Referral of proposed actionawsassets.wwfnz.panda.org/downloads/palta_1_1.pdfPalta-1 exploration well Page 5 Palta-1 is a true exploration well. Despite the proximity of the Palta prospect

Palta-1 exploration well Page 1

Referral of proposed action

Project title: Palta-1 exploration well, WA-384-P

1 Summary of proposed action 1.1 Short description

Shell Development (Australia) Pty Ltd (SDA) proposes to drill the Palta-1 exploration well in Petroleum Permit Area WA-384-P, located in the Southern Exmouth Basin, Western Australia (Figure 1). Palta-1 is located in Commonwealth marine waters approximately 50 km west of the boundary of the Ningaloo Marine Park, in 1350 m water depth. Drilling is scheduled to occur in September 2011 at the earliest but timing is dependent on rig availability and the well could be drilled any time through to Q3 2012. The well is planned to take approximately 60 days to complete.

1.2 Latitude and longitude

Latitude: 22° 03’ 49.734” S

Longitude: 113° 11’ 40.1424” E

1.3 Locality and property description

The proposed Palta-1 well is located in Commonwealth waters in the Southern Exmouth Basin within Permit Area WA-384-P. Water depth at the drilling location is 1350 m. The proposed well is 50 km west of the boundary of the Ningaloo Marine Park, Western Australia. The location of the well is shown in Figure 1. The precise location of the well may move marginally following interpretation of the recently collected Salsa 3D site survey. However, the maximum extent of any movement in an easterly direction (ie towards Ningaloo Marine Park) is 2 km. Movements in other directions (ie further away from Ningaloo Marine Park) of up to 7 km are also possible.

1.4 Size of the development footprint or work area

(hectares)

The Palta-1 well site will temporarily occupy an area encompassing the drill hole location and the footprint of the Mobile Offshore Drilling Unit (MODU). MODUs are typically moored using 8 anchors, with each anchor disturbing about 25 m2 of seabed during the drilling campaign (200 m2 in total). Notionally, for the Palta-1 well, the anchors will be spread out in an even radial pattern extending about 3500 m from the rig. Therefore, the maximum size of the development area is about 3850 ha, which will be occupied for approximately 60 days. If a Dynamically Positioned (DP) MODU is used, this area is reduced to the size of the rig (~80 x 80 m).

1.5 Street address of the site

Not applicable

1.6 Lot description

The proposed Palta-1 exploration well will take place in Commonwealth marine waters of the Southern Exmouth Basin within Permit Area WA-384-P.

1.7 Local Government Area and Council contact (if known)

Not applicable – the proposed Palta-1 exploration well will be in offshore Commonwealth waters.

1.8 Time frame

The proposed Palta-1 exploration well will take approximately 60 days to complete, including contingency time, and is proposed to be conducted at the earliest in September 2011. The actual dates are dependent on rig availability and regulatory approval, with Shell having a permit commitment for a well in WA-384-P between 21 August 2011 and 20 August 2012.


1.9 Alternatives to proposed action

X No.

SDA as the operator of Exploration Permit WA-384-P is undertaking

its nominated commitments on this Exploration Permit

Yes, you must also complete section 2.2

1.10 Alternative time frames etc

X No

SDA as the operator of Exploration Permit WA-384-P is required to

undertake the activity during 2011, depending on rig availability and regulatory approval.

Yes, you must also complete Section 2.3. For each alternative,

location, time frame, or activity identified, you must also complete details in Sections 1.2-1.9, 2.4-2.7 and 3.3 (where relevant).

1.11 State assessment

X No.

Proposal is located wholly in Commonwealth waters

Yes, you must also complete Section 2.5

1.12 Component of larger action

No

X Yes, you must also complete Section 2.7

1.13 Related actions/proposals

No

X Yes, provide details: Salsa 3D Marine Seismic Survey (EPBC 2010/5629) and Guacamole 2D Marine Seismic Survey (EPBC

2008/4381).

1.14 Australian Government

funding

X No

Yes, provide details:

1.15 Great Barrier Reef Marine Park

X No

Yes, you must also complete Section 3.1 (h), 3.2 (e)


Figure 1 Location of Palta-1 well


2 Detailed description of proposed action

2.1 Description of proposed action

Shell Development (Australia) Pty Ltd (SDA) proposes to drill the Palta-1 exploration well in Petroleum Permit Area WA-384-P located in the Southern Exmouth Basin, Western Australia (Figure 1). Drilling is scheduled to start in September 2010 at the earliest but timing is dependent on rig availability and obtaining all required approvals. The Drill Rig Due to the water depth at the Palta-1 location a semi-submersible MODU is required to perform the activity. A semi-submersible MODU is supported by large pontoon-like structures that are ballasted during drilling operations, drawing the rig’s pontoon’s below the sea surface to provide the required stability. The operating deck is elevated some 30-40m above the pontoons on large steel columns well clear of the ocean. The MODU most likely will be moored; typically by eight (8) anchors, two from each corner of the main deck. Alternatively, a Dynamically Positioned MODU may be used; its position maintained by the use of thrusters. SDA is currently looking at the technical suitability and availability of MODU’s to drill the Palta-1 well but is yet to contract a specific rig. Mobilisation As the MODU is yet to be contracted the point of mobilization is currently unknown. However, as the rig evaluation process is focused on MODUs in the Australasian geographical area, the mobilisation point will likely either be from a nearby location in Australia or from Singapore. Any rigs mobilised from outside Australian waters will obtain all the necessary AQIS inspections and clearances prior to arrival in Australia. The MODU would be towed to the Palta-1 well location using a Anchor Handling and Support Vessel (AHSV) with the MODU move procedure developed and implemented by the drilling contractor. The current planned well location (see Section 1.2 and Table 1) has been selected using the existing Guacamole 2D seismic data but this location may move marginally, dependent on the results of the final processing of the Salsa 3D seismic data captured during Dec 2010 – February 2011. Support

Once on location the rig will be supported by up to three vessels. The support vessels will be a combination of AHSVs and Platform Support Vessels (PSV). If a moored MODU is contracted then AHSVs will be used to deploy and accurately position the MODU’s anchors. The support vessels will then be used by the MODU to conduct safety lookouts for helicopter transfers and monitor the exclusion zone that will be maintained around the MODU. The vessels will also supply the MODU with fresh water, food, fuel, cement and drilling fluid materials (including fluids and bulk products) and drilling equipment. One of the vessels will remain on location with the MODU at all times. Personnel will access the MODU via helicopter from Learmonth and due to the short flying distance involved, it is anticipated that helicopter refuelling on the rig will not be required. As with previous activities undertaken by Shell in the region, vessels associated with the Palta-1 well will not enter or transit through the Ningaloo Marine Park during normal operations.

Drilling Method Drilling will take place 24hrs a day and is planned to take about 60 days; however, this is ultimately dependent on operational efficiencies and weather conditions. The well is planned as a vertical well to a total maximum depth of 5650m (4325 m below the seabed plus 1350m water depth). The drilling procedure for the well will follow Shell’s updated Well Design and Engineering Manual (DEM1) and will be managed in accordance with the Shell Health, Safety, Security and Environment Management System (HSSE MS). Shell’s approach to managing well safety has been reviewed and strengthened post the Montara and Macondo spills, with the DEM1 manual and HSSE MS both updated (see Section 4).


Palta-1 is a true exploration well. Despite the proximity of the Palta prospect to the developments off the North West Cape, Palta is a gas prospect. The Palta prospect lies deeper in the stratigraphy than the oil fields closer to North West Cape and this stratigraphic depth indicates that heavy oils are not likely. According, the drilling plan is very conservative and has been designed to address the geological uncertainties of the Palta location. In addition, the Salsa 3D site survey, which was only completed in February and is currently undergoing analysis with the latest high definition technology, was undertaken specifically to increase the understanding of the geological uncertainties and mitigate risks of the well location. The final well location may move marginally from the nominated location if the Salsa 3D seismic data uncovers shallow drilling hazards at the nominated location. The plan for the well will be to drill a 1067mm (42 inch) hole riser-less to approximately 1,445m true vertical depth below the rotary table (TVDRT) using a 914mm (36 inch) drill bit and 1067mm (42 inch) hole opener and then install and cement a 914mm (36 inch) conductor casing. After drilling out the 914mm (36 inch) conductor shoe a 610mm (24 inch) hole will then be drilled riser-less to a depth of ~2700m TVDRT. As the 1067mm (42 inch) and 610mm (24 inch) hole sections will be drilled riser-less, the drill cuttings and mud will be deposited directly on the seabed. It is anticipated that both sections will be drilled with seawater (70%) and high viscosity gel sweeps (30%). A 508mm (20 inch) surface casing string will then be installed and cemented into position. The Blowout Prevention (BOP) stack will then be installed, along with a diverter system, and function and pressure tested. The BOP configuration will comply to Shell’s updated Well Control Manual (EP2002_1500) as detailed in Section 4. Drilling will then continue with a 432mm (17 inch) bit and 508mm (20 inch) under-reamer assembly to ~3000m TVDRT using a KCl/polymer/glycol/PHPA water-based mud (WBM) system. The WBM will consist of between 92-98% water, with the remaining 2-8% made up of drilling fluid additives. Drilling additives typically used include sodium chloride, potassium chloride, bentonite, barite, calcium carbonate and polymers. Drill cuttings will be separated from the WBM and discharged from the MODU to the ocean. A 406mm (16 inch) liner will then be run and cemented in place. This 406mm (16 inch) liner has been included in the well design to mitigate against the risk of losses in weak formations below the 508mm (20 inch) shoe. However, if no operational problems are encountered, this 406mm (16 inch) liner could be omitted from the actual well construction. Next a 375mm (14 ¾” inch) bit with a 406mm (16 inch) under-reamer assembly will be used to drill out of the 406mm (16 inch) casing shoe to ~3700m TVDRT. A 340mm (13 3/8 inch) intermediate casing string will then be run and cemented in place. A 311mm (12 ¼” inch) bit will be used to drill to a depth of ~4800m TVDRT. During this section a synthetic-based mud (SBM) will be used (see below for details). A 251mm (9 7/8 inch) production casing will be run and cemented. The well will then be drilled using SBM to its final total depth (TD) of between 5325 and 5675 m TVDRT using a 216mm (8 ½ inch) bit. A 178mm (7 inch) liner will be held as a contingency in case operational drilling difficulties are encountered in drilling this final section. Should this have to be run and cemented the well will reach its TD using a 152mm (6 inch) hole section. All drilling fluid design is as per Shell’s Drilling Fluid Manual (EP88_2837). It is likely that due to the potentially high temperatures anticipated in the lower sections of the Palta-1 well (up to 175°C at TD) that the SBM base oil will be required. The SBM is likely to be Shell’s Saraline 185V which has previously been assessed on its toxicity and biodegradation performance and approved for use by the WA Department of Mines and Petroleum (DMP). The decision to use a SBM system in the deeper hole sections is from a well control perspective:

• The 311mm (12 ¼ inch) and 216mm (8 ½ inch) hole sections have potentially long claystone intervals which could be subject to deterioration with WBM in use, resulting in an increase risk of hole complications. The highly inhibitive properties of SBM provide a better quality and


more stable hole, leading to fewer drilling and hole condition problems. Problems encountered with WBM over the claystone sections include increased risk of swabbing reservoir fluid into the hole when tripping, problems getting casing to bottom or getting stuck with casing and difficulty or inability to complete logging program including getting stuck.

• The formations encountered in the 216mm (8 1/2 inch) hole section potentially have a high temperature of 175°C. Drilling through such formations requires a special formulation of fluid, which is more easily achievable and stable when using SBM rather than WBM, maintaining better control over the wellbore.

• Gas hydrates are a key concern when drilling in deep water environments (high pressure and low temperature). Gas hydrates are an ice-like material that can form when kick gas mixes with water-based drilling fluids at high pressure and low temperature and affect the performance of the BOP. Hydrate formation is generally avoided when using SBM.

• Using SBM in the 311mm (12 ¼ inch) and 216mm (8 ½ inch) hole sections will lead to improved operational efficiency including faster rates of penetration, fewer hole problems, reduced tripping times and frequency.

Drill cuttings from the 311mm (12 1/4 inch) and 216mm (8 ½ inch) hole sections drilled using SBM will be processed via a cutting dryer (to reduce the discharge of SBM on cuttings to below the regulator’s 10% limit) prior to discharging the cuttings into the ocean. SBM generates larger and firmer drill cuttings than those produced by WBM. These are easier to remove from the drilling fluid, lead to a lower total discharge volume due to the larger particle size and reduced footprint on the seabed. Bulk SBM will not be discharged to the environment, it will be returned onshore for reprocessing/recycling. Formation evaluation using both electric wireline logging and logging while drilling (LWD) technology will be conducted after a number of the hole sections have been drilled. This could include vertical seismic profiling (VSP) and/or Seismic While Drilling (SWD) LWD technology. SWD or VSP would be undertaken in accordance with procedures that incorporate the requirements of the ‘EPBC Act Policy Statement 2.1 – Interaction between offshore seismic exploration and ceteaceans’ (DEWHA, 2008a). Both options are very similar in that they use an identical stationary sound source (4 x 150 cubic inch source operated at 2000psi). Modelling of a larger 4 x 250 cubic inch source indicates maximum broadband sound source levels of 195 db re 1 mP/Hz at 1m from a stationary source. Sources used for seismic surveys are significantly larger with capacities often in the 3000 to 4000 cubic inch which produce maximum broadband sound source levels of 200-250 db re 1 mP/Hz at 1m as it is towed. SWD involves firing the acoustic source around five times every 3 hours over an eight day period. VSP involves firing the acoustic source more continuously over an eight to 10 hour period. There will be no production testing (i.e. no flaring). At completion of the drilling program, the well will be plugged and abandoned in line with the Shell Well Abandonment Manual and Guideline (EP2010_1305). Table 1 summarises the activities and details of the Palta-1 Drilling Campaign.

Table 1: Palta-1 Drilling Campaign Summary

Permit area WA-384-P

Basin South Exmouth

Surface location Longitude: 113 deg 11’ 40.1424” E Latitude: 22 deg 03’ 49.734” S

Type of Well Exploration

Water Depth 1350m

Scheduled Commencement Date Q3 2011 – Q3 2012

Campaign period Approximately 60 days

Drill Rig/Support Vessels MODU/ up to 3 support vessels

Proposed Total Depth (TVDRT) 5325m TVDRT (maximum 5675mTVDRT)

1067mm (42 inch) Seawater and Hi-Vis Gel


Drilling Fluids

610mm (24 inch) Seawater and Hi-Vis Gel

432mm (17 inch) x 508mm (20 inch)

KCl/polymer/glycol/PHPA WBM

375mm (14 ¾” inch) x 406mm (16 inch)

KCl/polymer/glycol/PHPA WBM

311mm (12 ¼ inch) Synthetic Based Mud (SBM)

216mm (8 ½ inch) Synthetic Based Mud (SBM)

Volume of cuttings (estimate only)

1067mm (42 inch) 63 m3

610mm (24 inch) 366 m3

432mm (17 inch) x 508mm (20 inch)

61 m3

375mm (14 ¾” inch) x 406mm (16 inch)

90 m3

311mm (12 ¼ inch) 84 m3

216mm (8 ½ inch) 32 m3

Total 696 m3

Production Testing No

Seismic Activity Potentially – VSP and/or Seismic while drilling

2.2 Alternatives to taking the proposed action

Not applicable. SDA is the operator of Exploration Permit WA-384-P and the activity relates to our commitments on the Permit granted under the Offshore Petroleum and Greenhouse Gas Storage Act 2006 (OPGGS Act).

2.3 Alternative locations, time frames or activities that form part of the referred action

Not applicable. SDA is the operator of Exploration Permit WA-384-P and the activity relates to our commitments on the Permit granted under the Offshore Petroleum and Greenhouse Gas Storage Act 2006 (OPGGS Act).

2.4 Context, planning framework and state/local government requirements

SDA as the operator of Exploration Permit WA-384-P is seeking to undertake its nominated commitments on the Permit, which includes the drilling of an exploration well. The objective of the proposed Palta-1 well is to determine the presence or absence of potential gas deposits. All activities conducted during the proposed survey will comply with current legislative requirements. In addition to the EPBC Act, the major relevant Commonwealth statutes and regulations are: • Offshore Petroleum and Greenhouse Gas Storage (OPGGS) Act;

• OPGGS (Environment) Regulations 2009; and • Petroleum (Submerged Lands)Act Schedule – Specific Requirement as to Offshore Petroleum

Exploration and Production 1995. The OPGGS (Environment) Regulations 2009 requires that a detailed Environment Plan (EP) be prepared and approved by the Designated Authority (DA), in this case the WA Department of Mines and Petroleum (DMP), before commencing the proposed drilling program. These regulations also require approval of an oil spill contingency plan (OSCP) which includes emergency response procedures. Vessel and sea-going operations during the survey will adhere to all relevant Australian and International statutes, regulations and agreements, which include the requirement for a Shipboard Marine Pollution Emergency Plans (SOPEP).


2.5 Environmental impact assessments under Commonwealth, state or territory legislation

SDA is preparing an EP and OSCP for the proposed Palta-1 exploration well which will be submitted to WA DMP for approval in accordance with the OPGGS (E) Regulations. The EP describes and assesses all aspects and potential impacts of the activities in a risk-based context. It also includes detailed environmental management measures, environmental performance objectives, roles and responsibilities and reporting requirements. A summary of the EP will be publicly available following acceptance by the DMP. The OSCP also details the emergency response procedures to be implemented in the unlikely case of a spill.

2.6 Public consultation (including with Indigenous stakeholders)

Shell identified key stakeholders and undertook extensive consultation for the Guacamole 2D and Salsa 3D Marine Seismic Surveys. Shell will continue its consultation with stakeholders listed below and has commenced Palta specific consultations or will have done so before commencement of the Palta-1 exploration well.

• Department of Sustainability, Environment, Water, Population and Communities (DSEWPaC)

• WA Department of Mines and Petroleum (DMP);

• Department of Resources, Energy and Tourism;

• Australian Fisheries Management Authority (AFMA);

• WA Department of Fisheries;

• WA Department of Environment and Conservation;

• Shire of Exmouth;

• WA Fishing Industry Council;

• Conservation Council of WA;

• World Wildlife Fund;

• Cape Conservation Group;

• The Wilderness Society;

• Marine Conservation Society;

• Centre for Whale Research (C Jenner);

• Australian Conservation Foundation; and

• Adjoining permit holders

• AMOSC

2.7 A staged development or component of a larger project

SDA as the operator of Exploration Permit WA-384-P is required to undertake its nominated commitments on the Permit, which includes the acquisition of seismic data and the drilling of an exploration well. In 2008, Shell undertook the Guacamole 2D Marine Seismic Survey across the broader region (EPBC 2008/4381). In 2010/11 Shell undertook the Salsa 3D Marine Seismic Survey over the Palta prospect area (EPBC 2010/5629). Both Guacamole and Salsa were completed without reportable or recordable incidents. The proposed Palta-1 exploration well is required to determine the presence or absence of potential hydrocarbons deposits. Currently there are no plans for any other exploration wells in WA-384-P. If Palta-1 encounters gas, it is likely that appraisal drilling would be required in the future to determine the commercial viability of the discovery. If this were to occur, future drilling activities would be the subject of a separate EPBC referral and approval.


3 Description of environment & likely impacts

3.1 Matters of national environmental significance

3.1 (a) World Heritage Properties

Description

There are no World Heritage Properties within the WA-384-P permit area. The Federal Environment Minister announced on 6 January 2010 that the Ningaloo Marine Park would be nominated for World Heritage listing. The nomination is in support of the Ningaloo Marine Park having a diverse range of marine species and unique geomorphic features (DEWHA 2010a). The proposed well location is 50 km to the west of the Ningaloo Marine Park (Figure 1).

Nature and extent of likely impact

Due to the distance between the well location and Ningaloo Marine Park, the nature of the proposed activities (see Section 2) and the management measures to be implemented (see Section 4), no direct or indirect impacts to proposed or current World Heritage properties are likely. Oil spill planning and response is discussed in Section 3.2(c).

3.1 (b) National Heritage Places

Description

There are no National Heritage Places within the WA-384-P permit area. The Ningaloo Coast (including Ningaloo Marine Park and Cape Range National Park) was recently (6 January 2010) included on the National Heritage List. The Ningaloo Marine Park and the Cape Range National Park are located approximately 50 km and 70 km (respectively) east of the proposed well location at their closest.


Due to the distance between the well location and the Ningaloo Coast, the nature of the proposed activities (see Section 2) and the management measures to be implemented (see Section 4), no direct or indirect impacts to National Heritage Places are likely. Oil spill planning and response is discussed in Section 3.2(c).

3.1 (c) Wetlands of International Importance (declared Ramsar wetlands)

Description

There are no Ramsar wetlands within the WA-384-P permit area. The closest Ramsar wetland, Eighty Mile Beach, is located more than 600 km away.


Due to the distance between the well location and Eighty Mile Beach, the nature of the proposed activities (see Section 2) and the management measures to be implemented (see Section 4), no direct or indirect impacts to Wetlands of International Importance are likely.


3.1 (d) Listed threatened species and ecological communities

Description

There are no listed Threatened Ecological Communities which occur in the marine environment. There are ten listed threatened species that may occur within the vicinity of the Palta-1 location (Table 2) which are discussed below. Some or all of these species may, on occasion, transit through the area; however, the proposed well location is unlikely to represent important habitat for any of these species. Shell has collected seismic data that indicates the Palta well location comprises a relatively flat, soft muddy bottom with no areas of hard substrate. There are no known nesting, breeding or aggregation areas for these listed threatened species in the vicinity of the proposed well. Shell has undertaken 90 days of summer time operations in and around WA-384-P (details below) during which time only one whale sighting was recorded. Table 2: Threatened Species and Communities that may transit through the WA-384-P permit area

Scientific name Common name Status

Birds Macronectes giganteus Southern giant petrel Endangered

Pterodroma mollis Soft-plumaged petrel Vulnerable

Mammals – Cetaceans Balaenoptera musculus Blue whale Endangered

Eubalaena australis Southern right whale Endangered

Megaptera novaeangliae Humpback whale Vulnerable

Reptiles Caretta caretta Loggerhead turtle Endangered

Chelonia mydas Green turtle Vulnerable

Dermochelys coriacea Leatherback turtle, Leathery turtle,

Luth

Endangered

Natator depressus Flatback turtle Vulnerable

Eretmochelys imbricate Hawksbill turtle Vulnerable

Birds

Two threatened marine birds species, the endangered southern giant petrel (Macronectes giganteus) and the vulnerable soft plumaged petrel (Pterodroma mollis), may pass through the region in transit to resting and feeding areas (CALM 1989; DEWHA 2010c). Other foraging groups of seabirds could also pass through the permit area, although seabirds in the north-east Indian Ocean are typically aggregated in areas adjacent to islands. The southern giant petrel breeds annually during the summer months on a number of islands in the subantarctic to Antarctic. The estimated population size is approximately 56,000 breeding pairs. During the winter months the southern giant petrel disperses widely in a circumpolar pattern extending north from 50°S to the Tropic of Capricorn and sometimes beyond. During the summer months southern giant petrels constantly forage in coastal and oceanic areas. At sea, foraging involves surface feeding on fish and cephalopods (DEWHA 2010c). Given the global dispersion, numbers of southern giant petrel at any given location are likely to be low. The soft-plumaged petrel is a marine, oceanic species generally found over temperate and sub Antarctic waters in the South Atlantic, southern Indian and western South Pacific Oceans. The birds breed on a number of islands in the subantarctic during summer months, burrowing nests among tussock grass and ferns on slopes and in valleys. The species is a regular and quite common visitor to southern Australian seas (Woodside Energy Limited 2010). The soft-plumaged petrel is often seen in small parties flying fast near the surface of the water, with its diet consisting mostly of molluscs, some fish and crustaceans taken by surface-seizing. There are no islands or other areas of seabird breeding significance, or important feeding grounds for seabirds, known in close proximity of the proposed Palta-1 well location. Given the global dispersion of both species and lack of critical habitat, numbers at any given location are likely to be low.


Mammals – Cetaceans

A wide range of cetaceans occurs in the Northwest Marine Region, and all are protected under Commonwealth legislation. Three of these species of cetaceans are listed as threatened under the EPBC Act: • Blue whale (Balaenoptera musculus) – Endangered; • Southern right whale (Eubalaena australis) – Endangered, and • Humpback whale (Megaptera novaeangliae) – Vulnerable. Southern right whales feed in the southern and subantarctic oceans, close to Antarctica, during the summer months and migrate north in winter for breeding. They are found in Australian waters for seven months of the year (approximately May to November). Main aggregations and calving/feeding areas are located in south western WA, Southern Australia, Victoria and around Tasmania (DEH 2005), well south of the Palta-1 location. However, individuals have occasionally been recorded in warmer temperate waters as far north as North West Cape off Western Australia, although sightings at these more northern locations are relatively rare (Shell 2008). Blue whales are widely distributed throughout the world’s oceans and have been recorded in waters off all Australian states excluding the Northern Territory. Blue whales are rarely present in large numbers outside recognised aggregation areas and are believed to calve in tropical waters in winter, with births peaking in May to June; however, the exact locations of this species’ breeding grounds are unknown (Bannister et al. 1996). There are two recognised subspecies of blue whale in Australia, the 'true' blue whale (Balaenoptera musculus intermedia) and the ‘pygmy' blue whale (Balaenoptera musculus brevicauda). During summer through to autumn, true blue whales feed mainly in the Antarctic, mostly on krill (Jenner et al. 2001). Pygmy blue whales are not generally found in the Antarctic and are thought to feed in productive regions in temperate latitudes. The Perth Canyon (32°S), 1000 km south of the Palta -1 well location, is the only known aggregation area off the coast of Australia for ‘pygmy' blue whales. No specific migration routes have been identified in the Australasian region for this species; however, it has been proposed that a pygmy blue whale migration route exists from the Perth Canyon along the west coast (Jenner, pers. comm.) and the Northwest Shelf (Woodside Energy Limited 2010) up towards Indonesia. Jenner (pers. comm.) suggested that the migratory path for pygmy blue whales can be expected to cover the 500 m to 1500 m depth range off North West Cape, including the proposed Palta-1 well location in 1350 m water depth. It is proposed that the peak migratory period for pygmy blue whales in this area occurs during the months of October to January. Shell undertook the Guacamole survey between November 21st 2008 and January 6th 2009, and the Salsa survey between December 23rd 2010 and February 5th 2011. Over about 90 days of operations in and around WA-384-P, only one whale sighting was recorded (08:33 hrs 23rd January 2011, position 22°09.85'S 113°21.9'E). which was of an unidentified whale mother and calf pair, supporting the notion that pygmy blue whales are rarely present in large numbers outside recognised aggregation areas. Humpback whales also have a wide distribution and have been recorded from the coastal areas off all Australian states and the Northern Territory (Bannister et al. 1996). Humpback whales migrate north to and south from calving grounds in the tropical north to feeding grounds in the Southern Ocean (DEH 2006a). The west coast population calves in the inshore waters of northern WA, between the Lacepede Islands and Camden Sound (Jenner et al., 2001; DEWHA, 2010c). During the southern migration cow/calf pairs are also known to aggregate in resting areas that include Exmouth Gulf and Shark Bay (Chittleborough, 1953). The west coast humpback whale population migrates north along the coast generally within the 500 m bathymetry, with numbers peaking in the vicinity of North West Cape in late July to early August


(Jenner et al. 2001). Humpback whale pods have been observed to show a stronger preference for shallower water during the peak southern migration, with the majority remaining inshore of the 200m depth contour. The southern migration past North West Cape occurs from September to October (Jenner et al. 2001). The proposed Palta-1 well is located in 1350 m water depth, well west (50 km) of both the northern and southern Humpback Whale migration routes (see Figure 2). Reptiles - Turtles

Up to five species of marine turtle species may occur in the WA-384-P permit area, all of which are listed as threatened and migratory species under the EPBC Act:

• Loggerhead turtle (Caretta caretta) – Endangered; • Green turtle (Chelonia mydas) – Vulnerable; • Leatherback turtle (Dermochelys coriacea) – Endangered • Flatback turtle (Natator depressus) – Vulnerable; and • Hawksbill turtle (Eretmochelys imbricate) – Vulnerable.

The loggerhead turtle has a global distribution throughout tropical, sub-tropical and temperate waters. Nesting is mainly concentrated on subtropical beaches (Marquez 1990). The closest known breeding/nesting grounds to the proposed survey area are on the Muiron Islands (Prince 1993; 1994), which are located approximately 102 km to the north-east (Figure 2). Seven separate breeding stocks of green turtle occur throughout Australian waters, with WA containing the breeding populations of the North West Shelf and Ashmore Reef (Limpus 2004). Green turtles are primarily herbivorous and their diet is comprised predominantly of seagrass and algae, indicating that they feed mostly in nearshore environments (Shell 2008) and are unlikely to be found around the Palta-1 location. The green turtle migrates from feeding grounds throughout northern Australia and Indonesia to nesting grounds along the North West Shelf and its associated islands. Turtle nesting occurs during summer, with the nearest nesting sites to the proposed survey area located along the mainland beaches of the Ningaloo coast and northward of Point Cloates (DEC 2008). All known breeding sites along North West Cape and associated islands are located at least 90 km north-east of the Palta (Figure 2). The leatherback turtle is a pelagic feeder and has the widest distribution of any marine turtle (Cogger et al. 1993). Leatherback turtles can be found in tropical, subtropical and temperate waters throughout the world (Marquez 1990). Nesting is mainly confined to tropical beaches although some nesting occurs on subtropical beaches (Marquez 1990). No major nesting grounds have been recorded in Australia, although scattered isolated nesting (1-3 nests per annum) occurs in southern Queensland (Limpus & McLachlan 1994). Although listed as potentially occurring within the area of the proposed well, the leatherback turtle is considered unlikely to be located within the area due to small population numbers and the lack of confirmed breeding areas in WA (Limpus 2004). The flatback turtle is found only in the tropical waters of northern Australia, Papua New Guinea and Irian Jaya (Woodside Energy Limited 2010). It is one of only two species of sea turtle that only nests in Australia. A major nesting area is located along the North West Shelf including Muiron and Sunday Islands, located more than 100 km north-east of the proposed well. Nesting occurs mainly in December and January. Hawksbill turtles are found in tropical, subtropical and temperate waters in all the oceans of the world. Hawksbill turtles are known to inhabit the open ocean, particularly during their earlier years (DEWHA 2010c) and nesting is mainly confined to tropical beaches (Marquez 1990). The closest major known breeding/nesting grounds to WA-384-P area are located on the Ningaloo Coast, located approximately 80 km to the north-east of Palta and Thevenard, Barrow, Montebello and Lowendal Islands, all located more than 150 km to the north-east (Figure 2) (DEWHA, 2010c). Given the hawksbill turtle’s wide distribution and the distance between known nesting beaches and the proposed well, it is unlikely that


the proposed survey will significantly impact on this species. The WA-384-P permit area does not contain any emergent land or shallow subtidal features. The proposed well is located approximately 70 km west of the shallower coastal waters of the Ningaloo Marine Park (Commonwealth Waters) and approximately 90 km south-west of the nearest known turtle breeding, nesting, or feeding grounds on the North West Cape (Prince 1993) (Figure 2). Given the distance between emergent land and the water depths of more than 1,000m at the proposed well location, it is expected that at most only low numbers of transient marine turtles may occur.


There are no listed Threatened Ecological Communities in the marine environment; therefore no impacts from the proposed Palta-1 well are possible. Although ten threatened species potentially transverse the WA-384-P permit area, the permit area does not contain any recognised feeding, breeding or aggregation areas and therefore is unlikely to support significant numbers of threatened species. Given Palta-1’s distance from the Ningaloo Reef system, distance from known migration paths, deep water, short duration of the drilling program and the management measures to be implemented for all environmental aspects of operations (see Section 4), the proposed well is unlikely to have an impact on any listed threatened species or their habitat as detailed below. Oil spill planning and response is discussed in Section 3.2(c). Marine birds

There are no islands or other areas of seabird breeding significance, or important feeding grounds for seabirds, known in close proximity of the proposed Palta-1 well location. The presence of the rig and vessels could deter birds from foraging in the immediate vicinity; however, any impact will be limited in areal and temporal extent, especially given the amount of similar open ocean habitat in the region. The risk of this significantly impacting individual birds that may be encountered in the WA-384-P permit area is very low. Mammals - Cetaceans

Considerable research has been undertaken into the effects of noise on baleen whales. While much of this research has been focused on seismic surveys, a number of studies and observations have been collected around active drilling rigs. This work indicates that maximum volumes produced by drilling rigs and support vessels is well below thresholds for physiological damage and indicates that any zone of affect which could cause behavioural response in baleen whales is generally limited to less than 5km from the drill rigs in deep water, with smaller zones of affect in shallower water. Behavioural responses included reduced swimming speeds and diversions away from the sound source. The risk of this significantly impacting individual whales that may be encountered is very low. In Victoria’s Otway Basin, Woodside Energy (2003) measured maximum ocean noise of 145 dB re 1µPa from a MODU during drilling, with sounds were below 120 dB greater than 99% of the time. Similarly, Santos (McCauley, 2004), also in the Otway Basin, observed that sound exceed the 120 dB level only 0.04% of the time when drilling their Casio-3 well. They observed that this noise level was limited to

within 4km of the drill rig. Richardson et al. (1995), in a comprehensive review, also reports that 50%

of migrating grey whales avoided MODUs when sounds exceeded 117 dB re 1µPa, which corresponds to a distance of about 3km from a drill rig. The Palta-1 well is located approximately 60 km offshore of the 500 m depth contour. Humpback whales predominately migrate northward inshore of the 500m depth contour and inshore of the 200m depth contour on their southern migration (Jenner et al. 2001). Numerous authors have measured that noise from drilling activities, including support vessels, is not detectable above background noise levels

between 8 and 29 km distance (Richardson et al. 1995 and McCauley, 2004) indicating that the drilling operations conducted at the Palta-1 location will not be detected by the overwhelming majority of migrating Humpback whales located some 60 km away. The small number of whales occurring in


deeper waters, closer to the Palta-1 location, may show behavioural responses if they approach within about 5 km. However, given the open ocean environment with no geomorphic constrictions on whale migration, whales are expected to swim pass the drill rig at a distance they are comfortable. If SWD or VSP is conducted, the short duration, small acoustic source and stationary nature of the activity, in combination with implementation of the EPBC Act Policy Statement 2.1 – Interaction between offshore seismic exploration and ceteaceans’ (DEWHA, 2008a) will ensure that the risk of this activity significantly impacting individual whales is very low. Reptiles - Turtles

The Palta-1 location is in deep water more than 60 km from the shallow waters of Ningaloo Reef and, given the open ocean habitat, is not expected to support significant numbers of turtles. Studies into the affects of seismic surveys on turtles also indicate that sea turtles may begin to show behavioural responses to an approaching seismic array at received sound levels of approximately 166 dB re 1 µPa (rms), and avoidance at around 175 dB re 1 µPa (rms) (Woodside Energy Limited 2010). This is well above the maximum levels generated by drilling operations therefore the risk of causing behavioural responses in turtles is very low.

3.1 (e) Listed migratory species

Description

The EPBC Protected Matters database also lists 14 species covered by the migratory provisions of the EPBC Act that may occur within the WA-384-P permit area (Table 3). Nine of these migratory species have also been identified as threatened species and are discussed above. All of these migratory species may traverse the proposed survey area; however, there are no breeding or nesting areas known in the area. Table 3: Migratory species that may occur within the WA-384-P permit area

Scientific name Common name

Marine Birds Macronectes giganteus* Southern giant-petrel*

Mammals Balaenoptera bonaerensis Antartic minke whale

Balaenoptera edeni Bryde’s whale

Balaenoptera musculus* Blue whale*

Eubalaena australis* Southern right whale*

Megaptera novaeangliae* Humpback whale*

Orcinus orca Killer whale

Physeter macrocephalus Sperm whale

Reptiles Caretta caretta* Loggerhead turtle*

Chelonia mydas* Green turtle*

Dermochelys coriacea* Leatherback turtle

Natator depressus* Flatback turtle*

Eretmochelys imbricate* Hawksbill turtle*

Sharks Isurus oxyrinchus Shortfin mako

Isurus paucus Longfin mako * Already identified as a Threatened Species

Other listed migratory species that were not identified by the DSEWPC protected matters database search within the WA-384-P Permit area but are known to occur in the vicinity of Ningaloo Marine Park include whale sharks (Rhincodon typus), dugongs (Dugong dugon), spotted bottlenose dolphins (Tursiops aduncus) and Indo-pacific humpback dolphins (Sousa chinensis). Marine Birds

Only one marine bird, the southern giant petrel was listed as a migratory species under the EPBC Act which may occur within the Salsa 3D marine seismic survey area. Details regarding its distribution and


ecology are described in Section 3.1 (d). Mammals – Cetaceans

Seven cetacean species are listed as migratory species under the EPBC Act that may occur in WA-384-P. Three of these species, namely the blue whale, humpback whale and southern right whale, were also listed as threatened species and are discussed in Section 3.1 (d). The remaining migratory species which may occur in the proposed survey area are the Antartic minke whale (Balaenoptera bonaerensis), Bryde’s whale (Balaenoptera edeni), Killer whale (Orcinus orca) and the Sperm whale (Physeter macrocephalus). The Antarctic Minke whale is predominately found in southern Australian and Antarctic waters during the summer feeding season as they feed almost exclusively on Antarctic krill (Shell 2008). During winter, the breeding areas are thought to be relatively dispersed in the open ocean areas throughout tropical and sub-tropical latitudes. It is therefore unlikely that occasional Antarctic Minke whales may occur in the region around WA-384-P. The Bryde’s whale is a pelagic species that prefers water temperatures above 20°C. This species is listed as migratory under the EPBC Act though it migrates only short distances in comparison with other cetacean species. This species is most common in coastal areas of tropical and subtropical waters around Australia (Shell 2008) but also occurs in offshore waters. Bryde’s whales that reside inshore (<200 m) appear to breed and calve year round with limited migrations, while those that reside in offshore waters (500-1,000 m) have an extended breeding and calving season over several months during winter (Woodside Energy Limited 2010; DEWHA 2010c) and exhibit some seasonal movement, although details of movement patterns are not well described or understood. Bryde’s whale may occur in proximity to the Palta-1 location but given the offshore waters, abundances are likely to be very low. Killer whales are known to be present in coastal waters all around Australia. This species is wide ranging and appears to migrate according to the distribution of particular prey species. Killer whales may be present in the WA-384-P at any time of year, although they tend to follow the migrations of Humpback whales (their primary prey) as well as other large baleen whales which migrate up and down the coast. Again, Killer whales may occur in the vicinity of the proposed well but given the offshore waters, abundances are likely to be very low. Sperm whales are a pelagic species found off the WA coast, typically between Cape Leeuwin and Esperance. Although these mammals can occur on the continental shelf, they are more commonly encountered close to the shelf edge and more widely dispersed offshore. In the open ocean there is a generalised migration southwards in summer, with a corresponding movement northwards in winter off the WA coastline (Bannister et al. 1996). It is unlikely that sperm whales will occur in large numbers within WA-384-P Permit area (Bannister et al. 1996). The Dugong tends to occur in shallow waters, along the coast and around larger islands in the region and is unlikely to be found in any numbers in the deep waters of the proposed Palta-1 well location. Reptiles - Turtles

A total of five marine turtles, including Loggerhead, Green, Leatherback, Flatback and Hawksbill turtles, were identified as migratory species which may occur in the WA-371-P permit area. These five marine turtle species were also listed as Threatened species and information regarding the distribution and ecology of these species is provided in Section 3.1 (d). Fish - Sharks

The Shortfin Mako shark is a wide-ranging oceanic and pelagic shark preferring waters above 16°C (DEWHA 2010c). The Longfin Mako shark is also widely distributed but rarely encountered oceanic tropical shark, found in Australian waters between Geraldton in Western Australia and Port Stephens in New South Wales (DEWHA 2010c). The whale shark also occurs broadly in tropical waters where the water surface temperature is between 21° and 25°C. A seasonal aggregation of whale sharks occurs in


the waters off the Ningaloo coast each year between late March and July, with the highest frequency of sightings occurring in April. The timing of this aggregation coincides with the high levels of productivity associated with annual coral spawning, resulting in an increased planktonic biomass and a more active food chain in the waters immediately adjacent to the Ningaloo Reef (Shell 2008). The Palta-1 well is located more than 60 km from the margin of Ningaloo Reef where the whale sharks aggregate. All three sharks may potentially travel through the area adjacent to the Palta-1 well; however, WA-384-P does not contain any recognised feeding, breeding or aggregation areas and therefore is unlikely to support significant numbers.


The potential impacts on migratory species, which are also listed threatened species, are detailed in Section 3.1(d). Mammals – Cetaceans

The potential impacts to Antarctic Minke and Bryde’s whales are similar to the potential impacts described for the listed threatened baleen whales in section 3.1 (d). However, the abundance of Antarctic Minke, Bryde’s, Sperm and Killer whales in and around the Palta-1 location is expected to be very low to zero, further reducing the likelihood of any impacts. By comparison to baleen whales, tooth whales, including Sperm and Killer whales, and dolphins are less sensitive to the low frequency noise generated by rigs and support vessels, so they are even less likely to be affected by Plata-1 drilling activities. Wales and dolphins occurring in deeper waters, close to the Palta-1 location, could potentially show behavioural responses, including attraction, if they approach within close proximity to the rig. However, given the open ocean environment with no geomorphic constrictions on movements, cetaceans are simply expected to swim pass the drill rig at a distance they are comfortable.

Fish - Sharks

The Longfin and Shortfin Mako are both highly mobile with a wide-ranging distribution in deep offshore waters and are not likely to be significantly impacted by the drilling activity. Similarly, whale sharks may transverse through the area around the Palta-1 location, especially if drilling occurs when the whale sharks congregate at Ningaloo. However, given Palta-1’s distance from Ningaloo Reef and the area of aggregation, Whale sharks are not likely to be significantly impacted by the drilling activity.

3.1 (f) Commonwealth marine area

Description

Not applicable - the proposed Palta-1 exploration well is located wholly in Commonwealth waters. Refer to Section 3.2 (c) for further information.


Not applicable

3.1 (g) Commonwealth land

Description

Not applicable. There will be no land based activities as part of the proposed Palta-1 exploration well.


Not applicable

3.1 (h) The Great Barrier Reef Marine Park

Description

Not applicable. The proposed Palta-1 exploration well will not be undertaken in the Great Barrier Reef Marine Park.


Not applicable


Figure 2: Environmental sensitivities around North West Cape


3.2 Nuclear actions, actions taken by the Commonwealth (or Commonwealth agency), actions taken in a Commonwealth marine area, actions taken on Commonwealth land, or actions taken in the Great Barrier Reef Marine Park

3.2 (a) Is the proposed action a nuclear action? X No

Yes (provide details below)

If yes, nature & extent of likely impact on the whole environment

3.2 (b) Is the proposed action to be taken by the

Commonwealth or a Commonwealth agency?

X No


If yes, nature & extent of likely impact on the whole environment

3.2 (c)

Is the proposed action to be taken in a Commonwealth marine area?

No

X Yes (provide details below)

The proposed Palta-1 exploration well is located wholly in Commonwealth waters.

If yes, nature & extent of likely impact on the whole environment (in addition to 3.1(h))

The main potential impacts associated with the drilling program and related activities are:

• Effects associated with the physical presence of the rig

• Effects associated with noise generated by the rig and support vessels-see Sections 3.1 (g and h)

• Effects associated with planned discharges (drill cuttings and muds, treated sewage, cooling water etc)

• Effects associated with unplanned discharges (spills of drilling muds, chemicals or hydrocarbons)

Physical presence of the rig

The rig and support vessels will operate 24 hours a day and will require lighting for safety and navigational purposes. Given the temporary nature of the operations, open ocean environment and considerable distance from coastlines, any impact from lighting will be minor.

The likelihood of the introduction of exotic or introduced marine species at the Palta-1is extremely remote for two reasons:

1. Adherence to the required quarantine clearances for rigs and vessels entering Australian waters; and

2. the deep water, open ocean environment location at Palta-1 provides minimal larval retention times or suitable habitat for coastal adapted exotic species.

The rig will temporarily occupy a seabed area encompassing the drill hole location and the footprint of the rig’s anchors if a moored MODU is used. Typically, these MODUs are moored using 8 anchors, with each anchor disturbing about 25 m2 of seabed during the drilling


campaign (200 m2). Notionally, for the Palta-1 well, the anchors wires will be spread out in an even radial pattern extending about 3500 m from the rig. Therefore, the maximum size of the development area if a moored MODU is about 3850 ha which will be occupied for the approximately 60 day drilling program. If a dynamically position MODU is used, then the area is reduced to the drill hole location and vessel. Support vessels will not anchor due to the depth of water. The proposed well location is located in the open ocean, in deep waters in excess of 1000 m. Due to the depths and topography encountered in the area, the seabed at the Palta-1 well location will comprises muddy silts and exclude any significant benthic habitats. The recently collected Salsa 3D seismic data will also be used to ensure that the final well and anchor locations avoid any hard substrates. The soft seabed is likely to support a high diversity but low abundance community of infaunal and epifaunal animals including sea cucumbers, ophiuroids, echinoderms, polychaetes, seapens, nematodes, copepods, molluscs and crustaceans. The likely impacts to the seabed include smothering and disturbance but soft sedimentary communities respond rapidly to disturbance and impacts are expected to be minor and short lived. Specific measures to avoid or reduce environmental effects are summarised in Section 4.

Effects associated with planned discharges

Routine planned discharges from the rig and support vessels include cooling water, treated sewage, grey water, bilge water and galley wastes. Given waste treatment, the temporary nature of the operations, the chemical properties of the discharged materials ,the open ocean environment and significant distance from coastlines, any impact will be minor.

The rig will also discharge drill cuttings and WBM. Bulk SBM will not be discharged to the environment, it will be returned onshore for reprocessing/recycling. Details of volumes and types of mud are provided in Table 1. Drill cuttings from the hole sections drilled using SBM will be processes via a cutting dryer (to reduce the discharge of SBM on cuttings to below the regulator’s 10% limit) prior to discharging the cuttings into the ocean. Only SBM approved by the petroleum regulator will be used on the Palta-1 well. Approval from the regulator is based on acceptable toxicity and biodegradation performance and designed to ensure that there is minimal impact on the environment. The discharge of cuttings and muds will result in localised burial of benthic organisms, alteration of the benthic substrate and increased turbidity in the water column. However, given the deep water, soft sedimentary environment, any impacts will be minor and recovery from exploration drilling has been demonstrated to be rapid . Specific measures to avoid or reduce environmental effects are summarised in Section 4.

Effects associated with unplanned discharges

Unplanned discharges could potentially include spills of drilling fluids, diesel or hydrocarbons from the gas drilling target. Drilling fluids are designed to be discharged to the environment; any impact would be similar to the planned impacts discussed above so an unplanned spill of drilling fluids is not discussed further.

The potential unplanned discharges investigated for the Palta-1 well were:

• An instantaneous 2 m3 diesel spill at the ocean surface resulting from a refuelling incident;

• A 200 m3 diesel spill over 1 hour at the ocean surface caused by a support vessel collision incident that results in the loss of integrity of one or two fuel storage compartmentsA;

• A continuous ~70,000 bbls/dayB release of condensate at the seabed for 77 days to represent a prolonged well blowout scenario. The blowout scenario was determined in

A The complete fuel load of a support vessel can be large, around 1000m3, but it is unlikely that more than one

or two fuel storage compartments would be compromised in an collision.


accordance to the United States Department of the Interior Bureau of Ocean Energy Management, Regulation and Enforcement notice NTL No. 2010-N06. The duration of the modelled blowout was increased from 30 days, as required by NTL No. 2010-N06, to 77 days to address DSEWPaC requirements. A seabed release was selected as the Palta-1 well will be drilled by a MODU which would detach in the case of a blow-out, resulting in the spill originating at the seabed rather than sea surface.

The Palta-1 prospect lies deeper in the stratigraphy than the oil fields closer to North West Cape (i.e. in permits WA-25-L, WA-28-L, WA-32-L, WA-35-L, WA-36-R, WA-42-L and WA-43-L). The stratigraphic depth of the prospect indicates that heavy oils are not possible and that Palta is expected to be a gas prospect, potentially rich in condensate. The worst case blow out scenario, as required by NTL No. 2010-N06, was determined assuming that the maximum depth of the hydrocarbon reservoir was open and that there was no impediment in the well to the flow of hydrocarbons. However, when interpreting the results of the modelling it should be remembered that the likelihood of a blow out occurring is extremely remote, estimated at 4.59 x 104 in Australia following the Montara incident (ConocoPhillips EPBC referral 2010/5718). This risk is lower for Palta-1, as the likelihood of a) discovering hydrocarbons and b) discovering significant quantities of hydrocarbons is low. Modelling of the different spill scenarios was undertaken by Asia-Pacific Applied Science Associated (APASA). For each scenario the modelling involves running multiple single spill simulations using the same spill information (i.e. release location, spill volume, duration and oil type) but commencing at different times and in different wind and current conditions to quantify the likely risk of exposure following a spill for any time of the year. Results are summarised in Table 4 and Figures 3-5. Table 4: Summary of Oils Spill Modelling results

Refuelling incident An instantaneous 2m3 diesel spill at the ocean surface, tracked for 10 days

Plots presented in Figure 3 Spill travels predominantly in a westerly direction (NW to SW) at all times of the year, into deeper water and away from the coast and shallow water. There is no shoreline contact under any simulation at any time of the year.

Vessel collision A 200m3 diesel spill over 1 hour at the ocean surface, tracked for 10 days

Plots presented in Figure 4 Spill travels predominantly in a westerly direction (NW to SW) at all times of the year, into deeper water and away from the coast and shallow water. There is no shoreline contact under any simulation at any time of the year.

Worst case well Blowout

A continuous ~70,000B bbls/day release of condensate at the seabed for 77 days, tracked for 85 days

Plots presented in Figure 5 Spills travel predominately in a south westerly direction for spills commencing in summer and parallel and away from the coast to the north and south for spills commencing in winter and the transition periods. Overall, spills predominately travel away or parallel to the coast, however, there is a low probability of shoreline contacts in all seasons (see Table 5 for summary).

Modelling indicates that the trajectory of surface diesel slicks is strongly influenced by the interaction of wind direction, large scale drift currents, which tend to occur as eddies (clockwise and anticlockwise), and currents directed parallel with the coastline. As a result

B Actually rate of condensate production modelled varies through time, commencing at 72,391.4 bbls/day,

declining to 71,451.2 bbls/day over three months


surface diesel spills travel predominantly in a westerly direction (NW to SW) at all times of the year, into deeper water and away from the coast, Humpback Whale migration paths, Ningaloo Marine Park and other matters of National Environmental Significance which occur closer to the coast. There is no shoreline contact under any simulation at any time of the year. The greatest potential impact (consequence) to the marine environment is associated with an extended uncontrolled release of hydrocarbon during the drilling campaign. Modelling was undertaken of an 11 week blow out, as required by DSEWPaC, and assumes that no response measures are implemented. However, Shell is currently assembling a globally deployable well capping system from existing equipment that will be available for the Palta campaign. This system would significantly limit the duration of any loss of well control scenario, reducing the volume of condensate entering the environment and reducing the potential for impacts to the environment (see Section 4 for further details of capping system). Additionally, in the case of a significant spill, response measures would be implemented to minimise environmental impacts (see Section 4 for further details). Modelling of the 11 week subsea blow out scenario indicates that the condensate is likely to discharge as droplets of relatively small size. This is driven by the depth of water at the discharge location, the pressure of gas leaving the reservoir and size of the open discharge hole. As a consequence, droplets are forecasted to rise over extended durations (10’s of hours to weeks) and travel considerable distances (10’s to 100’s km), driven by complex and relatively fast (up to 2 knots) drift currents, before surfacing. There is frequently a net migration southward, parallel with the coastline, prescribed by the water currents. However, the circular eddies generate localised currents in all directions and these currents are forecast to deliver oil, most frequently, a large distance towards the south or west of the release point before oil surfaces to become subject to the additional effect of the wind on the surface of the condensate. When drift currents are weak and the opposing wind is relatively strong, migrations towards the northeast can result. On surfacing, the transport of the condensate will continue to be affected by the prevailing current patterns but will also become affected by the prevailing wind. Given the volume of condensate being released on a daily basis and the long duration of the modelled blow out scenario (11 weeks), there is a low probability of shoreline contact in all seasons, the details of which are summarised in Table 5. To calculate the probability of shoreline oiling, the coast was divided into sections as described in Table 5. Shoreline locations that were indicated to have the highest potential for surface-bound condensate to wash ashore were the middle and southern sections of North West Cape, he islands at the entrance to Shark Bay (Dirk Hartog, Bernier and Dorre Island), the coastline along the Zuytdorp cliffs and the Abrolhos Islands. The minimum time until condensate reaches any coastline is 480 hours (20 days) (Table 5). This very long minimum times until shoreline contact means that the condensate is likely to be well weathered. The long minimum times until shoreline contact also enable mobilisation of substantial resources to help combat the spill prior to any condensate reaching sensitive coastal habitats (see Section 4).


Table 5: Coastal contact for condensate following a worst case blowout of 11 weeks duration

(Threshold set at > 0.15g/m2, equivalent to a silvery sheen. Season refers to the time at which the

spill commences) Ningaloo MP –

North

Point Murat - Point Cloates

Ningaloo MP - South

Point Cloates – Cape Cuvier

Shark Bay

Cape Cuvier – Cape Inscription

Zuytdorp Cliffs

Cape Inscription – Zuytdorp Point

Abrolhos Islands

Probability of oil on coast

Summer – 0.08 Winter – 0.2

Transition – 0.12


Transition – 0.04

Summer – 0.08 Winter – 0.04 Transition – 0.25


Transition – 0.25

Summer – 0.2 Winter – 0.3 Transition – 0.2

Minimum time to coastal contact (hrs)

Summer - 565 Winter - 560

Transition - 1035

Summer - 1025 Winter - 510 Transition - 560




Mean maximum beached concentration

of oil (g/m2)


Transition - 125




Transition - 470


Potential Impacts on Matters of National Environmental Significance Hydrocarbons vary in their impacts depending on volumes, toxicity, solubility and persistence, and rate and stage of degradation. Diesels and condensates are light products with high evaporation rates when discharged at the ocean surface, especially in warm tropical waters. A subsurface release of condensate will result in condensate distributed throughout the water column, not just the ocean surface. Effects of hydrocarbon on habitats and wildlife can be broadly summarised as: • direct physical and chemical alteration of natural habitats; • direct physical smothering effects on flora and fauna; • direct toxic effects and physiological effect on on flora and fauna; and • indirect changes on flora and fauna resulting from changes to prey and predator and habitat alterations. The discussion below considers all the spill scenarios presented above, including the 11 week blow out scenario, which is modelled assuming no response is mounted. However, in the unlikely event of the loss of well control, Shell’s tertiary well control plans (see Section 4 for further details) should significantly limit the duration of any uncontrolled release of hydrocarbons and significantly reduce the potential for impacts to the environment below that indicated by the model results.

Cetaceans (Whales, Dolphins and Dugongs) Cetaceans surface to breathe air so they are vulnerable to exposure to an oil slick on the sea surface. They are relatively smooth-skinned and hairless so contact with oil on the surface and in the water column should only result in sub-lethal impacts such as minor adherence, irritation and adsorption. In the event of a large gas condensate release, there is a risk that cetaceans in the area will be affected. Impacts will depend on the cetaceans spatial and temporal distribution and feeding preferences at the time of the spill. Regardless of season, modelling indicates that spilt hydrocarbons both in the water column and on the sea surface predominately heads away from the coast and migration routes, limiting the potential for impacts. However, in the 11 week blowout scenario, there is a low probability that well weathered hydrocarbons will approach coastlines and migration routes. Humpback, Blue and the other whales are unlikely to be feeding as they migrate past Ningaloo so impacts should be limited to direct contact with highly weathered condensate. The impact on dugongs should also be limited to direct contact with highly weathered condensate as their food source, sea grass should largely be unaffected by any spill as it is located on seabed. Dolphins can be more residential and are more likely to be actively feeding in the region on fish and shell fish so are potentially more susceptible to both the direct and indirect impacts following a spill.


Turtles The impact on turtles should also be limited as their abundance in offshore waters is limited. Turtles are also air breathers and smooth skinned so contact with condensate on the surface and in the water column should only result in sub-lethal impacts such as minor adherence, irritation and adsorption. However, should spilt hydrocarbons reach the shore it can also disrupt, alter or destroy nesting sites and incubating young, affecting subsequent generations. Modelling indicates that there is only a low probability (0.08) of condensate reaching the nesting beaches around North West Cape and the Murion Islands during the summer nesting period and that there is considerable time (565 hours) before the condensate reaches the coastline to enable spill mitigation measures to be enacted e.g. booming of nesting beaches. Seabirds and shorebirds Birds are especially susceptible to oil spills, especially if they spend considerable time on or near the surface of the sea and on affected foreshores. Oiling affects the feathers insulation and waterproofing properties and ultimately the bird’s survival. However, both the southern giant petrel (Macronectes giganteus) and the soft plumaged petrel (Pterodroma mollis) are more abundant in temperate or Antarctic waters and unlikely to be found off the Ningaloo coast in large numbers so potential impacts will be limited. Fish A wide variety of fish species occur in the waters of the region with varying physiology, feeding behaviours and habitats. Eggs, larvae and young fish are comparatively sensitive to hydrocarbon (particularly dispersed oil), as demonstrated in laboratory toxicity tests. However, there is no definite evidence from case histories to suggest that hydrocarbon pollution has significant effects on fish populations in the open sea. This may be partly because hydrocarbon-induced deaths of young fish are often of little significance compared with significantly larger natural losses each year through natural predation and fishing. The Longfin and Shortfin Mako are both highly mobile with a wide-ranging distribution in deep offshore waters and are not likely to be present in significant numbers or impacted significantly following a spill. Direct impacts from contact with condensate in the water column on sharks should only result in sub-lethal impacts such as minor adherence, irritation and adsorption. Indirect impacts are potentially of greater concern for Whale Sharks who undertake long migrations to feed in the waters off Ningaloo. Impacts on coral fecundity caused by an oil spill may affect the amount of food available for Whale Sharks. However, in the 11 week blowout scenario, there is only a low probability (highest probability of 0.2 in winter) that hydrocarbons will contact the Ningaloo reef system and it will take at least 560 hours before contact which can be used to combat the spill. Other matters of NES The condensate spill modelling presented shows that spilt hydrocarbons, both at the seabed and on the sea surface, generally travel towards the open ocean and away from Ningaloo Marine Park. However, under the 11 week blow out scenario there is a low probability of coastal contacts in the Ningaloo Marine Park, Murion Islands Marine Park, Shark Bay World Heritage Area and elsewhere in Commonwealth Marine waters. Coastal impacts would result in condensate on beaches, rocky coasts and reefs, impacting upon these habitats and their values. However, modelling indicates that there is significant time (see Table 5) before any coastal impact occurs to mount a response and limit potential impacts. The modelling presented does not take into account the very low probability of a blow out occurring in the first place (4.59 x 104), Shell’s spill response measures or Shell’s tertiary well control plans (see Section 4), which should limit the duration of any uncontrolled release of hydrocarbons to a significantly shorter period than 11 weeks modelled and also significantly reduce the potential for impacts to the environment and matters of NES.


Figure 3 Instantaneous 2m3 diesel spill at the ocean surface tracked for 10 days

Note that the plots presented do not represent the extent of a single spill, rather they represent the extent of 200 independent spills and accordingly cover a much larger area than a single spill. The plots are expressed as contours of probability of exposure following a spill. The threshold for modelling is 0.15g/m2.

Summer

Winter

April Transition

September Transition


Figure 4 Instantaneous 200m3 diesel spill at the ocean surface tracked for 10 days Note that the plots presented do not represent the extent of a single spill, rather they represent the extent of 200 independent spills and accordingly cover a much larger area than a

single spill. The plots are expressed as contours of probability of exposure following a spill. The threshold for modelling is 0.15g/m2.

Summer

Winter

April Transition

September Transition


Figure 5 Continuous ~70,000 bbls/day release of condensate at the seabed for 77days tracked for 85 days Note that the two plots presented are examples of a spill, one with a northerly trajectory and one with a southerly trajectory. Twenty five spill scenarios were run for each season to

determine the probability of exposure and shoreline contact, as summarised in Table 5.

Northerly trajectory

Southerly trajectory


3.2 (d)

Is the proposed action to be taken on Commonwealth land?

X No


If yes, nature & extent of likely impact on the whole environment (in addition to 3.1(i))

3.2 (e) Is the proposed action to be taken in the

Great Barrier Reef Marine Park?

X No


If yes, nature & extent of likely impact on the whole environment (in addition to 3.1(j))

3.3 Other important features of the environment

3.3 (a) Flora and fauna

The North West Marine Bioregional Plan Bioregional Profile (DEWHA, 2008b) describes the flora and fauna of the region as predominantly tropical, with high species diversity (linked to the diversity of habitats), but lower endemism compared to more temperate latitudes due to the region’s strong Indo-Pacific links. Marine species with broad distributions such as marine mammals, fish, sharks, and seabirds may transit through WA-384-P; however, the permit area does not contain habitats likely to be critical to any of these species, including EPBC Act listed threatened and migratory species (see Tables 2 and 3), therefore impacts are unlikely. The proposed well location is located in the open ocean, in deep waters in excess of 1000 m. Due to the depths encountered in the area, the seabed at the Palta-1 well location comprises muddy silts and exclude any significant benthic habitats. The soft seabed is likely to support a high diversity but low abundance community of sea cucumbers, ophiuroids, echinoderms, polychaetes, seapens, nematodes, copepods, molluscs and crustaceans. The nearby Exmouth Plateau is considered an important area for communities adapted to depths of 1,000 m (DEWHA, 2008b). Previously collected seismic data indicates that it is unlikely that any hard substrates will be occur in the vicinity of the proposed well location; however, the recently collected high definition Salsa 3D seismic data will be used to ensure that the final well and anchor locations avoid any hard substrates. Due to the water depths and the lack of significant benthic habitats, impacts to any benthic communities as a result of the proposed well are expected to be very low.

3.3 (b) Hydrology, including water flows

Not applicable 3.3 (c) Soil and Vegetation characteristics

Not applicable

3.3 (d) Outstanding natural features

Not applicable

3.3 (e) Remnant native vegetation

Not applicable 3.3 (f) Gradient (or depth range if action is to be taken in a marine area)

The Palta-1 location is on a comparatively gently sloping portion of the southern Exmouth Plateau/ Curvier Margin continental slope in 1350m water depth. The continental slope in the region is dissected by numerous canyon systems. Geoscience Australia has identified 109 submarine canyons along the western West Australian continental slope, 46 on the Cuvier Margin region where Palta-1 is located and 63 further south on the Perth Margin (Whiteway et al., 2010). Palta-1 is located between the Cape Range Canyon, approximately 15km to the north and Cloates Canyon, approximately 20 km to the south, which is sufficiently distant to be unaffected by the


discharge of drilling cuttings and muds. These canyons are also much deeper (1800-2500m) than the seabed depth at the Palta-1 well location (~1350m). As condensate is more buoyant than water, spilt hydrocarbons would travel up through the water column and away from the seabed in these canyons.

3.3 (g) Current state of the environment

The marine environment in and around the Palta-1 location is essentially undisturbed. There are several existing offshore developments north east of the proposed Palta-1 location area (e.g. Enfield, Stybarrow, Vincent, Pyrenees, Van Gogh), closer to the Ningaloo Marine Park, and other anthropogenic activities in the broad area include commercial and recreational fisheries and shipping activities.

3.3 (h) Commonwealth Heritage Places or other places recognised as having heritage values

Ningaloo Marine Park is listed on the Register of the National Estate - See Section 3.1(a and b) and 3.3(j) for further details. 3.3 (i) Indigenous heritage values

Not applicable

3.3 (j) Other important or unique values of the environment

The most prominent environmental feature of the region is the Ningaloo Reef, which is protected by the Ningaloo Marine Park, under joint State (CALM, 1989) and Commonwealth (Environment Australia, 2002) jurisdiction. Ningaloo reef is a diverse fringing reef located within several kilometres of the Western Australian coastline that extends approximately 260 km southward of North West Cape. The Ningaloo Marine Park is located approximately 50 km east of the proposed Palta-1 well location.

Other important geomorphic features of the surrounding environment include the Exmouth Plateau to the north and, Cape Range and Cloates Canyons located either side of the proposed survey aea. The Exmouth Plateau covers approximately 50,000 km2 and is considered to support a significant number of species adapted to depths of 1,000 m. It has been suggested that the Cape Range and Cloates Canyons may drive an upwelling, providing cold, nutrient-rich waters onto the plateau or Ningaloo Reef. Both the Exmouth Plateau and the canyon systems are located in the Gascoyne ‘Area for Further Assessment’ currently being investigated as part of the Marine Bioregional Planning Process for the North-west Marine region (DEWHA, 2008b). Due to the limited intrusiveness of the proposed well and the mitigation measures that are proposed, the proposed operations are not expected to impact on these features.

3.3 (k) Tenure of the action area (eg freehold, leasehold)

The proposed Palta-1 well will be undertaken wholly within Commonwealth waters within Permit Area WA-384-P.

3.3 (l) Existing land/marine uses of area

Commercial fishing – State Managed

There is minimal State managed commercial fishing effort in the vicinity of the proposed Palta-1 well location. The North Coast Shark Fishery extends from longitude 114°06’ E (North West Cape) to 123°45’ E (Koolan Island). This fishery does not overlap the proposed well location and has been closed indefinitely in the area between the North West Cape and a line longitude 120° E, including all waters south of latitude 18° S, primarily to protect the breeding stock of sandbar sharks (Department of Fisheries, 2009).


A well established prawn fishery operates within Exmouth Gulf, with all activity confined to 5 nautical miles from the Western Australian coastline. It does not overlap the proposed well location (Department of Fisheries, 2009). No commercial demersal scalefish fishing is permitted between 21° 56´ and 23° 07´ S (‘Point Maud – Tantabiddi Well’ closure) which overlaps the proposed well location. Recreational fishing is acceptable in this region (Department of Fisheries, 2009). Commercial fishing – Commonwealth Managed

Commonwealth managed commercial fisheries that overlap with the Palta-1 include the Western Deepwater Trawl, Southern Blue Fin Tuna Fishery, Western Skipjack Fishery and Western Tuna and Billfish Fishery. Commercial fisheries operating in or in the vicinity of the proposed well will be contacted by SDA and informed of the location and timing of the activities. The Western Deepwater Trawl Fishery sector is located in deep water off Western Australia from the 200 m isobath to the edge of the Australian Fishing Zone (AFZ). Effort and catch have been very small for the fishery in the past few years (66.3 tonnes caught between 2007 and 2008), with only 11 permits issued during 2009 (AFMA, 2010a). The Southern Bluefin Tuna Fishery extends along all of the Australian coastline and into offshore waters with key fishing areas located in the Great Australian Bight and south-eastern Australia. This Fishery targets Southern Bluefin Tuna, a highly mobile and widely distributed species throughout waters of the southern ocean. Due to the overfishing of this species, the Southern Bluefin Tuna Fishery is in decline, with only 118 fishing permits issued during 2009 (AFMA, 2010b). The Western Skipjack Tuna Fishery extends from the WA coastline out to the extent of the Australian Exclusive Economic Zone. There were only 13 permits issued during 2009 (AFMA, 2009). The Western Tuna and Billfish Fishery extends westward from Cape Peninsula in Queensland, off the coast of Western Australia out to the Exclusive Economic Zone and eastwards to the South Australia and Victorian boarder. Permits for 93 vessels and three carrier boats were issued in 2009.

Tourism

Nature-based tourism provides a significant economic benefit to the Exmouth region. Tourism is centred around Ningaloo Reef and other inshore waters that are popular for scuba diving and snorkelling and provide the opportunity to observe whales, whale sharks, dolphins and manta rays. With the exception of offshore fishing charters, most marine tourism activities occur within State waters close to the coast (DEWHA, 2008b). Commercial tour boat operators generally operate along the middle to northern end of the reef and the seasonal Whale Shark searches are conducted within the marine park (Shell, 2008). Across Western Australia as a whole during the 2008-2009 reporting period, the DEC issued a total of 290 marine interaction licences, including 14 whale shark, 126 whale watching, 93 boat-based dolphin watching, two dugong watching and two marine turtle interaction licences (DEC, 2009b). Recreational beach and ocean fishing are also popular attractions, with high fishing effort recorded off the west coast of the North West Cape Peninsula extending beyond the marine park boundaries to approximately 100 km offshore (DEWHA, 2008b). Game fishing tournaments are held annually off Exmouth waters. Offshore fishing charters are managed by the Director of National Parks and require special permits.


Commercial shipping

Vessels travelling along the shipping lane running parallel to the WA coastline and heading in a northerly direction to the Port of Dampier (associated with iron ore carriers, salt carriers and LNG tankers) and beyond to South East Asian ports may pass through the WA-384-P permit area. However, shipping traffic is unlikely to be affected as the proposed activity as the well is located in open waters with no constrictions on shipping movements. All other users of the area, including shipping and fishing stakeholders will be notified of the proposed activities and kept informed throughout the proposed operations to minimise interactions between the drilling program and other activities.

3.3 (m) Any proposed land/marine uses of area

The proposed Palta-1 exploration well is located in the Gascoyne ‘Area for Further Assessment’ currently being investigated as part of the Marine Bioregional Planning Process for the North-west Marine region. The well is located between the Cape Range Canyon, approximately 15km to the north and the Cloates Canyon, approximately 20 km to the south. Due to the position of the activity away from the canyons, the soft sedimentary benthic environment and the activity management measures that will be implemented (see Section 4), the proposed operations are not inconsistent with the potential future use of the area as a Marine Protected Area.

4 Measures to avoid or reduce impacts Potential environmental risks associated with drilling programmes are well understood and managed through well-tested management system and procedures. All management measures to be implemented for the Plata campaign will be detailed in the Palta-1 Exploration Well Environment Plan (EP) and Oil Spill Contingency Plan, which also requires approval by the Designated Authority (DA), the WA Department of Mines and Petroleum (DMP), under the OPGGS (E) Regulations. The EP will describe and assesses all aspects and potential impacts of the activity in a risk-based context. It will also include an Implementation Strategy detailing specific environmental management measures and environmental performance objectives to avoid or reduce impacts. An extract of this Implementation Strategy is presented in Table 6. Shell focuses on five critical and integrated areas to ensure safe well design and drilling in deepwater;

• rigorous training, • global standards, • a safety case approach to risk identification and mitigation, • robust and multiple barriers, and • 24 hour / 7 day-a-week real time monitoring.

Discussion of each of these points and additional details on management plans including the measures to avoid impacts from Synthetic Based Mud use are presented below.


Table 6: Palta-1 Environmental Performance, Objective Standards and Measurement criteria

Activity Potential Impact Objective Standard Commitment Criteria Vessel Movement/ Operation

• Collision with other vessels

• Collision with marine life

• No collisions with other vessels or cetaceans

• Navigation Act 1912 • EPBC Act Policy Statement 2.1

when undertaking VSP or SWD

• Notice to Mariners advising of the presence of the MODU will be issued through the Australian Maritime Safety Authority (AMSA)

• Vessel Masters shall not knowingly approach within 500 m of cetaceans

• Notification to fishing and shipping industries of the MODU position and exclusion zone once final location known.

• Supply vessels to maintain 24 hour watch. • Establish and maintain a 500 m exclusion

zone around drill ship (radar and 24 hour radio watch)

• Vessels not to enter NMP under normal operations

• Complete Whale and Dolphin Sighting Report Sheet in the event Wildlife is reported in area

• Adherence to EPBC Act Policy Statement 2.1 when undertaking VSP or SWD

Vessel Movement/ Operation

Anchor damage Minimise impact on benthic communities

Palta Mooring Plan • Anchors are placed in identified areas, minimise anchor movement.

• Mooring plan to produced and identify suitable location for anchors


Pollution from deck drainage resulting from oily machinery areas

Minimise potential for oil contamination of the sea from MODU and support vessel deck drainage discharge & machinery spaces

• Comply with Annex I of MARPOL 73/78

• APPEA Code of Practice 5.3.2 (waste management)

• Absorbents and containers will be available on the ship to clean up small accumulations of contaminants

• Accumulations of oil, grease and other contaminants will be collected and removed from decks prior to any wash down.

• Ensure that water discharged from the separator contains no more than 15 ppm oil in water.

• Containment of deck areas where hydrocarbons are present

• Oil/water separation device that is checked for functionality.

• Machinery space drainage to slops tank for shipment of oil to shore. Records to be maintained in oil record book.

• Monitor the sea visually to confirm lack of visible sheen.


Pollution from treated sewage and grey water

Minimise potential for un-aesthetic discharge of domestic wastewater and food scraps

• APPEA Code of Practice 5.3.2 (waste management)

• MARPOL 73/78

• Domestic grey water will be discharged in compliance with MARPOL regulations

• Use of biodegradable detergents only

• Domestic wastewater treatment apparatus to be tested and checked to be operating according to design specifications during drilling programme.

• Sewage, water and wastes from the kitchen, shower and laundry areas are committed to pass through a screen of less than 25 mm diameter prior to discharge

• Domestic grey water will be discharged under OPGGSA and MARPOL regulations.

• Maintain sewage discharge log and waste log


Activity Potential Impact Objective Standard Commitment Criteria Vessel Movement/ Operation

Hydrocarbon spill-refuelling Minimise risk of fuel spill during refuelling

• APPEA Code of Practice 5.3.2 (spill prevention and marine support)

• Fuelling only to be undertaken during daylight and favourable weather conditions as determined by the Master of the vessel.

• Transfer hoses are fitted with ‘dry break’ couplings.

• Ensure that all refuelling activities are undertaken in accordance with rig specific and standard industry procedures

• Continuous visual monitoring of hoses, couplings and the sea surface during refuelling

• All valves and flexible transfer hoses to be checked for integrity prior to use.

• Confirm fuel transfer hoses are fitted with “dry break” couplings.

• Continuous visual monitoring of hoses, couplings and the sea surface during refuelling

• Containment of deck areas where hydrocarbons are present

• Any spillages to be recorded on a Notice of Incident Report. Spills >80 litres to be reported to WA DMP within 2 hours.

Drilling Introduced marine species Minimise risk of introducing invasive species

• Quarantine Act - comply with AQIS ballast water & biofouling requirements

• If rig mobilising from outside Australia, underwater inspection of hull prior to sail away

• If rig mobilising from outside Australia, inspection of hull prior to departure

• Ballast water exchange in compliance with AQIS requirements

Drilling Drill cutting discharge Maximise recovery of

drilling fluid from cuttings before discharge

• Maximise recovery of drilling fluid from cuttings before discharge

• APPEA Code of Practice 5.3.1 (well programme) & 5.3.2 (waste management)

• Low toxicity SBM drilling fluid to be used (DMP guidelines (Cobby & Craddock 1999)

• Use of shale shakers and/or cuttings dryer to recover as much of the drilling fluid as possible prior to discharging the cuttings to the ocean

• Optimise the solids control equipment including regular washing down of shaker screens to maximise the opportunity for separation.

• SBM will be recovered for subsequent re-use on other drilling programmes

• MODU shale shaker to be tested and operational to design specifications during drilling programme.

• Performance of shale shaker and cuttings dryer to be monitored by Shell Drilling Supervisor.

• Auditable record of the volume of drilling fluids discharged to be maintained


Activity Potential Impact Objective Standard Commitment Criteria Drilling Hydrocarbon spills including

well blow out Minimise risk for adverse environmental effects arising from major oil spill

• Shell Design and Engineering Manual (DEM1).

• Shell’s EP2002_1500 Well Control Manual

• Shell Well Abandonment Manual and Guideline (EP2010_1305)

• Palta WOMP • APPEA Code of Practice 5.3.1

(emergency response and planning, ship selection)

• APPEA Code of Practice 5.3.2 (spill prevention)

• Well designed and constructed to required Shell standards including casing design/load cases for early life hot kill and a hot collapse

• All critical Well Control equipment subjected to OEM certification

• eWCAT Well Control Assurance Tool.

• Qualified and competent well engineers compliant with Shell Round 2 and industry accredited Advanced Well Control Training

• double barrier to be maintained at all times between the environment and any potentially hydrocarbon bearing zone (weighted drilling fluid to overbalance the formation pressure and Blowout Preventer (BOP))

• BOP with dual shear rams • BOP will be pressure tested prior

to the well and then on installation

• OSCP drill conducted before well reaches hydrocarbon zone (See Attachment 1).

• Shell Globally deployable well capping system

• All oil pollution incidents in Commonwealth water to be reported (See Attachment 1).

• Confirm that the BOP and well control mechanisms have been tested and found operational prior to commencement of operations.

• Confirm that the OSCP drill conducted and SOPEPs are fully stocked


Incident and Spill Prevention

At Shell we consider the prevention of major incidents paramount. Shell is fully committed to the systematic approach to managing safety and ensuring 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 blowout events. These are addressed by People Competence, Design Integrity, Technical Integrity and Operating Integrity (see Figure 6). Listed below are some of the areas under these topics that Shell implements in their commitment to Process Safety. Figure 6: Shell Well Integrity/Process Safety Management Diagram

Rigorous Training – appropriate staff competency is regarded as an underlying factor and pre-requisite for integrity throughout all phases of a wells life.

• Shell Wells Engineers undergo a rigorous training program which includes coursework, on the job training in the field and in the office, and formal examination culminating with the award of the prestigious Round 2 certificate. Passing Round 2 exam is a prerequisite for key operational roles.

• Advanced Well Control Training – Well control is a critical competence for personnel in well site and office supervisory positions. Shell is developing an Advanced Well Control training course for their well engineers that will be mandatory every two years, commencing in Q2 2011. The course will be accredited by the International Association of Drilling Contractors and the International Well Control Forum.

• Trade test – to ensure subcontractor competence levels meet the minimum Shell requirements, trade tests became mandatory in 2010. The trade tests cover key well design, well control and general well engineering topics. If unsuccessful, consultants cannot work in operational safety critical roles.

• Principal Technical Experts – Shell has a network of industry renowned experts to support and independently assure Shell’s well designs and technical standards. All wells, including Palta-1, are assessed and the final well design requires approved by these Principal Technical Experts. These Principal Technical Experts are independent of the team designing and delivering the well.

• A focus on frontline supervisory behaviours toward safety, integrity and performance forms the basis of a new competency development program. This will be implemented for well site supervisors during 2011 and 2012.

Global Standards for Well Design Integrity – all wells are designed in compliance with Shell standards to assure mechanical and functional integrity for all anticipated loads throughout the life of the well. These standards meet or exceed current International and Australian standards. The Palta-1 casing design has been conducted to the Shell Design and Engineering Manual (DEM1). This includes


designing wells for an early life hot kill and a hot collapse (even though no production operations are planned for this exploration well). The well is designed for these load cases so that should a blowout situation occur, any tertiary well control action that would shut in and kill the well is still within the design envelope of the casing design. Risk identification and mitigation through Safety Cases: We use a Safety Case approach in our wells worldwide. This requires Shell and its contractors to systematically identify the risks in drilling operations and align plans to mitigate those risks; this alignment is critical and mandatory before drilling begins. A Contractor Safety Case ties into Shell’s Safety Management System and is developed for every Shell-contracted drilling rig. Through systematic implementation of the Safety Case:

• Health, Safety & Environment issues are clearly identified and assessed,

• Regulatory and Shell Global requirements are met,

• Risks are removed or mitigated according to a structured, systematic Shell process, with any remaining risks demonstrated to be both tolerable and As Low As Reasonably Practicable (ALARP)

• Critical safety items and procedures are identified to manage remaining risks

• A comprehensive environmental management plan is developed

• Social, health, and environment benefits and opportunities are identified Robust barriers to ensure Blowout Prevention: At Shell we consider the prevention of major incidents paramount and robustly apply multiple control barriers to prevent incidents from happening in the first place. The following information outlines the measures Shell puts in place to prevent a blowout occurring. The well design starts with the selection of an optimised location for avoidance of geological hazards. To this end, the Salsa 3D site survey, which was only completed in February and is currently undergone analysis with latest high definition technology, was undertaken to increase the understanding of the geological uncertainties and risks around the Palta well location. The final well location will move marginally from the nominated location if the high definition Salsa 3D seismic data uncovers new subtle shallow drilling hazards at the nominated location. Shell’s well control manual requires a double barrier to be maintained at all times between the environment and any potentially hydrocarbon zone.

• Weighted drilling fluid to overbalance the formation pressure is the primary barrier during the well construction phase of the well activity.

o Formation pressures have been estimated from sub-surface basin modelling and by using offset well data (Falcone-1A, Herdsman-1, Blackdragon-1, Indian-1, Cody-1, Flinders Shoal-1, Kybra-1, Mermaid-1 and Arabella-1). However, as the Palta-1 well is an exploration well with limited offset well control of the deepest reservoir target, there is a large variation between the minimum and maximum formations pressures expected. Because of this continuous real-time pore pressure monitoring will be ongoing throughout the execution phase of the well. This real-time monitoring will look at primary well control indicators (gas, cuttings etc..) as well as the use of real-time LWD data to input into the ‘pre-drill’ model.

• The drilling mud and chemicals will be provided by a recognized industry contractor. The drilling fluid offshore will be managed by two Drilling Fluids Engineers onboard at all times, one of whom is directly responsible to Shell and supervises the drilling fluids Contractor personnel. The mud formulations will be lab tested prior to operations – with this lab testing independently verified by the Shell global fluids specialist team in Houston.

• The second barrier is the Blowout Preventer (BOP) which will be fitted with Dual Shear Rams. A shear ram is a component in a BOP that cuts (shears), through pipe and forms a seal


against well pressure. The BOP ram configuration on the Palta-1 well will have a dual shear ram configuration. Having a second shear ram will make the well less vulnerable in case one shear ram fails to seal the wellbore in an emergency situation. To assure that the rams are effective, and will cut pipe at acceptable operating pressures, Shell typically performs a shear test using the BOP and drill pipe planned for use on the well. This will be done prior to commencement of Palta-1 well drilling.

o In any unplanned well control event (i.e. an influx of hydrocarbons into the wellbore) the pressure will be contained by the casing and the BOP, with the influx circulated. Any Well Control event will be dealt with in accordance with the planned bridging document between the Drilling Contractor Well Control Manual and Shell’s Well Control Manual.

o The BOP stack will be pressure tested prior to the well and then on installation (this tests the connection between the wellhead and the BOP). Testing (pressure and function) will then continue either as per the drilling rigs NOPSA approved vessel safety case (VSC) or as per testing requirements in the Shell Well Control manual – whichever is stricter.

o In the event of a malfunction of the BOP the well would be suspended with downhole barriers as per the Shell Well Control manual which includes a double barrier policy.

o Drilling contractor staff will all be trained and certified in well control in accordance with Shell’s Well Control Manual (EP2002_1500 ) which is specified in the Shell Global Model Rig Contract that will be used when contracting a drilling unit.

• At the end of operations the Palta-1 well will be plugged and abandoned according to Shell Well Abandonment Manual and Guideline (EP2010_1305).

24 hour/ seven day a week real-time monitoring: Shell’s global Well Integrity Management system assures that a well’s status is monitored and managed effectively. It also assures that changes in integrity status are detected, managed and resolved while applying global barrier policies and quantified, acceptable levels of risk. Our eWCAT Well Control Assurance Tool is a monitoring system for well control certification of equipment and people providing 24 hour/7 days a week coverage. The system provides key metrics to monitor compliance, using a ‘traffic lights’ system for displaying a transparent view of the current status and provides a consistent global framework and approach to well control compliance management. Tertiary Well Control Tools and Techniques: Shell is currently assembling a globally deployable well capping system. This will be available for Shells activities from Q3 2011, including the Palta campaign. The system is modularized and deployable globally with the target of having the system in country within 2 weeks of a loss of well control incident. Shell requires that a well specific capping program will be prepared for each well that includes, logistics, personnel, deployment methodology and well interface requirements. In addition, a pre-planned response has already been designed for the event that primary and secondary well control is lost and a blowout event occurs. This response planning includes ensuring:

• The development of a Palta specific capping program. • Sufficient drill strings available in country to be able to drill a relief well. • Selecting a number of options for the location for relief well. • A relief well specific program design able kill the Palta well. • Indentifying potential relief well drilling units suitable for the conditions available within the

Shell group, regionally, globally. Shell through APPEA is also pursuing opportunities for a mutual aid accord the Australian activities.

• Contracts are in place with global Emergency Well Control companies.

Incident and Spill Response


Shell has prepared an Oil Spill Contingency Plan (OSCP) for its Southern Exmouth Basin permits covering activities conducted in WA-384-P. The Emergency Response Plan (ERP), of which the OSCP is a part, will be tested prior to the commencement of drilling campaign to ensure that all personnel are aware of and familiar with their personal responsibilities in these plans. The OSCP was originally developed for the Salsa 3D Marine Seismic Survey, after the Montara and Macondo spills, and has already undergone two reviews by WA DMP and a review by AMOSC. It will be further updated with the results of the oil spill modelling undertaken in support of the Palta-1 well and rig details once known, prior to drilling the well, and submitted for approval by the WA DMP. OSCP information regarding the first response to any oil spill is included in Attachment 1. The OSCP contains the following information:

• Spill response activation protocols. • Responsibilities of Shell, Rig and Supply Vessel personnel. • Oil spill response priorities. • Integration with other plans (Natplan and Amosplan). • Tier 1, 2 and 3 response arrangements. Tier 1 response would be managed by Shell using

onsite resources (Shipboard Oil Pollution Emergency Plan or SOPEP) or may require assistance from offsite resources. Tier 2 response will also be initially managed by Shell but will require wider industry and/or State Government assistance. Shell is a founding member of AMOSC, an industry funded oil spill response organisation and would call upon AMOSC as required. Tier 3 response will ultimately be managed by AMSA, as Palta-1 is located in Commonwealth waters, with full support from Shell.

• Reporting requirements. • Response strategies – offshore and onshore. • Emergency contact directory. • Oil spill modelling.

The spill modelling indicates that all spills at the Palta-1 well location predominately travel out to sea and away from coastal sensitivities, Humpback whale migration paths and other matters of National Environmental Significance. Diesel surface spills disperse very quickly and evaporate readily, especially in warm tropical seas. Because surface spills travels offshore and away from coastlines, reefs and shoals, dispersant use is not recommended, except for safety reasons, as dispersant use is unlikely to result in any environmental net benefit. Dispersants typically increase the overall toxicity of spilt diesel or condensate by distributing hydrocarbons through the water column and are only recommended to avoid contact of spilt hydrocarbons with sensitive coastlines or emergent features such as reefs. For small spills, the initial response will include activation of the support vessel’s and rig’s SOPEP. The SOPEP on the supply vessels and the rig will contain absorbent pads and pillows, absorbent booms and socks, chemical resistant gloves, waste disposal bags, brooms, scoops, dust pans, absorbent and containers. These are largely designed to contain and clean-up spilt hydrocarbons onboard. In addition, each support vessel will be equipped with a dispersant system - one dedicated storage tank = 8m³, discharge boom system @ 50m³ per hour or 0.83m³ per minute. However, note that dispersant use on environmental grounds also requires approval from the regulator and is not at the discretion of the oil company. The primary purpose of this SOPEP equipment is to assist in the response for small spillage originating from the vessel or MODU (e.g. fuel transfer activities). Small spills will be tracked by a support vessel until the spill disperses and evaporates. The support vessel may use its motion and propellers to help disperse the spill more quickly if safe to do so and will also maintain a watch for fauna such as turtles and whales. However, as modelling indicates, surface spills generally track offshore where the likelihood of encountering fauna is low. The rig and support vessels will hold oil spill tracking buoy which can be deployed to track spills. In the unlikely event that a spill is travelling towards coastlines, or emergent features such as reefs, there is sufficient time to collect dispersant and booms from the AMOSC stockpile in Exmouth (See


Attachment 2), Geelong or elsewhere to tackle the spill. As an example, from logistics planning it is estimated that minimum travel time from Exmouth to the well location via vessel is 7 hours and flight time from Geelong to Learmonth is 9 hours. This compares to the minimum time (20 days) for spilt condensate from the Palta-1 well location to travel to the Shark Bay area.

In the event of a larger spill, the trajectory, volumes and weathering of condensate will be determined in order to assess if habitats and fauna are at risk and the appropriate response methods. Modelling indicates that even for a worst case discharge scenario, the probability of oil reaching coastlines is low and that it takes a minimum of 20 days to reach the coast. This time enables local, regional, national and international resources to be activated before a spill reaches environmental sensitivities. As the condensate is released at the seabed and is not visible, the initial response will be to commission deterministic oil spill trajectory modelling to identify where the spill is likely to travel and surface, and commence aerial monitoring. Modelling will also be used to inform on spill trajectories and the need to spray dispersants. The spill response will follow the OSCP (Attachment 1). Spill response equipment for large spills is available from AMOSC stockpiles, including the Tier 3 stockpile in Geelong. Shell is currently assembling a globally deployable well capping system. This will be available for Shells activities in Australia from Q3 2011, including the Palta-1 well. The system is modularized and deployable globally. A Palta-1 specific capping plan will be prepared prior to drilling that includes, logistics, personnel, deployment methodology and system interface with the top of the well to significantly limit the duration of any blowout scenario. The aim of the system is to have the capping system in country within 2 weeks of a blowout and deployed as soon as weather conditions allow. The initial response to a loss of well control incident will also include activation of the of the Palta capping plan. Synthetic Based Muds Management The use of Synthetic Based Mud (SBM) will be managed using the Shell reviewed and approved Drilling Fluid Contractor’s SBM & Base Oil Handling Procedures. The procedures manage the handling of SBM and base oil from the supply base through to the use on the MODU and subsequent return to onshore. They cover Health, Safety and Environmental aspects of handling these fluids and associated chemicals. The overriding objectives of these SBM Management Procedures are: • no medical incidents attributable to use of SBM; • zero accidental discharge overboard of any synthetic fluids; and • minimised discharges of synthetic fluids on cuttings. Synthetic fluids on cuttings will be

measured using the Drilling Fluids Contractor’s procedures and will be less than the regulatory limit of 10%.

The SBM Management Procedures address four primary areas: namely equipment and containment, handling procedures, discharge monitoring and health. As a minimum, specific procedures will address the following operations where there is a spill potential: • Transfer of base oil to/from MODU tanks to/from supply vessel; • Transfer of SBM to/from mud pits to/from supply vessel; • Transfer of base oil to/from MODU tanks to/from mud pits; • Displacement of well to SBM (non-SBM drill out); • Displacement of well from SBM during the abandonment phase; • Containment of green cement and spacer in SBM; • Displacement of riser to/from SBM to/from seawater; and, • Transfer of SBM or base oil to/from road tanker/storage tank to/from supply boat. A start up checklist will be completed prior to accepting SBM or base oil on the MODU. This checklist will be signed off by the Shell Drilling Supervisor and the Offshore Installation Manager (OIM) for the MODU to ensure compliance. Any exceptions must be justified and discussed with all concerned


parties. There will be two Drilling Fluids Engineers onboard at all times, one of whom is directly responsible to Shell and supervises the drilling fluids Contractor personnel. One of their principal responsibilities is to ensure compliance with the SBM procedures. Regular audits and checklists will be among the tools used. A crucial aspect to ensuring successful handling of the SBM is to provide adequate training of all involved personnel, either at the supply base location or offshore. This training will address equipment and containment, handling procedures, discharge monitoring and health. Offshore inductions will include information on the correct type and use of Personal Protective Equipment (PPE) and specific training will be provided to those personnel directly involved in handling SBM. Health and hygiene issues will also be addressed in detail. A start up checklist and regular audits will ensure that the ship is stocked with SBM-specific supplies of PPE. These include barrier creams, cleaners, slicker suits and disposable coveralls.


5 Conclusion on the likelihood of significant impacts

5.1 Do you THINK your proposed action is a controlled action?

X No, complete section 5.2

Yes, complete section 5.3

5.2 Proposed action IS NOT a controlled action. The proposed Palta-1 well is not a controlled action as it is not likely to have a significant impact on any matter of national environmental significance for the following reasons:

• There are no World Heritage or National Heritage places, Wetlands of International Significance or Threatened Ecological Communities within close proximity to the Palta-1 well site. The boundaries of the Ningaloo Marine Park is located 50km from the Palta-1 well location at closest point.

• The Palta-1 well site does not represent significant habitat for any listed threatened or migratory species. The well location is in deep water (1350m) and located more than 50 km from the recognised humpback whale migration routes, whale shark aggregation areas and coastal sensitivities. Studies on underwater noise generated by MODU and support vessels demonstrate that significant impacts to cetaceans are unlikely. DSEWPC’s guidelines for minimising interactions with cetaceans will be used if VSP or SWD is undertaken.

• Given the depth of water and lack of benthic features at the well location, the region is unlikely to have particular importance to any species. The well is located 15-20 km from deepwater canyons so is unlikely to have a significant impact on these features or the broader marine environment

• Shell’s systematic approach to managing safety for Palta-1 includes stringent well design and engineering standards, competency and integrity specifications, the collection of detailed site data through the acquisition and high definition processing of the Salsa 3D Seismic Survey to mitigation against potential geohazards risks, more conservative well load casing requirements, requirement for double barriers in place at all times and BOP with dual shear rams means that the chance of a blowout in the first instance is extremely remote.

• Oil spill modelling indicates that in the event of a worst-case well blowout (~70,000 bbl/day over 77 days), spills generally track away or parallel to the coast and that there is only a low risk of shoreline exposure and a very long minimum time until shoreline contact.

• Shell spill contingency planning requirements will also ensure that in the highly unlikely event of a significant spill, a rapid and pre-planned response is instigated. This includes a capping system which will significantly limit the duration of a blow out.


6 Environmental record of the responsible party Yes N

o

6.1

Does the party taking the action have a satisfactory record of responsible environmental management?

X

In Australia, Shell has undertaken previous seismic operations, including the Octantis, Guacamole and Salsa Marine Seismic Survey in 2007, 2008 and 2010 respectively. All were undertaken by Shell without any reportable environmental incidents. Shell has also undertaken previous drilling operations, most recently the drilling of numerous wells in Permit Areas WA-371-P and AC\P-41 As one of the world’s leading Energy companies, Shell is committed to publicly report on our HSE performance. Details of our global environmental performance and HSE performance can be found on Shells global website at the following address: http://sustainabilityreport.shell.com/2009/ourperformance/ourperformancein2009.html

Note that 2010 report is in preparation.

6.

2

Has either (a) the party proposing to take the action, or (b) if a permit has been applied for

in relation to the action, the person making the application - ever been subject to any proceedings under a Commonwealth, State or Territory law for the protection of the

environment or the conservation and sustainable use of natural resources?

X

If yes, provide details

6.

3

If the party taking the action is a corporation, will the action be taken in accordance with

the corporation’s environmental policy and planning framework?


If yes, provide details of environmental policy and planning framework

Work associated with the proposed Palta-1 well will be conducted as per the Shell Health, Security, Safety and Environment (HSSE) Commitment and Policy (see below). These include subordinate policies and standards such as Climate Change, Sustainable Development, Diversity & Inclusiveness, and Shell’s Global Minimum Environmental Standards. Minimum Environmental Standards for our operations are in place and apply to all Shell companies and all joint ventures where we have operational control. A copy of Shells HSSE Commitment and Policy can be found on our global website: http://www.shell.com/home/content/environment_society/s_development/our_commitments_and_standards/hse_com_policy/

Commitment

In Shell we are all committed to: • Pursue the goal of no harm to people; • Protect the environment; • Use material and energy efficiently to provide our products and services; • Respect our neighbours and contribute to the societies in which we operate; • Develop energy resources, products and services consistent with these aims; • Publicly report on our performance; • Play a leading role in promoting best practice in our industries; • Manage HSSE & SP matters as any other critical business activity; and • Promote a culture in which all Shell employees share this commitment. In this way we aim to have an HSSE & SP performance we can be proud of, to earn the confidence of customers, shareholders and society, to be a good neighbour and to contribute to sustainable development.

Policy

Every Shell Company: • Has a systematic approach to HSSE & SP management designed to ensure compliance with the law and to achieve continuous performance improvement; • Sets targets for improvement and measures, appraises and reports performance; • Requires contractors to manage HSSE & SP in line with this policy; • Requires joint ventures under its operational control to apply this policy, and uses its influence to promote it in its other ventures; • Engages effectively with neighbours and impacted communities; and • Includes HSSE & SP performance in the appraisal of staff and rewards accordingly.

Shells Control Framework contains the environmental and social requirements that apply to every Shell company, as well as joint ventures where we have operational control. The framework covers areas including contractor HSSE management, environment, health, HSSE management systems, personal and process safety, transport, product stewardship and social performance. It contains a simplified set of mandatory standards that define high level HSSE and SP principles and expectations. All this information can be obtained in further detail on the Shell global website: http://www.shell.com/home/content/environment_society/s_development/our_commitments_and_standards/hse_manuals/


6.4

Has the party taking the action previously referred an action under the EPBC Act, or been responsible for undertaking an action referred under the EPBC Act?

Provide name of proposal and EPBC reference number (if known)

Shell have previously referred actions under the EPBC Act for the following projects: • Salsa 3D Marine Seismic Survey (EPBC 2010/5629) • Development of Liquefied Natural Gas Facility and Pipeline (EPBC 2009/5007 and

5008) • Prelude Floating Liquefied Natural Gas Facility (EPBC 2008/4146) • Guacamole 2D Marine Seismic Survey (EPBC 2008/4381) • Octantis 3D Marine Seismic Survey (EPBC 2007/3935) • Drilling of 12 Exploration Wells, Permit Area WA-371-P (EPBC 2006/3005) • Floating Liquefied Natural Gas facility (EPBC 2001/533)


7 Information sources and attachments (For the information provided above)

7.1 References Australian Fisheries Management Authority (2009). Western Skipjack Tuna Fishery. Available at: http://www.afma.gov.au/fisheries/tuna/skipjack/default.htm Australian Fisheries Management Authority (2010a). Western Deepwater Trawl Fishery. Available at: http://www.afma.gov.au/fisheries/northern_trawl/deepwater/default.htm Australian Fisheries Management Authority (2010b). Southern Bluefin Tuna Fishery. Available at: http://www.afma.gov.au/fisheries/tuna/sbt/default.htm Bannister, J.L., Kemper, C.M. and Warneke, R.M. (1996).The Action Plan for Australia Cetaceans. Australia Nature Conservation Agency, Perth, Australia. Available at: http://www.environment.gov.au/coasts/publications/cetaceans-action-plan/ Chittleborough, R. G. (1953) Aerial observations on the humpback whale, Megaptera nodosa (Bonnaterre), with notes on other species. Aust. J. Mar. Freshw. Res.4: 219-26. Cogger, H.G., Cameron, E.E., Salier, R.A. and Eggler, P. (1993). The Action Plan for Australian Reptiles. Australian Nature Conservation Agency, Canberra. Conservation and Land Management (1989). Ningaloo Marine Park (Commonwealth Waters) Management Plan 1989-1999. Department of Conservation and Land Management (CALM), Perth, WA. Department of Environment and Conservation (2008). Marine Turtles in Western Australia. Available at: http://www.naturebase.net/content/view/2462/1401/ Department of Environment and Conservation (2009). Draft Marine Turtle Recovery Plan for Western Australia 2009-2016. Wildlife Management Program No. 45. Department of Environment and Conservation, Perth Department of Environment and Conservation (2009b). Annual Report 2008-2009. Department of Environment and Conservation, Perth, Western Australia. Department of Environment and Heritage (2005). Southern Right Whale Recovery Plan 2005-2010. Available at: http://www.environment.gov.au/biodiversity/threatened/publications/recovery/e-australis/pubs/e-australis.pdf Department of Environment and Heritage (2006a). Humpback Whale Recovery Plan 2005-2010. Available at: http://www.environment.gov.au/biodiversity/threatened/publications/recovery/m-novaeangliae/pubs/m-novaeangliae.pdf Department of Environment and Heritage (DEWHA) (2006b). Australian National Guidelines for Whale and Dolphin Watching 2005. Available at: http://www.environment.gov.au/coasts/publications/whale-watching-guidelines-2005.html Department of Environment, Water, Heritage and the Arts (DEWHA). (2008a). EPBC Act Policy Statement 2.1 – Interaction between offshore seismic exploration and whales, September 2008. DEWHA, Commonwealth of Australia. Department of Environment, Water, Heritage and the Arts (DEWHA). (2008b). The North-west Marine Bioregional Plan: Bioregional Profile. Prepared by DEWHA, Commonwealth of Australia, Canberra, Australia. Department of Environment, Water, Heritage and the Arts (DEWHA). (2010a). The Ningaloo Coast, Western Australia. Available at: http://www.environment.gov.au/heritage/places/national/ningaloo/index.html.


Department of Environment, Water, Heritage and the Arts (DEWHA). (2010b). Protected Matters Database. Available at: http://www.environment.gov.au/erin/ert/epbc/index.html Department of Environment, Water, Heritage and the Arts (DEWHA). (2010c). Species Profile and Threats Database. Available at: http://www.environment.gov.au/cgi-bin/sprat/public/publicspecies.pl. Last accessed 13/08/2009. Department of Fisheries (2009). State of the Fisheries Report 2008/2009. Available at: http://www.fish.wa.gov.au/docs/sof/2008/index.php?00 Department of Mines and Petroleum (2009). Location and Estimated Period of Humpback Whale Activity in WA. Published by Department of Mines and Petroleum, Government of Western Australia on 15 September 2009. Available at: http://www.dmp.wa.gov.au/8481_1479.aspx Environment Australia (2002). Ningaloo Marine Park (Commonwealth Waters) Management Plan. Published by Environment Australia, Commonwealth of Australia, Canberra, ACT. Limpus, C.J. (2004). A Biological Review of Australian Marine Turtles. Department of Environment and Heritage, Canberra, ACT and Queensland Environmental Protection Agency, QLD. Limpus, C.J. & N. MacLachlin (1994). The conservation status of the Leatherback Turtle, Dermochelys coriacea, in Australia. In: James, R, ed. Proceedings of the Australia Marine Turtle Conservation Workshop, Gold Coast 14-17 November 1990. Page(s) 63-67. Qld Dept. Env. & Heritage. Canberra, ANCA.

Jenner, C. and Jenner, M. (2002). Humpback Whale and Mega Fauna Survey 2000/2001 Report, Northwest Cape, Western Australia. Centre for Whale Research (Western Australia) Inc.: Fremantle. Neff, JM, Mckelvie, S, Ayers Jr, RC, 2000, Environmental Impacts of Synthetic Based Drilling Fluids. Report prepared for MMS by Robert Ayers and Associates, Inc. U.S. Department of Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2000-064, pp 118. Marquez, R. (1990). FAO Species Catalogue; Sea Turtles of the World. An annotated and illustrated catalogue of the sea turtle species known to date. FAO Fisheries Synopsis. 125 (11):pp 81. Rome, Food & Agric. Org. of United Nations. Available at: http://www.fao.org/docrep/009/t0244e/t0244e00.htm McCauley, R.D. (1994). Seismic surveys. In: Environmental Implications of Offshore Oil and Gas Development in Australia – The Findings of an Independent Scientific Review, Swan, J.M., Neff, J.M. and Young, P.C. (Eds). Australian Petroleum Exploration Association, Sydney, pp 19-121. McCauley, R.D. 2004. Underwater sea noise in the Otway Basin – drilling, seismic and blue whales. Report prepared by Centre for Marine Science and Technology, Curtin University, for Santos Ltd. As cited in Santos Ltd Offshore Drilling Campaign – WA-26-L and WA-191-P (Carnarvon Basin) EPBC referral Prince, R.I.T. (1993). Western Australian marine turtle conservation project: an outline of scope and an invitation to participate. Marine Turtle Newsletter. 60:Aug-14. Prince, R.I. (1994). Status of the Western Australian marine turtle populations; the Western Australia Marine Turtle Project 1986-1990. In: Russel, J., ed. Proceedings of the Australian Marine Turtle Conservation Workshop, Gold Coast 14-17 November 1990. Page(s) 1-14. Qld Dept Env. & Heritage. Canberra, ANCA. Richardson, W.J., Greene Jnr C.R., Malme, C.I. and Thomson, D.H. 1995. Marine Mammals and Noise. Academic Press. San Diego.

Shell Development Australia (2008). Referral of a proposed action: Guacamole 2D Marine Seismic Survey Exmouth Basin: WA-384-P, WA-385-P & WA-394-P. Prepared by Shell Development Australia for the Department of Environment, Water, Heritage and the Arts and approved 8 September 2008. Tanya Whiteway, Andrew Heap, Tara Anderson and Rachel Przeslawsk 2010 Western Australia Marine Survey Reveals Seafloor Environments Geoscience Australia completes its largest mapping survey under Australia’s Offshore Energy Security Program Poster Presentation


United States Department Of The Interior Bureau Of Ocean Energy Management, Regulation, And Enforcement (2010) Notice NTL No. 2010-N06 NATIONAL NOTICE TO LESSEES AND OPERATORS OF FEDERAL OIL AND GAS LEASES, OUTER CONTINENTAL SHELF (OCS) Information Requirements for Exploration Plans, Development and Production Plans, and Development Operations Coordination Documents on the OCS Woodside (2003). Environmental Impact Statement/Environmental Effects Statement: Otway Gas Project. Woodside Energy Ltd., Perth. Woodside Energy Limited (2010). Referral of a proposed action: Laverda 3D Marine Seismic Survey and Vincent M1 4D Marine Seismic Survey. Prepared by Woodside Energy Limited, Perth, Western Australia on 23 March 2010.

7.2 Reliability and date of information This referral was compiled using information sourced from an extensive selection of scientific papers, published reports, books and government websites. All information used has undergone technical, scientific, peer and/or public review, resulting in a referral which contains information of a high quality nature.

7.3 Attachments

� attached Title of attachment(s)

You must attach

figures, maps or aerial photographs showing the project locality (section 1)

� Figure 1

figures, maps or aerial photographs showing the location of the project in respect to any matters of national environmental significance or important features of the environments (section 3)

� Figure 2

If relevant, attach

copies of any state or local government approvals and consent conditions (section 2.5)

N/A

copies of any completed assessments to meet state or local government approvals and outcomes of public consultations, if available (section 2.6)

N/A

copies of any flora and fauna investigations and surveys (section 3)

N/A

technical reports relevant to the assessment of impacts on protected matters that support the arguments and conclusions in the referral (section 3 and 4)

N/A

report(s) on any public consultations undertaken, including with Indigenous stakeholders (section 3)

N/A


REFERRAL CHECKLIST HAVE YOU:

� Completed all required sections of the referral form?

� Included accurate coordinates (to allow the location of the proposed action to be mapped)?

� Provided a map showing the location and approximate boundaries of the project area?

� Provided a map/plan showing the location of the action in relation to any matters of NES?

� Provided complete contact details and signed the form?

N/A Provided copies of any documents referenced in the referral form?

� Ensured that all attachments are less than two megabytes (2mb)?

� Sent the referral to the Department (electronic and hard copy preferred)?


Attachment 1: OSCP Flowcharts


Figure 1 Spill Response


Table 1 OCSP Mobilisation

Tier levels Tier 1 guidance Spill has been stopped

Does not present a hazard Is not likely to impact environmentally

sensitivity areas Is within currently on-site capabilities eg

vessel SOPEP

Tier 2 guidance Spill may not have been stopped

Does present a moderate and local/short term hazard

may impact environmentally sensitivity areas Is not within currently on-site capabilities –

requires additional off-site capabilities


Does present a high and regional/long-term hazard

may impact environmentally sensitivity areas Is not within Shell capabilities eg external help

required Spill Volumes

< 80 litres 80 litres - 10 tonnes 10 - 1000 tonnes > 1000 tonnes

Combat Agencies

Shell

Shell AMSA for C’wealth waters DoT for WA waters

Shell Mobilisation

Implement vessel/ RIG SOPEP

• Implement vessel/RIG SOPEP

• CSR informs DDM within 1hr (ph 0420 909 376)

• DDM informs IRC immediately

• IRC activates IRT • IRT informs EC

• Implement vessel/RIG SOPEP • CSR informs DDM within 1hr (ph 0420 909 376) • DDM informs IRC immediately • IRC activates IRT • IRT informs EC • EC notifies COO • COO activates CMT

External Mobilise

• If response requirements beyond SDA

resources, invoke mutual aid using

Contacts in Appendix 2.

• If AMOSC support and resources

needed, DDM (or Shell Country Chair)

mobilises AMOSC (ph 0438 379 328).

• If response requirements beyond SDA,

invoke mutual aid using Contacts in Appendix

2.

• If AMOSC support and resources needed,

DDM (or Shell Country Chair) mobilises

AMOSC (ph 0438 379 328).

• If Combat Agency Role beyond SDA, DDM

(or Shell Country Chair) hands over Combat

Agency Role to HMA:

• AMSA for C’wealth waters (ph 1800 641 792)

• DoT for State waters(ph 08 9480 9924)

• AMSA response in accordance with NATPLAN

or DoT responses in accordance with

WESTPLAN


Table 2 Spill Response Reporting

Tier levels Tier 1 guidance Spill has been stopped

Does not present a hazard Is not likely to impact environmentally

sensitivity areas Is within current on-site capabilities eg

vessel SOPEP

Tier 2 guidance Spill may not have been stopped Does present a moderate and

local/short term hazard may impact environmentally

sensitivity areas Is not within currently on-site

capabilities – requires additional off-site capabilities


Does present a high and regional/long-term hazard

may impact environmentally sensitivity areas Is not within Shell capabilities eg external

help required

Spill Volumes

< 80 litres

80 litres - 10 tonnes 10 - 1000 tonnes > 1000 tonnes

Inform verbally

CSR informs DDM at next scheduled meeting

• CSR informs DDM within 1hr (ph 0420 909 376)

• DDM informs IRC immediately. • DDM informs DMP Duty Officer

verbally within 2hrs of spill (ph 0419960 621)

• DDM informs NOPSA within 2hrs of spill (ph 08 6461 7090)

• CSR informs DDM within 1hr (ph 0420 909 376) • DDM informs IRC immediately. • DDM informs AMSA within 1hr of spill (ph 1800 641 792) for spills in or likely to enter c’wlth

waters • DDM informs DoT within 1hr of spill for spills in or likely to enter state waters (ph 08 9480

9924) • DDM informs DMP within 2hrs of spill (ph 0419 960 621) • DDM informs NOPSA within 2hrs of spill (ph 08 6461 7090)

Written Report

End of Campaign report

• DDM written report to DMP and NOPSA within 3 days using Incident Report Form (Appendix 8)

• DDM written report to AMSA (fax 02 6230 6868) and/or DoT (fax 08 9216 8982) within 3 days using POLREP (Appendix 1)

• DDM written report to DMP and NOPSA within 3 days using Incident Report Form (Appendix 8)


Attachment 2: AMOSC Exmouth Spill Response Equipment List Description Asset ID Quantity Vikospray Spray Unit MOSES PALA014 G-030-13 1

Simplex Helicopter Spray Bucket; 1 x pair spray arms; emergency spares; 2 x aluminium shipping containers MOSES PDKA216 G-031-02 1

Dispersant transfer pump & hoses; emergency spares; aluminium shipping container - Yanmar MOSES PALA 005/006 G-032-02 1

Komara 12k disc skimmer; power pack and hoses; emergency spares; MOSES PDCA 116/117 G-051-03 1

Ro-Vac vacuum recovery unit; vacuum head and recovery hopper (modified); emergency spares; aluminium shipping container MOSES PDBA 098/099/100/101 G-070-03 1

GT 185 weir skimmer and light oil adaptor; power pack, pallet base and protective cover; hose reel and hoses, pallet base and protective cover; emergency spares; remote control unit; aluminium shipping container, total of 40m offshore hose G-081-02 1

4 x 25 metre lengths Beach Guardian Boom; 4 x soft carrier bags; steel pallet cage (400 m) MOSES PDIA 194 G-110-01 4

4 x 25 metre lengths Beach Guardian Boom; 4 x soft carrier bags; steel pallet cage (100m) 4 cages of 4 booms MOSES PDIA 194 G-110-02 1

2 x 25 metre lengths Versatech Zooom Boom, 2 x soft carrier bags; steel pallet cage MOSES PDHA 177 G-111-01 2

4 x 25 metre lengths Versatech Zooom Boom, 4 x soft carrier bags; steel pallet cage, 3 cages of 4 booms; 1 cage of S/L equipment (7) (300m) MOSES PDHA 177 G-111-02 4

General purpose transfer pump and hoses; emergency spares; aluminium shipping container MOSES PALA 008 G-120-02 1

Beach Guardian deployment kit including: Echo power blower, Honda water pump, suction strainer and hoses, 2 x towing ends, 1 x 80 metre rope & ASTM connectors; emergency spares; aluminium shipping container MOSES PDIA 196 G-130-02 1

Shore anchors including: 10 x steel stakes, 10 x wooden stakes, 1 x ramming cap, 1 x sledge hammer; steel shipping container MOSES PDOA 233/234/235/236/237 G-132-04 1

Fastank 9000 1; steel container, aluminium container (1994) MOSES PBDA 039/041 G-140-02&05 2

3M sorbent (as of May 2004), 4 bags (4x3m each bag), (400 booms=1,200m), 4 bales & 100 sheets sorbent sheet (100 sheets per bag) MOSES MOSA 313 G-150/151-01 1

3M sorbent (as of May 2004) (Cage nos. 10,11,17,19), 6 bags booms (4x3m each bag), Type 56 4 x 100 sheets G-150/151-02 1

OM 240 DP rope mop machine complete; aluminium container, 2 mops, 4 inch MOSES PDAA 133 G-160-02 1

Electric/steam generator; lights; emergency spares MOSES PAKA 001/002/003/004 G-260-01 1

Oiled fauna kit aluminium freight container MOSES MOFA 312 G-330-01 1

Oiled fauna kit contents (consumables) MOSES MOFA 312 G-330-02 1

Decontamination Kit inc. tables, tents, pools, bottles, first aid kit, knives, tarpaulins, gloves, goggles, sorbent, signs etc. (consumables) MOSES PDY 120803 G-331-01 1

Items within AMOSC Response Equipment Container (G-332), 70 ltr bins (2x$60); ASTM Joiners x2; 10ltr fuels cans (2x$25); 27kg anchors (2x$400); Dan floats (4x$150); 250m 12mm rope ($250); Yellow steel toolbox (1x$300) G-332-01-01 0

Response tool box G-500-01 1

Dasic Slickgone NS Dispersent 30 x 1000l ltr (1 t) containers G-604 30