply base) to Windhoek (Headquarters) and the

helicopter that will link Walvis Bay to the Rig offshore in PEL 44 (RBS Geotagged Image Series 2019).



Plate 1.5: Walvis Bay International Airport (top) and Arandis Airport (bottom), the support base for the Windhoek link fixed wing aircraft

and helicopter support link to the rig offshore (RBS Geotagged Image Series, 2019).



2. SUMMARY OF THE EIA FINDINGS

2.1 Overview of the Findings

Detailed assessments of any likely positive and negative impacts have been undertaken and the results are contained in the EIA Vol. 2 of 3 Report with the mitigation measures described in this EMP Vol. 3 of 3 (EMP) report and both prepared in accordance with the provisions of the national legislation, regulations and international best practices. Each potential impact is discussed in the EIA Report based on all relevant information available. While no field-based site-specific surveys / studies were conducted for this project, the information that was available is considered adequate for the assessment of the potential impacts on the receiving environment with respect to the proposed multiple well drilling operations in PEL 44. As with all environmental assessment studies there are those impacts, that as long as mitigation measures are in place, regulations are adhered to and activities properly monitored, are low risk and have low or no significance environmental impact. Others have a potential for moderate and high significance impact and should be evaluated and monitored with far more severity and caution. EMP monitoring requirements shall be commensurately more stringent. A further consideration is the locality of the proposed drill sites with respect to sensitive environmental ecosystems. In this case the proposed drill holes are more than 181 km offshore, in water depth averaging -1000m, hence the level of environmental impact is greatly reduced with no overlapping and competing marine users such as commercial fishing grounds. The proposed drilling location is beyond typical foraging ranges of marine birds and mammals and well outside the Namibian commercial fishing areas and marine protected areas. Furthermore, the result of the oil spill modelling and favourable predominant wind and current directions in the BCLME are coast-parallel, such that in an event of an accidental oil spill occurring, it’s highly unlikely that the oil slick will reach the sensitive coastal zone. More so, however, the probability of an accidental oil spill occurring is very low.

2.2 Summary of the EIA Results

2.2.1 Summary Impacts During Logistics and Mobilisation Phase

Tables 2.1 -2.6 summarises the impact assessment results of the planned and unplanned activities of the logistics and mobilisation stages on various receiving environments and facets of the Benguela Ecosystem. The summary results of the impact assessment for the logistics and mobilisation stages are presented in form of a matrix covering the following: ❖ Sensitivity of receptors (Table 2.1);

❖ Impact magnitude (Table 2.2); ❖ Duration / time period of exposure (Table 2.3);

❖ Geographical extent (Table 2.4);

❖ Probability, likelihood of occurrence (Table 2.5), and;

❖ Overall significant impacts (Table 2.6).



Table 2.1: Sensitivity of receptors with respect to the routine and accidental logistics and mobilisation related activities.

RECEPTORS / TARGETS THAT MAY BE IMPACTED (RESOURCES) PHYSICAL ENVIRONMENT BIOLOGICAL ENVIRONMENT SOCIAL ENVIRONMENT

Air Q

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y

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Seabed

To

pogra

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Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

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urism

and

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Local F

isheries

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EN

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RO

UT

INE

AN

D P

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SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) 2 2 - - - - - - - - 2 2 2 - -


2 2 - - - - - - - - 2 2 2 - -

3 Windhoek Office 2 2 - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - 2 1 1 1 2 2 2 2 1 1 2 2 1 5 Physical Oceanographic Disturbance - 2 2 2 2 2 2 2 2 2 2 2 2 2 2 6 Waste generation 1 2 2 2 1 1 2 2 2 2 2 2 2 2 1 7 Air Emissions 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Atmospheric Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2

10 Light 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 11 Increased marine traffic 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1

AC

CID

EN

TA

L

12

Accidental Diesel / marine gasoil

1

1

2

1

1

1

2

2

2

2

2

2

2

2

1



Table 2.2: Impact magnitude with respect to the routine and accidental logistics and mobilisation related activities.

MAGNITUDE


Air Q

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y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent

Qualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

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xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL



2 2 - - - - - - - - 2 2 2 - -

3 Windhoek Office 2 2 - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - 2 1 1 1 2 2 2 2 1 1 2 2 1 5 Physical Oceanographic Disturbance - 2 2 2 2 2 2 2 2 2 2 2 2 2 2 6 Waste generation 1 2 2 2 1 1 2 2 2 2 2 2 2 2 1 7 Air Emissions 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Atmospheric Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 10 Light 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 11 Increased marine traffic 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1

AC

CID

EN

TA

L

12


1

1

2

1

1

1

2

2

2

2

2

2

2

2

1



Table 2.3: Duration of impact with respect to the routine and accidental logistics and mobilisation related activities.

DURATION


Air Q

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r Q

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Seabed

To

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Sedim

ent Q

ualit

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Benth

ic E

colo

gy

Fis

hes

Tu

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s

Seabirds

Ma

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am

mals

Sensitiv

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Habitats

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urism

And

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isheries

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AN

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AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) T T - - - - - - - - T T T - -


T T - - - - - - - - T T T - -

3 Windhoek Office T T - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - T T T T T T T T T T T T T 5 Physical Oceanographic Disturbance - T T T T T T T T T T T T T T 6 Waste generation T T T T T T T T T T T T T T T 7 Air Emissions T T T T T T T T T T T T T T T 8 Atmospheric Noise T T T T T T T T T T T T T T T 8 Noise T T T T T T T T T T T T T T T 10 Light T T T T T T T T T T T T T T T 11 Increased marine traffic T T T T T T T T T T T T T T T

AC

CID

EN

TA

L

12


T T T T T T T T T T T T T T T



Table 2.4: Geographical extent of impacts with respect to the routine and accidental logistics and mobilisation related activities.

GEOGRAPHICAL EXTENT


Air Q

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y

Clim

ate

Sea W

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r Q

ualit

y

Seabed

To

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phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

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am

mals

Sensitiv

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Habitats

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urism

And

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ES

EN

CE

OP

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AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) L L O O O O O O O O O O O O O


L L - - - - - - - - L L L - -

3 Windhoek Office L L - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - L L L L L L L L L L L L L 5 Physical Oceanographic Disturbance - L L L L L L L L L L L L L L 7 Waste generation L L L L L L L L L L L L L L L 6 Air Emissions L L L L L L L L L L L L L L L 8 Atmospheric Noise L L L L L L L L L L L L L L L 9 Noise L L L L L L L L L L L L L L L 10 Light L L L L L L L L L L L L L L L 11 Increased marine traffic L L L L L L L L L L L L L L L

AC

CID

EN

TA

L

12

Accidental Diesel / marine gasoil L L L L L L L L L L L L L L L



Table 2.5: Probability, likelihood of occurrence of impacts with respect to the routine and accidental logistics and mobilisation related activities.

PROBABILITY


Air Q

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y

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y

Seabed

To

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phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

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am

mals

Sensitiv

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Habitats

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urism

And

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isheries

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INE

AN

D P

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SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) B B B B B B B B B B B B B - -


B B - - - - - - - - B B B - -

3 Windhoek Office B B - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - B B B B B B B B B B B B B 5 Physical Oceanographic Disturbance - B B B B B B B B B B B B B B 6 Waste generation B B B B B B B B B B B B B B B 7 Air Emissions B B B B B B B B B B B B B B B 8 Atmospheric Noise B B B B B B B B B B B B B B B 9 Noise B B B B B B B B B B B B B B B 10 Light B B B B B B B B B B B B B B B 11 Increased marine traffic B B B B B B B B B B B B B B B

AC

CID

EN

TA

L

12


B B B B B B C C C C C C C C B



Table 2.6: Significance of impacts with respect to the routine and accidental logistics and mobilisation related activities.


ENVIRONMENT

Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l H

abitats

To

urism

And

Recre

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n

Local F

isheries

Navig

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nd

Tra

ffic

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ratio

n &

Min

ing

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AN

D P

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SIC

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PR

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OP

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AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL



1/2 1/2 - - - - - - - - 1/2 1/2 1/2 - -

3 Windhoek Office 1/2 1/2 - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - 2/2 1/2 1/2 1/2 2/2 2/2 2/2 2/2 1/2 1/2 2/2 2/2 1/2 5 Physical Oceanographic Disturbance - 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 6 Waste generation 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/2 7 Air Emissions 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 8 Atmospheric Noise 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 9 Noise 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 10 Light 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 11 Increased marine traffic 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/2

AC

CID

EN

TA

L

12


1/2 1/2 2/2 1/2 1/2 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/2



2.2.2 Overall Summary Spudding and Drilling Operations 2.2.2.1 Summary of Impacts

Tables 2.7 – 2.12 summarises the impacts of the different routine planned and unplanned activities and accidental events associated with the spudding and drilling operations phase of the proposed multiple wells drilling operations in PEL 44 with respect to the various components of the receiving onshore, coastal and marine environment. The assessed activities are as follows: ❖ Physical presence rig and support vessel including the exclusion zone;

❖ Physical disturbance from drilling activity; ❖ Planned discharge of drill cuttings, drilling mud and cementing; ❖ Planned discharge of wastes (deck drainage, galley waste, bilge water, sewage, detergents

etc.); ❖ Noise / sound emissions (drilling, support vessels, helicopter and VSP activities; ❖ Light emissions from rig and support vessel; ❖ Unplanned marine discharge (incl. spills of fuel, oils, chemicals, wastes); ❖ Cumulative effects; and; ❖ Major accidental events such diesel or oil spill from a Blow-out.

2.2.2.2 Summary of Impact Assessment Results

The summary results of the impact assessment for the spudding and drilling operations stages are presented in form of a matrix covering the following:

❖ Sensitivity of receptors (Table 2.7);







Table 2.7: Sensitivity of receptors with respect to the routine and accidental spudding and drilling operations related activities.


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

S

edim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

and

Recre

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n

Local F

isheries

Navig

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nd

Tra

ffic

Ma

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n &

Min

ing

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TIA

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INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) 2 2 2 1 1 1 2 2 2 2 2 2 2 2 -


2 2 - - - - - - - - 2 2 2 - -

3 Windhoek Office 2 2 - - - - - - - - - - - - -

OFFSHORE


2 2 2 2 2 2 2 2 2 2 1 1 2 2 1

5 Physical disturbance from drilling activity 2 2 2 2 2 2 2 2 2 2 1 1 2 2 1 6 Planned discharge of drill cuttings, drilling mud and

cementing - - - 2 2 2 2 2 2 2 1 1 2 2 1


- - - 2 2 2 2 2 2 2 1 1 2 2 1


- - - - - 2 2 2 2 2 1 1 2 2 1

8 Light emissions from rig and support vessel - - - - - - 2 2 2 2 1 1 2 2 1 10 Unplanned marine discharge (incl. spills of fuel, oils,

chemicals, wastes) - - - - 2 2 2 2 2 2 1 1 2 2 1

11 Cumulative effects 1 1 2 1 2 2 2 2 2 2 1 1 2 2 1

AC

CID

EN

TA

L

12

Major accidental events such diesel or oil spill from a Blow-out

1

1

3

1

1

1

3 3 3 3 3 3 3

2

1



Table 2.8: Impact magnitude with respect to the routine and accidental spudding and drilling operations related activities.

MAGNITUDE


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

S

edim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

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n

Local F

isheries

Navig

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nd

Tra

ffic

Ma

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ratio

n &

Min

ing

SO

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CE

S O

F P

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EN

TIA

L IM

PA

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RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) 2 2 2 1 1 1 2 2 2 2 2 2 2 2 -


2 2 - - - - - - - - 2 2 2 - -

3 Windhoek Office 2 2 - - - - - - - - - - - - -

OFFSHORE

4 Physical presence rig and support vessel including the

exclusion zone 2 2 2 2 2 2 2 2 2 2 1 1 2 2 1

5 Physical disturbance from drilling activity 2 2 2 2 2 2 2 2 2 2 1 1 2 2 1 6 Planned discharge of drill cuttings, drilling mud and

cementing - - 2 2 2 2 2 2 2 2 1 1 2 2 1


- - 2 2 2 2 2 2 2 2 1 1 2 2 1


- - - - - 2 2 2 2 2 1 1 2 2 1

8 Light emissions from rig and support vessel - - - - - - 2 2 2 2 1 1 2 2 1 10 Unplanned marine discharge (incl. spills of fuel, oils,

chemicals, wastes) - - - - 2 2 2 2 2 2 1 1 2 2 1

11 Cumulative effects 1 1 2 1 2 2 2 2 2 2 1 1 2 2 1

AC

CID

EN

TA

L

12

Major Accidental Diesel / Oil Spill - -

2

1 1 1 2 2 2 2 2 2 2 2 1



Table 2.9: Duration of impact with respect to the routine and accidental spudding and drilling operations related activities.

DURATION


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

S

edim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) T T T T T T T T T T T T T T -


T T - - - - - - - - T T T - -


OFFSHORE

4 Physical presence rig and support vessel including the

exclusion zone T T T T T T T T T T T T T T T

5 Physical disturbance from drilling activity T T T T T T T T T T T T T T T 6 Planned discharge of drill cuttings, drilling mud and

cementing - - T T T T T T T T T T T T T


- - T T T T T T T T T T T T T


- - - - - T T T T T T T T T T

8 Light emissions from rig and support vessel - - - - - - T T T T T T T T T 10 Unplanned marine discharge (incl. spills of fuel, oils,

chemicals, wastes) - - - - T T T T T T T T T T T

11 Cumulative effects T T T T T T T T T T T T T T T

AC

CID

EN

TA

L

12


-

-

T T T T T T T T T T T T T



Table 2.10: Geographical extent of impacts with respect to the routine and accidental spudding and drilling operations related activities.

GEOGRAPHICAL EXTENT


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

S

edim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) L L O - - - O O O O O O O O -


L L - - - - - - - - L L L - -


OFFSHORE


L L L L L L L L L L L L L L L

5 Physical disturbance from drilling activity L L L L L L L L L L L L L L L 7 Planned discharge of drill cuttings, drilling mud and

cementing - - L L L L L L L L L L L L L


- - L L L L L L L L L L L L L


- - - - - L L L L L L L L L L

9 Light emissions from rig and support vessel - - - - - - L L L L L L L L L 10 Unplanned marine discharge (incl. spills of fuel, oils,

chemicals, wastes) - - - - L L L L L L L L L L L

11 Cumulative effects L L L L L L L L L L L L L L L

AC

CID

EN

TA

L

12

Major Accidental Diesel / Oil Spill O O O O O O O O O O O O O O O



Table 2.11: Probability, likelihood of occurrence of impacts with respect to the routine and accidental spudding and drilling operations related activities.

PROBABILITY


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

S

edim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) B B C B B B C C C C B B B C -


B B - - - - - - - - B B B - -


OFFSHORE


B B B B B B B B B B B B B B B

5 Physical disturbance from drilling activity B B B B B B B B B B B B B B B 6 Planned discharge of drill cuttings, drilling mud and

cementing - - B B B B B B B B B B B B B


- - B B B B B B B B B B B B B


- - - - - B B B B B B B B B B

9 Light emissions from rig and support vessel - - - - - - B B B B B B B B B 10 Unplanned marine discharge (incl. spills of fuel, oils,

chemicals, wastes) - - - - B B B B B B B B B B B

11 Cumulative effects B B B B B B B B B B B B B B B

AC

CID

EN

TA

L

12





Table 2.12: Significance of impacts with respect to the routine and accidental spudding and drilling operations related activities.


ENVIRONMENT

Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l H

abitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL



1/2 1/2 - - - - - - - - 1/2 1/2 1/2 - -

3 Windhoek Office 1/2 1/2 - - - - - - - - - - - - -

OFFSHORE


- - 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

5 Physical disturbance from drilling activity 1/1 1/1 1/1 1/1 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1 6 Planned discharge of drill cuttings, drilling mud and

cementing --- - 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1


- 1/1 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1


- - - - - 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

9 Light emissions from rig and support vessel - - - - - - 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1 10 Unplanned marine discharge (incl. spills of fuel, oils,

chemicals, wastes) - - 2/2 - - - 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

11 Cumulative effects 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/1 1/1 2/2 2/2 1/1

AC

CID

EN

TA

L

12


1/2 1/2

2/2

1/2 1/2 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/2



2.2.3 Summary Assessment of Impacts During Decommissioning

The impacts assessment results of the planned and unplanned activities of the decommissioning phase on various receiving environments of the Benguela ecosystem are similar to those of the logistic and mobilisation phases (Tables 2.13 - 2.18). The summary results of the impact assessment for the logistic and mobilisation phases and similar to the decommissioning phase are presented in form of a matrix covering the following: ❖ Sensitivity of receptors (Table 2.13);







Table 2.13: Sensitivity of receptors with respect to decommissioning / abandonment phase.


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

and

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL



2 2 - - - - - - - - 2 2 2 - -

3 Windhoek Office 2 2 - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - 2 1 1 1 2 2 2 2 1 1 2 2 1 5 Physical Oceanographic Disturbance - 2 2 2 2 2 2 2 2 2 2 2 2 2 2 6 Waste generation 1 2 2 2 1 1 2 2 2 2 2 2 2 2 1 7 Air Emissions 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Atmospheric Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2

10 Light 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 11 Increased marine traffic 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1

AC

CID

EN

TA

L

12


1

1

2

1

1

1

2

2

2

2

2

2

2

2

1



Table 2.14: Impact magnitude with respect to the decommissioning / abandonment phase.

MAGNITUDE


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL



2 2 - - - - - - - - 2 2 2 - -

3 Windhoek Office 2 2 - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - 2 1 1 1 2 2 2 2 1 1 2 2 1 5 Physical Oceanographic Disturbance - 2 2 2 2 2 2 2 2 2 2 2 2 2 2 6 Waste generation 1 2 2 2 1 1 2 2 2 2 2 2 2 2 1 7 Air Emissions 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Atmospheric Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 8 Noise 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 10 Light 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 11 Increased marine traffic 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1

AC

CID

EN

TA

L

12


1

1

2

1

1

1

2

2

2

2

2

2

2

2

1



Table 2.15: Duration of impact with respect to the decommissioning / abandonment phase.

DURATION


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) T T - - - - - - - - T T T - -


T T - - - - - - - - T T T - -


OFFSHORE

4 Ballast water - - T T T T T T T T T T T T T 5 Physical Oceanographic Disturbance - T T T T T T T T T T T T T T 6 Waste generation T T T T T T T T T T T T T T T 7 Air Emissions T T T T T T T T T T T T T T T 8 Atmospheric Noise T T T T T T T T T T T T T T T 8 Noise T T T T T T T T T T T T T T T 10 Light T T T T T T T T T T T T T T T 11 Increased marine traffic T T T T T T T T T T T T T T T

AC

CID

EN

TA

L

12


T T T T T T T T T T T T T T T



Table 2.16: Geographical extent of impacts with respect to the decommissioning / abandonment phase.

GEOGRAPHICAL EXTENT


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) L L O O O O O O O O O O O O O


L L - - - - - - - - L L L - -


OFFSHORE

4 Ballast water - - L L L L L L L L L L L L L 5 Physical Oceanographic Disturbance - L L L L L L L L L L L L L L 7 Waste generation L L L L L L L L L L L L L L L 6 Air Emissions L L L L L L L L L L L L L L L 8 Atmospheric Noise L L L L L L L L L L L L L L L 9 Noise L L L L L L L L L L L L L L L 10 Light L L L L L L L L L L L L L L L 11 Increased marine traffic L L L L L L L L L L L L L L L

AC

CID

EN

TA

L

12

Accidental Diesel / marine gasoil L L L L L L L L L L L L L L L



Table 2.17: Probability, likelihood of occurrence of impacts with respect to the decommissioning / abandonment phase.

PROBABILITY


Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL

1 Walvis Bay (Shore/ Operational Base Activities) B B B B B B B B B B B B B - -


B B - - - - - - - - B B B - -


OFFSHORE

4 Ballast water - - B B B B B B B B B B B B B 5 Physical Oceanographic Disturbance - B B B B B B B B B B B B B B 6 Waste generation B B B B B B B B B B B B B B B 7 Air Emissions B B B B B B B B B B B B B B B 8 Atmospheric Noise B B B B B B B B B B B B B B B 9 Noise B B B B B B B B B B B B B B B 10 Light B B B B B B B B B B B B B B B 11 Increased marine traffic B B B B B B B B B B B B B B B

AC

CID

EN

TA

L

12





Table 2.18: Significance of impacts with respect to the decommissioning / abandonment phase.


ENVIRONMENT

Air Q

ualit

y

Clim

ate

Sea W

ate

r Q

ualit

y

Seabed

To

pogra

phy

Sedim

ent Q

ualit

y

Benth

ic E

colo

gy

Fis

hes

Tu

rtle

s

Seabirds

Ma

rin

e M

am

mals

Sensitiv

e C

oasta

l

Habitats

To

urism

And

Recre

atio

n

Local F

isheries

Navig

atio

n a

nd

Tra

ffic

Ma

rin

e E

xplo

ratio

n &

Min

ing

SO

UR

CE

S O

F P

OT

EN

TIA

L IM

PA

CT

RO

UT

INE

AN

D P

HY

SIC

AL

PR

ES

EN

CE

OP

ER

AT

ION

AL

AC

TIV

ITIE

S

ONSHORE / COASTAL



1/2 1/2 - - - - - - - - 1/2 1/2 1/2 - -

3 Windhoek Office 1/2 1/2 - - - - - - - - - - - - -

OFFSHORE

4 Ballast water - - 2/2 1/2 1/2 1/2 2/2 2/2 2/2 2/2 1/2 1/2 2/2 2/2 1/2 5 Physical Oceanographic Disturbance - 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 6 Waste generation 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/2 7 Air Emissions 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 8 Atmospheric Noise 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 9 Noise 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 10 Light 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 11 Increased marine traffic 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/2

AC

CID

EN

TA

L

12


1/2 1/2

2/2

1/2 1/2 1/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 2/2 1/2



2.2.4 Risk-Assessment Approach

In line with the IMO guidance on risk assessment for oil spill, a five (5) steps approach was adopted. The following is the summary of the key steps that were undertaken as part of the risk assessment process:

❖ Identification of Oil Spill Scenarios: Potential scenarios that may lead to an accidental

release of oil are identified. The source of the spill, event, oil type and volume were considered. This has been achieved by conducting a risk assessment analysis in order to understanding the key processes and issues that may result in potential oil spills. The results of this step were recorder in the risk register;

❖ The level of impact and likelihood of occurrence of all oil spill scenarios were identified semi

quantitatively assessed (Tables 2.19 and 2.20); ❖ The potential impact and likely trajectory of an oil spill identified in the oil spill scenarios

outlined in the Risk Register was assessed; ❖ The tiered response approach and response strategy suitable for each scenario has been

defined. Influencing factors include: oil type, spill volume, climate, proximity to sensitive resources and response capability, and;

❖ The risk assessment process was completed by determining the level of impacts in terms of

low, medium or high risk. Based on the results of the environmental assessment process covering Scoping and this Environmental Impact Assessment (EIA), a risk assessment associated with an accidental oil spill occurrence and its likely impact was undertaken. The results of the various risk scenarios and the associated tiered response strategy in line with this OSCP are shown in Table 2.21. Therefore, the accidental oil spills risks are considered ALARP (As Low As Reasonably Practicable) and tolerable.

Table 2.19: Level of likely impacts.

Severity Environment

1 Slight impact

2 Minor local impact

3 Moderate regional impact

4 Major national impact

5 Extensive international impact

Table 2.20: Likelihood of occurrence.

Likelihood Definition

A Never happened of in the industry

B Heard of in the industry

C Has happened in the organisation or more than once per year in the industry

D Has happened at the location or more than once per year in the organisation

E Has happened more than once a year at the location



Table 2.21: Risk Assessment results.

No. Source Event Oil Type Spill Volume

Impact Likelihood (Table 2.20)

Consequence (Table 2.19)

Risk Response Strategies

Tiered Resources

1

PSV/ Rig

Minor operational spill during diesel transfer - release on deck

Diesel

<1 m³

Deck spill unlikely to reach the sea - likely drainage to sullage tank for separation

D

1

Low

Deck clean-up expected to be undertaken for a spill of this size

Appropriate Tier 1 resources such as the on-board spill kit. This will include sorbents, sand, plastic sheeting, PPE, shovels, rakes and buckets.

2

PSV/ Rig

Minor operational spill during diesel transfer - release to the sea

Diesel

<1 m³

Released to the sea. Small volume expected and oil likely to disperse quickly

D

2

Medium


Continuous monitoring should be undertaken to ensure further pollution does not occur

Appropriate Tier 1 resources and continued monitoring and evaluation of the situation.

3

Rig

Full bore release of diesel due to transfer hose rupture

Fitted at either end of hose so worst-case scenario would be loss of entire capacity hose

Diesel

5-10 m³

Release to sea. Small volume expected and the oil is likely to disperse quickly

B

1

Low

Due to the small release volume and distance offshore, continued monitoring and evaluation of the situation is required until all the oil has dispersed

Continued monitoring and evaluation of the situation



Table 2.21: Cont.

No. Source Event Oil Type Spill Volume




Tiered Resources

4

Rig

Minor operational spill - release on deck

Lube oil, hydraulic oil, SBM etc.

<1 m³

Deck spill unlikely to reach the sea - likely drainage to sullage tank for separation

B

1

Low



5

PSV

Small operational spill

Utility oils, hydraulic oil, Lube oil etc.

<1 m³

Deck spill unlikely to reach the sea

B

1

Low



6

Rig

Total loss of diesel inventory following loss of entire tank (collision/grounding/structural failure)

Diesel

(Total inventory)

Release to sea. Shoreline impact is expected to be minimal due to prevailing wind and current direction

Possible local media interest

B

3

Low

Due to the large release volume and distance offshore, continued monitoring and evaluation of the situation is required until all the oil has dispersed. Assisted natural dispersion may also be considered

Appropriate Tier 1 resources



Table 2.21 Cont. No. Source Event Oil

Type Spill Volume




Tiered Resources

7

Largest PSV (Pacific Askari)

Offshore diesel spill following loss of entire tank (collision/structural failure)

The largest PSV diesel tank volume is considered.

Diesel

3002

Release to sea Shoreline impact is expected to be minimal due to prevailing wind and current direction Possible national media interest

B

4

Medium

Continued aerial monitoring and surveillance of the spill until the oil volume is considered insignificant

All available Tier 1 resources

Tier 2: WACAF Aerial Surveillance Aircraft

8

PSV

Onshore loss of all diesel from a single tank due to impact with jetty or errant vessel within the Port of Walvis Bay area

The largest PSV diesel tank volume is considered.

Diesel

996 m³

Release to sea (in port area). National Park coastline and sensitive coastal habitats impacted Government and national media interest guaranteed

B

4

Medium

Containment and recovery of oil where possible. Shoreline clean-up operations and continual aerial surveillance


Consider Tier 2: WACAF Aerial Surveillance Aircraft

Consider Tier 3: OSRL

9

PSV

Discharge of contaminated ballast, engine room bilges or overflow from bunker during transfer operations within the port of Walvis Bay

Oily water

<3 m³

Release to sea (in the Port of Walvis Bay area)

Possible local media interest

C

1

Low

Continuous monitoring should be undertaken to ensure further pollution does not occur. Containment and recovery operations may be mobilised.


Port of Walvis Bay Tier 1 oil spill response equipment

10

Rig

Loss of well control during operations resulting in a release for 70 days until the primary well has been exhausted.

Crude

794.93 m3/day

Release to sea National Park and sensitive coastal habitats coastline impacted. International media and government interest guaranteed.

B

5

High

Wide scale aerial dispersant application, extensive containment and recovery, shoreline clean-up and continual aerial surveillance


Tier 2: Aerial Dispersant Application and Surveillance Aircraft

Tier 3: OSRL / International Support



3. REGULATORY REGISTER

3.1 Constitutionality of the Environmental Assessment

The regulatory framework that guides petroleum exploration and development in Namibia puts forward the fundamental concept of sustainable development and application of environmental safeguard tools. This principle ensures that if any action has a suspected risk of negatively impacting the public or the natural environment in the absences of scientific consensus that the action is harmful, the burden of proof that the action is not harmful, and falls on the perpetuator of the action. This principle signifies social responsibility to protect the public and the natural environment from exposure to harm.

The Namibian government has developed a strategic plan “Vision 2030” to guide direction for developmental partners, local authorities, private sector and government ministries of the countries common goal. Vision 2030 insures that; The nation shall develop its natural capital for the benefit of its social, economic and ecological well-being by adopting strategies that: promote the sustainable, equitable and efficient use of natural resources; maximize Namibia’s comparative advantages; and reduce all inappropriate resource use practices. However, natural resources alone cannot sustain Namibia’s long-term development, and the nation must diversify its economy and livelihood strategies.

Overall, however, the constitution is the Namibian fundamental law of its sovereign and independent republic and a driving principle for all regulatory frameworks or Act promulgated. The relevance of the Constitution to environmental management as applicable to the proposed petroleum exploration (drilling of an exploratory well) in PEL 44 can be taken from Article 95: Promotion of the Welfare of the People. This affirms that the State shall actively promote and maintain the welfare of the people by adopting policies aimed at the maintenance of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future. Article 101 further states that; “the principles embodied within the constitution shall not of and by themselves be legally enforceable by any court, but shall nevertheless guide the Government in making and applying laws.” The courts are entitled to have regard to the said principles in interpreting any laws based on them. This has resulted in the development and promulgation of a number of binding legal environmental policies, Act and regulations. The most important pieces of environmental legislations that is in line with Article 95 of the Constitution with respect to the proposed offshore petroleum exploration in PEL 44 are those covering petroleum, fisheries, environment, maritime, health and safety.

3.2 Drilling Permit Requirements Register

Based on the analysis of all the key and relevant regulatory systems in Namibia with respect to the proposed drilling by M & P Namibia (Pty) Ltd in PEL 44, the following are the key and important permits and endorsements required before the drilling can go ahead:

(i) Environmental Clearance Letter / Certificate;

(ii) Oil Spill Contingency Plan (OSCP) Approved / Endorsed;

(iii) Emergency Response Plan (ERP) Approved / Endorsed;

(iv) Radioactive Authorisation (Import and Export Permits) for the use of radioactive sources

for logging;

(v) Pollution Safety Certificate for the platform to be used in the Namibian Waters;



(vi) Explosive Permit Registration (Import and Export Permits) as a consumer and importer of explosives and for the use of explosive materials in the drilling process;

(vii) Preapproval for the use of dispersants in an event of an oil spill, and;

(viii) Letter of consent to drill or permit to drill, drilling reporting and notification of well

abandonment and drilling completion.

The Environmental Clearance Certificate (ECC) is one of the major permit requirements that requires a lot of time and is key to all other subsequent predrilling, drilling and post drilling permits. The overall objective of this permit is to make sure that all the environmental issues associated with the proposed project have been addressed and a management plan have been developed to manage / mitigate any likely impacts. The proposed project requires Environmental Clearance Certificate because it falls within the list of activities under the Environmental Management, 2007, (Act No. 7 of 2007) that cannot be undertaken without a full Environmental Assessment study.

3.3 Petroleum Exploration and Production Legislation Register

In accordance with the Petroleum (Exploration and Production) Act 1991 (Act 2 of 1991), and in an effort to promote petroleum exploration activities in Namibia, the Ministry of Mines and Energy is the Competent Authority and has the mandate to issue three types of licenses namely; Reconnaissance, Exploration and Production Licences. A reconnaissance licence is issued under Section 26 of the Petroleum (Exploration and Production) Act 1991 (Act 2 of 1991), and includes any renewal of such licence. Reconnaissance activities are carried out for or in connection with the search for petroleum by geological, geophysical and photogeological surveys and includes any remote sensing techniques. Exploration licence is issued under Section 34 of the Petroleum (Exploration and Production) Act 1991 (Act 2 of 1991), and includes any renewal of such licence. A production licence is issued under Section 50 and includes any renewal of such licence. M & P Namibia (Pty) Ltd holds exploration licenses under PEL 44 offshore and intends to implement the activities of the exploration programme drilling of exploration wells over selected target within PEL 44.

3.4 Environmental Legislation and Regulations Register

The purpose of the Environmental Management Act, (EMA), 2007, (Act No. 7 of 2007) and the associated EIA Regulations No. 30 is to give effect to Articles 95(c) and 95 (1) of the Namibian Constitution by establishing general principles for the management of the environment and natural resources. It further promotes the coordination and integrated management of the environment. The Environmental Management Act sets out the following principles of environmental management and fully embraces public and stakeholders consultations and participation process:

(i) Renewable resources must be used on a sustainable basis for the benefit of present and

future generations;

(ii) Community involvement in natural resources management and the sharing of benefits arising from the use of the resources, must be promoted and facilitated;

(iii) The participation of all interested and affected parties must be promoted and decisions

must take into account the interest, needs and values of interested and affected parties;

(iv) Equitable access to environmental resources must be promoted and the functional integrity of ecological systems must be taken into account to ensure the sustainability of the systems and to prevent harmful effects;



(v) Assessments must be undertaken for projects which may have a significant effect on the environment or the use of natural resources;

(vi) Sustainable development must be promoted in all aspects relating to the environment;

(vii) Namibia's cultural and natural heritage including, its biological diversity, must be

protected and respected for the benefit of present and future generations;

(viii) The option that provides the most benefit or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long term as well as in the short term must be adopted to reduce the generation of waste and polluting substances at source;

(ix) The reduction, re-use and recycling of waste must be promoted;

(x) A person who causes damage to the environment must pay the costs associated with

rehabilitation of damage to the environment and to human health caused by pollution, including costs for measures as are reasonably required to be implemented to prevent further environmental damage;

(xi) Where there is sufficient evidence which establishes that there are threats of serious or

irreversible damage to the environment, lack of full scientific certainty may not be used as a reason for postponing cost-effective measures to prevent environmental degradation, and;

(xii) Damage to the environment must be prevented and activities which cause such

damaged must be reduced, limited or controlled.

The proposed drilling project by M & P Namibia (Pty) Ltd covering PEL 44 falls within the categories of listed activities that cannot be undertaken without an Environmental Clearance Certificate. An Environmental Clearance for a listed activity is issued based on the review and approval by the Environmental Commissioner of the findings of an Environmental Assessment covering Scoping, Environmental Impact Assessment (EIA) and the development of an Environmental Management Plan (EMP).

3.5 Other Key National Legal Instruments Register

The following are some of the key legislation relevant to the proposed offshore drilling project in PEL 44:

1. Environmental Assessment Policy for Sustainable Development and Environmental

Conservation (1995);

2. Environmental Management Act, (No. 7 of 2007) (Not yet implemented);

3. Marine Resources Act, (Act 27 of 2000) and all associated regulations;

4. Territorial Sea and Exclusive Economic Zone of Namibia Act 3 of 1990; 5. Namibian Ports Authority Act, (Act 2 of 1994) and all associated regulations; 6. Merchant Shipping Act, (Act 57 of 1951); 7. Marine Traffic Act, (Act 2 of 19981) (As amended by Act 15 of 1991); 8. Prevention and Combating of Pollution of the Sea by Oil Act, (Act 6 of 1981) (as amended

by Act 24 of 1991);



9. Dumping at Sea Control Act 73 of 1980;

10. Immigration Control Act 7 of 1993; 11. Customs and Excise Act 20 of 1998; 12. Value Added Tax Amendment Act 2002; 13. Value Added Tax 5 of 2004; 14. Namibian Income Tax Amendment Act 2003; 15. Namibia Income Tax Act 1991;

16. The Regional Councils Act, 1992, (Act 22 of 1992); 17. The Local Authorities Act, 1992, (Act 23 of 1992);

18. Hazardous Substances Ordinance 14 of 1974; 19. Atmospheric Pollution Prevention Ordinance 11 of 1976; 20. Water Resources Management Act, 2004, (Act No. 24 of 2004); 21. Atomic Energy and Radiation Protection Act (Act No. 5 of 2005); 22. The Nature Conservation Ordinance, Ordinance 4 of 1975, Amendment Act, Act 5 of 1996

and the current draft Parks and Wildlife Management Bill of 2006; 23. The Labour Act 2004, (Act 15 of 2004), amended 2010;

24. United Nations Law of the Sea Convention (UNCLOS), of 1982, and;

25. International Convention for the Prevention of Pollution from Ships (MARPOL 78) and

Namibia is a party to Annexes I, II, III, IV and V of MARPOL 73/78.

3.6 Regional Frameworks and Protocols Register

Namibia party to number of regional initiatives, bilateral and co-operative agreements implemented across southern, west and central Africa. These include:

1. The Convention for Co-operation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region (Abidjan Convention): The Abidjan Convention is a co-operative agreement in the protection and development of the marine and coastal environment of west and central Africa. The Convention was adopted by 11 countries at a conference in Abidjan in March, 1981;

2. Benguela Current Large Marine Ecosystem (BCLME) Programme Regional Oil Spill Contingency Plan: The BCLME programme was a five-year project (2002-2007) funded by the Global Environment Facility (GEF). The BCLME programme was designed to improve the structures and capacities of Namibia, Angola and South Africa in addressing transnational environmental problems. The Centre for Biodiversity, Ecosystem Health, and Pollution based in Luanda (Angola) coordinated a regional policy to minimise the transboundary impacts of oil pollution from activities in the Exclusive Economic Zone (EEZs) of the individual countries in 2003(Rohr, 2008). This regional plan allows for the holistic management of the Benguela Current Large Marine Ecosystem as a whole;



3. Multi-bilateral Search and Rescue (SAR) Agreement: Namibia is a signatory to a Maritime Search and Rescue (SAR) Agreement with South Africa, Madagascar, Mozambique and the Comoros, and;

4. Southern African Development Community (SADC) Protocol on Transport & Meteorology: The SADC treaty and declaration was signed in 1992 and currently has 15 member states. The SADC treat aims to improve the quality of life and economic status for the people of Southern Africa through a number of shared initiatives, including those concerned with transport and meteorology within Namibia.

3.7 International Obligations Register

Namibia is signatory to the following International Conventions:

1. United Nations Convention on the Law of the Sea, 1982 (UNCLOS-82);

2. International Maritime Organization (IMO) Convention, 1948;

3. International Convention on the Safety of Life at Sea, 1974/78;

4. International Convention on the Regulations for Preventing Collisions at Sea, 1972;

5. International Convention on Tonnage Measurement of Ships, 1969;

6. International Convention on Oil Pollution Preparedness, Response and Co-operation, 1990 (OPRC 1990);

7. International Convention for the Prevention of Pollution from ships, 1973 as modified by the

Protocol of 1978 (MARPOL 73/78);

8. International Convention on Civil Liability for Oil Pollution Damage, 1992 (CLC Protocol of 1992);

9. International Convention on the Establishment of an International Fund for Compensation

for Oil Pollution Damage, 1992 (Fund Protocol of 1992);

10. International Convention Relating to Intervention on the High Sea in Case of Oil Pollution Casualties as amended 1969/73.

The Conventions of relevance to oil spill contingency, preparedness and response are as follows:

1. United Nations Convention on the Law of the Sea, 1982 (UNCLOS 82);

2. International Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC 90);

3. International Convention for the Prevention of Pollution from Ships (MARPOL 73/78);

4. International Fund for Compensation for Oil Pollution Damage (Fund 1992), and;

5. Civil Liability Convention (CLC) 1969 (amended with 1992 protocol).



4. EMP AND MONITORING FRAMEWORK

4.1 Introduction

This section of this EIA and EMP Report provides a detailed plan of action required on the implementation of the mitigation measures for minimising the identified significant negative impacts on the receiving onshore, coastal and marine environments. The EMP Framework presented in this chapter also provides the management actions including roles and responsibility requirements for implementation of the EMP by M &P Namibia (Pty) Ltd throughout the duration of the proposed drilling programme covering logistics and mobilisation, spudding and drilling as well as demobilisation abandonment stages. The EMP requirements must be implemented by the Operator (M &P Namibia (Pty) Ltd) as well as all the contractors and subcontractors who will undertake the various activities of the proposed multiple wells drilling operations.

This EMP gives commitments including financial, equipment and human resources provisions for effective implementation of the mitigation measures and management of the likely environmental liabilities during the proposed multiple wells drilling operations. Monthly environmental monitoring, review, assessments and evaluation of the environmental performances covering the rig offshore (PEL 44), Operations (Shore) base Walvis Bay Port and Aviation Support Base (Walvis Bay International Airport / Arandis Airport) must be undertaken for the duration of the proposed drilling programme.

4.2 EMP Provisions

4.2.1 Objectives

The purpose of an EMP is to identify how commitments made in the EIA Section of this report will be translated into actions in the field and the timings for implementing these actions. It also identifies key roles and responsibilities. The EMP is the mechanism for ensuring that measures developed for the protection of the natural and human environment through the EIA process are implemented in an appropriate and timely manner. Its main objectives are to:

❖ Ensure the Project is compliant with applicable national environmental and social legal

requirements, Maurel & Prom Namibia (Pty) Ltd’s standards, and Good International Industry Practice (GIIP);

❖ Provide a framework for planning and implementation of all mitigation measures identified in the EIA Report (presented in Chapter 3 and Chapter 6);

❖ Outline roles and responsibilities of Maurel & Prom Namibia (Pty) Ltd, its contractors, and relevant authorities;

❖ Identify training and competency requirements, and;

❖ Describe Project communication protocols and identify documentation and reporting requirements.

The EMP also provides a framework for the monitoring of proposed mitigation measures to:

❖ Ensure they are carried out in accordance with the EIA, and;

❖ Demonstrate their effectiveness, or identify areas where supplementary measures may be

required.

In accordance to Maurel & Prom Namibia (Pty) Ltd internal requirements, this framework EMP is a ‘live’ document, meaning that it will be reviewed, amended and updated by Maurel & Prom



Namibia (Pty) Ltd and the appointed contractor as the Project design develops and more detailed information becomes available. This will allow for achievement of effective sustainability management and continuous improvement of the Project’s environmental and social performance. The EMP will be regularly reviewed by the relevant Project teams and, where changes or corrective actions are deemed necessary, amendments will be made.

4.2.2 EMP Requirements and Standards

The proposed multiple wells drilling operations will be performed strictly in accordance with the M &P Namibia (Pty) Ltd specifications, operational manuals, procedures, standards and the Environmental Policy and Procedures. References/guidelines/benchmarks to be used include the American Petroleum Institute (Table 4.1), and other International Standards and Specifications (Table 4.2) and their respective regulations, procedures and operation manuals. Where appropriate standards and specifications are not defined, internationally recognised standards and specifications as well as petroleum exploration best practices will be used. A primary objective will be to drill the well to the highest HSE standards.

Furthermore, according to the International Finance Corporation (IFC) Performance Standard PS1 (IFC, 2012), a project’s proponent should establish and maintain a Social and Environmental Management System appropriate to the nature and scale of the project and commensurate with the level of social and environmental risks and impacts. Environmental and social issues relevant to the Project are also guided by a number of legal requirements and standards. These include, but are not limited to, the following:

❖ The provisions of the Environmental Management Act, 2007, (Act No. 7 of 207) and the

Environmental Impact Assessment Regulations 2012,

❖ International and regional conventions and agreements guidelines, including guidance from International Convention on the Safety of Life at Sea (SOLAS) and MARPOL 73/78 measures for prevention of pollution;

❖ Maurel & Prom Namibia (Pty) Ltd’s Safe and Sustainable Operations Policy, Human Rights

Policy and Non-Technical Risk Standard, together with relevant internal management standards and guidance documents;

❖ Industry codes of practice promulgated by the International Petroleum Industry

Environmental Conservation Association (IPIECA), or International Association for Oil and Gas Producers (IOGP), and;

❖ Relevant international standards e.g. 2015 IFC Environmental Health and Safety Guidelines

for Offshore Oil and Gas Development. Table 4.1: Other International Standards.

Reference Specification Description Institute of Petroleum Model Code of Practice - Hazardous Area Classification

Institute of Petroleum Use of Diesel Engines and Electrical Appliances in Zone Area Classification Code 2 Areas

IADC IADC Drilling Manual

MODU Code 79 The code for construction and equipment of Mobile Offshore Drilling Unit

SOLAS The Safety of Life at Sea Convention

ISBN 2-7108-0600-2 Drilling Data Handbook, Editions Technique, English Edition, Institute Français Du Petrole



Table 4.2: American Petroleum Institute (API) Standards.

Reference API Specification Description API Spec 4F Specification for Drilling and Well Servicing Structures

API Spec 5CT Specification for Casing and Tubing

API Spec 5D Specification for Drill pipe

API Spec 7 Specification for Rotary Drilling Equipment

API Spec 7B-11C Specification for Internal-Combustion Reciprocating Engines for Oil Field Service

API Spec 8A Specification for Drilling and Production Hoisting Equipment

API Spec 9A Specification for Wire Rope

API Bull 5C2 Bulletin on Performance Properties of Casing, Tubing and Drill Pipe

API Bull 5A2 Bulletin on Thread Compounds for Casing, Tubing and Line Pipe

API RP 5A5 Recommended Practice for Field Inspection of New Casing, Tubing and Plain End Drill Pipe

API RP 5C Recommended Practice for Care and Use of Casing and Tubing

API RP 7G Recommended Practice for Drill Stem Design and Operating Limits

API RP 8B Recommended Practice for Hoisting Tool Inspection and Maintenance Procedures

API RP 9B Recommended Practice on Application, Care and Use of Wire Rope for Oil Field Service

API RP 49 Recommended Practices for Safe Drilling of Well Containing Hydrogen Sulphide

API RP 53 Recommended Practices for Blow Out Protection Equipment Systems for Drilling Wells

API RP 54 Rec. Practices for Safety and Health for Oil and Gas Well Drilling and Servicing Operations

API RP 59 Recommended Practices for Well Control Operations

API RP 7C-11F Rec. Practices for Installation Maintenance and Operation of Internal Combustion Engines

API Spec 10 Specifications for Materials and Testing for Well Cements

API Bull 10C Bulletin on Oil Well Cement Nomenclature

API Spec 10D Specification for Bow-Spring Casing Centralisers

API RP 10F Recommended Practice for Performance of Cementing Float Equipment

API Spec 13A Specification for Oil Well Drilling Fluid Materials

API Rec RP 13B Recommended Practice for Standard Procedure for Field Testing Drilling Fluids

API Bull 13D Bulletin Rheology of Oil Well Drilling Fluids

API Rec RP 13E Recommended Practice for Shale Shaker Screen Cloth Designation

API RP 13F Bulletin on Oil Gas Well Drilling Fluid Chemicals

API Spec RP 13G Recommended Practice for Drilling Mud Report Form

API Rec RP 13I Recommended Practice, Standard Procedure for Laboratory Testing Drilling Fluids

API Rec RP 13J Recommended Practice for Testing Heavy Brines

API Rec RP 13K Recommended Practice for Testing Heavy Brines

API Rec RP 7G Recommended Practice for Drill Stem Test Design and Operation Limits

API Rec RP 48 Recommended Practice for Drill Stem Test Report Form

API Bull SA2 Bulletin on Thread Compounds for Casing, Tubing and Line Pipe

API RP 44 9.3 Recommended Practice for Sampling Petroleum Reservoir Fluids

4.2.3 EMP Roles and Responsibilities

4.2.3.1 Proponent (M &P Namibia (Pty) Ltd)

The overall responsibilities for environmental accountabilities for environmental assessment, management and monitoring with respect to the proposed multiple wells drilling operations lies with M &P Namibia (Pty) Ltd. In event of a negative environmental impact such as an oil spill, resulting in environmental liabilities, the M &P Namibia (Pty) Ltd, will be liable in accordance with the Namibian Environmental Management Act of 2007, (Act No. 7 of 2007) made effective as from February 2012 as well as within the framework of the international maritime laws and obligations to which Namibia is party. Maurel & Prom Namibia (Pty) Ltd will ensure that all commitments are implemented and that the Project’s environmental and social performance



complies with the relevant legal, regulatory and policy standards (Chapter 2). Maurel & Prom Namibia (Pty) Ltd’s responsibilities include:

❖ Establishing clearly documented responsibilities, lines of communication and operational

procedures with the Project Contractor(s);

❖ Implementation and updating of the Project Stakeholder Engagement Plan (SEP) and for engaging actively with the Namibian governmental agencies and key stakeholders on all aspects of the Project compliances;

❖ Through contractual clauses, ensuring that the Contractor(s) comply with the environmental

and social commitments specified in the EMP and specifying that the Contractor(s) allocate qualified staff, vessels, and equipment to carry out the Project;

❖ Managing the performance of the Contractor(s) through inspections and monitoring, and;

❖ Obligating or verifying that the Contractor provides sufficient training to its employees/crew

to meet the EMP requirements.

Maurel & Prom Namibia (Pty) Ltd representatives will be responsible for:

❖ Monitoring the Contractor’s performance and providing advice on environmental, health and safety issues during the Project planning, operation and decommissioning;

❖ Monitoring the implementation of Maurel & Prom Namibia (Pty) Ltd Safe and Sustainable

Operations Policy and Project EMP;

❖ Stopping work in the event of non-compliance, and imposing remedial action and informing the relevant personnel, companies and organisations, and;

❖ Preparing non-compliance reports to be submitted to the Project Manager.

A dedicated Maurel & Prom Namibia (Pty) Ltd representative will be onboard the drillship to ensure compliance with approved operating procedures, including those concerning environmental protection and safety. The Maurel & Prom Namibia (Pty) Ltd representative will have the assistance of an office-based project management team.

Maurel & Prom Namibia (Pty) Ltd will designate a land based representative responsible for engagement with local fishing enterprises, government fisheries agencies authorities in advance of drilling operations to ensure that any potential disturbance caused by the safety exclusion zone is minimised. The Maurel & Prom Namibia (Pty) Ltd representative will also provide prior notification to fishing licence holders who have the potential to be operating in or near the Project Area of Influence. This notification will advise license holders of the safety exclusion zone, the schedule for its operation, and the measures that will be used to communicate with fishing vessels that are in the vicinity of the exclusion zone.

4.2.3.2 Drilling Contractor and Support Vessel Contractors

Maurel & Prom Namibia (Pty) Ltd will designate a drilling contractor who will have direct responsibility for the execution of the drilling programme and implementing the Project SSEA management plans and procedures in line with applicable national standards, as well as Maurel & Prom Namibia (Pty) Ltd procedures and guidelines. Maurel & Prom Namibia (Pty) Ltd will also contract the support vessels necessary to support the Project. All vessels will be certified by either the Oil Companies International Marine Forum (OCIMF) or the International Marine Contractors Association (IMCA) (unless this certification is not required) and will have passed the Offshore Vessel Inspection Database (OVID) inspections, and operate in accordance with GIIP, reducing the risk of operational failures.



As this EMP is a live document, it will be agreed and checked by the drilling contractor as required to ensure that all environmental requirements are implemented.

It is expected that the drilling contractor will:

❖ Appoint an SSEA Advisor within its Project team who will facilitate the implementation of this

EMP and other Project specific plans;

❖ Ensure that all environmental licenses and permits from the relevant authorities are valid prior to commencing the Project;

❖ Ensure that operational controls and procedures are fully consistent with the level of

specifications and safeguards set out in the EIA Report and EMP;

❖ Provide Maurel & Prom Namibia (Pty) Ltd with weekly SSEA reports on Project performance and environmental monitoring;

❖ Take appropriate steps to contain and minimise damage in the event of a non-routine event,

in compliance with the Emergency Response Plan;

❖ Identify in advance the additional elements or events which are likely to pose environmental and social risks, and inform Maurel & Prom Namibia (Pty) Ltd on risk management strategies, and;

❖ Report non-compliances and incidents, including near-misses, irrespective of their scale to

Maurel & Prom Namibia (Pty) Ltd management.

The drilling programme will be carried out under the management of the Maurel & Prom Namibia (Pty) Ltd Drilling Manager while the drillship Offshore Installation Manager (OIM) and support vessel Captains will have overall authority and responsibility for vessel operation. The Captains will oversee the vessel crew and will ensure everyone onboard receives the necessary health and safety training.

4.3 EMP Framework

4.3.1 EMP Mitigation Measures, Monitoring and Reporting

The Project personnel onboard the drillship and support vessels and the Maurel & Prom Namibia (Pty) Ltd operations team will be required, as a minimum, to adhere to the requirements listed in this framework EMP summarised in Tables 4.3 – 4.19. The following is the quick summary reference to the mitigation measures, monitoring frequency and reporting as well as roles and responsibilities tables of the of the EMP framework outlined in Tables 4.3 – 4.19:

1. Physical presence of drillship and support vessels mitigation measures and monitoring

provisions (Table 4.3);

2. Physical disturbance from drilling activity (Table 4.4);

3. Increased light levels from routine vessel and drillship operations (Table 4.5);

4. Sound generation from drilling, support vessel and VSP activities (Table 4.6);

5. Increased sound from fixed wing aircraft and helicopters during take- off, landing and overflight (Table 4.7)

6. Atmospheric emissions from routine drillship, support vessels and helicopter operation

(Table 4.8);



7. Onshore support operations and waste management (Table 4.9);

8. Discharge of Water Based Mud (WBM) and drill cuttings to the sea (Table 4.10);

9. Discharge of treated Synthetic-Based Mud (SBM) and drill cuttings to the sea (Table 4.11);

10. Discharge of cement to the seabed (Table 4.11);

11. Planned marine discharges (Table 4.13);

12. Unplanned marine discharges (e.g. minor spillages of fuel, lubricants / maintenance oils

(Table 4.14);

13. Accidental event: Loss of vessel, equipment or material (Table 4.15);

14. Accidental event: Collision with marine wildlife during vessel operations (Table 4.16);

15. Accidental Event: Loss of MGO containment on the drillship or support vessels due to ship collision or another major event (Table 4.17);

16. Accidental event: Loss of drilling mud during drilling (Table 4.18), and;

17. Accidental event: well blowout following loss of well control (Table 4.19).



Table 4.3: Mitigation measures, monitoring and reporting for physical presence of drillship and support vessels mitigation measures and monitoring provisions.

Project Activity / Aspect

Potential Impact

Mitigation and Management Measures

Monitoring / Reporting

Required

Task Frequency

Responsibility

1. Physical presence of drillship and support vessels

Potential for disruption to

marine navigation

due to presence of the 500 m

radius safety exclusion

zone around the drillship

❖ A 500 m radius navigational safety exclusion zone centred on the drillship while at the well site will be enforced for the duration of the drilling programme.

❖ The drillship and support vessels will monitor shipping activities and enforce the safety exclusion zone around the drillship to prevent collision with other sea users.

❖ All vessels will be certified by either the Oil Companies International Marine Forum (OCIMF) or International Marine Contractors Association (IMCA) (unless this certification is not required) and will have passed the Offshore Vessel Inspection Database (OVID) inspections, and operate in accordance with GIIP, reducing the risk of operational failures.

❖ The drillship and support vessels will operate in compliance with national and international maritime regulations including MARPOL 73/78 regulations, MARPOL requirements (Annex V), guidance from International Convention on the Safety of Life at Sea (SOLAS), as well as industry good practice guidelines.

❖ The drillship and support vessels will have internationally recognised identification / warning signals in place in line with international shipping regulations.

❖ The drillship and support vessels will carry appropriate navigation lights for operating during night-time and periods of poor visibility.

❖ Advanced positioning equipment will be used to maintain communications with other vessels and to provide accurate information on the position of the drillship.

❖ Notifications on the Project programme will be issued by Maurel & Prom Namibia (Pty) Ltd to the Petroleum Commissioner, Walvis Bay Port Captain and other relevant stakeholders, in advance of the mobilisation of the drillship. At least one-week advance notice of any area restrictions will be provided. Variations / delays to the programme will also be communicated in advance throughout the operation.

❖ Discussions will be held with the Petroleum Commissioner sufficiently in advance of Project activity so that safe navigation measures can be designed and implemented, e.g. Notice to Mariners regarding exclusive zone and any navigation hazards.

❖ Early warning radar and communication systems onboard the drillship and support vessels will be used to monitor vessel movements and to communicate with those nearing the exclusion zone. Collision avoidance procedures will be deployed should the exclusion zone be breached.

❖ Approaching vessels, including fishing vessels, will be contacted by VHF radio, or if they do not respond, external loud speakers will be used.

❖ Supply vessels approaches into Walvis Bay Harbour should be made with caution to avoid interaction with any cetaceans or seal that may be in the coastal area

Number of encroachments into the 500 m safety exclusion zone by unauthorised vessels to be recorded

On each occurrence during drilling programme.

M &P Namibia (Pty) Ltd

Near misses and recordable incidents Commissioner

Individual incident reports will be submitted on each occurrence during drilling programme.

Record number of complaints / concerns received from stakeholders (e.g. fisherman, other shipping vessels) and logged via either the relevant authorities or the Project Grievance Mechanism


Maintain up to date Stakeholder Register to ensure all potentially affected stakeholders are considered and notified accordingly

Weekly during drilling

programme.

Issue Notice to Mariners. At least three weeks prior to spudding the well and then weekly during drilling programme and on completion of the drilling programme to advise of demobilisation.



Table 4.4: Mitigation measures, monitoring and reporting for physical disturbance from drilling activity.


Potential Impact



Required

Task Frequency

Responsibility

2. Physical disturbance from drilling activity

Potential for disruption to commercial

fishing activity due to presence of the

500 m radius safety exclusion zone around the

drillship.

❖ The drillship and support vessels will monitor transit and fishing vessels at all times within the area around the exclusion zone

❖ The Project will be diligently planned and the potential for interference with other sea users will be minimised through notifications to relevant maritime authorities through the Petroleum Commissioner and other sea users such as fishery organisations, prior to commencement of the Project.

❖ Prior notification to licence holders for those fisheries that have the potential to be operating in the vicinity of the safety exclusion zone at least two weeks before the drilling commences. This notification will advise license holders of the exclusion zone, the schedule for its operation, and the measures that will be used to communicate with fishing vessels that are in the vicinity of the exclusion zone.

Record number of complaints / concerns received from stakeholders (e.g. fisherman, other shipping vessels etc.) and logged via either the relevant authorities or the Project Grievance Mechanism



Maintain up to date Stakeholder Register to ensure all potentially affected stakeholders are considered and notify accordingly as maybe applicable.

Weekly during drilling programme.

Issue Notice to Mariners. At least three weeks prior to spudding the well and then weekly during drilling programme and on completion of the drilling programme to advise of demobilisation.

Checks will be made to ensure that level of lighting onboard the drillship is commensurate with the activities being undertaken.

Daily during drilling programme.



Table 4.5: Mitigation measures, monitoring and reporting for increased light levels from routine vessel and drillship operations.


Potential Impact



Required

Task Frequency

Responsibility

3. Increased light levels from routine vessel and drillship operations

Potential impacts to

marine wildlife from lighting

impacts.

❖ The level of lighting will be in compliance with safety regulations at sea.

❖ The drillship will also require lighting to allow drilling operations to

continue safely during the hours of darkness. The level of lighting will be commensurate with the activities being undertaken and will be in compliance with maritime safety regulations at sea.

Checks will be made to ensure that level of lighting onboard the drillship is commensurate with the activities being undertaken.

Daily during drilling programme




Table 4.6: Mitigation measures, monitoring and reporting for sound generation from drilling, support vessel and VSP activities.


Potential Impact



Required

Task Frequency

Responsibility

4. Sound generation from drilling, support vessel and VSP activities

Potential

disturbance to

marine fauna

including marine

mammals, sea

turtles and fish from

underwater noise.

The drillship will only be on location for the minimum number of days required to conduct the drilling operations (maximum of 50 days). The operational and maintenance procedures on the drillship will aim to optimise the efficiency of the equipment and the schedule of operations. ❖ Optimise vessel movement through careful planning. ❖ The following measures will be applied during Vertical Seismic Profiling

(VSP) operations: o A "soft-start" procedure will be implemented, which is a process

whereby the seismic source operation is slowly ramped up, usually by turning on the seismic energy sources in a staged manner until the required power is reached.

o To minimise additional noise in the marine environment, the soft-start (from commencement of soft-start to full power) should be at least 20 minutes and not significantly longer (for example, soft-starts greater than 40 minutes are considered to be excessive).

o The soft-start procedure will only commence if no marine mammals or sea turtles are sighted for 30 minutes within 500 m of the centre of the seismic source array (the 'mitigation zone'). If marine mammals are detected within this distance, the soft-start will be delayed until their passage results in the marine mammals or sea turtles being more than 500 m away from the source.

o The monitoring of marine fauna will be undertaken for the duration of the VSP survey either by a Marine Fauna Observer (MFO) or by a designated member of the drilling crew who has been trained by a marine ecologist to perform this role.

o Maurel & Prom Namibia (Pty) Ltd will start the VSP operations during the day time and in good visibility conditions.

o Visual monitoring or a 'pre-acquisition' search will begin no less than 30 minutes prior to start-up of the VSP operations and continue until operations cease or sighting conditions do not allow observation of the sea surface.

Compliance with vessel transit routes and exclusion areas to be monitored in relation to the Project Logistics Plan.



Complete Marine Fauna recording forms during VSP survey activities to record number of sightings of marine mammals / sea turtles (e.g. species, position, time of encounter).

During the VSP survey (maximum 6 days at full power plus a short soft-start).

Marine Fauna Report to be included in the monitoring report at end of the Project.

Report to be submitted to the Petroleum and Environmental Commissioners within three (3) months of completion of drilling programme.



Table 4.7: Mitigation measures, monitoring and reporting for increased sound from fixed wing aircraft and helicopters during take- off, landing and overflight.


Potential Impact



Required

Task Frequency

Responsibility

5. Increased sound from fixed wing aircraft and helicopters during take- off, landing and overflight at Walvis Bay International Airport / Arandis Airport as well as Helicopter offshore

Noise generated by

helicopters have the

potential to impact

on the coastal and marine wildlife

receptors

surrounding the

Aviation base and offshore helipad during take-off,

landing and cruising

landing

❖ Fixed Wing and Helicopter flights and movements will be carefully planned to limit the number of journeys, with an average of six return flights per week expected under routine circumstances.

❖ The Civil Aviation Authority / Airport Company will be consulted to confirm requirements for the fixed wing aircraft and helicopter routes, airspeed and flight altitudes for take-off, cruising and landing. The routes, speeds and altitudes will be optimised to minimise disturbance to human and wildlife receptors.

❖ Maurel & Prom Namibia (Pty) Ltd will use an existing facility in Windhoek and Walvis Bay International Airport / Arandis Airport that has capacity to handle additional air traffic and has suitable control measures in place to minimise disturbance to any potential surrounding receptors (which will already be subject to existing helicopter noise).

❖ Maurel & Prom Namibia (Pty) Ltd shall ensure that the regular maintenance of the fixed wing aircraft and helicopters will be undertaken by contractors in line with manufacturers and regulatory requirements.

❖ The fixed wing aircraft and helicopter contractors will be prohibited from circling or hovering over marine mammals or sites identified as sensitive for seabird colonies unless essential for safety or operational purposes.

Flight records to be monitored in relation to the national aviation approved route plans.


Fixed Wing and helicopter Operators and Maurel & Prom Namibia (Pty) Ltd

Monitoring of the fixed wing aircraft and helicopter maintenance records to ensure manufacturers operating standards are met.


Fixed Wing and helicopter Operators

Record number of complaints / concerns received from stakeholders (e.g. residents living near airport in Windhoek and Walvis Bay International Airport / Arandis Airport or under flight path) via either the relevant authorities or the Project Grievance Mechanism





Table 4.8: Mitigation measures, monitoring and reporting for atmospheric emissions from routine drillship, support vessels and helicopter operations.


Potential Impact



Required

Task Frequency

Responsibility

6. Atmospheric emissions from routine drillship, support vessels and helicopter operations

Emissions to atmosphere from

the proposed multiple wells drilling operations have the

potential to impact air quality and

contribute to global

GHG levels

❖ Maurel & Prom Namibia (Pty) Ltd will undertake comprehensive pre-project planning to ensure that the Project operations are conducted efficiently and in the minimum period of time, which shall assist in minimising the number of trips for support vessels, fixed wing aircraft and helicopters between the drillship and the onshore support bases.

❖ All shipboard emissions will be in compliance with MARPOL Regulations for the prevention of air pollution from ships (Annex VI) updated in 2003, aiming to reduce atmospheric emissions such as SOX, NOX and particulate matter globally.

❖ All vessel, fixed wing aircraft and helicopter power generation equipment and exhaust systems will be well maintained in accordance with written procedures based on the manufacturer’s guidelines or applicable industry code or engineering standards to ensure efficient and reliable operation.

❖ Vessel fuels will comply with IMO/MARPOL specifications with a sulphur limit of 3.5% and no ozone depleting substances shall be used. MGO will be used as the fuel for the drillship and support vessels thereby complying with this requirement.

❖ Vessels will switch off any surplus engines and equipment when not in use and avoid unnecessary idling, revving or excessive speeds where practical.

Fuel delivery notes (as required by MARPOL regulations) including information about fuel quality (e.g. sulphur / water content) to be inspected for each bunkering operation

For each bunkering operation.

Support Vessels / Drilling Contractor and M &P Namibia (Pty) Ltd

Undertake full maintenance inspection prior to drilling commencing.

.

Once at start of Project prior to drilling commencing.

Drilling Contractor

Undertake regular maintenance of engines, compressors and generators. Records shall be made of all maintenance checks and a copy shall be sent to the Vessel Captain with notations of any problems revealed by the check.


Support Vessels / Drilling Contractor and M &P Namibia (Pty) Ltd

Monitor and record fuel consumption of the drillship and support vessels


Support Vessels / Drilling Contractor

The following will be recorded and included in the End of Well Environmental Report:

o Volume of fuel used by the drillship and each support vessel (recorded daily in tonnes and reported monthly); and

o - Estimated volume of emissions generated as a result of the fuel used.

Total Project fuel consumption and emissions generated to be reported in End of Well Environmental Report.




Table 4.9: Mitigation measures, monitoring and reporting for onshore support operations and waste management.


Potential Impact


Monitoring / Reporting Required

Task Frequency

Responsibility

7. Onshore support operations and waste disposal

❖ Occasional increase in the level of marine traffic to, and use of, port facilities by supply vessels.

❖ Potential impacts from onshore waste disposal.

❖ Minimise local disturbance by use of existing ports

Monitor vessel journey log in relation to the Project Logistics Plan and prepare Log Book summarising vessel movements

Report to be submitted to Petroleum and Environmental Commissioners within three (3) months of completion of drilling programme

Support Vessel Contractor and Maurel & Prom Namibia (Pty) Ltd

❖ Maurel & Prom Namibia (Pty) Ltd and the contractors will produce a Project specific Waste Management Plan (WMP) at the start of the Project. The WMP will include a detailed description of the waste management measures to be implemented and the final disposal route for each waste type. The WMP will meet Namibian regulatory requirements and will be consistent with GIIP.

❖ The drilling contractor and supply vessel operators to minimise waste. ❖ Solid and liquid waste generated onboard the drillship and support vessels

will be segregated and stored in appropriate containers onboard. Hazardous and non-hazardous wastes will be stored separately and in accordance with onboard operational controls. Skips will be transferred from the drillship to a support vessel for transport to shore for disposal, sorting, storage, treatment and further disposal of treated waste.

❖ All wastes will be collected, stored and transported off-site in appropriate bins and containers and only appropriately licenced companies will be employed for the transportation, recycling and disposal of waste.

❖ Hazardous waste will be stored onshore within a covered area in suitable closed containers that are clearly labelled and located on an impermeable surface. Secondary containment will also be provided to capture any leaks or spills.

❖ The drilling contractor and vessel operators will record and report all waste types and quantities generated on the vessel as defined in the WMP.

❖ The drilling contractor and vessel operators will maintain a Garbage Book including a record of consumed materials.

❖ Both hazardous and non-hazardous wastes will be handled under rigorous Duty of Care protocols in line with GIIP and national regulations.

❖ Maurel & Prom Namibia (Pty) Ltd will audit potential waste management contractors and waste management facilities during the Project planning stage to identify a suitable facility

Maurel & Prom Namibia (Pty) Ltd will undertake audits of potential waste management contractors and waste management facilities during the Project planning stage

During Project planning phase.


Monitor, log and record waste for each waste category in accordance with the requirements of the WMP.

For the duration of the drilling programme


Ensure that each waste shipment has the necessary waste transfer documentation prior to transfer to shore and in the case of hazardous waste the Materials Safety Data Sheets (MSDS) documentation.

For each waste transfer planned.

Support Vessels / Drilling Contractor and Maurel & Prom Namibia (Pty) Ltd

A final visual inspection of all waste consignments will be made prior to sign-off and uplift of the waste.

For each waste transfer planned.


Inspections / audits to be undertaken to monitor the performance of the waste management systems during the drilling programme

Monthly for the duration of the drilling programme.


A Waste Report will be prepared to summarise waste generated during the Project and will include copies of all waste transfer documentation

To be prepared within two months of completion of the drilling programme




Table 4.10: Mitigation measures, monitoring and reporting for discharge of Water Based Mud (WBM) and drill cuttings to the sea.


Potential Impact



Required

Task Frequency

Responsibility

8. Discharge of Water Based Mud (WBM) and drill cuttings to the sea

Water Based Mud and drill cuttings discharged to the seabed may result in impacts including direct chemical toxicity to benthic fauna; burial and smothering of benthic fauna and reduction in sediment quality (e.g. changes in grain size, organic and oxygen content).

❖ WBM chemical components to be selected for the Project are to be PLONOR (posing little or no risk) as far as possible and Maurel & Prom Namibia (Pty) Ltd will ensure that batches of barite supplied for use in WBM formulations will meet applicable heavy metal concentrations for mercury (<1 mg/kg) and cadmium (<3 mg/kg) dry weight (total).

❖ Maurel & Prom Namibia (Pty) Ltd will submit the final drilling chemical inventory to the Petroleum Commissioner for review following completion of the well design and chemical assessment and selection process prior to drilling commencing.

❖ The drillship will only be on location for the minimum number of days required to conduct the drilling operations (maximum of 50 days). The operational and maintenance procedures on the drillship will aim to optimise the efficiency of the equipment and the schedule of operations.

❖ Maurel & Prom Namibia (Pty) Ltd will have experienced day and night drilling supervisors onboard the drillship throughout the drilling operations to ensure compliance with approved operating procedures, including those concerning environmental protection and to also ensure that the drilling programme is conducted safely.

❖ A detailed well and well fluid design will be undertaken by Maurel & Prom Namibia (Pty) Ltd and the well design and construction will be reviewed by an independent well examiner prior to the commencement of drilling.

❖ Drilling operations will only be undertaken during weather conditions (e.g. wind speed, wave height) that are within the drillship’s operational limits and operations will be suspended if limits are exceeded

Final drilling chemical inventory to be submitted to the Petroleum Commissioner for review following completion of chemical assessment and selection process.

Drilling chemicals inventory to be submitted to the Petroleum Commissioner prior to Project start.


Each batch of barite supplied for use in WBM will be tested by supplier to confirm applicable heavy metal concentrations for cadmium (<3 mg/kg) and mercury (<1 mg/kg) content are met.

Once prior to drilling commencing


Monitor and record quantity of chemical additives used and discharged in the hole sections drilled with WBM


Drilling Fluids Contractor

Volumes and composition of WBM and cuttings discharged at the end of each well section will be recorded.


Drilling Fluids Contractor

A summary of the WBM and cuttings discharge records shall be included in the End of Well Environmental Report to be submitted to Petroleum and Environmental Commissioners





Table 4.11: Mitigation measures, monitoring and reporting for discharge of treated Synthetic-Based Mud (SBM) and drill cuttings to the sea.


Potential Impact



Required

Task Frequency

Responsibility

9. Discharge of treated Synthetic-Based Mud (SBM) and drill cuttings to the sea

The discharge of treated and SBM drill cuttings to the water column from the drillship may result in impacts including direct chemical toxicity to water column fauna, reduction in primary production of phytoplankton, disruption to feeding or behaviour in zooplankton, fish cetaceans, turtles and diving birds due to increased suspended sediments in the water column and chemical toxicity to benthic fauna from deposition of treated cuttings discharged.

❖ Prior to drilling, a chemical assessment and selection process will be conducted to select SBM with the best environmental performance and lowest toxicity while concurrently achieving optimal drilling performance.

❖ The base oil to be selected will be a Group III SBM (either highly refined mineral oil or synthetic base oil) which has lower toxicity and greater biodegradability compared to other groups of SBM and offers the potential for improved environmental performance.

❖ Maurel & Prom Namibia (Pty) Ltd will submit the final drilling chemical inventory to Petroleum Commissioner for review following completion of the well design and chemical assessment and selection process prior to drilling commencing.

❖ The drillship will only be on location for the minimum number of days required to conduct the drilling operations (maximum expected of 50 days). The operational and maintenance procedures on the drillship will aim to optimise the efficiency of the equipment and the schedule of operations.

❖ Maurel & Prom Namibia (Pty) Ltd will have experienced day and night drilling supervisors onboard the drillship throughout the drilling operations to ensure compliance with approved operating procedures, including those concerning environmental protection and to also ensure that the drilling programme is conducted safely.

❖ A detailed well and well fluid design will be undertaken by Maurel & Prom Namibia (Pty) Ltd and the well design and construction will be reviewed by an independent well examiner prior to the commencement of drilling.

❖ The returned SBM and cuttings from the lower hole sections will undergo processing on the drillship to enable the SBM to be reused and to reduce the oil on cuttings (OOC) to meet <6.9% OOC, in line with the Maurel & Prom Namibia (Pty) Ltd Drill Fluids & Cuttings Disposal Guidelines.

❖ The solids discharged to the environment via the cuttings chute will be measured to ensure that an OOC discharge limit of less than 6.9% is complied with throughout well drilling operations.

❖ At the end of the drilling program, the recycled and unused SBM will be retained onboard and subsequently returned to the supplier for re-cycling via supply vessel.

❖ Drilling operations will only be undertaken during weather conditions (e.g. wind speed, wave height) that are within the drillship’s operational limits and operations will be suspended if limits are exceeded.




Monitor and record quantity of chemical additives used and discharged in the hole sections drilled with SBM

Once prior to drilling commencing


Monitor closely and log the percentage of oil remaining in the cleaned SBM and cuttings prior to discharge to ensure that target of <6.9% OOC is met


Drilling Contractor

A summary of the SBM and cuttings discharge records shall be included in the End of Well Environmental Report to be submitted to Petroleum and Environmental Commissioners


Fluid Drilling Contractor





Table 4.12: Mitigation measures, monitoring and reporting for discharge of cement to the seabed.


Potential Impact



Required

Task Frequency

Responsibility

10. Discharge of cement to the seabed

The discharge of cement to the seabed during the cementing of the hole section casings may cause deterioration in the sediment and water quality in addition to smothering benthic fauna in the vicinity of the well site.

❖ Prior to drilling a chemical assessment and selection process will be

conducted to select cement with the best environmental performance and lowest toxicity while concurrently achieving optimal performance.

❖ Ensure that only the minimum quantity of cement is used to reduce discharge volumes.

❖ Dry cement will not be discharged to the marine environment under routine conditions.




Monitor and record quantities of cementing chemicals used and discharged daily

Daily during drilling programme

Drilling Contractor

Excess cement at the seabed will be observed (via periodic ROV surveys) and corrective action taken to minimise excess accumulations

As per ROV survey schedule.

Maurel & Prom Namibia (Pty) Ltd via ROV contractor

A summary of the cement volumes used shall be included in the End of Well Environmental Report to be submitted to Petroleum and Environmental Commissioners





Table 4.13: Mitigation measures, monitoring and reporting for planned marine discharges.


Potential Impact



Task Frequency

Responsibility

11. Planned marine discharges

Potential impacts on marine and coastal ecology due to planned marine discharges.

❖ All discharges from the drillship and support vessels will be in compliance with MARPOL 73/78 Regulations for the prevention of pollution from ships by sewage and oil (Annex I and IV, updated 2003), viz o Vessels must be equipped with an oil filtering system, automatic cut-off, and

an oil retention system. o Overboard discharge from the oily water treatment system will be monitored

for oil-in- water content. Sensors in the port and starboard deck drains of the drillship will continuously monitor the oil content of the water and are set to divert the waste stream into storage tanks for treatment if the oil-in-water content exceeds 15 ppm.

o Oily residues will be retained onboard within the bilge tanks for disposal at appropriate onshore waste reception facilities in accordance with the Project specific Waste Management Plan.

o Discharge of noxious liquid substances, pollution hazard substances, and associated tank washings is prohibited. Vessels require periodic inspections and must carry a Procedures and Arrangements Manual and Cargo Record Book.

o Discharge of sewage is permitted only if the vessel has approved sewage treatment facilities, the test result of the facilities is documented, the effluent will not produce visible floating solids nor cause discoloration of the surrounding water and at a distance of more than 3 nautical miles (NM) from the nearest land. Sewage which is not comminuted or disinfected has to be discharged at a distance of more than 12 NM from the nearest land.

o Disposal of garbage from vessels is prohibited. Vessels must carry a Garbage Management Plan and shall be provided with a Garbage Record Book.

o Discharge of food waste is allowed if ground to pass through a 25 millimetres (mm) mesh and the vessel is en route and more than 12 NM from land.

❖ The drillship and support vessel contractors will maintain an Oil Record Book (ORB) and hold a valid International Oil Pollution Prevention (IOPP) certificate.

❖ The Project will comply with the 2004 International Convention for the Control and Management of Ships' Ballast Water and Sediments requirements which are come into force in September 2017 to prevent the spread of harmful aquatic organisms between regions (IMO, 2016).

❖ The drillship and support vessels will implement, if applicable, ship-specific ballast water and sediment management plans and will need to carry ballast water record books and an international ballast water management certificate.

Monitor and record chemicals used and discharged


Drilling Contractor

Undertake visual checks during discharge of grey and treated black water to confirm that no floating solids are observable.


Wastewater analysis to be carried out prior to discharge to ensure that oil-in-water threshold of 15 ppm is met

Maintenance schedule for drainage systems to be checked and audited.

Undertake audit of the drillship including spot checks

Drilling Contractor

The Garbage Management Plan and Garbage Record Book will be maintained to record how waste items are managed and disposed of.

Support Vessels / Drilling Contractor Record time, quantity and location

of ballasted water taken onboard and discharged to sea and log in Ballast Water Record Book.

For each ballasting activity.

Undertake audit against Ballast Water Management Plan.

Monthly during the drilling programme.

Summary of sewage discharged and estimated volumes of treated black water discharged daily



Daily estimated volumes of grey water and galley waste will be recorded.



Table 4.14: Mitigation measures, monitoring and reporting for unplanned marine discharges (e.g. minor spillages of fuel, lubricants / maintenance oils).


Potential Impact

Mitigation and Management Measures Monitoring / Reporting Required

Task

Frequency

Responsibility

12. Unplanned marine discharges (e.g. minor spillages of fuel, lubricants / maintenance oils)

Potential impacts from a minor spill of chemicals or hydrocarbons may cause physical

oiling and toxicity impacts to marine fauna and flora and contamination of coastal habitats in the immediate vicinity of the discharge area.

❖ The drilling programme will be conducted using protocols for prevention of marine pollution in accordance with MARPOL 73/78 requirements, relevant national legislation and best practices

❖ Maurel & Prom Namibia (Pty) Ltd representative will be onboard the drillship to ensure compliance with approved operating procedures, including those concerning environmental protection and to also ensure that the drilling programme is conducted safely.

❖ Maurel & Prom Namibia (Pty) Ltd and the appointed contractors will exercise high vigilance against spill risk and Tier 1 spill emergency response will be available (on drillship and all supply vessels) for the duration of the Project.

❖ Crews will be adequately trained, supervised and regularly holds drills for deck spills and clean-up. ❖ Strict operational controls will be in place for material loading and unloading, including the minimisation

of chemical transfers and loading operations. ❖ Procedures will be put in place for bunkering, re-fuelling and transfer of lubricants and other chemicals

in bulk, such as only refuelling during daylight and in good weather conditions and supervision of bunkering activities, to minimise likelihood of spillage.

❖ Refuelling and bunkering at sea, if required during the Project, will only take place at a safe distance from the coast, shallow areas or other potential hazards.

❖ Non-return valves will be installed on fuel transfer hoses, hoses will be tested and inspected as a part of a regular maintenance programme.

❖ Hazardous materials will be stored in fit for purpose containers or sealed drums with secondary containment to minimise the risk of spillage.

❖ All support vessels will carry fast rescue boats, VHF radios and the crew will be trained in personnel rescue techniques. In the event of a full or partial evacuation of the drillship, the primary method of evacuation is by helicopter, with supply vessels able to support the operation if required. They will also carry spill response equipment, allowing them to provide Tier 1 assistance in case of an oil spill.

❖ Containment of all materials for transfer to/from the drillship will be double checked. ❖ Emergency response procedures will be implemented immediately in the event of a spill. ❖ Adequate spill containment and clean up equipment will be available. ❖ Spills will be cleaned up immediately and generated waste to be managed as a hazardous waste. ❖ Ensure regular check of spill recovery materials held on the drillship and support vessels to ensure that

they are in date / certified. ❖ Materials Safety Data Sheets (MSDS) to facilitate efficient spill response will be available. ❖ The drillship will have an effective drainage and containment system, including dedicated oily waste

holding tank and will have spill control units onboard. ❖ Risk assessment procedures, and operational restrictions will be established for the vessels. ❖ Transfer operations will be supervised at all times on the supply vessels and the drillship. ❖ Regular maintenance and inspection of equipment and high-risk spill points will be conducted. ❖ Drillship inspection will be carried out prior to spudding the well. Spill control measures will be a subject

of that inspection. ❖ Drillship audits will be checked to ensure validity and, if not in date, a new audit will be carried out.

Maintenance and inspection of equipment and high spill risk points (bunkering hoses, storage tank valves

Weekly during drilling programme Weekly during drilling programme


Checks of spill recovery materials held on the drillship and support vessels to ensure that they are in date / certified

All hydrocarbon and chemical spills regardless of volume will be internally reported and investigated by Maurel & Prom Namibia (Pty) Ltd.

On each occurrence during drilling programme


All hydrocarbon and chemical spills and any MARPOL 73/78 regulation oil pollution incident will be reported to the Petroleum Commissioner by Maurel & Prom Namibia (Pty) Ltd.



Table 4.15: Mitigation measures and monitoring activities for accidental event: Loss of vessel, equipment or material.


Potential Impact



Task Frequency

Responsibility

13. Accidental Event: Loss of vessel, equipment or material

Potential impacts may include loss of benthic habitat and damage to subsea features (e.g. marine archaeological sites).

❖ All equipment brought onto, and taken off the drillship will be recorded and regularly

checked against inventory lists to monitor for any losses. ❖ Compliance with Maurel & Prom Namibia (Pty) Ltd Safe and Sustainable Operations

Policy and Management Standards and the contractor health and safety policy, including training of crew, will help minimise the possibility of equipment and vessel loss.

❖ Drilling operations will only be undertaken during weather conditions (e.g. wind speed, wave height) that are within the drillship’s operational limits and operations will be suspended if limits are exceeded.

❖ Any incidents involving loss of equipment or materials will be reported to the relevant maritime authorities through the Office of the Petroleum Commissioner.

❖ Any lost materials, equipment or a vessel will be located and promptly salvaged if and when it is safe and practicable to do so.

Monitor weather forecasts for extreme weather in excess of operating tolerances


Drilling Contractor

Record and update inventory lists to monitor for any equipment losses

Weekly during drilling programme


Dropped object incidents to be reported to Maurel & Prom Namibia (Pty) Ltd and investigated internally



Maurel & Prom Namibia (Pty) Ltd to prepare report for submission to the Petroleum Commissioner.





Table 4.16: Mitigation measures, monitoring and reporting for accidental event: Collision with marine wildlife during vessel operations.


Potential Impact



Task Frequency

Responsibility

14. Accidental Event: Collision with marine wildlife during vessel operations

Potential for injury or death to marine mammals and sea turtles in the event of collision with a vessel.

❖ Experienced marine crew watching for obstructions / animals in water during

transit. ❖ Project vessels will manoeuvre around animals if they lie in its path and reduce

speed to avoid the imminent risk of collision with marine mammals and turtles. ❖ Project vessels will not intentionally approach marine mammals or sea

turtles for the purposes of casual viewing. ❖ Maurel & Prom Namibia (Pty) Ltd will inform the Petroleum Commissioner

following completion of the Project of any marine fauna collisions

Monitoring of sea surface for marine mammals

vessel transit

Continuously during drilling programme

Support Vessel

Contractors

Collision incidents with marine mammals / sea turtles during vessel operations to be recorded (e.g. species, position, time of encounter) and reported to Maurel & Prom Namibia (Pty) Ltd.


Support Vessel

Contractors

Marine mammals / sea turtles collisions to be reported to the Petroleum Commissioner

Collisions with marine fauna will be reported to Petroleum Commissioner within three (3) months of completion of drilling programme.




Table 4.17: Mitigation measures, monitoring and reporting for accidental Event: Loss of MGO containment on the drillship or support vessels due to ship collision or other major event.


Potential Impact



Task Frequency

Responsibility

15. Accidental Event: Loss of MGO containment on the drillship or support vessels due to ship collision or other major event

Potential for a significant spill of hydrocarbons.

Physical oiling and toxicity impacts to marine fauna and flora, contamination of coastal habitats.

Deterioration in air quality from the evaporation of volatile hydrocarbon compounds.

Accumulation of oil and chemicals in the food chain and in sediments. Loss of biodiversity and revenue.

❖ A 500 m radius navigational safety exclusion zone centred on the

drillship while at the well site and for the duration of the drilling programme will be enforced.

❖ The drillship will monitor transit / fishing vessels within the area and to maintain the exclusion zone and a support vessel will be at location or on route to location at all times to assist if required.

❖ Early warning radar and communication systems onboard the drillship and support vessels will be used to monitor vessel movements and to communicate with those nearing the exclusion zone.

❖ Collision avoidance procedures will be developed prior to mobilisation of the drillship

❖ Ongoing liaison with the shipping and fishing authorities and other fishing groups shall be maintained through the Office of Petroleum Commissioner and the Ministry of Fisheries and Marine Resources

❖ Approaching vessels, including fishing vessels, will be contacted by VHF radio, or if they do not respond, external loud speakers will be used.

❖ All Project vessels will have a SOPEP, which will be verified by Maurel & Prom Namibia (Pty) Ltd for adequacy to respond to a spill from a potential collision.

❖ Project specific Emergency Response Plans and OSCP will be in place prior to drilling commencing and will be subject to approval from the relevant Namibian regulatory authorities.

❖ Availability of adequate spill containment and clean up equipment (guided by OSCP requirements) appropriately sited and accessible at short notice.

❖ Spill emergency response to be on standby for the duration of the Project.


Prior to mobilisation and at least once during drilling programme


All hydrocarbon and chemical spills regardless of volume will be internally reported and investigated by Maurel & Prom Namibia (Pty) Ltd



Petroleum Commissioner will be notified of hydrocarbon and chemical spills by Maurel & Prom Namibia (Pty) Ltd



Any MARPOL 73/78 regulation oil pollution incident will be reported to the Petroleum Commissioner by Maurel & Prom Namibia (Pty) Ltd.



Reviews of SOPEP, Emergency Response Plan and Project OSCP



Scheduled emergency response drills to be undertaken to incorporate aspects of the Project OSCP



In the event of a spill, spill response and monitoring to be implemented in accordance with approved Emergency Response Plans and Project OSCP and equipment will be in place.





Table 4.18: Mitigation measures, monitoring and reporting for accidental event: Loss of drilling mud during drilling.


Potential Impact



Task Frequency

Responsibility

16. Accidental Event: Loss of drilling mud during drilling

Potential loss of mud from wellbore to the marine environment in event of loss of station keeping

❖ Testing of the drillship's DP systems and inspection of certificates will

be undertaken prior to mobilisation. ❖ Maurel & Prom Namibia (Pty) Ltd will prepare a Chemical Management

Plan which shall include a batch analysis of bulk chemicals (e.g. barites, bentonite, calcium carbonates etc.) prior to use and a chemical assessment and selection process to ensure that, wherever possible, chemicals with the lowest environmental impact are used and that substitutions are considered for chemicals with a high level of toxicity or other undesirable properties such as low biodegradation potential.

❖ Drilling operations will only be undertaken during weather conditions (e.g. wind speed, wave height) that are within the drillship’s operational limits and operations will be suspended if criteria are exceeded

Monitor weather forecasts for extreme weather in excess of operating tolerances


Drilling Contractor

Operations test of the DP redundancy systems

Prior to drilling commencing and then monthly during the drilling programme.

Record any incidents where the backup DP

system was used


Record any incidents where the vessel lost its station-keeping ability




Table 4.19: Mitigation measures, monitoring and reporting for accidental event: well blowout following loss of well control.


Potential Impact



Task Frequency

Responsibility

17. Accidental Event: well blowout following loss of well control

Potential for a significant spill of hydrocarbons.

Physical oiling and toxicity impacts to marine fauna and flora, contamination of coastal habitats.

Deterioration in air quality from the evaporation of volatile hydrocarbon compounds.

Indirect impacts could include: habitat loss, impact on tourism and fisheries, complications arising from waste disposal, transboundary issues.

Accumulation of oil and chemicals in the food chain and in sediments. Loss of biodiversity and revenue

❖ Specialist and competent drilling contractors will be selected by Maurel & Prom Namibia (Pty) Ltd to undertake the Project using an approved contractor selection process.

❖ Drilling will follow Maurel & Prom Namibia (Pty) Ltd Oil’s Well Engineering Standards and established GIIP drilling safety standards to minimise the risk of well control loss.

❖ The drilling contractor crew will be adequately experienced, trained in well control techniques and supervised by Maurel & Prom Namibia (Pty) Ltd. Emergency drills will be held regularly.

❖ Training of key personnel in spill response will be conducted. ❖ Detailed well and well fluid design will be undertaken by Maurel &

Prom Namibia (Pty) Ltd and the well design and construction will be reviewed by an independent well examiner prior to drilling commencing.

❖ Weighted drilling fluids will provide the primary barrier and the well will be carefully controlled and monitored.

❖ Well to be monitored for flow at all times from the drillers control station in accordance with all Maurel & Prom Namibia (Pty) Ltd and drilling contractor policies and well control guidelines.

❖ An appropriately sized BOP will be used for drilling the well and it will be subject to regular testing and maintenance.

❖ BOP design to include ROV remote interfaces to key BOP functions, including shear rams.

❖ Project specific Emergency Response Plans and OSCP will be in place prior to drilling commencing and will be subject to approval from the relevant Namibian regulatory authorities.

❖ Availability of adequate spill containment and clean up equipment (guided by OSCP requirements) appropriately sited and accessible at short notice.

❖ Spill emergency response to be on standby for the duration of the Project.

❖ Maurel & Prom Namibia (Pty) Ltd has access to capping stacks from and Wild Well Control (WWC) and dispersant from Oil Spill Response Limited (OSRL) in order to provide enhanced response capability


Once at the beginning of the drilling programme


The Petroleum Commissioner will be notified of hydrocarbon and chemical spills by Maurel & Prom Namibia (Pty) Ltd


Maurel & Prom Namibia (Pty) Ltd Reviews of SOPEP, Emergency

Response Plan and Project OSCP

Prior to mobilisation and at least once during drilling programme

Scheduled emergency response drills to be undertaken to incorporate aspects of the Project OSCP



Maintenance and function and pressure testing of the BOP in accordance with API Recommended Practice S53: Recommended Practise for Blowout Prevention Equipment Systems for Drilling Wells

On installation and function test weekly during drilling programme

Drilling Contractor

In the event of a spill, spill response (including notifications of relevant Namibian authorities) and monitoring to be implemented in accordance with approved Emergency Response Plans and Project OSCP, and equipment will be in place



Prior to commencement



5. HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT GUIDANCE

5.1 Health, Safety and Environmental Compliances

Potential hazards such as the risk of fire or blowout event are removed or managed, based on risk assessments, safe operational systems of work, standards, procedures of the Health, Safety and Environmental Management (HSEM) requirements, competency and skills of staff and workers as well as procedures and manuals. In order to effective management of these issues, equipment manual and procedures shall be enforced and where applicable written procedures shall be prepared covering the following:

1. Personal protective equipment (PPE); 2. Lockout/ tagout of equipment;

3. Entry into confined spaces;

4. Compressed gas cylinder handling;

5. Cable/hoist sling safety and scaffolding;

6. Helicopter safety;

7. Electrical safety;

8. Personnel transfer to/from the rig;

9. Temperature extremes, where appropriate;

10. Welding and cutting, and chemical safety;

11. Pressure and leak testing;

12. Hydrogen sulphide;

13. Radiological protection;

14. Explosives;

15. Cranes and lifting devices, and;

16. Incident reporting and investigation.

Health, Safety and Environmental Management requirements apply to all contractors and subcontractor working on site as well as all other employees. Protective respiratory equipment must be used by employees when exposure levels for welding fumes, solvents and other materials present in the workplace exceed local or internationally accepted standards, or threshold limit values (TLVs) as annually published, for example, by the American Conference of Governmental Industrial Hygienists (ACGIH) in "Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices."

Feasible administrative and engineering controls, including sound-insulated equipment and control rooms should be employed to reduce the average noise level in normal work areas. Plant equipment should be well maintained to minimize noise levels. Personnel must use hearing protection when exposed to noise levels above 85 dB (A).



Prior to entry and occupancy, all confined spaces (e.g., tanks, sumps, vessels, sewers, excavations) must be tested for the presence of toxic, flammable and explosive gases or vapours, and for the lack of oxygen. Adequate ventilation must be provided before entry and during occupancy of these spaces. Personnel must use air-supplied respirators when working in confined spaces, which may become contaminated or deficient in oxygen during the period of occupancy. Observers/assistants must be stationed outside of confined spaces to provide emergency assistance, if necessary, to personnel working inside these areas.

Sanitary facilities should be well equipped with supplies (e.g., protective creams) and employees should be encouraged to wash frequently, particularly those exposed to dust, chemicals or pathogens. Ventilation systems should be provided to control work area temperatures and humidity. Personnel required working in areas of high temperature and/or high humidity should be allowed to take frequent breaks away from these areas. Pre-employment and periodic medical examinations should be conducted for all personnel, and specific surveillance programs instituted for personnel potentially exposed to toxic or radioactive substances.

All installations shall be designed and operated to protect the health and safety of employees and the community. The following safety procedures and practices should be implemented in the workplace:

1. Shield guards or guard railings should be installed at all belts, pulleys, gears and other

moving parts; 2. Elevated platforms and walkways, and stairways and ramps should be equipped with

handrails, toeboards and non-slip surfaces; 3. Electrical equipment should be grounded, well insulated and conform with applicable codes; 4. Eye protection should be worn by personnel when in areas where there is a risk of flying

chips or sparks, or where intense light is generated, and;

5. Protective clothing appropriate to conditions should be worn in all facility areas and when walking outside living quarters and meeting rooms on a platform.

Training plans, programs, and practices are to be established and carried out for all personnel. They will include training on basic safety procedures and on environmental issues, and job specific safety procedures according to their duties and responsibilities. Training shall include:

1. Instruction on the operation of equipment;

2. Emergency survival and firefighting;

3. How to read and understand Material Safety Data Sheets (MSDSs), and safe chemical

handling;

4. Emergency response procedures;

5. Personal protective equipment;

6. Evacuation, including alternative means of egress from the platform, and;

7. Applicable regulatory requirements.



The creation of a Health, Safety and Environment (HSE) Committee within the ERT of the command and control as well as the rig and operation base units is recommended. Employees and management have an opportunity in meetings of the HSE Committee to discuss and communicate safety and environmental issues and their control. Participation must include contractors and subcontractor employees as appropriate and applicable. Monitoring data should be analysed and reviewed at regular intervals and compared with specified requirements so that any necessary corrective actions can be taken. Records of monitoring results should be reported to the responsible authorities and relevant parties, as required. Frequent sampling, chemical analysis, and toxicity testing may be required during the start-up and during upset conditions. Monitoring frequency could be carried out as follows:

1. At least once per month for effluents;

2. Annually for air emissions, in addition to running a greenhouse gas estimation model

annually;

3. As needed for noise; 4. As needed for workplace air quality;

5. Prior to entering all confined spaces, and;

6. Radiation survey annually for contaminated sites and every three years for clean sites.

Onsite managers for the command and control, the rig and the operations base including the supply vessel, shall maintain records of significant environmental, health and safety matters. This information should be reviewed and evaluated to improve the effectiveness of the environmental, health and safety programme.

Records to be included are as follows:

1. All incidents resulting in an incapacity to work for at least one full workday beyond the day

on which the accident or illness occurred;

2. The total number of days of absence from work as the result of an incident;

3. Fatalities;

4. Annual air emissions monitoring data;

5. Monthly effluent monitoring data;

6. Radiation survey annually for contaminated sites and every three years for clean sites;

7. Environmental, health and safety training conducted including course topics and attendees;

8. Spills, fires and other emergencies;

9. Number of emergency response drills and spill response drills conducted without equipment deployment, and;

10. Number of emergency response drills and spill response drills conducted with equipment

deployment.



The following operational documents are important for effective risk management on the rig and must be available onboard the rig at all times:

1. Shipboard Oil Pollution Emergency Plan;

2. Safety Management Manual – Ship Instructions, and;

3. Safety Management Manual – Ship Emergency Preparedness. Summary of the above information shall be provided to authorities such as the Ministry of Mines and Energy, Ministry of Environment and Tourism, Ministry of Works and Transport, Ministry of Fisheries and Marine Resources in the Annual Monitoring Reports.

5.2. Oil / Diesel Spill Responses

5.2.1 Oil Spill Contingency Plan (OSCP) In fulfilment of the Namibian requirements of the Petroleum (Exploration and Production) Act 1991 (Act 2 of 1991) and the Regulations under the Prevention and Combating of the Pollution of the Se by Oil Act 1984 as amended under the Promulgation of Prevention and Combating of Pollution of the Sea by Oil Amendment Act, 1991 (Act 24 of 1991), M & P Namibia (Pty) Ltd is required to prepare an Oil Spill Contingency Plan (OSCP) for the proposed multiple wells drilling operations in PEL 44 for approval by the Department of Maritimes Affairs in the Ministry of Work and Transport. The Oil Spill Contingency Plan (OSCP) to be prepared shall be a complementary document to the M & P Namibia (Pty) Ltd Emergency Response Plan (ERP) for the proposed multiple well drilling operations in the PEL 44 and all linked to this EMP Vol. 3 of 3 Report. The OSCP document shall establish and define information, strategies, procedures and the structure for responding to emergencies involving oil spills, with the purpose to stop or minimize any accidental discharge of hydrocarbons and to mitigate negative effects. The OSCP is applicable to any oil spill scenarios involving M & P Namibia (Pty) Ltd and its contractors, including the drilling rig, platform supply vessels (PSV) and other companies working offshore for the drilling campaign in Namibia and will make provisions for the following: (i) 2 boats with tanking capacity for recovery oil;

(ii) One skimmer of 350 cum/hr per boat; (iii) Wide spray system for dispersion application in each boat; (iv) 2 reels of containment booms (200 m) per boat, and; (v) One oil spill specialist per boat. The OSCP to be prepared shall have a 1 – 3-tiered response structure as shown in Fig. 5.1 with the tier 1 response being of low severity and comprising small spills such as a tank spill or refuelling spillages. The tier 3 response on the other hand shall be of high severity resulting from a major spill such as an uncontrolled Blow Out.



TIER 1 RESPONSE SEVERITY

1. Small oil spills, or those which can be quickly and easily cleaned up using on-site resources

2. Spill volume is less than 40 tons

3. Able to respond to the spill immediately

4. Day time release

5. Spill has stopped

6. Oil will not impact environmentally sensitive areas

7. Sufficient M & P Namibia (Pty) Ltd / contractor personnel available

LOW

(Minor Spills

Such as Tank Leaks /

Refuelling Spillages)

HIGH

(Major Spill Such as Uncontrolled

Blow Out)

TIER 2 RESPONSE

1. Oil spills which pose a threat of significant pollution resulting in the activation of the local authorities’ emergency response plans, and the mobilization of external oil spill response resources

2. Spill volume >40 tons

3. Danger of fire or explosion

4. Freshly spilled crude oil accumulating close to an installation

5. Night time / poor visibility

6. Continuous release

7. Oil is moving towards environmentally sensitive area(s) e.g. the wetlands; seal or seabird colonies

8. Activation of OSRL

9. Other company’s operations impacted

10. National media attention

TIER 3 RESPONSE

1. Covers catastrophic spills, which require the mobilization of international support

2. Major incident causing oil spill >40 tons

3. Death or potentially very serious threat to life

4. Activation of OSRL Support

5. International media attention

6. Catastrophic impact on local and regional communities

7. Oil moving outside Namibian waters

Figure 5.1: Characteristics of Tier 1, 2 and 3 oil spills.

5.2.2 OSCP and the National Marine Pollution Contingency Plan (NMPCP)

The OSCP to be prepared by M & P Namibia (Pty) Ltd for the proposed multiple wells drilling operations in PEL 44 shall be linked to the National Marine Pollution Contingency Plan (NMPCP) for support when and if required. The National Marine Pollution Contingency Plan (NMPCP) is the main plan which covers all marine oil spills in Namibia and to which the Project ERP and OSCP shall be linked (Figs. 5.1 and 5.2). In accordance with the Prevention and Combating of Pollution of the Sea by Oil, Act 1981 and the 1991 Amendment Act, Act 24 of 1991, designates the Ministry of Works and Transport as the National Responsible Authority with regard to oil spill preparedness, response and coordination in the Republic of Namibia. This responsibility falls under the Directorate of Maritime Affairs (DMA) in the Department of Transport, Ministry of Works and Transport. The Directorate of Maritime Affairs acts as the coordinating agency during an oil spill, while the Directorate of Civil Aviation is responsible for routine air surveillance through civilian aircraft reports, hiring of surveillance and rescue aircraft and helping in the facilitation of visas and clearance for foreign personnel, aircraft and equipment. Overall the response to general emergencies in Namibia is regulated by the National Emergency system. Under this system, the Namibian Cabinet is the highest authority (Fig. 5.1). The National Risk Management Committee (NRMC) reports to the Cabinet through the Secretary to the Cabinet. The NRMC is composed of representatives of Government and non-Governmental agencies. It is the principal policy formulating and coordinating body for civil emergencies.



Figure 5.2: National Marie Pollution Contingency Plan (NMPCP) Governance structure,

(Source: NMPCP, 2017) Figure 5.3: National Marine Pollution Contingency Plan (NMPCP) legal, administrative

and planning framework showing the link to other plans including the Offshore Petroleum Industry Marine Pollution Plan to be developed specifically for PEL 44 (Source: NMPCP, 2017).

5.2.3 Guidelines to Appropriate Response Strategies

The extent of the response strategy employed will vary depending upon the size and type of the spill. Not all strategies will be suitable to all types of spills. The response strategies should not be used in isolation but shall form part of an overall response tactical operation. Having defined probable spill scenarios and considered the likely behaviour of the spilt oil and the resources



under threat, the following is summary of the key strategies for the proposed M & P Namibia (Pty) Ltd drilling operation:

❖ Monitor and Evaluate;

❖ Application of Chemical Dispersant;

❖ Offshore Containment and Recovery;

❖ Shoreline Protection and;

❖ Clean Up, and;

❖ Waste Management.

The response decision flowchart shown in Fig. 5.4 must be used to initiate the appropriate response strategy following any oil spill event regales of the size (Tier 1, 2 or 3). Response strategies have been developed based on the risk assessment, oil spill modelling, environmental and socioeconomic setting and the legal framework present in Namibia.

The following are the key documents that must be complimentary to the Project OSCP with respect to the specific requirements:

❖ Crisis Management Plan;

❖ Emergency Response Bridging Document – ERBD;

❖ Flights Emergency Response Plan (CHC);

❖ H2S Contingency Plan;

❖ Walvis Bay Port shore/ operations base Emergency Response Procedure;

❖ Walvis Bay International Airport / Arandis Aviation support base Emergency Response

Procedure;

❖ MedEvac – Medical Evacuation Procedure (International SOS);

❖ Rig Emergency Response Plan;

❖ Supply Vessels Emergency Response Plan;

❖ Oil Spill Contingency Plan (OSCP);

❖ Oil Spill Response Limited (OSRL) Services Agreement;

❖ Radiation Management Plan (RMP);

❖ Waste Management Plan (WMP);

❖ Environmental Management Plan (EMP) Vol. 3 of 3, and;

❖ Well Control Emergency Response Plan (Wild Well Control).



Figure 5.4: Deciding on an appropriate response strategy.

5.3 Emergency Preparedness Guidance

5.3.1 Emergency Response Plans (ERP)

In fulfilment of the requirements of the Petroleum (Exploration and Production) Act 1991 (Act 2 of 1991) and the condition contained in the Model Petroleum Agreement signed between the Ministry of Mines and Energy and M & P Namibia (Pty) Ltd and Partners, an Emergency



Response Plans (ERP) shall be prepared by the operator, M & P Namibia (Pty) Ltd for approval by the Petroleum Commissioner in the Ministry of Mines and Energy (Competent Authority). The ERP to be prepared shall have response levels that may include the following (Fig. 5.5 and Table 5.1):

❖ LEVEL I - Operational Response: Managed by the incident facility/site, using the resources available on site;

❖ LEVEL II - Onshore Tactical Response: Supporting the decisions and actions taken

by the Level I response teams; and provide the additional resources needed for emergency control. The Emergency Management Team, are responsible for issues such as, POB reconciliation, contractor liaison, logistical support, information gathering for corporate public relations and initial statutory notifications etc, and;

❖ LEVEL III – Onshore Strategic Response: Supporting and monitoring the actions and

effectiveness of the Level II Emergency Management Team, the Level III Crisis Management Team shall concentrate on the long-term strategic implications of the emergency. In particular the legal and reputational issues created by the emergency, and long-term recovery issues.

Figure 5.5: Tier 1, 2 and 3 ERP response organisation.



Table 5.1: Summary of the emergency scenarios and operational response procedure.

Emergency Scenario

Facility

Operational Response

Procedures

Responsible Person for

Starting

Responsible Person for Following

Up the Actions

1.1 Personnel injury/illness

Drilling rig

MedEvac Procedure Company Man Drilling Superintendent

Rig Emergency Response Plan

Offshore Installation Manager OIM)

Rig Manager

Platform Supply Vessels (PSVs)

MedEvac Procedure Company Man Drilling Superintendent

Supply Vessels Emergency Response Plan

Captain Vessel Coordinator

Walvis Bay Operations Support Bases

MedEvac Procedure Logistics Base Supervisor

Logistics Coordinator

Headquarters Windhoek

Headquarters Emergency Response Procedure

Manager responsible for the victim

Administrative Manager

1.2

Man overboard or missing person at sea

PSVs Supply Vessels Emergency Response Plan


Drilling rig Rig Emergency Response Plan

OIM Rig Manager

1.3 Fire, explosion



Company Man Drilling Superintendent


OIM Rig Manager




Security Supervisor


Walvis Bay Operations/ Support Bases

Operations or Support Base Emergency Response Procedure

Logistics Base Supervisor


1.4

Total power loss, collision, loss of stability or dynamic positioning, flooding, etc.




OIM Rig Manager

1.5 Aircraft Emergencies

On drilling rig helicopter deck

Rig Emergency Response Plan

OIM Rig Manager

Out of drilling rig helicopter deck (close to the airport)

Flights Emergency Response Plan

Responsible Person A (TBA)

Responsible Person B (TBA)

Out of drilling rig helicopter deck (close to the rig)

Flights Emergency Response Plan




Table 5.1: Cont.

Emergency Scenario

Facility

Operational Response

Procedures

Responsible Person for

Starting

Responsible Person for Following

Up the Actions

1.6 Oil Spill and Pollution

Drilling rig

Rig Ship Oil Pollution Emergency Plan (SOPEP)

Offshore Installation Manager (OIM)

Rig Manager

Platform Supply Vessels (PSVs)

Supply Vessels Ship Oil Pollution Emergency Plan (SOPEP)

Captain

Vessel Coordinator

Walvis Bay Operations Base

Operations Base Emergency Response Procedure



At sea Oil Spill Response Plan Company Man

Drilling Superintendent

1.7 Well Control Emergencies

Drilling rig

Well Control Emergency Response Plan (WWC)

Company Man


OIM

1.8 Accidents with radioactivity / explosives

Drilling rig TCP / Radioprotection Plan

Company Man

Drilling Superintendent Field Engineer

1.9 H2S Emergencies

Drilling rig H2S Contingency Plan


OIM

1.10

Events with evolution to Emergency Evacuation

Drilling rig / PSVs

Supply Vessels Emergency Response Plan



Rig Emergency Response Plan Company Man


OIM Rig Manager

Walvis Bay Operations / Support Bases

Operations or Support Base Emergency Response Procedure







Business Continuity Plan

Finance and Administrative Manager

General Manager

5.3.2 Purpose of the ERP and Organisational Framework

The purpose of the ERP shall be to define clear procedures and actions plan with respect to any anticipated abnormal conditions and emergencies that may be associated with the proposed multiple well drilling operations in PEL 44. Examples include: injuries and loss of life, fires and



explosions, collision, flooding and loss of ballast, release of flammables and toxic gases, and loss of support craft (Table 5.1). The ERP shall contain the following aspects:

❖ A description of the ERP (structure; roles; responsibilities; decision makers); ❖ Policies defining measures for limiting or stopping events in question and conditions for

termination of action;

❖ Easy-to-follow procedures for responding (details of response equipment and location, procedures, training requirements, duties, etc.);

❖ Descriptions and procedures for alarm and communications systems;

❖ Precautionary measures for securing the well;

❖ Evacuation procedures;

❖ List of on-site first aid supplies and available backup medical support, MEDEVAC facilities,

and other emergency facilities, and;

❖ Relief well arrangements including description of equipment, consumables and support systems to be utilised.

Overall ERP shall ensure that the equipment and more so personnel, who have the knowledge and the authority are aware of all the potential accidents and emergency incidents likely to occur during the proposed multiple wells drilling operations and that the emergency system shall be activated and continuously tested and ready to handle the situation as required.

5.3.3 ERP Organizational Response Structure (ORS)

M & P Namibia (Pty) Ltd Namibia Emergency Response Plan (ERP) Organisational Response Structure (ORS). The ORS framework shown in Fig. 5.6 is based on five basic functions (command, response action, logistics, planning and management). This structure shall be defined in detail in the ERP Document and applied to small or large-scale emergencies. The ORS shall be flexible so that its parties are called upon to provide assistance as necessary, depending on the type and size of the emergency. In the Operational Response Procedures, equipment, response materials and human resources needed to control emergencies shall be fully provided. The Incident Commanders (IC) for each operational unit shall be responsible for keeping these resources available or for overseeing contractors to ensure they keep all necessary resources available. If, for any reason, the resources defined for an emergency are not enough, the Incident Commanders of Response Actions are responsible for acquiring extra resources. Fig. 5.6 shows the concept of response levels applied to this emergency response plan in order to classify the need for response resources.



Figure 5.6: Emergency Response Plan (ERP) organisational notification / response structure.

5.4.4 Emergency Response Principles

In the ERP Document to be prepared for the proposed project, the Emergency Team / unit leaders shall ensure that duties, responsibilities and lines of command in an emergency situation are understood as clearly defined and as far as possible similar to normal operations to ensure that the emergency situation is handled rationally and professionally. As part of the implementation of the ERP the following emergency guiding principles shall be adopted by the Emergency Response Team and associated emergency response units and support staff on the rig, supply vessel and onshore:

(i) All personnel are aware of the lines of communication, reporting and information flow with

respect to the command and control of the emergency situation;



(ii) An emergency organisation shall have personnel with professional expertise and authority to take executive decisions to avoid unnecessary delay and ensure that the situation is handled rationally and professionally;

(iii) The duties assigned to one and the same person in the emergency organisation shall be

compatible with each other;

(iv) All actions and activities in an emergency situation shall be recorded in order to ensure traceability, experience retention and transfer, and;

(v) In an emergency situation priority shall be given to efforts that minimise and reduce the

consequences and harmful effects in the following order.

5.4 Useful Contacts to be Included in the ERP and OSCP Tables Coastal area covering Walvis Bay and Swakopmund emergency numbers and facilities In addition to the key list of contact person and institutions to be provided in the ERP and OSCP, the following is list of key selected contact details of key persons to be contacted in case of an emergency especially an oil spill:

1. Ms. Maggy Shino, Petroleum Commissioner, Ministry of Mines and Energy +264-

812882182, Tel: +264 61 2848209, Fax: +264 61 2848200, Email: [email protected];

2. Mr. Tupa Iyambo, Chief Inspector of Petroleum Affairs, Ministry of Mines and Energy Cell: +264 81 240 2183 Telephone, +264 61 284 8300, Fax: +264 61 284 8200; [email protected]

3. Mr. Pinehas N. Auene | Deputy Director: Directorate of Maritime Affairs | Ministry of Works and Transport (MWT) | Tel: +264 64 203317 | Fax: +264 64 205266 | Mobile: +264 816 6491 88; Email: [email protected]

4. Dr Fredrick Mupoti Sikabongo – Deputy Environmental Commissioner, Office of the

Environmental Commissioner, Ministry of Environment and Tourism (MET), +264 812930537, Tel: +264 61 284 2751, Fax: +264 61 240 339, Email: freddy.Sikabongo@met .gov.na

5. Mr. Colgar Sikopo, Director of Parks and Wildlife Management, Ministry of Environment and

Tourism (MET), Tel: +264 61 2842528, Fax: +264 61 229936, Email: [email protected];

6. Mr. Christopher Munwela, Deputy Director, Division: North West Regions, Ministry of

Environment and Tourism (MET), Tel: +264 67 313436; Fax: +264 67 313593; Email: [email protected];

7. Mr. Joshua Kazeurua, Chief Warden, Skeleton Coast National Park, Ministry of Environment

and Tourism (MET), Mobile: +264-813569321, Email: [email protected]

8. Mr. Peter Amutenya, Director of Operations, Ministry of Fisheries and Marine Resources. Tel No. 061-205 3009 /3116, Fax No. 061-240412, Email: [email protected];

9. Mr. Immanuel Mulunga, Managing Director, National Petroleum Corporation of Namibia

(Pty.) Ltd (Namcor), +264-811277267, +264 61 204 5000 +264 61 204 5061/30/92; [email protected]




mailto:freddy.Sikabongo@met%20.gov.na

mailto:freddy.Sikabongo@met%20.gov.na







10. Dr. Anja Kreiner, Chief Environment, Ministry of Fisheries and Marine Resources, National Information and Research Centre, Tel: +264 (0)64 410 1000 (switchboard)/ +264 (0)64 410 1158 (direct line), Fax: +264 (0)64 40 4385 or +264 (0)64 406784, Email: [email protected] or [email protected]

11. Dr Hashali Hamukuaya, Benguela Current Commission, Telephone: +264 64 406901, Fax: +264 64 406902/3

12. Dr. Jean-Paul Roux – Head: Ecosystem Analysis Section, Ministry of Fisheries and Marine

Resources, Lüderitz Marine Research. Tel: 063202415 / 0813083949, email: [email protected];

13. Dr. Jessica Kemper – African Penguin Conservation Project. Specialist in seabird

rehabilitation, Tel: 063202442 / 0813231110, email: [email protected]; and;

14. Dr. Ingrid Wiesel – Brown Hyena Research Project. Tel: 063202114, email: [email protected].

Table 5.2: Coastal area covering Walvis Bay and Swakopmund emergency numbers and

facilities.

WALVIS BAY AND SWAKOPMUND TOWNS

FACILITY / SERVICES TELEPHONE NO.

Cottage Medi-Clinic Private Hospital (Swakopmund)

Tel +26 46 441 2200- and 24-Hour Emergency Centre +264 46 441 2200

Police 10111

Med rescue +264 64-200 200

Sea Rescue +264 64-203 202 / 203581

Welwitschia Private Hospital (Walvis Bay)

+264 64-218911

Road Guard 0800 11 22 33

Fire Brigade +264 64-203117

Welwitschia Private Hospital +264 64-218911

Ambulance +264 64 216 309

Air Ambulance Walvis Bay +264 866 255 5387

CITY OF WINDHOEK

FACILITY / SERVICES TELEPHONE NO.

MedRescue + 264 61 230 505/6/7

Ambulance +264 61 21 1111

International SOS Namibia +264 61 289 0911

Fire Brigade +264 61 21 1111

City Police - Fire Brigade (ambulance, accidents and injuries)

+264 61 211 111

Windhoek Main Station +264 81 222 2516 +264 61 209 4111

City Police - Crime Prevention Unit (24 hrs)

+264 61 290 2239 / 290 2018







Table 5.3: Government of Namibia (GRN) in-Country emergency response focal points.

Organization Name Position Telephone

(Office) Mobile

Directorate of Disaster Risk Management

Office of the Prime Minister

Mr Japhate Iitenge Director +264612873550

+ 264614351000 +26481 129 7117

Maritime Rescue Centre

Directorate of Maritime Affairs; Ministry of Works and Transport

Shift Supervisor Shift

Supervisor +264 64

203202/203581 +264 85522072

Port Control 1Walvis Bay

Namibian Ports Authority Lukas Kafuna Port Captain +264642082355

+264 811279259 +264 811295260

Port Control 2Walvis Bay

Namibian Ports Authority Shift Supervisor

Shift Supervisor

+264642082355 +264 811279259 +264 811295260

Marine Pollution Control and Search and Rescue (SAR) Division Directorate of Maritime Affairs; Ministry of Works and Transport

Pinehas Auene Deputy Director

+264 64 208 6300 +264 816649188

Directorate of Maritime Affairs; Ministry of Works and Transport

R Kalomho Acting Director +26461208 206/231 +264 811 410 467

Ministry of Fisheries and Marine Resources (MFMR)

Moses Maurihungirie Permanent Secretary

+264612053911

Department of Environmental Affairs Ministry of Environment and Tourism (MET)

Dr Fredrick Mupoti Sikabongo

Deputy Environmental Commissioner

+264612842751 +264 812930537

Petroleum Directorate Ministry of Mines and Energy (MME)

Mrs M Shino Petroleum

Commissioner +264612848209 +264812882182

Petroleum Directorate Ministry of Mines and Energy (MME)

Tupa Iyambo Chief

Petroleum Inspector

+264612848209 +264812402183

National Petroleum Corp. of Namibia (Pty) Ltd (NAMCOR)

Immanuel Mulunga Managing Director

+264612045000 +264811277267

National Petroleum Corp. of Namibia (Pty) Ltd (NAMCOR)

Victoria Sibeya Exploration Executive

+264612045070 +264811433455

Ministry of Safety and Security (MSS)

Commissioner Andreas Nelumbu

C

Erongo Region Regional

Commander +264 64 219 001 +264 81 377 4774

National Radiation Protection Authority Ministry of Health and Social Services

A. Tibinyane Director +264 61 2032418 +264811222319

National Radiation Protection Authority Ministry of Health and Social Services

J. Eiman Deputy Director

+264 61 2032415 +264 81 1296770

1 Port Limits only. Outside port limits, DMA 2 Port Limits only. Outside port limits, DMA



6. CONCLUSIONS AND RECOMMENDATIONS

6.1 EMP Conclusions

This EMP Vol. 3 of 3 Report has been prepared based on the findings and recommendations of the EIA Vol. 2 of 3 Report. Both the EIA and EMP Reports have been prepared in accordance and in line with the provisions of the applicable national regulations and based on good international oil and gas industry practices. Prior to the mobilisation for the proposed drilling operations appropriate reports, documentations and formal application forms shall be prepared in order to support the applications for all the required predrilling, drilling and post-drilling consents, endorsements, permits, authorisations and certifications in line with all the applicable regulations.

6.2 Recommendations

6.2.1 EMP and Environmental Clearance Certificate (ECC)

Based on the content of this EMP Vol. 3 of 3 Report, it is hereby recommended that M & P Namibia (Pty) Ltd (the Proponent) be issued with the Environmental Clearance Certificate (ECC) for the proposed multiple wells drilling operations in PEL 44, offshore central Namibia The ECC shall be inclusive of all the supporting activities at Walvis Bay Port the shore/ operations and Walvis Bay International Airport/ Arandis Airport, the aviation bases. The Proponent shall prepare a detailed EMP Vol. 3 of 3 with mitigation measures to be implemented.

6.2.2 Other Permits Requirements

In accordance with the provisions of Petroleum (Exploration and Production) Act 1991 (Act 2 of 1991) and associated amendments as well as all other relevant Namibian laws, regional and international environmental and petroleum exploration standards and practices, the implementation of the proposed multiple wells drilling operations can only be undertaken once the following permits / endorsements / consents have been obtained:

(i) Oil Spill Contingency Plan (OSCP) Approved / Endorsed by the Department of Maritime


(ii) Emergency Response Plan (ERP) Approved / Endorsed by the Petroleum Commissioner, Ministry of Mines and Energy (MME);

(iii) Radioactive Authorisation (Import and Export Permits) for the use of radioactive sources

for logging Issued by the Radiation Authority, Ministry of Health and Social Services (MHSS);

(iv) Pollution Safety Certificate for the rig to be used issued by the Department of Maritime


(v) Explosive Permit Registration (Import and Export Permits) as a consumer and importation of explosives into Namibia for the use of explosive materials in the drilling process issued the Ministry of Safety and Security (MSS);

(vi) Preapproval for the use of dispersants in an event of an oil spill issued by the Ministry of

Fisheries and Marine Resources (MFMR), and;

(vii) Letter of consent to drilling or permit to drill, Drilling Reporting and Notification of well abandonment and drilling completion issued by the Office of the Petroleum Commissioner, Ministry of Mines and Energy (MME).



6.2.3 Notification for Project Implementation

In line with the provisions of the Petroleum Act, the proponent is required to notify the Petroleum Commissioner in the Ministry of Mines and Energy (MME) on various matters related to the project operations, safety, environment and general drilling progress including the following:

❖ Exact location of the rig, date and estimated duration of the planned drilling

implementation;

❖ Drilling progress and all matters related the drilling operations;

❖ All Health, Safety and Environmental (HSE) related issues, and;

❖ Drilling completion and results thereof.

It’s the responsibility of the Petroleum Commissioner in the Ministry of Mines and Energy (MME) to notify all the mariners through Hydrographic Office in Cape Town on the exact location of the rig and the exclusion zone prior to the drilling implementation. The proponent shall also notify key stakeholders such as the following:

❖ Ministry of Fisheries and Marine Resources (MFMR);

❖ Ministry of Environment and Tourism (MET);

❖ Ministry of Works and Transport;

❖ NamPort;

❖ Namcor;

❖ Ministry of Health and Social Services (Radiation Authority);

❖ Ministry of Safety and Security (Explosive Division);

❖ Benguela Current Commission;

❖ Fisheries / marine related associations / bodies, and;

❖ Public as maybe required through a general advert published in the local newspapers.

6.2.4 Project Communications Protocols

All Communications between the rig and support vessels, maritime traffic and relevant maritime authorities are essential to ensure that operations are conducted safely and with no adverse impacts to the environment. The vessels shall be equipped with legally required communication equipment ranging from satellite devices to hand held radios to inform nearby marine users of the drill rig’s location or support vessels’ movements. All communication procedures undertaken with stakeholders and with other sea users during the Project operations shall be recorded as part of the Project stakeholder process, which will be prepared and implemented before and throughout the Project operations. This will include discussions with the public and stakeholders potentially affected by the Project.

6.4.5 Safety Exclusion Zone

In line with the provision of the Petroleum Act, a 500 m radius navigational safety exclusion zone centred on the rig while at the well site shall be enforced for the duration of the drilling



programme. The rig and supply vessels will jointly monitor transit / fishing vessels within the area around the exclusion zone. Early warning radar and communication systems on board the supply vessels and drill rig will be used to monitor vessel movements and to communicate with those nearing the exclusion zone. Collision avoidance procedures will be developed prior to mobilisation of the drill rig for deployment to deal with the unlikely eventuality that the exclusion zone is breached.

6.4.6 Other Project Operational Related Control Safety Measures

The drilling rig and all support vessels to be used for the proposed multiple well drilling operations shall be operated in accordance with all applicable national legislation and regulations as well as international requirements such as MARPOL 73/78 Regulations for the prevention of pollution from ships by sewage and oil (Annex I and IV, updated 2003). In accordance with MARPOL requirements, there will be no planned discharge of wastewater within 12 nautical miles (NM) of the nearest land. Other project operational related control safety measures will include:

❖ The drilling operations shall be undertaken by a competent international, specialist drilling

contractor using a rig that will meet all the Namibian and international safety standards and with minimal impact on the environment;

❖ The drilling contractor shall be required to meet all the proponents, Namibian and

international requirement and standards;

❖ All vessels shall be certified by the Namibian Authorities (Department of Maritimes Affairs and Inspectors in the Ministry of Mines and Energy);

❖ The drilling rig and support vessels shall operate in compliance with national and

international maritime regulations including MARPOL 73/78 regulations, MARPOL requirements (Annex V), guidance from International Convention on the Safety of Life at Sea (SOLAS), as well as industry good practice guidelines;

❖ The drilling rig and support vessel shall have internationally recognised identification /

warning signals in place in line with international shipping regulations;

❖ The drilling rig and support vessels to be used shall carry appropriate navigation lights for operating during night-time and periods of poor visibility. The level of lighting will be in compliance with safety regulations at sea and, although it represents a localised and temporary disturbance to marine wildlife, it is necessary for human safety. Advanced positioning equipment will be used to maintain communications with other vessels and provide accurate information on the position of the drill rig;

❖ Drilling operations shall only be undertaken during weather conditions (e.g. wind speed,

wave height) that are within the drill rig’s operational limits and operations will be suspended if limits are exceeded;

❖ Refuelling and bunkering at sea, if required will only take place at a safe distance from the

coast, shallow areas or other potential hazards;

❖ The drilling rig and support vessels shall have a Shipboard Oil Pollution Emergency Plan (SOPEP) in place, in accordance with International Maritime (IMO) guidelines. The SOPEP will include among others, oil spill contingency and response procedures to be implemented during refuelling operations. Any potential spills will be coordinated in compliance with the National Marine Contingency Plan of Namibia, and;

❖ The drill rig and supply vessels shall monitor shipping activities and enforce a safety

exclusion zone around the drill rig to prevent collision with other sea users.



6.2.7 Safety Health and Environmental Awareness (SHEA) and Monitoring

Safety Health and Environmental Awareness (SHEA) is part of the overall Environmental Monitoring that shall be implemented at all project sites (Shore, Aviation and rig) and in addition to the awareness that is often undertaken as part of the drills for ERP testing of the in-country preparedness. SHEA activities shall be implemented by the onsite HSE team through the site debriefing activities and all other permits to work procedures. The following is the summary of some of the key monitoring areas that shall be implemented: ❖ Awareness activities shall be undertaken effectively during operations. The awareness

activities will cover operations procedures, Safety, Health and Environment Awareness (SHEA) for the rig the operations and support bases as well as information dissemination to key stakeholders such as the Ministry of Mines and Energy, Ministry of Environment and Tourism, Ministry of Fisheries and Marine Resources as well as other key stakeholders;

❖ Drills and emergency response preparedness related activities associated with the Port of

Walvis Bay (Logistic Operation / Shore base), Walvis Bay International Airport / Arandis Airport (Logistic Aviation support base) and the rig in PEL No. 44 shall be undertaken effectively before project implementation that all the various contractors are aware of the arrangements and all the operations of the project;

❖ Drilling location monitoring environmental performance and compliance monitoring

framework undertaken in order to make sure that all the activities are in compliance with the (EMP) requirements;

❖ Shore / Operations base (Walvis Bay Port) environmental performance and compliance

monitoring framework undertaken in order to make sure that all the activities are in compliance with the (EMP) requirements;

❖ Aviation Base (Walvis Bay International Airport / Arandis Airport) environmental

performance and compliance monitoring framework undertaken in order to make sure that all the activities are in compliance with the (EMP) requirements;

❖ Drilling location in PEL No. 44 (the Rig) environmental performance and compliance

monitoring framework undertaken in order to make sure that all the activities are in compliance with the (EMP) requirements, and;

❖ Overall Health Safety and Environment (HSE) performance monitoring framework

established for Port of Walvis Bay (Logistic Operation / Shore base), Walvis Bay International Airport / Arandis Airport (Logistic Aviation support base) and the drilling rig location in PEL No. 44.

It is highly recommended that ongoing environmental monitoring activities be undertaken for the duration of the proposed drilling programme through the appointment of an Environmental Coordinator or delegated HSE Officer. The duties of the Environmental Coordinator or delegated HSE Officer shall be to: (i) Oversee and coordinate the implementation of the EMP and SHEA activities;

(ii) Undertake overall environmental coordination activities through the preparation of

monthly progress reports on the coordination of ecological activities including results of any incidences associated with the rig (offshore) and the operational (Shore) base (Walvis Bay);

(iii) Environmental Observer (EO) on-board the rig for the duration of the Vertical Seismic

Profile (VSP) survey;



(iv) Prepare monthly reports on the awareness training and activities undertaken for personnel on board the drill rig (offshore), the operations base Walvis Bay and the aviation base Walvis Bay International Airport / Arandis Airport as well as any other stakeholders interactions, and;

(v) Prepare final Health, Safety and Environment Environmental Monitoring (HSEEM) or

Closure Report at the end of each of the proposed wells drilled to be submitted to the Ministry of Environment and Tourism, National Petroleum Corporation of Namibia (Namcor), Ministry of Mines and Energy, NamPort, Ministry of Fisheries and Marine Resources and Ministry of Works and Transport. The closure report for each well drilled shall be prepared within three (3) months after the drilling operations have been completed for each well and shall present the environmental monitoring performances and activities undertaken and achievements made throughout the duration of each well drilled.

Documents

Maurel & Prom Namibia (Pty) Ltdeia.met.gov.na/screening/407_app_00407_emp_vol_3_of_3_m_p_nam… · Document ID: EMP Vol. 3 of 3 Report December 2019 Version.Final Owner: Maurel &