NON-TECHNICAL SUMMARY INTRODUCTION/media/Nanoq/Files/Hearings/2010/Offent… · ENVIRONMENTAL RESOURCES MANAGEMENT CAPRICORN GREENLAND EXPLORATION-1 i NON-TECHNICAL SUMMARY INTRODUCTION

ENVIRONMENTAL RESOURCES MANAGEMENT CAPRICORN GREENLAND EXPLORATION-1

i

NON-TECHNICAL SUMMARY

INTRODUCTION

This is the Non Technical Summary of an Environmental Impact Assessment

(EIA) for an offshore multiple well exploration drilling programme (the

Project). The programme will be conducted within the Sigguk exclusive licence

2008/10 (Sigguk Licence) off west Greenland between June and October 2010,

with a two month contingency window over November and December in case

relief well drilling is required. The EIA has been produced by Environmental

Resources Management (ERM) on behalf of Capricorn Greenland Exploration-

1 Ltd (Capricorn), a subsidiary of Cairn Energy PLC (Cairn).

This EIA includes details related to the entire drilling programme as it is

important that the impacts associated with drilling individual wells are not

assessed in isolation, but considered as part of the wider drilling project.

Detailed environmental survey data is only included for the first two wells of

this programme (Alpha and T8) and this EIA is therefore only intended to

accompany the drilling application for these two wells. Further revisions of

the EIA which include the results of environmental surveys for subsequent

wells will therefore be produced for any drilling application beyond the first

two wells.

The EIA has been undertaken in accordance with applicable Greenland

legislation and standards, international guidance and the corporate policies

and expectations of Cairn.

EIA Standards and Permitting

The regulatory framework for offshore oil and gas activities in Greenland is

currently being revised. The Bureau of Minerals and Petroleum (BMP) is the

main implementing agency for laws relating to hydrocarbon exploration, and

has been consulted throughout this EIA process.

Scope

As well as the EIA, a separate Social Impact Assessments (SIA) has been

produced for the Project by ERM on behalf of Capricorn. Social, economic and

health factors are therefore excluded from the EIA and covered by the SIA.

In preparing this EIA, a range of existing information sources and new studies

have been used. A comprehensive literature review has been conducted using

reports prepared by environmental organisations from Greenland and

Denmark, as well as information sourced during internet research and the

results of computer modelling and simulations. Field surveys have been

conducted to investigate the physical, chemical and biological environment


ii

and studies have been undertaken on weather patterns, ice movements and

currents.

The geographical scope of the EIA includes the Sigguk Licence (also referred to

as the Sigguk Block or the Licence Area) together with the wider marine and

coastal environment where relevant to the potential impacts of the Project.

The focus of the EIA is on the locations within the Sigguk Licence where the

exploration wells are to be drilled (see Figure 1 below).

Figure 1 Sigguk Exclusive Licence 2008/10 Off West Greenland

Proponent and EIA Practitioner

Capricorn Greenland Exploration-1 is a subsidiary of Cairn Energy PLC based

in Edinburgh, UK. Cairn is an independent, public oil and gas exploration

and production company quoted on the London Stock Exchange.


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ERM is a leading global provider of environmental, health and safety, risk,

and social consulting services, with 137 offices in 39 countries employing

approximately 3,300 staff. ERM is a corporate member of the Institute of

Environmental Management and Assessment (IEMA) and has worldwide

expertise in environmental and social impact assessment for offshore oil and

gas projects, including operations in Arctic waters.

ASSESSMENT METHODOLOGY

Overview of the Impact Assessment Process

This EIA has been undertaken following a systematic process that predicts

and evaluates the probable impacts of the Project on aspects of the physical

and biological environments; it identifies measures to mitigate adverse

impacts, and to provide benefits, as far as is reasonably practicable.

The overall approach is shown in Figure 2. Screening and Scoping for the EIA

(and SIA) has been underway throughout Project planning and has involved

consultation with the Greenland Government and key stakeholders, review of

legislation and international standards and examination of previous

environmental studies. Engagement with the authorities and key Non-

Governmental Organisations (NGOs) has continued throughout this process,

as has interaction with the Project Team.

Figure 2 Overview of IA Approach

Baseline Data Collection

To provide a baseline against which potential impacts can be assessed, the EIA

provides a description of the conditions that will prevail in the absence of the

Project. The baseline includes information on all receptors and resources

Screening

Scoping

Sta

keh

old

er e

ng

ag

em

en

t

Inte

racti

on

wit

h p

roje

ct

pla

nn

ing

an

d d

esig

n

Baseli

ne s

tud

ies (

exis

tin

g d

ata

co

lle

cti

on

an

d n

ew

su

rveys)

Predict magnitude of impacts

Evaluate their significance

Investigate options for mitigation

Reassess residual impact (as required)

Assessment

Management Plans/

Mitigation Register

Reporting and Disclosure

Screening

Scoping

Sta

keh

old

er e

ng

ag

em

en

t

Inte

racti

on

wit

h p

roje

ct

pla

nn

ing

an

d d

esig

n

Baseli

ne s

tud

ies (

exis

tin

g d

ata

co

lle

cti

on

an

d n

ew

su

rveys)

Predict magnitude of impacts

Evaluate their significance

Investigate options for mitigation

Reassess residual impact (as required)

Assessment

Management Plans/

Mitigation Register

Reporting and Disclosure


iv

identified as having the potential to be significantly affected by the proposed

Project. For this IA, baseline data collection proceeded in several stages:

• Collection of available data from existing sources including:

o government agencies;

o research and academic organisations;

o published sources;

o external stakeholders and the public; and

o previous offshore exploration Preliminary EIAs held by the client.

• Environmental and geophysical surveys of the well site locations to inform

the physical and biological components of the baseline, including physical,

chemical and biological analysis of samples taken.

• In-country information gathering and stakeholder interviews to inform oil

spill sensitivity mapping and socio-economic baseline for the SIA.

Assessment of Impacts

The assessment describes what will happen by predicting and quantifying as

far as possible the magnitude of impacts. The term ‘magnitude’ is used as

shorthand to encompass all the dimensions of the predicted impact including:

• the nature of the change (what is affected and how);

• its size, scale or intensity;

• its geographical extent and distribution;

• its duration, frequency, reversibility, etc; and

• where relevant, the probability of the impact occurring.

Magnitude also includes any uncertainty about the occurrence or scale of the

impact. An overall grading is provided to determine whether an impact is of

negligible, small, medium or large magnitude.

The next step in the assessment process is to explain what the magnitude of an

impact means in terms of its importance to people and the environment. This

is referred to as Evaluation of Significance. Criteria for assessing the

significance of impacts are clearly defined and take into account whether the

Project will:

• Cause legal or accepted environmental standards to be exceeded, or make

a substantial contribution to the likelihood of a standard being exceeded.

• Adversely affect protected areas or valuable resources, conservation areas,

rare or protected species, protected landscapes, historic features.

• Conflict with established government policy, for example to reduce CO2

emissions or recycle waste.


v

Magnitude and sensitivity are looked at in combination to evaluate whether

an impact is significant and if so its degree of significance (see Figure 3).

Figure 3 Evaluation of Significance

Mitigation and Residual Impacts

Where the assessment results in significant impacts, methods for practical and

affordable mitigation are identified. These measures have been agreed with

the Project proponent and integrated into the Project design. Following

agreement on feasible mitigation, impacts are re-assessed taking into account

the mitigation measures now integrated into the Project. Where an impact

could not be completely avoided the residual impact has been reassessed and

the possibility for further mitigation considered.

ENVIRONMENTAL SETTING

Physical Environment

Climate

The mean monthly air temperatures for sampling sites to the north and south

of the block varied from a minimum of -21.96 °C to the north of Sigguk and a

maximum of 13.15 °C to the south of Sigguk. Average precipitation at the

nearest towns of Aasiaat and Sisimiut varied from 16 mm at Aasiaat in

January and February to 52 mm at Sisimiut in August. Wind speeds at the

Alpha wellsite location varied between an average of 2.9 m/s in July and

6.17 m/s in October (see Figure 4).

Magnitude of Impact

Va

lue

/Se

nsiti

vity

of

Reso

urc

e/R

ece

pto

r

Small Medium Large

Hig

hM

ediu

m

Low

Not Significant

Minor

Moderate

Major


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Figure 4 Comparative Wind Speed Frequency by Direction (July to October)

Source: C-Core, 2009

Bathymetry

The transition to continental slope off central West Greenland occurs at

approximately 400 m deep. Near the Sigguk block the continental shelf is

incised by a broad deep, low-relief channel, informally named the

Uummannaq Channel. The Sigguk block varies in depth from around 300 m

in the east of the block to 1,840 m in the northwest of the block. The first two

wells to be drilled will be located in water depths of 300-450 m. Other

potential drilling sites within the licence area lie in water depths of 370-620 m.

Seabed

The seafloor and shallow geology throughout the Sigguk block is

characterised by a thin layer of relatively fine grained, well sorted, poorly

consolidated sediments that blanket the area and accumulate in seabed

depressions. Surveys of the area have found that areas of the seabed have

been heavily scoured by icebergs. The sediments at both initial drilling sites

are predominantly sandy silt with clay and a small fraction of gravel and

coarser sediment, and with occasional larger, ice-rafted rocks of variable size.

Sediment sampling has been carried out at both initial drilling sites and shows

low organic content of sediments, ranging from < 0.05% to approximately

0.5%.

Oceanography

Surface circulation shows the West Greenland Surface Water flowing north

over the shelf along the west coast of Greenland and Arctic Surface Water

from the Canadian Arctic Archipelago flowing south along the eastern coast of

Baffin Island. Below these surface waters a branch of the Irminger Current

flows north forming West Greenland Intermediate Water over the bulk of the

West Greenland Shelf Slope while Arctic Water and Transition Water flow

south over the western side of the basin. The study site is located near the

transition between north flowing shelf waters to the east and south flowing

waters over the bulk of the basin to the west (see Figure 5).


vii

Figure 5 Regional Currents off West Greenland

Source: Brian Petrie, Bedford Institute of Oceanography

Generally, currents in the study area are weak. The mean surface currents at

the two initial well sites are in the range of 2-3 cm/s up to a depth of

approximately 50 m. Wave heights in eastern Baffin Bay are small. When

larger waves do occur, they are usually of short duration. The maximum

average significant wave height within the Sigguk block occurs from

November through January which coincides with peak monthly wind speeds.

Sea surface temperatures off the west coast of Greenland are lowest in January

and February and highest in August at approximately 6 to 8°C, although

variation throughout the year is low. Sea surface salinity in the study area

also shows little variation.

Ice Conditions

In the Sigguk block, the period between mid-June and mid-November is

normally ice free but occasionally sea ice may drift from the central sections of

southern Baffin Bay into the area during the summer. When sea ice does

occur it tends to be very large floes of thin first year ice. However, the cover

of ice is changeable and large areas of open water are common.

Ice thickness in Davis Strait is highly variable. Ice formed in newly opened

leads often develops a thickness of greater than 0.5 m during winter months.

Older ice that begins forming in autumn often grows to thicknesses of 1.2 m.


viii

Figure 6 Total Concentration of Ice at the Project Area June to October (2007 data)

Source: C-Core, 2009

The drift pattern of sea ice off west Greenland is not well understood, with

local drift to some extent controlled by the major surface systems together

with the strength and direction of the surface winds, especially in southern

waters. Nearly all ice drift in the western portion of Davis Strait is in a

southerly direction, with typical velocities observed in southern Baffin Bay

during winter and spring of 10 cm/s increasing to 20-30 cm/s in Davis Strait.

Icebergs are formed when ice at the outlets of glaciers on the west coast of

Greenland calve from the glacier. Icebergs are formed on the west coast

throughout the year and are carried by sea currents, but also affected by the

wind. Ummannaq Fjord and Disko Bay are important sources of icebergs to

the Disko West region. These areas can produce 10,000-15,000 icebergs per

year. Icebergs tracked for the Project had a mean drift speed of 0.21 m/s and

varied from almost stationary to a maximum of 1.59 m/s (3.1 knots) during

storm conditions. These icebergs drifted in almost all directions but

predominantly east with variability in drift direction caused by the prevailing

current pattern.

Sediments

Environmental surveys at the proposed drilling sites studied the physical,

chemical and biological characteristics of the seabed. Sediment samples from

the well locations and regional samples from other points within the licence

area showed organic content of the sediment to be low, with hydrocarbon

levels consistent with naturally occurring hydrocarbon levels and no

indication of hydrocarbon contamination.


ix

Biological Environment

Primary Production

Primary production (organic matter produced by photosynthesis eg

phytoplankton or algae) off western Greenland is high, although the

important spring bloom usually starts in late April and develops throughout

May, therefore coming before the planned operations. Most primary

production occurs close to the coast and in fjords, with high levels of primary

production also occurring at marginal ice zones.

Zooplankton

Various types of zooplankton (eg shrimp, crustaceans) are present in the

waters off west Greenland and form a key food source for many other species

in this area such as fish, whales and seabirds. More than 85% of the

zooplankton present are crustaceans. The most common are Calanus

copepods which have been found in high numbers over the fishing banks and

deeper waters of Disko Bay.

Invertebrates

Benthic communities are an important ecosystem component on the West

Greenland continental shelf in Baffin Bay, although relative importance

decreases with increasing depth and distance from shore. The benthic

communities found at the two initial wellsite locations were very similar as

they have similar seabed substrates (ice modified silty sediments). No

protected or particularly sensitive habitats were found (eg coral reefs).

Species abundance was comparable or higher than other studies in western

Baffin Bay or southern Davis Strait but was lower for comparable depth

ranges and had similar abundances to those studies conducted in deeper

waters. The diversity of benthic animals was also lower than the southern

Davis Strait.

Fish

The waters around Greenland contain approximately 250 species of fish. Of

these, 18 species of particular importance or common off West Greenland have

been described in the EIA baseline. Thorny skate and Atlantic cod have been

assessed to be Vulnerable on the IUCN Red List, the Greenland shark has been

assessed to be Near Threatened and all other species are of Least Concern.

Most fish will spawn inshore, away from the exploration block, or at other

times of the year when drilling will not take place. The only species that may

spawn in the shallow areas of the block in June is herring.

Seabirds

Within Greenland there are 58 established breeding species of seabird, with a

further 17 species which are regular summer visitors. Due to the harsh

climate very few species overwinter in Greenland, although a number of


x

seabirds winter off the coast around the edge of the fast coastal ice. Seabirds

also aggregate in colonies along the coastline and up to 84% of all colonies in

Greenland are on the west coast. There are 14 species of seabird known to

breed in colonies that are found in the vicinity of the Sigguk block.

Some species of seabird moult their feathers whilst at sea and can form large

rafts of birds. These birds include common eider, king eider, Brünnich’s

guillemot and little auk. During this time they are unable to fly but are still

able to swim at some speed.

Marine Mammals

There are 19 species of marine mammal that regularly occur in the waters and

along the coast of western Greenland in the vicinity of the licence area: 13

species of whale, 5 species of seal, walrus and polar bear. Data on the

numbers and movements of marine mammals off west Greenland remain

sparse, although tracking and distribution studies are ongoing and likely

presence of certain key species can be shown, such as the Beluga wintering

grounds in Figure 7.

Figure 7 Beluga Wintering Ground


xi

Protected Areas and Threatened Species

Fin and blue whale are listed as Endangered on the IUCN Red List. Beluga

and narwhal are listed as Critically Endangered and bowhead whale is listed

as Near Threatened on Greenland’s Red List. All five seal species are listed as

Least Concern or Vulnerable on the IUCN Red List. The harbour seal is listed

as Critically Endangered on Greenland’s Red List. Walrus is listed as

Endangered on the IUCN Red List and polar bears as Vulnerable on both the

IUCN and Greenland Red List.

Atlantic cod and Thorny skate appear as ‘Vulnerable’ on the IUCN red list,

with Greenland shark listed as ‘Near Threatened’. A number of other species

are placed in the category of ’Least Concern’, including Arctic skate, three-

spined stickleback, Atlantic salmon, Arctic char and common grenadier.

The ivory gull is listed as Near Threatened on the IUCN list, with other

species listed as being of Least Concern. This differs from Greenland’s red list,

which lists the common eider, thick-billed murre and ivory gull as Vulnerable;

the Arctic tern, Atlantic puffin and Sabine’s gull as Near Threatened; and the

black-legged kittiwake is listed as Endangered.

Greenland has 11 Ramsar Sites (Wetlands of International Importance), of

which six are found along the west coast. Greenland’s Ilulissat Icefjord has

been designated a UNESCO World Heritage Site and several areas have also

been designated nature reserves or bird protection areas. The legally

protected areas in western Greenland are shown in Figure 8 below.

Figure 8 Protected Areas in Western Greenland

Important Bird Areas in western Greenland as identified by BirdLife

International are shown in Figure 9 below.


xii

Figure 9 Important Bird Areas

THE PROJECT

Capricorn has a working interest in a total of eight exploration licences off the

south and west coasts of Greenland, although the current drilling programme

and the remit of this EIA is concerned solely with the planned exploration

programme in Block 1, Sigguk. The drilling programme is planned to take

place over four months, with a two month contingency for relief well drilling

in case of a major unplanned event (see Table 1 below).

Table 1 Outline Drilling Schedule

2010 May June July August Sept Oct Nov Dec

Mobilisation

Drilling (4 wells)

Relief Well

The programme will involve the drilling of four wells, with the possibility of

drilling up to a further two wells in the same block within the existing project

schedule should initial drilling go faster than expected and if it proves

operationally worthwhile.

The drilling programme itself will employ a range of cutting-edge technology

and operating standards to meet the challenges of drilling in the offshore

Arctic environment. Two mobile offshore drill units (MODUs) (Figure 10) will

be employed in order to provide a high degree of operational and safety

contingency. A number of vessels will be employed to provide support and


xiii

emergency cover for the operations, including supply boats, support vessels

and ice breakers. A ‘wareship’ will provide offshore storage and contingency

accommodation, with helicopters and fixed wing aircraft used to transfer

personnel to and from the field area, the support facilities and the

international airport at Kangerlussuaq. Existing onshore facilities at Nuuk,

Aasiaat, Sisimiut and Ilulissat will be utilised for material lay down, helicopter

operating base, handling of some wastes, supply of fuel, water and materials

and limited onshore accommodation for up to 12 project personnel.

The two MODUs are the Stena Forth, a modern drill ship designed to work in

deep water and harsh conditions including broken ice, and the Stena Don, a

dynamically-positioned semi-submersible drilling unit also designed for work

in harsh environments. As both MODUs remain on station using thrusters

there is no requirement for anchoring during normal operations.

Figure 10 Stena Forth Drillship and Stena Don Semi-Submersible Drilling Rig

Source: Photo courtesy of Stena

The planned drilling depths are between 3,000 and 4,000m below seabed. The

drilling process uses drilling bits of different sizes to drill a series of holes

from the seabed to the planned well depth. Water based muds will be used as

drilling fluids which will be circulated inside of the drill string to the bit in

order to remove cuttings and maintain stability. Although mainly water

(around 75%), for the muds to work effectively, inert substances are also

added such as barite and clays. Various other chemicals will be added to the

mud to provide the qualities required for safe and efficient drilling. The

chemicals used are assessed against international standards and ranked

according to potential toxicity. The Project plans to use only substances

categorised as those which Pose Little Or No Risk (PLONOR) to the Marine

Environment, or that are ranked in the least potentially harmful hazard band

(Gold or E).

Rock cuttings from the drilling process will be circulated back to the drilling

unit where the muds are separated for reuse and the treated cuttings are

discharged to sea. Between 500 and 740 m3 of cuttings are expected to be


xiv

produced from each well. Modelling has shown that the majority of cuttings

will be deposited within 300-800 m of the well location, with bottom

deposition greater than 1 mm extending less than 200 m from each site. Once

each section of the hole has been drilled, the drill string will be lifted out and

casing will be lowered into the hole and cemented into place. At the end of

the drilling programme the used muds will be discharged to sea.

If drilling results indicate the presence of hydrocarbons, the wells may be

tested. Testing is used to establish reservoir and fluid characteristics such as

pressure and flow rate. If required, there will be a controlled flow of

hydrocarbons back to the drill unit where they will be tested and flared. The

likelihood of flaring being undertaken is estimated at less than 6% per well. If

flaring is carried out it will involve an estimated 48 hrs of flow time spread

over 5 days, with the total volume flared from each well estimated at around

30,000 barrels of oil, or 80 million cubic feet of gas. Any flaring will require

permitting by the Greenland authorities and will be monitored for signs of

incomplete combustion. An oil recovery vessel with full dispersant capability

will be on standby throughout the process.

Following completion, the wells will be plugged and suspended. Each well

will have an industry standard wellhead at the surface, with a protective cover

to prevent damage to or from the wellhead due to snagging or collision. Once

all wells have been drilled, the MODUs and support vessels will demobilise to

their next job or home base.

SUMMARY OF IMPACTS AND MITIGATION

The proposed exploration activity has the potential for sources of noise and

atmospheric emissions, as well as physical disturbance and a variety of

discharges and wastes. Those sources identified in this assessment are typical

of drilling activities in waters around the world. There are no unusual or

unique emissions, discharges or other potential sources of environmental

impact. A detailed study of the potential impacts, sensitivity of receptors,

mitigation measures and any residual impact has been carried out and is

included within the EIA report. An overview of the main areas of impact,

related operations and mitigation measures is shown in Table 2 below.

Table 2 Summary of Main Impact Areas, Operations and Mitigation Measures

Potential

Impact

Source of Impact / Area

of Operations

Mitigation Measures

Disruption

to other sea

users

Mobilisation, the 500m

exclusion zone around

drilling operations and

vessel movements to and

from the Project areas.

• Early and ongoing consultation with local communities,

authorities and other key stakeholders. Use of support

vessels to alert other marine craft of the operations.


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Potential

Impact


of Operations

Mitigation Measures

Seabed

impacts

Entry of the drill bit and

cuttings discharged from

the drilling process.

• Anchoring has been avoided by using DP drilling units.

• The seabed has been studied and sampled to establish

the baseline environment. No benthic habitats or species

were identified which have limited distribution or are

considered to be rare or protected.

• Cuttings will be cleaned before being discharged and

dispersion has been modelled to show the extent of

seabed impact from the accumulation of cuttings.

Noise Underwater noise from

drilling and the

movement and

positioning of the

MODUs and vessels.

Airborne noise from

plant and machinery,

plus helicopter and

aircraft movements.

• Regular maintenance programme for plant and

machinery.

• Noise levels are not high enough to cause harm to

marine life and any behavioural response is expected to

be temporary and short term.

• Any use of a seismic source for well testing will follow

industry best practice to minimise disturbance to marine

mammals.

• Helicopter travel will be planned taking into account

sensitive coastal areas and periods to minimise

disturbance.

Air quality Combustion emissions

from plant and

machinery on the

MODUs and vessels.

Emission to air from

aircraft movements.

Emissions to air from

potential well test

flaring.

• Regular maintenance programme for plant and

machinery.

• Use of arctic grade low sulphur fuel to reduce emissions.

• Probability of flaring estimated at less than 10% per

well. Any flaring will be for a limited period (estimated

at 48 hours over 5 days) and will be closely monitored

with spill response vessels on standby.

Water

quality

Discharges of ‘domestic’

drainage and sewage

from the MODUs and

vessels.

Discharge of organic

food waste offshore.

Discharge of cuttings

during drilling and

release of drilling mud at

the end of drilling.

Use of chemical

additives in the mud.

• Sewage, grey water and kitchen waste will be treated,

handled and discharged according to MARPOL

standards.

• Bilge and drainage water will be treated to MARPOL

standards (< 15ppm oil in water).

• Drilling will use only water based muds.

• All chemicals will be registered according to

international standards and the least impacting

chemicals selected which will do the job.

• Cuttings will be treated to remove mud for reuse.

• Any oil on cuttings from the formation will be separated

on the drilling unit. No oil on cutting will be discharged

over the side if it will result in an oil sheen on the

surface

Waste Routine drilling

operations will produce

a range of hazardous

and non-hazardous

wastes.

Limited waste will also

be produced from

vessels and onshore as

part of the support

operations.

• All solid wastes will be transferred to a registered waste

management contractor for disposal at appropriate

licensed facilities. No waste materials, other than

cuttings and food waste, will be discharged to sea.

• All wastes will be managed and disposed of according

to the Waste Management t Plan, the Duty of Care and

relevant legislation.

• Waste oil from any unplanned event will be disposed of

in accordance with the Oil Spill Plan.


xvi

Potential

Impact


of Operations

Mitigation Measures

Oil spills

and

unplanned

events.

A major unplanned

event such as a blow-out

may release large

quantities if crude oil

into the environment.

Storage and refuelling

incidents may also cause

the release of fuel or

chemicals into the

environment.

• Two rigs are being used in order to provide contingency

capability for relief well drilling.

• Oil spill modelling has been carried out and a detailed

oil spill contingency plan implemented.

• In the case of a well control incident, the well will be

closed in at the Blow-Out Preventer (BOP).

• Operating procedures are in place for fuel and material

transfers and onboard storage of hazardous materials.

• An ice management plan will be adopted to help

minimise the risk of collision with icebergs.

• Refuelling operations will be conducted in calm weather

conditions and closely monitored.

The mitigation measures outlined in the EIA and the overall Project Plan are

the result of extensive industry experience with offshore exploration drilling,

and are tried and tested. Furthermore, the management systems required to

implement such measures are well understood and known to be effective.

There is, therefore, a high level of confidence that potential effects will be

reduced to levels As Low As Reasonably Practicable (ALARP) through the

successful implementation of the management and mitigation measures

detailed herein.

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