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Shell Development (Australia) Pty Ltd (ACN 14 009 663 576) Palta-1 Exploration Well WA-384-P Environment Plan Summary

Palta-1 Exploration Well WA-384-P Environment Plan Summary · Shell Development (Australia) Pty Ltd Summary Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012 2 TABLE OF

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Shell Development (Australia) Pty Ltd (ACN 14 009 663 576)

Palta-1 Exploration Well

WA-384-P Environment Plan

Summary

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

2

TABLE OF CONTENTS 1. Introduction ........................................................................................................ 3 2. Shell as Operator ................................................................................................ 3 3. Activity Description ............................................................................................ 3 4. Description of the Environment ........................................................................ 5

4.1. Physical ....................................................................................................... 5 4.2. Biological ..................................................................................................... 5 4.3. Conservation areas ...................................................................................... 5 4.4. Socio-Economic Environment ...................................................................... 6

5. Management Approach ...................................................................................... 7 6. Environmental Hazards and Controls ............................................................... 7 7. Consultation ....................................................................................................... 9 8. Contact Details ................................................................................................... 9 APPENDIX A: Hazards and Controls ....................................................................... 10

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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1. Introduction

This document provides a summary of the Environment Plan for the Palta-1 well, which was accepted by the National Offshore Petroleum Safety and Environment Authority on 7th August 2012.

2. Shell as Operator

Shell’s Australian exploration and production business has been operating for more than 75 years and holds an interest in about 20% of the gas resources in Australian waters. Shell is involved in a number of major Australian gas projects including the Shell operated Prelude project, which will be the first deployment of Shell’s Floating Liquefied Natural Gas technology. Shell is also a non-operating partner in the North West Shelf project, the Gorgon joint venture and the Wheatstone joint venture. Shell maintains an extensive exploration portfolio, with 10% of Shell’s global exploration budget spent in Australia. Shell has safely drilled 17 exploration wells in the Browse Basin since 2006 and operated three seismic surveys in Southern Exmouth. Shell’s exploration and production business is based in Perth and employs almost 400 people.

Shell has more than 30 years experience in deepwater operations and many of the deepwater technologies in use today were developed by Shell. In 2007 Shell performed a major review of its deep-water capabilities and safety procedures in response to the increasing challenges of greater water depths and more complex reservoir conditions. This led to improvements to procedures, including the strengthening of standards in well control, design and completion and the management of contractors.

In response to the Montara incident in August 2009 and the Deepwater Horizon incident in April 2010, Shell undertook another rigorous review of its drilling processes to ensure it was operating at best practice. In March 2011, Shell became the first oil and gas company to be awarded a permit to drill a new exploration well in the Gulf of Mexico following the Deepwater Horizon incident. This demonstrates the credibility of Shell’s robust approach to safety and responsible operations, based on rigorous global standards and practices.

3. Activity Description

Shell plans to drill a single exploration well (Palta-1) targeting gas in Exploration Permit WA-384-P, located in the Southern Exmouth Basin, Western Australia (Figure 1). Drilling is scheduled to commence in September-October 2012 and the well is planned to take 2-3 months to drill.

The drilling programme will be carried out by the Noble Clyde Boudreaux Mobile Offshore Drilling Unit (drilling rig), which is managed by Noble Corporation (Noble). The drilling rig will be supported by three offshore vessels working from the Port of Broome. Aviation support and crew changes to the Noble Clyde Boudreaux drilling rig will be conducted through Learmonth (Karratha Airport may be used as a contingency).

Table 1: Activity details

Well Water Depth Latitude Longitude Exploration Permit

Palta-1 1,292 m 22° 05’ 11.790” S 113° 10’ 50.904” E WA-384-P

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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Palta-1 is situated in Commonwealth marine waters approximately 50 km west of the boundary of the Ningaloo Marine Park (~70 km from the coast) in 1,292 m water depth. In line with previous activities undertaken by Shell in the region, vessels associated with the Palta-1 well will not enter within 10 km of the Ningaloo Coast World Heritage Area during normal operations.

Figure 1: Palta-1 Location

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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4. Description of the Environment

4.1. Physical

The most prominent environmental feature of the broader region is the Ningaloo Reef, which is protected by the Ningaloo Marine Park, under joint State and Commonwealth jurisdiction and forms part of the Ningaloo Coast World Heritage Area. The Ningaloo Marine Park boundary is located approximately 50 km east of the Palta-1 well location. Ningaloo reef (~70 km east of the Palta-1 location) is a diverse fringing reef located within several kilometres of the Western Australian coastline that extends approximately 260 km southward of North West Cape. It is the longest fringing barrier reef in Australia.

The Cape Range and Cloates subsea canyons are located approximately 15 km to the north and 20 km to the south of Palta-1 respectively. The oceanic habitat of the region is characterised by deep, relatively warm, low nutrient waters. The climate of the North West Shelf region is arid sub-tropical. Summers (September to March), are hot with winds predominantly from the south-west. In winter (May to July), winds from the south dominate. Tropical cyclones typically occur in the region three to four times per year between December and April, bringing strong winds, heavy rain and high seas. The oceanic circulation of the region is influenced by local tides (semidiurnal), wind driven surface currents (which reflect the prevailing seasonal wind directions), and regional currents such as the Leeuwin Current and the Ningaloo Current.

4.2. Biological

The seismic data collected from site surveys indicate that the drilling rig anchoring footprint for Palta-1 comprises a relatively flat, soft muddy bottom with no areas of hard substrate. The soft seabed is likely to support meiofauna (mainly nematodes and harpacticoid copepods) and a high diversity but low abundance community of infauna and epifauna including sea cucumbers, ophiuroids, echinoderms, polychaetes, seapens, molluscs and crustaceans. The nearby Exmouth Plateau is considered an important area for communities adapted to depths of 1,000m. Due to the water depths the soft sedimentary environment and the lack of hard substrate that could potentially support significant benthic habitats, the significance of any impacts to benthic communities as a result of the drilling activity are expected to be low.

The open ocean environment of the region generally supports mobile fish species such as tuna, mackerel, marlin and sailfish and demersal species including snapper, sea perch, emperors, lizardfish and goatfish. Larger marine species including cetaceans, sharks and sea turtles are also widely distributed throughout the open ocean environment, with higher expected concentrations closer to the coast near Ningaloo Reef. The Department of Sustainability, Environment, Water, Population and Communities Protected Matters Database lists seventeen threatened and eight additional migratory species that potentially traverse the permit area and adjacent areas including cetaceans, birds, turtles and sharks. There are no recognised feeding, breeding or aggregation areas in close proximity to the permit area and therefore these areas are unlikely to support significant numbers of these species.

4.3. Conservation areas

Shell has committed that the drilling rig and vessels will not enter the Ningaloo Coast World Heritage Area or within 10 km of the Ningaloo Marine Park during normal operations.

The State and Commonwealth Ningaloo Marine Parks and the Murion Islands Marine Management Area, which make up the marine components of the Ningaloo Coast World

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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Heritage Area, are located 50 km west of Palta-1. Habitats and fauna of the Ningaloo Marine Park include 43 demersal fish species, large sharks, such as the oceanic white-tipped shark (Carcharhinus longimanus) and grey reef shark (Carcharhinus amblyrhynchos), and manta rays (Manta birostris) occur in deep water outside the reef and are likely to be found in Commonwealth waters. Manta rays congregate inside the reef particularly in autumn and winter as well as in deep water. Numerous other species of rays, small sharks, and juveniles of the larger shark species occur inside the reef, in State waters.

The Palta-1 well and the entire permit area are located in the proposed Gascoyne Marine Reserve, more specifically, in a proposed IUCN VI ‘multiple use zone’ which, when gazetted, will still allow for petroleum exploration and production.

4.4. Socio-Economic Environment

A search conducted of the Department of Indigenous Affairs Aboriginal Heritage Sites Register did not identify any indigenous heritage values within the permit area. Although numerous ship wrecks are documented along the Ningaloo coast, no known ship wrecks occur within the vicinity of the proposed drilling site. Historic places along the Ningaloo coast include the Fin, Perth and Zvir shipwrecks and the Point Cloates Lighthouse.

There is minimal Western Australian State or Commonwealth managed commercial fishing effort in the vicinity of the proposed Palta-1 well location. Hence the impact of drilling Palta-1 on fishing activities is expected to be minor to none. State managed fisheries management zones overlapping the permit area include the Mackerel Managed Fishery, the West Coast Deep Sea Crustacean (Interim) Managed Fishery, and the West Coast Rock Lobster Managed Fishery. Fisheries management zones adjacent to the permit area include the North Coast Shark Fishery, the Shark Bay Prawn and Scallop Fishery, the Gascoyne Demersal Scalefish Fishery, the West Coast Demersal Scalefish (Interim) Managed Fishery, the Western Australian Pearl Oyster Fishery, and the North Coast Prawn Managed Fisheries. Commonwealth managed commercial fisheries that overlap with the Palta-1 location include the Western Deepwater Trawl, the Southern Blue Fin Tuna Fishery, the Western Skipjack Fishery and the Western Tuna and Billfish Fishery.

Nature-based tourism provides a significant economic benefit to the Exmouth region. Tourism activities centred around the Ningaloo Reef include scuba diving, beach fishing, and snorkelling. With the exception of offshore fishing charters, most marine tourism activities occur within State waters close to the coast. Game fishing tournaments are held annually off Exmouth waters in March, which does not overlap with the drilling period.

Extensive petroleum exploration and production activity occurs in the region and the industry has developed major production and/ or storage operations on Barrow, Thevenard and Varanus Islands and in the waters off the North West Cape. There are five existing Floating, Production, Storage and Offload facilities north east of the proposed Palta-1 location area (Figure 1). However, there is no existing petroleum infrastructure in or adjacent to the permit area.

Vessels travelling along the shipping lane running parallel to the Western Australian coastline and heading in a northerly direction to South East Asian ports may pass through the permit area. However, shipping traffic is unlikely to be affected as the well is located in open waters with no restrictions on shipping movements. A ‘Notice to Mariners’ advising of the presence of the drilling rig will be issued through the Australian Maritime Safety Authority prior to the commencement of the activity.

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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5. Management Approach

The Shell Commitment and Policy on Health, Safety, Security, Environment and Social Performance (HSSE and SP) applies across Shell globally and is designed to protect people and the environment.

Key features of the policy are:

Systematic approach to HSSE and SP management designed to ensure compliance with the law and to achieve continuous performance improvement;

Targets for improvement, appraisals and performance reporting;

Requirement for contractors to manage HSSE and SP in line with this policy; and

Effective engagement with neighbours and impacted communities.

All of Shell’s operations comply with the Shell HSSE and SP Control Framework, a comprehensive corporate management framework, comprising a simplified set of mandatory standards applicable to every Shell company, contractor and joint ventures under Shell’s operational control.

The drilling activity will be managed to comply with the relevant State and Commonwealth Acts and regulations, industry standards and applicable international agreements.

Shell’s overall environmental objective for the Palta-1 well is to avoid or reduce environmental risks to as low as reasonably practicable. Specific objectives, standards and performance criteria for each aspect of the activity that has the potential to cause adverse environmental impact have been identified. Environmental performance will be measured and reported against these standards and criteria as part of Shell’s commitment to continuous improvement of environmental, health and safety performance.

An Implementation Strategy has been incorporated into the Environment Plan per the Offshore Petroleum Greenhouse Gas Storage (Environment) OPGGS (E) Regulations. This includes:

Measures, systems, and practices to ensure environmental performance objectives and standards are met;

Roles and responsibilities;

Measures to ensure workers are aware of their responsibilities;

Competency and training;

Monitoring, auditing and incident investigations;

Records and reporting;

Oil Spill Contingency Plan.

6. Environmental Hazards and Controls

A risk analysis has been undertaken for all aspects of operations, in accordance with the Shell HSSE and SP Control Framework and in line with the principles outlined in the Australian Standard AS/NZS ISO 31000:2009 Risk Management and HB 203:2006 Environmental Risk Management.

To demonstrate that risks are as low as reasonably practicable, all mitigation measures have been considered and where these measures are practical, they have been included.

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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Incidents with a consequence severity equal to or greater than level 3 (moderate) are considered ‘Reportable Incidents’ in line with Regulation 26 of the OPGGS (E) Regulations. Based on the risk assessment, though the probability of occurrence is low, two possible unplanned events, are considered to have a moderate or greater consequence, if they occur:

Death or injury of a member of a threatened, migratory or species as a result of a collision with the vessel; and

A hydrocarbon spill resulting from a well blow out.

To avoid a potential collision with marine life during transit, vessels will adhere to the intent of the Australian National Guidelines for Whale and Dolphin Watching 2005, which requires that: Vessel Masters shall maintain a watch for whales during transit; Vessel Masters shall not knowingly approach within 300 m of whales; If whales are observed within 300-100 m of a vessel during transit, Vessel Masters will alter course away from the whales if safe to do so; If whales are observed <100 m from a vessel, Vessel Masters will power down to ‘no wake speed’ and alter course away from the whales if safe to do so. In addition, vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine Park at any time during the activity during normal operations.

Blowouts are not common and with existing technology represent a very low risk in drilling programmes. There are elaborate monitoring systems to detect potential blowouts and such events can occur only if all of the monitoring systems fail or if the casing, wellhead or Blowout Preventers fail. The occurrence of such circumstances has been greatly reduced by improved technology. The likelihood of a blow out occurring from exploration and production activities across the industry is extremely remote. The blowout frequency for all types of drilling has been estimated at 4.59 x 10-4 (ConocoPhillips EPBC referral 2010/5718) in Australia following the Montara incident.

Shell’s first priority in exploration is always the prevention of major incidents and minimisation of any safety or environmental risks. Shell is fully committed to the systematic approach to managing safety and ensuring the integrity of Shell operations and assets. A number of fundamental processes are in place to manage the integrity of the barriers to prevent major incidents or blow-out events during drilling activities. Shell continually develops people, procedures and equipment further in order to keep well operations safe at all times. Safe well operations demand highly competent people, strict safety procedures and rigorous design, construction and maintenance standards for all equipment. Shell applies a multi-layered well control system designed to minimise risks, so if any one system or device fails it should not lead to a loss of containment. For example, the Palta-1 drilling rig will be fitted with a Blowout Preventer with double ram shears, providing a double redundancy capability, which increases the likelihood that the well can be successfully closed. In the very unlikely event there were to be a failure of all primary and secondary well control measures, Shell has developed a capping stack that will be available for the Palta-1 well. This system will allow Shell to safely cap and shut off the well and minimise any potential hydrocarbon release. To permanently secure and control the well, a relief well has been designed, relief well equipment has been acquired, potential relief well drilling units suitable for the conditions have been identified, and contracts are in place with global Emergency Well Control companies to facilitate successful capping and relief well drilling operations. Additional response capability is in place via an Oil Spill Contingency Plan, which outlines Shell’s oil spill response preparedness for the Palta-1 drilling activity.

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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The remainder of possible events, both planned and unplanned, are assessed as having slight or minor consequences. Appendix A presents the hazards and controls for the activity.

7. Consultation

Shell recognises that the Palta-1 well location is located adjacent to an environmentally sensitive region, and is committed to a public consultation process, which has been extensive and ongoing since March 2010. The consultation to date has comprised face to face meetings, formal and informal correspondence and phone conversations.

Stakeholders have been and are currently able to raise their concerns via direct communication, primarily through Shell’s dedicated Communications focal point for the Southern Exmouth Region and dedicated Palta-1 email address [email protected].

Shell has engaged numerous stakeholders as part of the consultation process, including relevant government agencies, shire councils, non government organisations, industry bodies, and oil spill response organisations located across Australia including the Gascoyne region, Exmouth, and Canberra.

Shell has continuously sought feedback from stakeholders on the Palta-1 exploration well and provided detailed information on Shell’s approach to well integrity, safety, technical capability and oil spill response planning in response to questions around Shell’s ability to operate safely in an environmentally responsible manner.

8. Contact Details

For further information, please contact:

Kelly Lamperd

[email protected]

0413 794 630

2 Victoria Avenue, Perth, Western Australia 6000

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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APPENDIX A: Hazards and Controls

Hazard /

Event

Safeguards – Mitigation Methods (control and recovery measures)

Planned Activities

Physical

presence of

drilling rig and

rig anchoring.

A ‘Notice to Mariners’ advising of the presence of the drilling rig will be issued through the Australian Maritime Safety Authority prior to the

commencement of the activity.

Vessels and the drilling rig will be equipped with sophisticated navigation aids and competent crew maintaining 24 hour visual, radio and radar

watch for other vessels and 500 m exclusion zone.

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Site survey and positioning of anchor to avoid environmental sensitivities.

Lighting of

vessels and

drilling rig.

Location of rig in open ocean away from coast.

Short activity duration (2-3 months).

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Excess pipe

drill thread

lubricant and

cement.

Selection of pipe drill thread lubricants and cement with the lowest environmental footprint that meets technical requirements.

Mixing of cement in small batches, limiting the volume of cement that could require disposal.

Unused additives returned to shore for reuse or disposal.

Discharge of

cooling

waters from

drilling rig.

The Palta-1 location is in open ocean, away from coastal environments and fauna migration routes (~50 km).

Cooling water is produced only during winching operations, which occur during mobilisation and demobilisation.

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Atmospheric

emissions

from fuel

combustion

on drilling rig

and vessels.

Engines (including exhaust systems, generators and incinerators) are maintained to operate efficiently and use low sulphur diesel.

All emissions will be compliant with MARPOL 73/78 Annex VI – Regulation for the Prevention of Air Pollution from Ships, enforced under the

Commonwealth Protection of the Sea (Prevention of Pollution from Ships) Act 1983).

The Palta-1 location in open ocean, away from coastal environments and fauna migration routes (~50 km).

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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Hazard /

Event

Safeguards – Mitigation Methods (control and recovery measures)

Noise

generated by

vessels and

drilling rig

activities.

The Palta-1 location in open ocean, away from coastal environments and fauna migration routes (~50 km).

Routine drilling and vessel noise thoroughly studied and documented to be below levels likely to cause physiological damage to marine fauna.

Seismic source used for vertical seismic profiling and / or seismic while drilling is significantly smaller than used for seismic surveys. These

operations will be conducted in line with the Environment Protection and Biodiversity Conservation Act Referral approval condition:

Pre-start up visual observations;

Soft start procedures;

Operating procedures;

Low visibility procedures.

A marine mammal observer will be present during vertical seismic profiling and/ or seismic while drilling activities.

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Transiting vessels will implement the requirements of Australian National Guidelines for Whale and Dolphin Watching 2005:

Vessel Masters shall maintain a watch for whales during transit;

Vessel Master shall not knowingly approach within 300 m of whales;

If whales are observed within 300-100 m of a vessel during transit, Vessel Masters will alter course away from the whales if safe to do so;

If whales are observed <100 m from a vessel, Vessel Masters will power down to ‘no wake speed’ and alter course away from the whales if safe to do so.

Bulk water

based muds

and drilling

muds coated

cutting

discharge.

Selection of drilling fluids with the lowest environmental footprint that meets technical requirements.

Top section drilled with seawater/ cleaning sweeps;

Mid sections drilled with water based muds; and

Low toxicity Synthetic Based Mud only used to drill bottom sections, where water based mud does not meet technical requirements.

This mud has demonstrated acceptable toxicity, biodegradation and bioaccumulation rates.

No bulk synthetic based mud discharged to ocean at any time throughout the duration of the activity.

Cuttings treated for mud recovery and reuse.

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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Hazard /

Event

Safeguards – Mitigation Methods (control and recovery measures)

Discharge of

deck drainage

sewage, food

scraps and

grey water

from drilling

rig and

vessels.

Deck spills cleaned up using adsorbents (spill kits) and/ or diverted to slops tanks.

Potentially contaminated water drained to slops tanks and passed through the oil/ water separator prior to discharge at <15 ppm or stored for

onshore disposal (MARPOL 73/78 Annex I – Regulation for the Prevention of Pollution by Oil from Ships under the Commonwealth Protection of

the Sea (Prevention of Pollution from Ships) Act 1983).

Food wastes, grey water, sewage treated in accordance with MARPOL 73/78 Annex V – Regulation for the Prevention of Pollution by Garbage

from Ships under the Commonwealth Protection of the Sea (Prevention of Pollution from Ships) Act 1983), including maceration to <25 mm

prior to discharge beyond 3 Nm from land, else >12 Nm from land.

Sewage treated in accordance with MARPOL 73/78 Annex IV – Regulation for the Prevention of Pollution by Sewage from Ships under the

Commonwealth Protection of the Sea (Prevention of Pollution from Ships) Act 1983):

The Palta-1 location is in open ocean, away from coastal environments and fauna migration routes (~50 km).

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Unplanned Events

Vessel

collision with

marine life.

Support vessels during transit will adhere to intent of the Australian National Guidelines for Whale and Dolphin Watching 2005:

Vessel Masters shall maintain a watch for whales during transit;

Vessel Masters shall not knowingly approach within 300 m of whales;

If whales are observed within 300-100 m of a vessel during transit, Vessel Masters will alter course away from the whales if safe to do so;

If whales are observed <100 m from a vessel, Vessel Masters will power down to ‘no wake speed’ and alter course away from the whales if safe to do so.

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Shell Development (Australia) Pty Ltd Summary

Palta-1 Exploration Well WA-384-P Environment Plan 17/08/2012

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Hazard /

Event

Safeguards – Mitigation Methods (control and recovery measures)

Sourcing of

drilling rig and

support

vessels with

overseas last

port of call

that may be

carrying non-

native marine

species.

The drilling rig will be dry towed from Brazil and cleaned of biofouling in South Africa prior to arrival in Australia, with an out of water journey

time ~40 days in total.

Vessels sourced with an overseas last port of call will have had an anti-foul treatment within 12 months or their hulls inspected and will be

cleaned prior to arrival in Australia.

Vessels and drilling rig will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine Park at any time during normal operations.

The Palta-1 location is much further than 12 Nm from land and much deeper than 200 m water depth. Rig and vessels carry little (if any) ballast water and may either 1) not need to discharge ballast in Australian Water or 2) will undertake exchange of high risk ballast outside Australia’s territorial sea prior to arrival, satisfying Australian Ballast Water Management Requirements.

Discharge of

wastes or

chemicals

into the

ocean.

Waste Management Plans developed to MARPOL 73/78 Annex V – Regulation for the Prevention of Pollution by Garbage from Ships and

Annex II– Regulation for the Prevention of Pollution by Noxious Liquid Substances in Bulk from Ships and Annex III– Regulation for the

Prevention of Pollution by Harmful Substances Carried by Sea from Ships under the Commonwealth Protection of the Sea (Prevention of

Pollution from Ships) Act 1983), and local requirements including:

a list of all hazardous substances planned to be used including material safety data sheets, storage requirements, details of provider, Australian regulatory requirements for disposal and procedures for managing accidental discharges/ spills;

requirement that all wastes be tracked and logged, sent to shore for recycling or disposal in government approved waste disposal site;

drilling rig has dedicated storage area for containers and tanks that contain segregated waste.

Proper bunding and drainage plugged to ensure that any surface spillage will be contained onboard the rig.

Vessels and drilling rig will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the

Ningaloo Marine Park at any time during normal operations.

Diesel or aviation fuel spill during drilling rig refuelling at sea.

At sea refuelling will occur only at the well location and with strict adherence to drilling rig and vessel refuelling procedures including:

Reinforced hoses with dry break couplings and fail-safe fittings;

Operation to commence in daylight only;

Favourable wind and sea conditions as determined by the Master of the vessels; and

Refuelling constantly observed by crew member in radio contact with Vessel Masters.

Shipboard Oil Pollution Emergency Plans.

Regulator accepted Oil Spill Contingency Plan in place before commencement of activity. Note that Oil Spill Modelling Assessment for all

seasons indicates surface spilt diesel travels away from Ningaloo Reef and WA coastline with no probability of shoreline contact.

Shell Development (Australia) Pty Ltd Summary

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Hazard /

Event

Safeguards – Mitigation Methods (control and recovery measures)

Spill resulting from a collision.

A ‘Notice to Mariners’ advising of the presence of the drilling rig will be issued through Australian Maritime Safety Authority prior to the

commencement of the activity. Ongoing communication with Australian Fisheries Management Authority and other commercial mariners such

that that presence of drilling rig and vessels widely communicated.

A safety zone of 500 m radius around the drilling unit will be maintained at the well site. The drilling rig will be located in open waters with no

navigation constraints and will be well lit at night and during times of poor visibility.

Vessels and drilling rig equipped with sophisticated navigation aids, navigational lighting and competent crew maintaining 24 hour visual, radio

and radar watch for other vessels.

Vessels will not enter the Ningaloo Coast World Heritage Area or within a 10 km buffer zone from the outer boundary of the Ningaloo Marine

Park at any time during normal operations.

Shipboard Oil Pollution Emergency Plans.

Regulator accepted Oil Spill Contingency Plan in place before commencement of activity. Note that Oil Spill Modelling Assessment for all

seasons indicates surface spilt diesel travels away from Ningaloo Reef and WA coastline with no probability of shoreline contact.

Loss of well

control/ well

blow out.

Regulator accepted Well Operations Management Plan and drilling program meeting Shell’s minimum requirements.

Prevention barriers:

Rigorous training;

Global Standards for Well Design Integrity;

Risk Identification and Mitigation through Safety Cases;

Robust Barriers to prevent against Blowout Prevention (with double redundancy shutoff capability); and

24/7 real-time monitoring.

Regulator accepted Oil Spill Contingency Plan, in place before commencement of activity, linking to the Palta-1 blow out contingency plan that

includes the development of a Palta-1 specific capping and containment program. This involves a globally deployable capping and containment

system; sufficient casing strings available in country to be able to drill a relief well; selected suitable location for a relief well; a relief well design;

potential relief well drilling units suitable for the conditions identified; and contracts are in place with global Emergency Well Control companies.