Oa14 - Epp - Ep201409207550 - 2015 10 21 - Final Redacted

Shelburne Basin Venture Exploration Drilling Project
Environmental Protection Plan
Project Shelburne Basin Venture Exploration Drilling Project
Document Title Environmental Protection Plan
Document Number EP201409207550
Document Revision O4A
Document Status Final - Redacted
Document Type Controlled
Owner / Author Candice Cook-Ohryn/Lara Smandych
Issue Date October 21, 2015
Expiry Date None

Security
Unrestricted
Classification
Disclosure None
Document
EP201409207550
Number:
Date of Issue: October 16, 2015
Custodian: Environmental Lead – Candice Cook-Ohryn/Lara Smandych
Approved by: Venture Manager – Christine Pagan
Document History
REVISION STATUS APPROVAL
Rev. Date Description Originator Reviewer Approver
1 20-Feb-15 Initial Draft C. Cook-Ohryn G. Krauss C. Pagan
2 27-May-15 2nd Draft C. Cook-Ohryn G. Krauss C. Pagan
3 30-July-15 3rd Draft L. Smandych G. Krauss C. Pagan
4 16-Oct-15 Final L. Smandych G. Krauss C. Pagan
5 21-Oct-15 Final-Redacted L. Smandych G. Krauss C. Pagan
Signatures for this Final revision
Document # EP201409207550 -2- October 21, 2015

Revision 5 - Redacted Unrestricted
Acronyms and Abbreviations
Accord Acts ....................... ..Canada-Nova Scotia Offshore Petroleum Resources

Accord Implementation Act and Canada-Nova Scotia
Offshore Petroleum resource Accord Implementation (Nova
Scotia) Act
Accord .................................. Canada-Nova Scotia Offshore Petroleum Resource Accord
ADW .............................................................................................. Approval to Drill a Well
ALARP ........................................................................... as low as reasonably practicable
API ...................................................................................... American Petroleum Institute
ALARP ...............................................................................as low as reasonably practical
BIP ........................................................................................ Business Improvement Plan
BOP....................................................................................................... blowout preventer
CACO ....................................................... Canada Civil Aviation Contingency Operations
CAPP ....................................................... Canadian Association of Petroleum Producers
CCG .............................................................................................. Canadian Coast Guard
CEA Agency .............................................. Canadian Environmental Assessment Agency
CEAA, 2012 ........................................... Canadian Environmental Assessment Act, 2012
CEAR .......................................................Canadian Environmental Assessment Registry
CEPA, 1999 .............................................. Canadian Environmental Protection Act, 1999
C-NLOPB ..................... Canada-Newfoundland and Labrador Offshore Petroleum Board
CNSOPB ................................................ Canada-Nova Scotia Offshore Petroleum Board
CO .......................................................................................................... carbon monoxide
CO2 ............................................................................................................ carbon dioxide
COGOA ................................................................. Canadian Oil and Gas Operations Act
Compensation Guidelines ...................... Compensation Guidelines Respecting Damage
Relating to Offshore Petroleum Activity
COSHH ......................................................... Control of substances Hazardous to Health
CPRA ....................................................................... Canadian Petroleum Resources Act
CSMP ........................................................... UA Contractor HSSE Management Process
CWS ..........................................................................................Canadian Wildlife Service
DFO................................................................................... Fisheries and Oceans Canada

DNV..................................................................................................... Det Norske Veritas
DSL .......................................................................................... Domestic Substances List
DWOP ............................................................................................. Drilling Well on Paper
EA ........................................................................................... environmental assessment
ECE ................................................................................. environmentally critical element
EEM ............................................................................... environmental effects monitoring
EIS ................................................................................ Environmental Impact Statement
EL ....................................................................................................... Exploration Licence
EPP…. .............................................................................. Environmental Protection Plan
EPPG .............................................................. Environmental Protection Plan Guidelines
ERP ........................................................................................ Emergency Response Plan
EVLT ........................................................................ Extended Venture Leadership Team
FCP ................................................................................... Fisheries Communication Plan
GHG ......................................................................................................... greenhouse gas
GWMS........................................................................ Global Wells Management System
H2S . ………………………………………………………………………...Hydrogen Sulphide
HEMP .............................................................. hazards and effects management process
HPU............................................................................................... hydraulic pumping unit
HAZID .....................................................................................Hazard Identification Study
HRA............................................................................................... health risk assessment
HSE ............................................................................... Health, Safety and Environment 1
HSE MS ....................................... Health, Safety and Environment Management System
HSSE ............................................................... Health, Safety, Security and Environment
HSSE & SP ..................... Health, Safety, Security, Environment and Social Performance
HSSE & SP CF………………………………..………..Health, Safety, Security,
Environment and Social Performance
Control Framework
HSSE & SP MS………………………………..………..Health, Safety, Security,
Environment and Social Performance
Management System
HUEBA…………………..………..Helicopter Underwater Emergency Breathing Apparatus
IA ......................................................................................................... impact assessment
1
The term ‘HSE’ can be used interchangeably throughout this submission with the terms ‘HSSE’, ‘HSSE
& SP’, ‘HSE &SP’

IADC........................................................ International Association of Drilling Contractors
IAS ..................................................................................... Integrated Automated System
IATA ...................................................................... International Air Transport Association
IMO ............................................................................ International Maritime Organization
IOGP ..................................................... International Association of Oil & Gas Producers
ISM ................................................................................ International Safety Management
JRCC............................................................................ Joint Rescue Coordination Centre
LMRP ..................................................................................... lower marine riser package
MARPOL ........................... ........................... International Convention for the Prevention
of Pollution from Ships
MARS ............................................................................ Marine Animal Response Society
MBCA ............................................................................... Migratory Birds Convention Act
MEDEVAC .......................................................................................... medical evacuation
MEG .................................................................................................. monoethylene glycol
MERP ........................................................................ Medical Emergency Response Plan
MMO ......................................................................................... marine mammal observer
MOC ............................................................................................. management of change
MODU ..................................................................................... mobile offshore drilling unit
MS . ……………………………………………………………..…………Management System
MSDS ......................................................................................Material Safety Data Sheet
NEB ............................................................................................... National Energy Board
NEBA ....................................................................... Net Environmental Benefits Analysis
NOTMAR.............................................................................................. Notice to Mariners
NOTSHIP ............................................................................................. Notice to Shipping
NOx............................................................................................................ nitrogen oxides
NPRI........................................................................ National Pollutant Release Inventory
OA .............................................................................................. Operations Authorization
OCNS .................................................................. Offshore Chemical Notification Scheme
OCSG................................................................. Offshore Chemical Selection Guidelines
OIM .................................................................................... Offshore Installation Manager
OPRC/IOPP ............................ Oil Pollution Preparedness, Response and Co-Operation
OSP.................................................................................................. Offshore Safety Plan
OSPAR................................................................................ Oslo and Paris Commissions

OSRL .......................................................................................Oil Spill Response Limited
OSRP ........................................................................................... Oil Spill Response Plan
OSV.............................................................................................. offshore support vessel
OWTG ................................................................... Offshore Waste Treatment Guidelines
PAM ...................................................................................... passive acoustic monitoring
PARCOM ............................................................................................. Paris Commission
PCPA ....................................................................................... Pest Control Products Act
PIC ................................................................................................... Person In Command
PLONOR .......................................................... Pose Little or No Risk to the Environment
PMS ................................................................................... Planned Maintenance System
PMR ..................................................................... Performance Monitoring and Reporting
Project ............................................. Shelburne Basin Venture Exploration Drilling Project
PRV ............................................................................................. pressure-reducing valve
PSM ..............................................................................................Process Safety Manual
QA/QC.......................................................................... Quality Assurance/Quality Control
RAM ............................................................................................ Risk Assessment Matrix
RCMP............................................................................. Royal Canadian Mounted Police
RWCP ................................................................................. Relief Well Contingency Plan
SBM ................................................................................................. synthetic-based mud
SDL ..................................................................................... Significant Discovery Licence
SEPCO.......................................................... Shell Exploration and Production Company
Shell ................................................................................................ Shell Canada Limited
SIA ....................................................................................................... Shell Internal Audi
SMBR ............................................................................. Shell Maritime Business Review
SMS .......................................................................... Stena Drilling Management System
SOCP ..................................................... Statement of Canadian Practice with Respect
to the Mitigation of Seismic Sound in the
Marine Environment
SOPEP .................................................................................. Shipboard Oil Pollution Plan
SOU . ……………………………………………………………………..Shell Open University
SOx ............................................................................................................. sulphur oxides
Stena ............................................................................................... Stena Drilling Limited
SWIS ............................................................................. Subsea Well Intervention Service
TDG.......................................................................... Transportation of Dangerous Goods

TIPS ...............................................................Technical Integrity Performance Standards
TQSP .........................................................Training and Qualifications Standard Practice
TVD ....................................................................................................... true vertical depth
UA ............................................................................................. Shell Upstream Americas
UAX ................................................................................. Upstream Americas Exploration
UK ............................................................................................................ United Kingdom
VLT........................................................................................... Venture Leadership Team
VOC ......................................................................................... volatile organic compound
VSP ................................................................................................ vertical seismic profile
WBM ...................................................................................................... water-based mud
WCB ..................................................................................Workers’ Compensation Board
WCP .............................................................................................. Well Containment Plan
WRP ............................................................................................. Wildlife Response Plan

DEFINITIONS
The following are specific terms and/or words that require additional clarification in this
document:
Shell Canada Limited - in the context of this document Shell Canada Limited (Shell)
refers to the Operator of the Shelburne Basin Venture and the Shelburne Basin Venture
Drilling Project (the Project), as well as those parts of the Shelburne Basin Venture
Team that undertake activities on behalf of Shell Upstream Americas Exploration (UAX),
e.g., the Shelburne Basin Venture Leadership Team (VLT).
Shelburne Basin Venture - all activities related to the Shell Canada Limited EL
acquisitions of 2012 and 2013.
The Project - the 2015 Shelburne Basin Venture Drilling Project, which is comprised of
all activities related to the drilling, and the suspension or abandonment of, two
Deepwater exploration wells in the Nova Scotia Offshore Area, from mid-2015 through
2016.
This document:
• will be held in the Common Library and can be accessed via the Shelburne
Venture SharePoint site. Controlled versions and revision announcements will be
published, and communicated to the appropriate Shell and contractor personnel
to ensure local implementation. Copies or extracts of this document, which have
been downloaded from the Sharepoint site, are uncontrolled copies and cannot
be guaranteed to be the latest version.
• may set requirements supplemental to applicable law and policy. However,

nothing herein is intended to replace, amend, supersede or otherwise depart
from any applicable law relating to the subject matter of this document. In the
event of any conflict or contradiction between the provisions of this document
and applicable law as to the implementation and governance of this document,
the provisions of applicable law shall prevail.

TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS ........................................................................ 3
DEFINITIONS ............................................................................................................. 8
FORWARD ............................................................................................................... 15
1. GENERAL ........................................................................................................ 18
2. PURPOSE AND SCOPE .................................................................................. 19
3. PROJECT DESCRIPTION ............................................................................... 20
3.1 Exploration Drilling Project versus Drilling Program ................................. 20
3.2 Initial Well locations .................................................................................. 21
3.3 Stena IceMax Drillship .............................................................................. 21
3.4 Helicopter Support .................................................................................... 21
3.5 Onshore Supply Base .............................................................................. 21
3.6 Support vessels ........................................................................................ 22
3.7 Office ........................................................................................................ 22
4. LEGAL REQUIREMENTS ................................................................................ 23
4.1 Regulatory Framework ............................................................................. 23
4.2 Guidance and Adopted Standards ........................................................... 25
4.2.1 Environmental Guidelines ............................................................ 25
4.2.2 Adopted Codes and Standards .................................................... 25
4.2.3 Shell’s Environmental Standards ................................................. 26
4.3 Applicable Plans and Procedures............................................................. 26
4.3.1 Routine Operations ...................................................................... 27
4.3.2 Emergency Preparedness and Response ................................... 30
5. SHELL HSSE MANAGEMENT SYSTEM......................................................... 35
5.1 Leadership and Commitment ................................................................... 37
5.2 Policies and Objectives ............................................................................ 38
5.2.1 Shell’s Commitment and Policy ................................................... 38
5.2.2 Stena Health, Safety & Environmental Health Policy
Statement .................................................................................... 40
5.2.3 Stena Management System ........................................................ 41
5.2.4 Objectives & Targets ................................................................... 42
6. ORGANIZATION, RESPONSIBILITIES AND RESOURCES........................... 43
6.1 Venture Level Organization and HSE Accountability................................ 43
6.1.1 Contractor Level Roles & Responsibilities ................................... 44
6.1.2 Environmentally Critical Roles ..................................................... 45
6.2 EPP Responsibilities ................................................................................ 46
7. HAZARD IDENTIFICATION AND RISK EVALUATION................................... 49
7.1 Hazard and Effects Management Process ............................................... 49
7.1.1 Risk Assessment Matrix (RAM) ................................................... 50
7.1.2 Bow Tie Analysis ......................................................................... 51

7.2 Environmental Assessment ...................................................................... 53
7.3 HSSE Studies........................................................................................... 55
7.3.1 HSSE Study Results .................................................................... 57
8. AWARENESS, COMPETENCE AND TRAINING ............................................ 59
8.1 Awareness................................................................................................ 59
8.2 Competence ............................................................................................. 59
8.3 Training .................................................................................................... 60
8.4 Contractor Management ........................................................................... 61
9. EPP MANAGEMENT........................................................................................ 63
9.1 EPP Review and Revision ........................................................................ 63
9.2 Document Control .................................................................................... 63
9.3 EPP Communication and Distribution ...................................................... 64
10. OPERATIONAL CONTROL ............................................................................. 66
10.1 Operations and Maintenance Procedures ................................................ 66
10.2 Structures, Facilities, Equipment and Systems Critical to
Environmental Protection ......................................................................... 66
10.2.1 Certificate of Fitness and Certification ......................................... 67
10.3 Management of Change ........................................................................... 68
11. MONITORING AND REPORTING.................................................................... 70
11.1 Performance Measurement and Compliance Monitoring ......................... 70
11.2 Audits and Inspections ............................................................................. 70
11.3 Managing Non-Conformities ..................................................................... 71
11.4 Records Management .............................................................................. 72
11.5 Continual Improvement ............................................................................ 73
11.6 Environmental Reporting .......................................................................... 74
12. ENVIRONMENTAL PROTECTION AND COMPLIANCE MONITORING
OF WASTE STREAMS .................................................................................... 76
12.1 Offshore Production Waste Streams ........................................................ 76
12.1.1 Summary of Offshore Waste Streams ......................................... 77
12.1.2 Authorized Discharges Subject to Compliance
Monitoring/Reporting ................................................................... 77
12.1.3 Authorized Waste Discharges Requiring Routine Reporting
but not Compliance Monitoring .................................................... 78
12.1.4 Authorized Waste Discharges Not Requiring Compliance
Monitoring or Routine Reporting .................................................. 78
12.1.5 Prohibited Discharges or Discharges Requiring Case by
Case Authorization ...................................................................... 79
12.2 Air Emissions............................................................................................ 79
12.2.1 Overview ...................................................................................... 79
12.2.2 Environmental Objectives ............................................................ 79
12.2.3 Environmental Protection Measures ............................................ 79
12.2.4 Compliance Monitoring Requirements ......................................... 80
12.2.5 Reporting ..................................................................................... 80
Document # EP201409207550 - 10 - October 21, 2015

12.3 Bilge and Ballast Discharges .................................................................... 80
12.3.1 Overview ...................................................................................... 80
12.3.5 Reporting ..................................................................................... 81
12.4 Deck Drainage.......................................................................................... 82
12.4.1 Overview ...................................................................................... 82
12.4.5 Reporting ..................................................................................... 83
12.5 Sewage and Grey Water .......................................................................... 84
12.5.4 Reporting ..................................................................................... 84
12.6 Cooling Water........................................................................................... 84
12.6.1 Overview ...................................................................................... 84
12.6.4 Reporting ..................................................................................... 85
12.7 Drilling Discharges ................................................................................... 85
12.7.1 Overview ...................................................................................... 85
12.7.5 Reporting ..................................................................................... 87
12.8 Blowout Preventer Fluids.......................................................................... 87
12.8.1 Overview ...................................................................................... 87
12.8.5 Reporting ..................................................................................... 89
12.9 Firewater and Fire Protection ................................................................... 89
12.9.1 Overview ...................................................................................... 89
12.9.5 Reporting ..................................................................................... 90
13. ADDITIONAL ENVIRONMENTAL PROTECTION CONSIDERATIONS .......... 91
13.1 Handling of Helifuel .................................................................................. 91
13.1.1 Overview ...................................................................................... 91

13.1.5 Reporting ..................................................................................... 92
13.2 Transfer of Fuel, Bulk Drilling Fluids and Liquid Wastes between
Vessels and Rig ....................................................................................... 92
13.2.4 Reporting ..................................................................................... 93
13.3 Vessel Operations .................................................................................... 93
13.3.1 Mobile Offshore Drilling Unit (MODU) .......................................... 94
13.3.2 Offshore Support Vessels (OSVs) ............................................... 95
13.4 Helicopter Operations ............................................................................... 96
14. CHEMICAL SELECTION AND MANAGEMENT .............................................. 98
14.1 Chemical Selection ................................................................................... 98
14.2 Offshore Chemical Management .............................................................. 98
14.3 Reporting .................................................................................................. 99
15. WASTE MANAGEMENT ................................................................................ 100
16. SPECIALIZED OPERATIONS ....................................................................... 101
16.1 Routine Testing of Blowout Preventer .................................................... 101
16.1.1 BOP Seal Hydrate Buildup Prevention ...................................... 101
See Section 12.8 of the EPP for further information on this activity. ...... 101
16.2 Routine Testing of Fire Suppression System ......................................... 101
16.3 Vertical Seismic Profiling ........................................................................ 101
16.4 Well Abandonment ................................................................................. 101
17. ENVIRONMENTAL INCIDENTS .................................................................... 103
17.1 Incident Reporting and Investigation ...................................................... 103
17.1.1 Incident Reporting to the CNSOPB............................................ 103
17.1.2 Incident Reporting to Other Authorities ...................................... 104
17.1.3 Incident Investigation ................................................................. 107
17.1.4 Exceedances and Sheens ......................................................... 108
18. ADDITIONAL ENVIRONMENTAL MONITORING ......................................... 109
18.1 Stranded Bird Monitoring and Handling .................................................. 109
18.2 Marine Mammal Monitoring .................................................................... 110
18.3 Spill Environmental Effects Monitoring ................................................... 110
19. PUBLIC AND STAKEHOLDER COMMUNICATION ..................................... 112
19.1 Communication with the Public .............................................................. 112
19.2 Communication with Commercial and Aboriginal Fisheries .................... 112
19.3 Communication with Regulatory Agencies ............................................. 114
20. REFERENCES ............................................................................................... 115
APPENDIX A – SHELBURNE BASIN VENTURE ORGANIZATION CHART ........ 117

APPENDIX B – LEACH’S STORM PETREL: GENERAL INFORMATION AND
HANDLING INSTRUCTIONS (WILLIAMS AND CHARDINE 1999) .............. 118
APPENDIX C – SHELBURNE BASIN VENTURE WASTE MANAGEMENT
PLAN (EP201505209133) .............................................................................. 119
APPENDIX D – SUMMARY OF MITIGATION, MONITORING AND FOLLOW
UP COMMITMENTS ....................................................................................... 120
APPENDIX E – CEAA DECISION STATEMENT CONDITIONS ............................ 125

LIST OF TABLES
Table 4.1 Legislation/Regulations/Directives ................................................... 24
Table 4.2 Environmental Management Plans .................................................. 28
Table 4.3 Emergency Response Plans ........................................................... 31
Table 6.1 EPP Roles and Responsibilities....................................................... 47
Table 7.1 EIS Assessment Summary .............................................................. 53
Table 7.2 HSSE Studies .................................................................................. 55
Table 7.3 Identified and Assessed Project Hazards ........................................ 57
Table 9.1 Document Control Records and Storage Location........................... 64
Table 9.2 EPP Distribution List ........................................................................ 64
Table 12.1 Summary of Operational Discharges ............................................... 77
Table 13.1 Operating Criteria for Stena IceMAX ............................................... 94
Table 13.2 Operating Criteria for Helicopters .................................................... 96
Table 17.1 Other Authorities ............................................................................ 105
LIST OF FIGURES
Figure 3.1 Project Location ............................................................................... 20
Figure 5.1 HSSE & SP Control Framework ...................................................... 36
Figure 5.2 Shell HSSE & SP Commitment and Policy ...................................... 39
Figure 5.3 Stena Drilling Health, Safety and Environmental Health Policy ....... 40
Figure 5.4 Stena Drilling Environmental Protection Policy ................................ 41
Figure 6.1 Onshore/Offshore Operations Interface Organizational Chart ......... 48
Figure 7.1 Hazard Identification System ........................................................... 50
Figure 7.2 Risk Assessment Matrix .................................................................. 51
Figure 7.3 Bow-Tie Analysis Diagram ............................................................... 52
Figure 8.1 Onshore/Offshore Operations Interface Organizational Chart ......... 59
Figure 10.1 Management of Change .................................................................. 68
Figure 11.1 Shell’s continual Improvement Cycle ............................................... 73

FOREWORD
This Environmental Protection Plan (EPP) (EP201409207550) is intended to provide the

environmental components of the larger HSSE management system framework for the
Shell Canada Limited (Shell) Shelburne Basin Venture Drilling Project (the Project) to
ensure the implementation of sound environmental management and protection in
association with the operational activities under the jurisdiction of the Canada-Nova
Scotia Offshore Petroleum Board (CNSOPB).
It is Shell’s policy to comply fully with all applicable statutory and regulatory
requirements. Approvals granted under the CNSOPB for the Project do not exempt
Shell from complying with all applicable legislation and other legal requirements. Note
that if Shell requires a higher level of environmental protection or management than the
applicable laws and regulations, the most stringent requirement will apply. Should a
case be noted where local regulatory requirements impedes on the higher Shell
standard, the issue will be brought to the attention of the appropriate regulatory agency.
This EPP identifies and outlines the environmental management for all personnel,
including contractors, that function in any capacity within the project and has been
developed to provide effective guidance on environmental management for Project
activities.
The EPP is established to identify and outline the environmental management

measures to be implemented in association with the Project and required of all
personnel, including contractors, that function in any capacity in association with the
Project. Additionally, this EPP is put in place to ensure compliance with relevant existing
environmental management commitments and requirements for Project operations. As
a result, this document should be read in conjunction with other environmental
regulatory documents, such as the Environmental Impact Statement (EIS) for the
Project (Stantec 2014) and regulatory approvals obtained in support of the Project, for
further detail and background.
The table below is a concordance table showing where each section of the CNSOPB/C-
NLOPB/NEB Environmental Protection Plan Guidelines (the Guidelines) can be found in
this document.

CONCORDANCE TABLE: CNSOPB EPP GUIDELINES TO SHELL’S EPP
SEC # CNSOPB EPP GUIDELINES SEC # SHELL EPP

FOREWORD
4.1 GENERAL
1 GENERAL
2 PURPOSE
4.2 PURPOSE AND SCOPE OF THE EPP
2 SCOPE
SHELL HSE POLICY
ENVIRONMENTAL POLICY 5.2.1
4.3 STENA ENVIRONMENTAL
STATEMENT 5.2.2
PROTECTION POLICY
APPLICABLE PLANS AND
4.3
APPLICABLE PLANS AND PROCEDURES
4.4
PROCEDURES OPERATIONS AND MAINTENANCE
10.1
PROCEDURES
4.5 PLANNING
HAZARD IDENTIFICATION, HAZARD IDENTIFICATION AND RISK
7.1
4.5.1 EVALUATION AND RISK EVALUATION
7.2
MITIGATION ENVIRONMENTAL ASSESSMENT
4.5.2 LEGAL REQUIREMENTS 4.1 REGULATORY FRAMEWORK
COMMITMENTS BY THE
4.5.3 5.2.4 OBJECTIVES AND TARGETS
OPERATOR
ADOPTED CODES AND STANDARDS
GUIDANCE AND ADOPTED 4.2.2
4.5.4 SHELL’S ENVIRONMENTAL
STANDARDS 4.2.3
STANDARDS
ENVIRONMENTAL PROTECTION AND
4.5.5 DISCHARGE LIMITS 12 COMPLIANCE MONITORING OF
WASTE STREAMS
4.6 IMPLEMENTATION AND OPERATIONS
RESOURCES, ROLES,
ORGANIZATION, RESPONSIBILITIES
4.6.1 RESPONSIBILITIES AND 6
AND ACCOUNTABILITIES
AUTHORITY
LEADERSHIP AND COMMITMENT
COMMITMENT, LEADERSHIP AND 5.1
4.6.2 VENTURE LEVEL ORGANIZATION AND
PARTICIPATION 6.1
HSE ACCOUNTABILITY
4.6.3 AWARENESS, COMPETENCE, AND TRAINING
4.6.3.1 AWARENESS 8.1 AWARENESS

8.2 COMPETENCE
4.6.3.2 COMPETENCE AND TRAINING
8.3 TRAINING
EPP COMMUNICATIONS AND
9.3 DISTRIBUTION
4.6.4 COMMUNICATION
19 PUBLIC AND STAKEHOLDER
COMMUNICATION
4.6.5 DOCUMENT CONTROL 9.2 DOCUMENT CONTROL

CONCORDANCE TABLE: CNSOPB EPP GUIDELINES TO SHELL’S EPP
SEC # CNSOPB EPP GUIDELINES SEC # SHELL EPP
4.6.6 OPERATIONAL CONTROL

OPERATIONS AND MAINTENANCE OPERATIONS AND MAINTENANCE
4.6.6.1 10.1
PROCEDURES PROCEDURES
STRUCTURES, FACILITIES,
EQUIPMENT AND SYSTEMS ENVIRONMENTAL CRITICAL
4.6.6.2 10.2
CRITICAL TO ENVIRONMENTAL EQUIPMENT
PROTECTION
SELECTION AND USE OF CHEMICAL SELECTION AND
4.6.7 14
CHEMICAL SUBSTANCES MANAGEMENT
4.6.8 DISPOSAL OF WASTE MATERIAL 15 WASTE MANAGEMENT
4.6.9 MANAGEMENT OF CHANGE 10.3 MANAGEMENT OF CHANGE
4.6.10 ENVIRONMENTAL INCIDENTS

EMERGENCY PREPAREDNESS EMERGENCY PREPAREDNESS AND
4.6.10.1 4.3.2
AND RESPONSE RESPONSE
INCIDENT REPORTING AND INCIDENT REPORTING AND
4.6.10.2 17.1
INVESTIGATION INVESTIGATION
4.7 CHECKING
COMPLIANCE MONITORING AND PERFORMANCE MEASUREMENT AND
4.7.1 11.1
PERFORMANCE MEASUREMENT COMPLIANCE MONITORING
ENVIRONMENTAL EFFECTS ADDITIONAL ENVIRONMENTAL
4.7.1.2 13
MONITORING MONITORING
4.7.2 AUDITING AND REVIEW
MANAGEMENT OF NON
4.7.3 MANAGING NON-CONFORMITIES 11.3
CONFORMITIES
4.7.4 CONTROL OF RECORDS 11.4 RECORD MANAGEMENT
PERFORMANCE MEASUREMENT AND
4.8 CONTINUAL IMPROVEMENT 11.5
COMPLIANCE MONITORING

1. GENERAL
This Environmental Protection Plan (EPP) has been developed in support of the
proposed Shell Canada Limited (Shell) Shelburne Basin Venture Exploration Drilling
Project (the Project) to meet the requirements of Shell’s Commitment and Policy on
Health, Security, Safety, the Environment and Social Performance (HSSE & SP
Commitment and Policy), further described in Section 5, which requires consideration of
environmental protection in all operations and activities as well as a systematic
approach to HSSE management in order to ensure compliance with the law.
Additionally, this EPP has been developed to meet the requirements for implementation
of a management system under the Canada-Nova Scotia Offshore Petroleum
Resources Accord Implementation Act (S.C. 1988, c.28) and Section 6(d) and 9 of the
Nova Scotia Offshore Drilling and Production Regulations (SOR/2009-317) which
require that an EPP is submitted in support of an application to conduct work or
activities related to drilling operations offshore Nova Scotia.
This EPP is the written demonstration that the Project complies with internal Shell,
external CNSOPB environmental management requirements and all related provincial
and federal legislation, including the Conditions outlined in the Decision Statement
issued under Section 54 of the Canadian Environmental Assessment Act, 2012 (CEAA)
(Appendix E).

2. PURPOSE AND SCOPE
The purpose of this EPP is to communicate Project requirements and commitments for
environmental management and protection to all Project personnel (including Shell staff
and contractors), regulatory agencies, other stakeholders, and potentially affected and
interested First Nations. This EPP outlines the respective environmental management
processes and procedures from the Shell HSSE & SP Control Framework (HSSE & SP
CF) which is Shell’s overarching Safety and Environmental Management System that
will be executed for the Project.
This EPP is aimed at outlining Project-specific environmental protection and

management procedures intended to manage potential Project-environment interactions
and identified hazards. Additionally, included in the EPP are relevant operational
commitments made and conditions imposed in association with the Environmental
Assessment completed in compliance with the Canadian Environmental Assessment
Act, 2012 or to ensure compliance with environmental regulatory requirements.
The scope of the EPP includes activities for the Project which will consist of the drilling,
and the suspension or abandonment of two Deepwater exploration wells, commencing
Q4 2015. The wells will be drilled by a mobile offshore drilling unit (MODU), with support
from one dedicated stand-by vessel, three offshore supply vessels (one of which will be
a back-up stand-by vessel), helicopter operations and a dedicated onshore supply base.

3. PROJECT DESCRIPTION
3.1 Exploration Drilling Project versus Drilling Program
The Project will be phased and divided into two separate drilling campaigns consisting
of up to seven exploration wells drilled over a four year period, from 2015 through 2019,
in accordance with the exploration period of the Exploration Licences (ELs). The second
drilling campaign or Project phase will be dependent upon the results of the first
campaign.
For the purpose of the EPP, the Project will consist of the drilling, and the suspension or
abandonment of two Deepwater exploration wells, commencing in Q4 2015. An
Operations Authorization (OA) and two Approval to Drill a Well (ADW) approvals will be
required from the CNSOPB prior to commencing operations.
The exploration drilling Project Area is shown in Figure 3.1 and encompasses portions
of Shell’s offshore ELs 2423, 2424, 2425, 2426, 2429 and 2430. The Project Area is
located approximately 250 km offshore from Halifax in a geographical offshore area
known as the Southwest Scotian Slope and a geological region known as the Shelburne
Basin. Water depths in the Project area range from 1500 m to 3000 m
Figure 3.1 Project Location

3.2 Initial Well locations
Specific drilling locations have been selected using data gathered from the 2013
Shelburne Basin 3D Seismic Survey, as well as more detailed Seabed, Geotechnical
and Geo-hazard Survey that was conducted in 2014.
Initially two exploration wells will be drilled in the Project Area, commencing in Q4 2015.
The specific technical details for the wells will be outlined in the drilling programs for
these wells, and will be submitted to the CNSOPB.
3.3 Stena IceMax Drillship

Each well in the first drilling campaign will be drilled using the Stena IceMax drillship.
The Stena IceMax is a dual mast, dynamically positioned, Polar Class 4, harsh
environment, ultra Deepwater drillship, designed and certified for year round worldwide
operations. Further details and description of the drillship and Stena’s Health, Safety
and Environment (HSE) Management System is provided in the Stena IceMax HSE
Case and Section 11.3 of this EPP.
3.4 Helicopter Support

Shell will have three Sikorsky S-92 helicopters under contract. Two will be equipped for
passengers (16 – 18 passengers), and one SAR/Medivac. They will be based at a
Heliport located at the HNZ/Canadian Helicopters Hangers at the Halifax Stanfield
International Airport will be used for the transfer of personnel from Heliport to the Stena
IceMax.
One of the helicopter’s will be used for crew change from Heliport to the Stena IceMax
while the other will serve as a technical back-up for the primary crew change helicopter
and for the SAR helicopter. A third helicopter is dedicated to Search and Rescue flights
and Medivac. It has the capability of rescue from vessels and the water using divers. A
thorough risk assessment has been performed for this operation and a mitigation plan
will be in place, with appropriate actions closed including pre-startup checks prior to rig
operations start-up.
3.5 Onshore Supply Base

The Woodside Supply Base (the Supply Base), located in Dartmouth, Nova Scotia in
Halifax Harbour is managed by the Blue Water Group under contract to Shell. The
Supply Base will allow for the storage of equipment and will have a Mud Plant and
Cement Silos, which are required to support Project drilling activities. Supply vessels
can moor directly at the Supply Base for vessel loading/off-loading of mud, equipment
or other materials. The Mud Plant operations at the Supply Base and the supply of
equipment to the Supply Base are outside the scope of this document.

3.6 Support vessels
Various support vessels (standby and supply) will be on contract for the duration of the
Project to support the Stena IceMax with day to day operations. The support vessels will
be prepared and certified for passenger transfers to the IceMax.
3.7 Office
Project operations will be managed from the Shell Halifax Office, which includes an
Emergency Control Center. The address is as follows:
Shell Canada Limited

1701 Hollis Street
10th Floor Founders Square
Halifax, Nova Scotia B3J 3M8
24 hour Duty Officer – <Redacted>

Nova Scotia Business Manager – <Redacted>
Nova Scotia HSSE Manager – <Redacted>

4. LEGAL REQUIREMENTS
4.1 Regulatory Framework
Petroleum activities in Nova Scotia’s offshore area are regulated by the CNSOPB, a
joint federal-provincial agency reporting to the federal Minister of Natural Resources
Canada and the provincial Minister of Energy. Additionally, a number of Federal
regulators are mandated for the management of various environmental resources and
components relevant to the Project.
The key Acts, Regulations and Directives relevant to environmental management of

Project operations within the scope of this EPP are summarized in Table 4.1.

Table 4.1 Legislation/Regulations/Directives
Statutory Document Responsible Regulatory Authority

Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act and Canada-Nova CNSOPB
Scotia Offshore Petroleum Resource Accord Implementation (Nova Scotia) Act (Accord Acts)
Nova Scotia Offshore Petroleum Drilling and Production Regulations CNSOPB
Nova Scotia Offshore Petroleum Installation Regulations CNSOPB
Nova Scotia Offshore Area Petroleum Geophysical Operations Regulations (and associated CNSOPB
Guidelines)
Nova Scotia Offshore Certificate of Fitness Regulations CNSOPB
Canadian Environmental Assessment Act, 2012 CEAA
Canadian Environmental Protection Act and Regulations Environment Canada
Migratory Birds Convention Act and Regulations Environment Canada
Species at Risk Act Environment Canada, Parks Canada,
Fisheries and Oceans Canada
Fisheries Act and Regulations Fisheries and Oceans Canada and
Environment Canada
Hazardous Product Act and Regulations Health Canada
Navigation Protection Act and Regulations Transport Canada
Transportation of Dangerous Goods Act and Regulations Transport Canada
The Oceans Act, 1996 Fisheries and Oceans Canada

4.2 Guidance and Adopted Standards
4.2.1 Environmental Guidelines

A number of existing guidance documents have been used to guide the development of
this EPP and to inform the requirements for environmental management and protection
during Project Operations. These environmental guidelines include:
• CNSOPB/CNLOPB Drilling and Production Guidelines (2009)

• CNSOPB/CNLOPB/NEB Environmental Protection Plan Guidelines (2011)
• CNSOPB/CNLOPB/NEB Offshore Waste Treatment Guidelines (2010)
• CNSOPB/CNLOPB/NEB Offshore Chemical Selection Guidelines (2009)
• CNSOPB/CNLOPB/NEB Offshore Physical Environment Guidelines (2008)
• Compensation Guidelines Respecting Damage Relating to Offshore Petroleum
Activity
• CNSOPB/CNLOPB Guidelines for Reporting and Investigation of Incidents
(2012)
• Statement of Canadian Practice with Respect to the Mitigation of Seismic Sound
in the Marine Environment (SOCP)
• Environment Canada’s Avoidance Guidelines for Migratory Birds
• Shell HSSE &SP CF Environment Manual Guides
o Water in the Environment Guide (V3-2013)
o Biodiversity Guide (V1-2013)
4.2.2 Adopted Codes and Standards
The Project will operate to current industry codes and standards along with Shell and
Contractor internal design standards to demonstrate asset integrity.
The primary Industry Organizations that support Project Operations are:
• International Association of Drilling Contractors (IADC)

• International Association of Oil & Gas Producers (IOGP)
• American Petroleum Institute (API)
Shell and Stena also comply with applicable Marine Codes and standards from the
following organizations in regards to environmental protection and management:
• IMCA – International Marine Contractors Association

• IMO – International Maritime Organization
o IMO – International Convention for the Prevention of Pollution from Ships
(MARPOL)

o IMO – International Convention on Oil Pollution Preparedness, Response
and Co-Operation (OPRC/IOPP)
4.2.3 Shell’s Environmental Standards
Section 5.3 of the OSP provides a detailed list of Shell’s primary drilling and logistical
standards that will be adopted for the Project and are inclusive of environmental
protection and management requirements where necessary. In addition to these
primary standards, Shell’s Health, Safety, Security, Environment and Social
Performance (HSSE & SP) Control Framework (HSSE &SP CF) contains a number of
manuals that specifically outline the associated requirements for environmental
management. The following internal environmental standards outlined under the HSSE
&SP CF have been used to inform and guide the environmental protection and
management for the Project and construction of this EPP:
• Environmental Manual – Biodiversity (V3 -2012)

• Environmental Manual – Greenhouse Gas and Energy Management (V4-2013)
• Environmental Manual – Specification for Discharge to Water (V3-2013)
• Environmental Manual – Water in the Environment (V3-2013)
• Environmental Manual – Waste (V2-2009)
• Projects Manual – Impact Assessment (V3-2011)
• Product Stewardship Manual – Product Stewardship (V2-2009)
4.3 Applicable Plans and Procedures

In order to ensure operational compliance with both internal and external requirements,
commitments and standards for environmental protection and management, a number
of Project level plans have been compiled, inclusive of this EPP, to guide operational
activities. These plans are intended to ensure that Project operations are conducted in a
manner that aligns with the established environmental standards and expectations for
the Project, accomplishes and complies with environmental mitigation commitments and
requirements and meets the outlined objectives and targets for environmental
performance.
The sections below provide an overview of the associated plans established to support
routine Project operations as well as emergency response in association with
environmental protection and management. Relevant procedural and guidance
documents incorporated into the associated plans or used to guide the plan have been
referenced in the sections below as relevant.

4.3.1 Routine Operations
The plans outlined in Table 4.2 are operational documents established to outline
environmental management and protection measures and requirements for routine
Project operations.

Table 4.2 Environmental Management Plans
Title Description Stena MS Shell MS

Operations Safety Plan An Project specific OSP has been created to support Stena IceMax HSE Case Shelburne Basin
(OSP) exploration drilling activities. This plan has been drafted L4-DOC-ICE-4126 Venture Operations
in to meet the requirements of Section 6(c) and Section L4-DOC-ICE-4127 Safety Plan
8 of the Regulations as well as internal safety (EP201501216147)
requirements under Shell’s HSSE &SP CF. . L4-DOC-ICE-4128
This plan will be managed as an evergreen document. L4-DOC-ICE-4129
The OSP is aimed at providing the HSSE Management L4-DOC-ICE-4131
System framework for the Project. The management
system is intended to ensure operators have Refer to OSP for full list of
documented policies and procedures for how they will Stena MS safety
carry out their activities while ensuring compliance and management document.
safety, environmental protection and prevention of
waste (resource conservation).
The OSP is aimed at demonstrating compliance to the

CNSOPB Acts and Regulations and is used to aid the
Project Team to achieve its business objectives of
driving continuous HSSE & SP performance
improvements and achieving Shell’s objective of Goal
Zero, which is no harm to people and no harm to the
environment.
Waste Management Plan A Project specific WMP has been drafted to support Environmental Protection Environmental Manual –
(WMP) exploration drilling activities and is included as Appendix Policy Waste Specification (V2
C of this EPP. L1-POL-MD-005 -2009)
The purpose of the WMP is to detail the management Management of Waste Wells HSSE & SP
processes and procedures for waste that is generated in Offshore Manual WS
association with the Project. In line with Shell’s internal L2-DOC-LPD-0102 38.80.31.10-Gen
CF requirement the WMP seeks to Waste Management Section 10.7
• Incorporates controls to reduce waste generation into L4-DOC-ICE-4320 Shelburne Basin
procedures and working practices Handling of Toxic and Other Venture Waste
Management Plan

Table 4.2 Environmental Management Plans

• Identify opportunities to reuse waste for the same or Dangerous Materials (EP201505209133)
alternative applications or return unused materials to L2-DOC-LPD-3777
suppliers
• Identify recycling and recovery opportunities for Hazardous Goods Handling
waste material Procedure
• Identify waste (types), segregates and stores waste L2-DOC-MAT-0180
All waste streams will be reported and opportunities for
reuse identified and implemented.
All waste generated by Wells activities must be
identified, segregated, and stored to meet the
requirements of the asset/venture and local legislation.
Environmental Protection This EPP will be managed as an evergreen document Discharges to Sea See above listed Shell
Plan (EPP) throughout Project operations. L2-DOC-LPD-0215 manual standards and
The EPP is intended to provide the environmental guides
components of the larger HSSE management system Environmental Signposts
framework for the Project to ensure the implementation
L2-DOC-LPD -3810
of sound environmental management and protection in
association with the operational activities.
The EPP is established to identify and outline the Identification of Environmental
environmental management measures to be Aspects and Impacts
implemented in association with the Project and L2-DOC-LPD-0104
required of all personnel, including contractors, that
function in any capacity in association with the Project. Identifying and Managing
Additionally, this EPP is put in place to ensure Environmentally Critical
compliance with relevant existing environmental Elements
management commitments and requirements for Project L2-DOC-LPD-4996
operations.

4.3.2 Emergency Preparedness and Response
A Project Emergency Response Plan (ERP) is in place to address response and
recovery activities related to significant potential emergencies. These plans cover the
following potential environmental hazards:
• Fire and Explosion

• Uncontrolled Well Flow
• Ship Collision
• Hurricane/ Storm
• H2S
• Helicopter Ditching in the Sea, or on Deck
• Hydrocarbon Spills to the Water
These plans outline Emergency Response procedures and follow the proper protocols
for establishing an incident command in support of all local and governmental
regulations.
Table 4.3 outlines the various emergency response plans that will be in place for the
Project and describes how they relate to the emergency response. Plans are available
in the Shell Halifax Office. Site-specific Emergency Plans are available for Aviation,
Marine, Shore-base, and Drilling. Plans will be exercised prior to initiating operations to
ensure proper protocols are adhered to. Plans will be exercised prior to initiating drilling
operations to ensure proper protocols are adhered to.

Table 4.3 Emergency Response Plans

Emergency Response Plan Shelburne has adopted the Shell HSSE & SP Stena IceMax HSE Case- Shelburne Basin Emergency
(ERP) Control Framework standard for Emergency Part 5 – Emergency Response Plan
Response, which will be the basis for managing Response (EP201506207187)
Emergencies. All Businesses delivering activities L4-DOC-ICE-4130
and projects within the venture are required to
implement this Shell CF Mandatory Manual, and
Onshore Emergency
expected to ensure that all activities carried out are
Response
supported by a robust Emergency Response Plan
(ERP) aligned with the CF requirements, including L2-PM-LPD-0305
a Medical Emergency Response Plan (MERP) and
Spill Response Plan, where applicable. Each one Emergency Contacts –
of the Businesses delivering activities and projects L4-DOC-ICE-4339
within the venture, are expected to respond to
emergencies in accordance with their established
Introduction – Rig
plans, and to notify the venture as follows.
Emergency L4-DOC-ICE-
Emergency Response plans are established as per 4181
the CF manual section Emergency Response and
escalation routes to Crisis Management Plans are
in place. Reference Element 5 – Planning and
Procedures for the plans, procedures and drills
related to Emergency Preparedness and Response
of the HSSE & SP CF.
Drills and exercises to test both the Incident
Command System structure and the site specific
ERP are conducted regularly. Site-specific
scenarios include but are not limited to:
• Gas releases,
• Fires/explosions,
• Injuries/fatalities,
• Hazardous material spills,


• Loss of Station Keeping.
Safety equipment inspections are completed for
eyewash stations, first aid kits and other
designated safety equipment.
The Emergency Response Plan including the
MERP will be submitted to, and reviewed by the
CNSOPB as part of the Drilling Operations
Authorization approval process.
Oil Spill Response Plan The Oil Spill Response Plan (OSRP) is intended as Shipboard Oil Pollution Shelburne Basin Venture Oil
(OSRP) a planning document to help identify and establish Plan (SOPEP) - Stena Spill Response Plan
the basis for Shell’s oil spill prevention and Ice Max (EP201506200570)
recovery in the event of any hydrocarbon spill and L4-DOC-ICE-4242 Shelburne Basin Venture
as such, by its very nature, cannot anticipate all Wildlife Response Plan
possible contingencies. (EP201505214465)
Objectives of the OSRP include:
• Describe Shell’s IMT
• Assign individuals to fill positions on the IMT
• Define the roles and responsibilities of team
members
• Define notification, activation, and mobilization
procedures to be followed if a discharge occurs
• Document equipment, manpower, and other
resources available to assist with the response
• Ensure compliance with Shell Upstream
Americas Corporate Environmental Policy
The OSRP is also comprised of the following
supplemental plans:
• Net Environmental Benefits Analysis (NEBA)
• Dispersants Operations Plan


• Wildlife Response Plan (WRP)
The OSRP, NEBA, WRP and Dispersants
Operations Plan will be submitted to, and reviewed
by the CNSOPB as part of the Drilling Operations
Authorization approval process.
Source Control Contingency The Source Control Contingency Plan is made up Contractor Procedure are Relief Well Contingency Plan
Plan of several specific documents to create the whole to follow Shell (EP201504208706)
plan. The Source Control Contingency Plan is Requirements Source Control Contingency Plan
intended to provide specific details on how to (EP2015620983)Shelburne
combat a major event (blowout, Tier 2/3 Spill, etc.). Basin Capping Procedure
The plans that make up the Source Control (EP201507220716)
Contingency Plan are: Shelburne Basin Subsea
• Relief Well Contingency Plan Dispersant Plan
• Capping Procedure (201508200371))
• Subsea Dispersant Plan
Each plan is specific to the Project to ensure the
procedures and controls are activated to help
mitigate an event. The Plans are submitted to, and
reviewed by the CNSOPB as part of the Drilling
Operations Authorization approval process.
Well Control Plan The Well Control Plan (often referred to as the Contractor Procedure are Cheshire 1-97 Well Control Plan
Blowout Contingency Plan) is one of the well(s) to follow Shell (EP 201503226899)
specific response guides that is applicable to Requirements
organizational levels which include (unless
otherwise noted): Initial Response Procedures,
Surface Blowout Scenarios, Logistics, Emergency
Classifications, and Critical Elements which
include: Equipment, Personnel, Suppliers,
Mobilization, Safety, General Intervention
Strategies, and Emergency Management


Organization.
Note: The Well Control Plan excludes Relief Well
Contingency Plans.

5. SHELL HSSE MANAGEMENT SYSTEM
Shell’s general operating principles are underpinned by a deliberate focus on safety and
environmental protection. Shell meets or exceeds regulatory requirements applicable to
its operations, which are designed to reduce risks to the environment and keep people
safe. Shell’s safety record is built on strict adherence to company standards and
multiple safety barriers to prevent incidents from occurring. Shell’s safety standards also
includes a culture that requires workers, contractors and visitors to stop any unsafe
activities.
Shell maintains a high level of integrity to protect the environment and the people that
work at its locations. The following sections will outline the Shell HSE Management
System and how it will be applicable to working offshore Nova Scotia.
The Shell HSSE & SP Control Framework (Figure 5.1) forms the basis for all activity
level documents, plans and procedures. The HSSE & SP Standards are organized by
topic into Manuals covering appropriate subjects. Lower level plans and procedures are
available within each subject area. The HSSE & SP CF, Manuals and the 8 Elements of
the HSSE & SP Management System describe how HSSE & SP is managed in Shell
and who is designated with accountabilities and responsibilities within the Shell
Shelburne Basin Venture.

Figure 5.1 HSSE & SP Control Framework

5.1 Leadership and Commitment
The HSSE & SP CF embodies Shell’s corporate policies and commitments to operate
legally, ethically, and in a manner that is socially responsible and sustainable.
Leadership and Commitment to HSSE & SP performance is a foundational element of

Shell’s HSSE & SP MS.
Shell’s HSE management system outlines the necessary leadership required to create
and sustain a culture that:
• establishes health, safety and environmental responsibility as core values among

employees;
• meets the requirements of Shell HSSE & SP policies and objectives and
operates in full compliance with all permits, regulations and HSE procedures;
• trains, develops and empowers employees to execute their defined HSSE & SP
roles;
• defines accountability for HSSE &SP performance; and
• evaluates and continuously improves HSSE & SP performance.
Shell Senior Leadership/Management ensure that HSSE &SP is an integral part of the
work place's culture by:
• Requiring that policies be implemented and that standards and procedures be

followed;
• actively and visibly participating in HSSE & SP activities (leading by example),
such as incident investigations, HSSE &SP MS training, reward and recognition
programs, industry/contractor workshops, inspections, open discussions with
interested third parties and audits;
• setting specific HSSE & SP objectives and targets for employees/workgroups,
and visibly monitoring performance and follow up;
• jointly developing and discussing HSSE & SP “results” and “activity”
improvement targets with contractors;
• reviewing the progress of the development, implementation and verification of
HSSE &SP MS and HSSE & SP cases and making the resources and expertise
available to meet the targets; and
• through managers conducting site visits ensuring actions items are tracked for
closure.

5.2 Policies and Objectives
5.2.1 Shell’s Commitment and Policy
Shell’s HSSE & SP Commitment and Policy applies across the organization and is
designed to help protect people and the environment. It includes aims aligned with the
Shell General Business Principles on how we operate and work to involve communities
close to our operations.
Shell’s commitment and policy reflects the integrated way work is conducted across
Shell in the areas of HSSE & SP. All Shell companies, contractors and joint ventures
under operational control are required to manage HSSE & SP in line with the
Commitment and Policy.
The Shell HSSE & SP Commitment and Policy (see Figure 5.2) provides the foundation
for a systematic approach to HSSE & SP management and outlines specific
commitments regarding objectives and performance expectations. The HSSE & SP
Commitment and Policy is communicated to employees and contractors, as well as
being displayed in office and work locations and underpins Shell’s HSSE & SP MS.

Figure 5.2 Shell HSSE & SP Commitment and Policy

5.2.2 Stena Health, Safety & Environmental Health Policy Statement
Stena Drilling’s Health, Safety and Environmental Health Policy (Figure 5.3) outlines the
company core values and beliefs and their commitment and aim for all business to be
conducted in a safe and efficient manner with no injury to people, harm to the
environment, or damage to equipment and the workplace. To meet this goal a number
of objectives are outlined in their policy statement which has been endorsed by Stena’s
Managing Director and Operating Manager.
Additionally, this policy outlines the responsibilities and accountabilities of employees,

management and supervisors in ensuring that the outlined objectives are implemented
and the overarching HSSE & SP goal is met.
Figure 5.3 Stena Drilling Health, Safety and Environmental Health Policy
5.2.2.1. Stena Environmental Protection Policy
As part of Stena’s Health, Safety and Environmental Health Policy, Stena has
developed a separate Environmental Protection Policy to specifically outline Stena’s

commitment to environmental protection second only to considerations affecting the
safety of people (Figure 5.4). In conducting their work in accordance with this policy,
Stena strives to ensure that all their business and operations are conducted in an
environmentally responsible manner.
Figure 5.4 Stena Drilling Environmental Protection Policy
5.2.3 Stena Management System
The Stena Drilling Management System (SMS) is an integrated management system

through which the company defines and delivers its business objective, identifies and
manages risk and systematically reviews performance. The management system is
further described in the Stena IceMax HSE Case: Part 2- Management System (L4-
DOC-ICE-4127).
Stena’s management system follows the Quality Standard ISO 9001 and is certified to
the ISO 14001 Environmental Standard. Stena Drilling has also achieved compliance
with the International Safety Management (ISM) Code, an international standard for the
safe management and operation of vessels and for pollution prevention adopted by the
International Marine Organization (IMO) in 1995. Compliance with this code is
mandatory for drilling vessels and is verified on an annual basis. The Stena

Management System contains a number of documented procedures which address
these requirements and verifies ongoing compliance. Where relevant to environmental
management, these documents have been referenced in the EPP.
5.2.4 Objectives & Targets
Shell’s main objective is Goal Zero: no harm and no leaks, an accident free workplace
and one free of significant incidents. In addition, Shell has a vision to deliver safe,
profitable, environmentally and socially responsible activities and projects, in line with
the expectations of our customer & stakeholders.
5.2.4.1. Project Level Objectives and Targets

HSSE & SP performance data from the Project are collected and reported to the
Venture Leadership Team on a weekly basis and to the CNSOPB quarterly, annually
and at the end of the exploration program. At the asset level, the goal is Zero injuries,
Zero environmental spills and 100% compliance with regulatory requirements.
Dissemination of information, including communication of hazards, mitigations, targets

and goals, is achieved through a number of different mediums:
• Presentations from Line Management via established monthly meetings

• Orientation training during arrival on the vessel/rig and for all new hires working
the project.
• Discussions during Quarterly Contractor Management Meetings.

6. ORGANIZATION, RESPONSIBILITIES AND RESOURCES
6.1 Venture Level Organization and HSE Accountability
Shell’s organization for the Shelburne Basin Venture Exploration Drilling Project is a
function-based organization drawn primarily from its Upstream Americas (UA)
organization, which includes all upstream operations in North and South America. The
UA organization provides the majority of technical and managerial support to field
operations in the Shelburne Basin through a matrix style organization. This organization
contains expertise in Safety, Environmental Protection, Health Management and
Emergency Response. The Shelburne Basin Venture organization chart and roles is
included in Appendix A.
Venture Manager (Atlantic Canada)

<Redacted>
The Venture Manager is the person accountable for ensuring Health, Safety, Security, &
Environmental Management Systems are fully implemented and effective, providing
input on strategy development for each project deliverable, sanctioning the manpower
and resources necessary for implementation of the EPP and holding personnel
accountable for its implementation and continued maintenance.
Shelburne Basin Venture Wells Operations Manager

< Redacted>
The Shelburne Basin Venture Operations Manager is the local senior focal responsible
for the project and the implementation of the EPP.
Shelburne Basin Venture Leadership Team (VLT)

Members of the VLT are responsible for ensuring compliance with the requirements of
the EPP, to the extent applicable to their respective teams.
Shelburne Basin Extended Venture Leadership Team (EVLT)

The leads of these teams are responsible for familiarizing themselves with the EPP,
communicating the specific requirements applicable to their team members and
contractors, while ensuring that deliverables and commitments are met within the
stipulated timelines.
HSE Representation
HSE representatives have been allocated for all Project components and workspaces
(MODU, Supply Base, Road, Marine, Aviation) to support execution of all parts of Shell
and contractor HSE management systems and the EPP. All Shell line management
personnel have an HSE oversite role.

Local Staff (Halifax and Offshore)
Shell Staff are responsible for ensuring the EPP is followed while identifying areas for
improvement to their respective managers and team leaders.
Contractors
All Contractors are responsible for familiarizing themselves with Shell’s Operations
Safety Plan (OSP), EPP and other various work documents. Workers are orientated to
the EPP to ensure that Shell’s Environmental objectives are achieved and maintained.
All Contractors providing a service or support for the Project are required to work in
accordance with the provisions of this EPP.
6.1.1 Contractor Level Roles & Responsibilities

Contractors are selected within the rigors of a well-defined bid and selection process. A
part of this selection process includes an assessment of resources (manpower,
equipment, and asset) required for the project; contractors are responsible to provide
fully certified equipment onshore and offshore including a MODU that meets its class
designation including the rig equipment, crews, and HSE management systems; and
meet local regulatory regulations, requirements and standards.
To ensure that the Health, Safety, and Environmental Management System is

integrated into all of its business activities, all Contractors will:
• Advise each manager, supervisor, employee of his/her HSE rolls and

responsibilities;
• Comply fully with all applicable HSE laws and regulations;
• Provide safe working rules, practices and procedures based on risk experience,
safety knowledge and competent work direction;
• Assess all anticipated known risks prior to starting a new activity or one that is
conducted very rarely;
• Ensure employees are qualified, trained, and competent to perform the work they
are assigned;
• Eliminate or minimize potential damage to equipment, vessel or environment;
• Investigate all incidents/accidents and take corrective action as appropriate;
• Ensure a rapid and appropriate response to emergencies is established and
maintained;
• Provide adequate and trained professional staff to support HSE activities;

• Monitor and report HSE performance for continuous improvement; and
• Establish a strong HSE culture within all working groups/teams and
contractor/Shell interface.
Every employee of the contractor has the responsibility to:
• Promptly report all hazards, incidents and near miss occurrences;

• Provide ideas and identify concerns to ensure environmental protection and
safety efforts and commitments are appropriately implemented and continuously
improved;
• Comply with all applicable federal, provincial and local regulations related to
health, safety, and environmental programs
6.1.2 Environmentally Critical Roles
In accordance with the EPP Guidelines, an environmentally critical role is defined as

“assigned work or responsibility key to the mitigation of the effects of pollution, or to
monitoring or managing structures, facilities, equipment and systems critical to
environmental protection” (CNSOPB 2011).
Environmentally critical roles for the Project have been identified in association with
bowtie analyses performed to assess the identified major hazards for the Project.
Further information on Shell’s risk assessment and management and the associated
bowtie analysis can be found in Section 5.3 of this document as well as section 6.4.5 of
the OSP (EP201501216147).
The list below outlines the associated personnel considered to be in environmentally

critical roles onboard the MODU and onshore:
• Drilling Supervisor
• Shell Onboard HSE Officer
• Stena HSE Officer
• Master/OIM
• Barge Master
• Senior DPO
• Chief Engineer
• Senior Operations Engineer
• Wells Operations Manager
• Rig Manager
• Drilling Superintendent

• Wells HSE (Well Planning)
Further details regarding required competencies and training for individuals in HSSE
critical roles is included in Section 8.3. Full details of the individual training
requirements for environmentally critical position training requirements can be found in
the Shelburne Basin Training and Competency Management Plan (EP201508200655).
6.2 EPP Responsibilities
The Project will be managed by Shell, which organizes its deepwater exploration
ventures to include the disciplines and expertise required to deliver a project. During
drilling, the two largest disciplinary teams will be the Well Delivery Team and the
Subsurface Team. Additional disciplinary support teams associated with the Project
include: Contracting and Procurement; Logistics; HSSE & SP; Environmental;
Regulatory; Commercial; Social Performance; Stakeholder Consultation; Indigenous
Relations; External Communications; Legal; and Finance.
The Operations Manager, Shell Drilling Superintendent, Stena Rig Manager and OIM
will have ultimate responsibility for ensuring the execution of and compliance with the
EPP on the MODU during operations. The Logistics Lead is responsible for executing
the relevant components of the EPP that apply to the Supply Base, Road, Marine, and
Aviation operations.
Table 6.1 summarizes the delegation of responsibilities pertaining to the management

and implementation of this EPP.
Figure 6.1 outlines the organizational structure and interface for onshore and offshore
Project operations.

Table 6.1 EPP Roles and Responsibilities
Role EPP Accountabilities & Responsibilities

• Overall accountability for the Shelburne Basin Venture
Shell Venture Manager
Exploration Drilling Program
• Accountability for operational execution and installation
compliance during the Project inclusive of EPP
Shell Operations Manager implementation
• Responsible for reporting environmental incidents to the
CNSOPB and other relevant regulatory authorities.
• Planning and execution of daily drilling operations in a
Shell Drilling Superintendent manner that maximizes HSE values and complies with HSE
commitments and regulatory requirements.
• Overall accountability for ensuring the appropriate HSE
Shell Venture HSE Manager
systems are in place and functioning
• Accountability for Support Vessel, Road Transport and
Shell Logistics Lead
Helicopter operations.
• Overall accountability for ensuring the appropriate HSE
Shell Wells HSE Supervisor
systems are in place and functioning
• Development and maintenance of the EPP
• Obtains CNSOPB Approval of EPP
• Supports communications pertaining to the content of the
Shell Environmental Lead EPP.
• Reviews monthly compliance reporting
• Responsible for ensuring submission of monthly
environmental compliance reporting to CNSOPB
• Overall accountability for HSE for Stena’s operations in
Stena Rig Manager support of Shell’s Shelburne Basin Venture Exploration
Drilling Program
• Overall authority and accountability regarding
Stena Master/ Offshore
environmental protection and implementation of the EPP on
Installation Manager (OIM)
the drilling rig.
• Supports the implementation of the EPP including
monitoring performance and compliance.
Stena Safety Officer
• Compilation and review of environmental compliance data
for reporting to CNSOPB
• Works with the Offshore Stena Safety Officer to support the
Shell Senior Offshore HSE
implementation of the EPP
Technician
• Conducts inspections and audits
Offshore Personnel and
• Executes all activities in compliance with EPP
Contractors

Figure 6.1 Onshore/Offshore Operations Interface Organizational Chart

7. HAZARD IDENTIFICATION AND RISK EVALUATION
Shell’s Health, Safety, Security, Environment and Social Performance Management
System (HSSE &SP MS) requires the identification of hazards that could potentially
impact personnel, the environment, assets or reputation. Proactive management is
required to ensure that these potential hazards are identified and the associated risks
assessed to ensure that appropriate controls are put in place and maintained to reduce
risks to as low as reasonably practicable (ALARP). Identification and management of
hazard associated HSE risks is conducted in a systematic manner as outlined below
and is ongoing throughout the full Project life cycle (Planning to Operations).
7.1 Hazard and Effects Management Process

Shell’s hazards and effects management process (HEMP) as shown in Figure 7.1 relies
on the principles of 'identify', 'assess', 'control' and 'recover', which are applied by
completing the following steps:
1. Identify HSE hazards and document their effects on people, assets, environment
and reputation in a Hazards and Effects Register
2. Assess the risk of identified hazards for worst case credible scenarios using the
Risk Assessment Matrix (RAM), and document this assessment of risk in the
Hazards and Effects Register (The Shell Risk Assessment Matrix or RAM is further
described in Section 7.1.1).
3. Manage Hazards having risks in the dark and light blue areas of the RAM through
effective implementation of the HSE Management System.
4. Where reasonably practicable, eliminate hazards or substitute hazards that have risk
in the yellow area and red area of the RAM with ones having lower risk.
5. Identify and implement controls and recovery measures for hazards in the yellow
area of the RAM to reduce risk to ALARP.
6. Identify and implement controls and recovery measures for hazards in the red and
yellow A5 and B5 areas of the RAM (as stated above for yellow risk hazards) and in
addition by a bow-tie or equivalent methodology. This methodology must include the
following:
a. Identify barriers to prevent a top event, to prevent escalation factors and to
reduce the consequences should the top event occur
b. Identify critical activities to maintain the barriers
c. Identify critical equipment and performance criteria
d. Identify criteria for ALARP determination
e. Provide a documented demonstration of ALARP
7. Prepare a remedial action plan to close any identified gaps.

Figure 7.1 Hazard Identification System
7.1.1 Risk Assessment Matrix (RAM)

Hazard associated risks are assessed using the Risk Assessment Matrix (RAM)
described in the Shell HSSE & SP CF and shown in Figure 7.2 below. The RAM’s
purpose is to establish a consistent process for assessing and characterizing HSSE
risks and is used in association with HSSE risk assessments and incident classification.
The Venture Leadership Team and the Front Line Managers are responsible to ensure
competence of staff and/or contractors applying the RAM. Figure 7.2 provides a
description of the RAM.

Figure 7.2 Risk Assessment Matrix
7.1.2 Bow Tie Analysis

Bow Tie analysis combines a fault tree with a consequence tree. Shell uses the Bow Tie
exercise for the assessment of high HSSE risk hazards. High HSSE risk hazards are
those shown in red on the RAM, plus A5 and B5, as outlined in Figure 7.2. An example
of a Bow Tie Analysis Diagram is provided in Figure 7.3. The Bow Tie consists of:
• Threats
• Barriers
• Hazards
• Top Event
• Recovery Measures (Barriers)
• Escalating Factors
• Consequences

A top event is the loss of control or release of the hazard. When effectively in place:
• Barriers prevent hazards from becoming a top event by stopping the threat; and
• Recovery preparedness measures (or recovery measures) prevent the top event
from becoming a severe consequence (i.e., cause harm, damage, or
environmental impacts).
Escalation factors are conditions that lead to increased risk due to loss of controls
(barriers or recovery measures). Escalating factor controls (or escalating controls) are
measures put in place to mitigate the effects of escalation factors.
Increasing the number and/or quality of barriers reduces the probability of something
occurring. Increasing the number and/or quality of recovery measures reduces the
impact of something occurring. Reducing the probability and/or the impact reduces the
risk.
Figure 7.3 Bow-Tie Analysis Diagram

7.2 Environmental Assessment
In addition to the Hazard and Risk assessment processes described above, Shell’s
HSSE & SP CF requires that an Impact Assessment (IA) be completed for all new
Projects to further identify and assess the potential environmental, social and health
impacts of a project and to implement mitigation measures to minimize negative impacts
and optimize any potential positive impacts. Where external regulatory requirements for
an IA exist, assurance is made that these external requirements allow compliance with
the Shell HSSE & SP CF framework requirements and additional analysis and
assessment are undertaken where gaps are noted.
In line with internal and external requirements, the primary study undertaken to identify
environmental hazards and evaluate environmental risks associated with the Project
was an environmental assessment (EA) pursuant to CEAA, 2012. The associated EIS
(Stantec 2014) documents the results of the EA, including a summary of baseline
environmental conditions and Shell’s commitments regarding mitigation measures to
avoid, prevent, reduce or manage risks to the environment. Relevant operational
mitigation measures and commitments to manage the potential environmental effects
noted in the EIS have been incorporated into the EPP where relevant. Table 7.1 below
provides a summary of the identified potential hazards (potential interaction) as well as
the identified and assessed potential environmental effects from the EIS. Additionally
Table 7.1 refers to the associated mitigations measure established as part of the EIS to
reduce the risk of the associated hazard and environmental effect to occur. Refer to
Appendix D for a full summary of the EIS mitigation commitments associated with the
Project. Additional requirements are outlined in the EA Report conditions released by
CEAA on June 15, 2015 and included as Appendix E.
Table 7.1 EIS Assessment Summary
Project Mitigation
Potential Hazard Environmental Effect
Component/Activity Measure
Presence and Vessel Strike (Marine Mortality or Physical Injury Appendix D:

Operation of MODU mammal and Sea No. 45
turtles)
Acoustic Emissions • Mortality or Physical Injury Appendix D:
(Marine Mammal, Sea (auditory injury) No. 53, 54
Turtles, Fish, Marine • Change in Habitat Use and
birds, Commercial Quality (sensory
fisheries, Aboriginal disturbance)
Use)
• Change in Availability of
Fisheries (avoidance- Fish)
• Change in Traditional Use
(avoidance – Fish)
Light Attraction • Mortality or Physical Injury Appendix D:
(stranding, starvation,

Project Mitigation
(Marine birds) collision, incineration) No. 4, 18
• Change in Habitat Use and
Quality (attraction to MODU)
Exclusion Zone • Change in Availability of Appendix D:
(Commercial fisheries, Fisheries Resources No. 53, 54
Aboriginal Use) (localized exclusion)
(avoidance –Fish)
Discharge of Drill Muds Cuttings Footprint • Mortality or Physical Injury Appendix D:
and Cuttings (benthic species and (smothering) No. 21, 22
habitat – Fish, • Change in Availability of
Commercial fisheries, Fisheries Resources (direct
Aboriginal Use) loss)
Direct or Indirect • Change in Habitat Use and Appendix D:
Exposure (Marine Quality (reduction in water No. 24, 25, 27, 28,
mammals, Sea turtles, and sediment quality, impact 53, 54
Fish, Marine birds, to prey species)
Commercial fisheries, • Change in Availability of
Aboriginal Use) Fisheries Resources
(avoidance- Fish)
Other Discharges and Indirect Exposure • Change in Habitat Use and Appendix D:
Emissions (Marine mammals, Quality (reduction in water No. 7, 26, 29, 35,
Sea turtles, Fish, and sediment quality, impact 53, 54
Marin birds) to prey species, temporary
avoidance)
• Change in Availability of
Fisheries Resources
(avoidance- Fish)
Direct Exposure • Mortality or Physical Injury Appendix D:
(Marine birds) (oiling, attraction to MODU) No. 7, 26, 29, 35,
• Change in Availability of 53, 54
Fisheries Resources (direct
loss)
(direct loss)
Vertical Seismic Acoustic Emissions • Mortality or Physical Injury Appendix D:
Profiling (Marine mammals, (auditory injury) No. 50, 51, 52, 53,
Sea Turtles, Fish, • Change in Habitat Use and 54
Marine birds, Quality (sensory

Project Mitigation
Commercial fisheries, disturbance)
Aboriginal Use) • Change in Availability of
Fisheries (avoidance- Fish)
Helicopter Transport Acoustic Emissions • Change in Habitat Use and Appendix D:
(Marine mammals, Quality (sensory No. 13, 14
Marine birds) disturbance)
Collision (Marine Mortality or Physical Injury Appendix D:
birds) No. 13, 14, 15
OSV Operations Vessel Strike (Marine Mortality or Physical Injury Appendix D:
mammals and Sea No. 8, 11, 12, 15,
turtles) 45
Acoustic Emissions • Change in Habitat Use and Appendix D:
(Marine mammals, Quality (sensory No. 11, 12, 53,54
Sea turtles, Fish, disturbance)
Marine birds, • Change in Availability of
Commercial fisheries, Fisheries (avoidance- Fish)
Aboriginal Use)
Light Attraction • Mortality or Physical Injury Appendix D:
(Marine birds) • Change in Habitat Use and No. 4, 18
Quality
Well Abandonment Physical Structure • Change in Habitat Use and Appendix D:
(Marine mammals, Quality (Localized No. 54, 55
Sea turtles, Fish, disturbance) Abandonment
Commercial fisheries, • Change in Availability of Plans
Aboriginal Use) Fisheries Resources (direct
loss)
7.3 HSSE Studies
The following HSSE studies (Table 7.2) have been performed to comply with Shell’s
HSSE &SP CF requirements to identify Project hazards, evaluate the associated risks
and determine appropriate controls and mitigations. Copies of these studies are
available upon request via the Shell Halifax Office.
Table 7.2 HSSE Studies

Study Date Scope
Completed
Environmental June 2014 The Shelburne Basin Venture Exploration Drilling Project
Impact Statement Environmental Impact Statement (EIS) (Stantec 2014)
evaluates potential environmental effects from the Project and
recommends mitigation and monitoring to manage adverse
environmental effects. The EIS also assesses a number of
accidental events including a subsea blowout.
Hazard October 2014 This register includes all hazards identified for Exploration
Identification Operations and their risk ratings. Environmental aspects are
(HAZID) / Hazard also identified and considered. Outputs of the HAZID will
and Effects include hazard listing and all associated controls for those
Register identified hazards.
Bow-tie October 2014 Bow-tie assessments are required to detail the mitigation
Assessments strategy for hazards potentially having red risk, or yellow 5A or
yellow 5B risk according to the Shell RAM.
Health Risk February 2015 Shelburne Basin Health Risk Assessment takes every
Assessment (HRA) reasonable precaution in the circumstances to protect the
employee’s own health and safety that will minimize the effects
of exposure to those health hazards most commonly
encountered in offshore exploration drilling operations
HSE Case June 2015 Major potential HSSE risks are documented in an HSSE Case
to demonstrate the hazards and effects associated with an
installation and its operation have been fully identified and risks
managed within the principles of As Low As Reasonably
Practicable (ALARP).
For the Shelburne Basin Drilling activities there is a Stena
Safety Case.
Where applicable, the existing Aviation, Marine and Road
Transport HSSE Cases will be relied upon for the Project.

7.3.1 HSSE Study Results
Table 7.3 outlines the Major Hazards and top events/worst case scenarios that were
identified as part of the HSSE studies conducted in association with the Project and that
could result in associated environmental consequences/effects. As part of these hazard
assessments, critical tasks and responsible positions have been identified and outlined
to prevent such an event. The associated bow-tie analysis and identified critical tasks
and roles to mitigate each hazard can be found in Section 6.4.5 – Table 8 of the OSP.
Table 7.3 also identifies the associated response plans to be implemented to address
the associated top event. Further information on these response plans is provided in
Section 4.3.2.
Table 7.3 Identified and Assessed Project Hazards
Potential Environmental
Top Event Response Plan
Major Hazard Consequence
HAZID
Reservoir Loss of Well Control – Environmental Damage ERP
Hydrocarbon Surface (product release to the OSRP
under Pressure Loss of Well Control - marine environment) Source Control
Subsea Contingency Plan
Well Control Plan
Shallow Gas Loss of Well Control- Environmental Damage ERP
Shallow Gas (product release to the
marine environment)
Approaching Ship Collision Environmental Damage (fuel ERP
Vessel or drilling fluid release to the
marine environment)
Engine Room Fire in Engine Room Environmental Damage ERP
Combustibles (resulting release of
combustibles, bilge to
marine environment)
Object at Dropped Object Environmental Damage ERP
Height (release or object loss to the
marine environment)
Air Transport Helicopter Ditching at Sea Environmental Damage (fuel ERP
Helicopter Ditching on the and/or material release to
MODU the marine environment)
Marine Bulk Loss of Containment Environmental Damage ERP
Transfers (release of product to the
Vessel to marine environment)
Vessel
Transfers
Environmental Impact Statement (Stantec 2014)

Table 7.3 Identified and Assessed Project Hazards
Accidental Worst Case Credible Environmental Effect Response Plan

Event Scenario
Subsea 24 900 bbl/day • Mortality or Physical ERP
Blowout 49 150 bbl/day Injury OSRP
(30 day • Change in Habitat Use Source Control
release) and Quality Contingency Plan
Well Control Plan
Operational 100 bbl Marine Diesel • Mortality or Physical ERP
Batch Spill Injury
(Instantaneous • Change in Habitat Use
release) and Quality
SBM whole 377.4 bbl (full tank • Mortality or Physical ERP
Mud Spill release) Injury
(Instantaneous 3604.2 bbl (full riser • Change in Habitat Use
release) release) and Quality
Vessel Spill 100 bbl Marine Diesel • Mortality or Physical ERP
(Instantaneous Injury
release) • Change in Habitat Use
and Quality

8. AWARENESS, COMPETENCE AND TRAINING
Training and competency management and assurance for the Project is detailed in the
Shelburne Basin Venture Training and Competency Management Plan
(EP201508200655) currently under development.
8.1 Awareness
All personnel are made aware of the existence of the EPP, Shell policies, plans and
procedures and how it relates to their role on the Project, during kick-off orientation
training. The EPP is described in the pre-start-up meetings to all workforce by the
Venture Operations Manager and the Venture HSE Lead with support from the
Environmental Lead. This meeting covers all aspects of the proposed drilling campaign,
including health, safety and environmental aspects. The environmental component of
this orientation will, among other things, address the environmental setting of the
Project, regulatory context and expectations as well as requirements for environmental
compliance.
8.2 Competence
Shell employees and contractors are qualified and competent to perform the work
required for the operations. The following processes are in place to provide competent
resources (Figure 8.1):
Figure 8.1 Onshore/Offshore Operations Interface Organizational Chart

• Recruitment - Every level of employment has to meet or exceed job specific
recruitment criteria such as experience in position, training and other
qualifications or educational background. Recruitment is a responsibility of each
contractor to validate any work experience and qualifications for the hiring of
personnel. This requirement is mandated by contracts that are vetted through
Shell Contracts and Procurement and CSMP process. Refer to the Shell Training
Matrix, Stena Ice Max HSE Case 2.3.5 & 2.3.6, and Stena Competence
Assurance Scheme for further details.
• Each Shell Employee and Contractor that will be working offshore prior to being
assigned to the project will have conducted and obtained a valid and full duty
Medical Evaluation as per CAPP’s - Atlantic Canada Medical Assessment for
Fitness to Work Offshore. These evaluations will be maintained by each
contractor at their respective location and will be available for assurance
purposes as required.
8.3 Training
Position specific training is provided to increase the knowledge and skill of workers.
Refresher training is provided at appropriate intervals. Mandatory training is listed in
each companies’ training plan or matrix and available on the MODU. The required
professional, marine, and trade certifications will be determined for the relevant roles
and maintained accordingly.
• All Shell personnel positioned in a HSSE Critical Roles performing any HSSE
Critical Tasks will have been assessed against the Front Line Barrier
Management Standard requirements that include Well Control Testing, Round 1
& Round 2 Well Diploma programs, and other standards that apply. These
qualifications will be verified through the training profiles found on SOU and with
Global Wells Training Coordinator. It is the responsibility of the Supervisor to
ensure these requirements have been followed and met.
• For Stena personnel, it is the responsibility of the OIM to ensure that all
employees assigned both Safety and Environmental Critical positions described
in the Stena HSE Case Critical Task sheets (refer to Table 8 of the OSP), has
met the training and qualification requirements outlined in the Stena HSE
Training Matrix for Competency Assurance for each identified critical task.
• Verification – Prior to starting work, each company must demonstrate that

training of their staff and contractors has been completed, and they will maintain
a training matrix and compliance status for their staff, including but not limited to
safety leadership training, Basic Survival Training with HUEBA, and H2S
awareness. This will be verified and audited through the Venture HSE Team
Lead and the Shelburne Basin Training Coordinator for the Shelburne Basin

drilling program based on the Shelburne Basin Training and Competency
Management Plan (EP201508200655).
• Stena’s policies and procedures relating to personnel competence are outlined in

the Stena Training Manual for each position. Full details on these position
requirements can be found through the Shelburne Basin Training and
Competency Management Plan (EP201508200655) which includes the training
matrices. It is the Rig Manager’s responsibility to ensure that personnel are
trained accordingly.
• Statutory training is coordinated by the Stena Training Administrator who keeps

records of all training completed. In-house and onboard training is recorded and
records held onboard by the OIM.
• Periodic audits confirm programs are functioning and effective.
8.4 Contractor Management
Shell utilizes a Contractor Management Program which identifies, early on in the

contracting process if the Contractor’s Management System is equivalent to Shell’s. If
after review, it is determined that the Contractor’s Management System is not
equivalent to Shell’s, then Management System interfaces from key contractors will be
included in the relevant Bridging Document(s). Each Bridging Document describes the
contractor specific details/mapping or bridging documents which provided support on
how the specific contractors are managing their risks to ALARP, if contractors are used
for the execution of the scope of work.
Contractor HSE management is performed in accordance with the UA Contractor HSSE

Management Process (CSMP). Implementation of CSMP provides assurance that
selected contractors are competent to perform the contracted work and that contractor
performance will be monitored and recorded for future contractor appraisals.
The Shell HSSE CF provides simple expectations for managing key HSSE risk. These
expectations are mandatory across Shell and are delivered in the form of the Contractor
HSSE Management Mandatory Manual.
In order to support bid evaluation, potential contractors are required to provide the
following for consideration :
• Past and current HSSE performance
• Demonstration of an existing HSSE MS that exhibits the same degree of
application and assurance as the Shell HSSE CF.
• Demonstration of an existing Competence Assurance process for personnel
• Demonstration that training programs support the management of the associated
HSSE risks

• Existing fitness to work process for personnel
• Demonstration that tools and equipment are suitable and safe for use.
This information is used to assess whether the chosen contractor has the capability and
resources to manage the HSSE risks associated with the proposed work. HSSE
performance will be a key consideration in determining a preferred contractor and the
Shell Contractor HSSE Management Manual requires preferential selection of those
companies that show good HSSE performance. During operations, Shell will
continuously monitor and regularly assess the HSSE performance of the associated
contractors to ensure compliance with the HSSE performance agreed in contract. The
Shelburne Basin Venture will have an assurance plan which lists the various process
level and worksite level audits and assurances that will be executed during operations.

9. EPP MANAGEMENT
9.1 EPP Review and Revision
Shell and Stena have reviewed this EPP to ensure that the appropriate aspects of their
HSE management systems and environmental policies are integrated and that the
environmental protection and measures are consistent with company requirements and
capabilities as well as established regulatory commitments.
Once a quarter the EPP is to be reviewed for changes in all policies that could have an
impact on the EPP. Additionally this EPP will be reviewed at the close of Project
Operations to identify any required adjustments or revisions as a result of lessons
learned from Project operations and in advance of any future operational activities. If
changes are needed, they will made, reviewed by Shell Leadership and resubmitted to
the CNSOPB for final approval. Once approved the changes will be distributed
throughout the assets of the Shelburne Basin Venture.
Changes to the EPP shall only be made in accordance to Shell Canada’s Management
of Change (MOC) process (Section 8.3) and with the engagement and approval of the
CNSOPB. No changes to the outlined commitments of this plan shall be implemented
until formal approval is provided by the CNSOPB and a revision has been issued.
Any revisions to the EPP will be communicated to any affected stakeholders and
revised version distributed to hardcopy holders and managed in accordance with Shell’s
document control system.
9.2 Document Control
Shell has a Document Control system to identify, collect, store, retrieve, route and
dispose of documentation to ensure operational integrity and regulatory compliance.
The process used to manage these documents is described on the Shell UA Control
Framework documents homepage. Printed documents are assumed to be uncontrolled,
potentially out of date, and require latest version verification. For more information, refer
to the Shelburne Basin Venture Document Management Plan (UAXSV-HSE0001-
PR01).

Table 9.1 provides a sample list of controlling documents and identified storage
locations.
Table 9.1 Document Control Records and Storage Location
Document/Record Storage Location

CNSOPB Regulatory Records and Submissions Shelburne Venture Sharepoint (Intranet) Web Site
Environmental Regulatory Records and Reports Shelburne Venture Sharepoint (Intranet) Web Site
(including EPP and EA materials)
Legal Records Local files / UA Legal – Calgary and Halifax Office
Preventative / corrective maintenance records of
PM Systems onboard Each Vessel
HSE critical equipment
Audit records and action items Fountain Assurance (Intranet) Web Site
Incident reporting records Fountain IMPACT (Intranet) Web Site
HSE Training records Shell Open University (Intranet) Web Site
Risk Management Documents Shelburne Venture Sharepoint (Intranet) Web Site
Personnel records (GPAs, CBDs, IDPs) Shell People (Intranet) Web Site
9.3 EPP Communication and Distribution
The contents of this EPP will be communicated, as appropriate, to all Shell and
contractor personnel involved with Project activities and with responsibilities associated
with the EPP. In addition, following finalization, Shell will disseminate hard copies to the
relevant parties involved in implementation and management of the EPP. Table 9.2
identifies the proposed hard copy distribution for the EPP.
In addition, all Shell and contract staff will have electronic access to the EPP through an
established online document management system. Interested public and first nation
stakeholders will be provided links to the document once finalized and posted on the
CNSOPB public document registry. Hard copies will be sent by mail as requested.
Table 9.2 EPP Distribution List
Role Company Location

Venture Manager Shell Shell Office - Calgary
Operations Manager Shell Shell Office - Halifax
Drilling Superintendent Shell Shell Office - Halifax
Shell Senior Drilling Supervisor Shell Shell Office - Halifax
Venture HSE Manager Shell Shell Office - Halifax
Wells HSE Lead Shell Shell Office –Houston
Environment Lead Shell Shell Office - Calgary

Table 9.2 EPP Distribution List
Role Company Location

Logistics HSE Lead Shell Shell Office - Halifax
Shell HSE Technician Shell Stena Ice Max
Rig Manager Stena Stena Office - Halifax
Offshore Installation Manager Stena Stena Ice Max
Safety Officer Stena Stena Ice Max
Environmental Advisor CNSOPB TD Centre, Halifax
Public and stakeholder communication is addressed in Section 19.

10. OPERATIONAL CONTROL
10.1 Operations and Maintenance Procedures
Shell Operations are managed according to a hierarchy of applicable plans and

procedures starting with the Shell HSSE & SP Control Framework and associated
HSSE &SP Mandatory Manuals as discussed in Section 4.3. These documents set the
framework of control that subsequent operating activities and contractors are required to
align with.
In addition and as described in Section 4.1 and 4.2 a number of statutory and guidance
documents are to be complied with and function to ensure environmental management
practices in addition to the internal standards and manuals
10.2 Structures, Facilities, Equipment and Systems Critical to Environmental

Protection
An environmentally critical element (ECE) is a structure, facility, equipment or system

whose failure will either cause or contribute to an environmental event, or the purpose
of which is to prevent or limit the effect of an environmental event.” Shell recognizes that
there are various critical elements associated with the Project that contribute to
environmental protection. For these elements to be effective, appropriate procedures for
installation, operation, inspection, testing, and maintenance activities must be well-
defined and executed.
The equipment and installations that are to be used in the work or activity to be
authorized are fit for the purposes for which they are to be used. ECEs as well as Safety
Critical Elements (SCE), which are often one in the same, are identified during Bow Tie
analyses and other studies as outlined in the respective HSE Case. Refer to Section
6.2.4 of the OSP for a complete list of all structures, facilities, equipment and systems
critical to environmental protection, which are noted on the Bowties and listed with each
Hazard Sheet.
A performance standard, the Technical Integrity Performance Standards (TIPS) exists

for each ECE and SCE. Each performance standard specifies and describes the tasks
necessary to validate that the ECE and SCE performs the function necessary for the
barrier to be effective, and includes the acceptance criteria which the ECE and SCE
must meet. The performance standard contains information on:
• System description, boundaries and function;

• Design and installation requirements;
• Operations and maintenance requirements; and
• Inspection and repair requirements.

Stena has an established procedure for Identifying and Managing Environmentally
Critical Elements (Doc. No. L2-DOC-LPD-4996). In accordance with this procedure, the
Stena OIM is responsible for ensuring that sufficient resources are available so that
ECEs are identified, documented and managed onboard the MODU as well as to
ensure that consideration is given to the minimum standards of ECE prior to purchasing
any new, replacement or modified equipment for the MODU. Stena’s Chief Engineer is
responsible for ensuring that the planned maintenance schedule is adequate for the
identified ECE, that maintenance schedules are adhered to, and that any ECE
failures/deficiencies are risk assessed and recorded. Stena’s Maintenance
Superintendent is responsible for ensuring that any ECE is identified in the maintenance
system and that History, Planning, and Outstanding Work Order reports are available.
Stena Drilling inspects and maintains environmentally critical elements onboard the
Stena IceMAX on a routine schedule which include the following systems:
• Bilge System
• Deck Drainage
• Drill Cuttings Cleaning System
• Sewage and Grey Water Systems
• Helifuel System
• Fire Control Systems
• Bulk Fuel and Fluid Transfer Systems
10.2.1 Certificate of Fitness and Certification
In accordance with CNSOPB requirements, the drilling vessel will possess a Certificate
of Fitness that has been approved by the CNSOPB prior to starting operations.
Equipment contractors interfacing with the Project must ensure that compliance with
company, industry standards, and regulatory requirements are maintained. Stena will
have an OA required Certificate of Fitness provided by Det Norske Veritas (DNV).
Additionally, the equipment contractor must ensure that compliance with Class, other
regulatory requirements and industry standards are maintained and Shell will conduct
inspections and audits to ensure this compliance is maintained.
Shell will ensure that all Contractor equipment is fit for purpose. Only appropriately
certified equipment will be used.
Any additional critical equipment requires appropriate certification prior to use (e.g.,
pressure vessels, materials handling equipment and lifting gear). It is the responsibility
of the Contractor to ensure that any such additional equipment is fit for purpose and
safe to use prior to entering service with Shell.

All lifting equipment (i.e., slings, shackles, pad-eyes, etc.) is visually inspected by a
competent person from the contractor prior to use and certified by a qualified third party,
annually, as a minimum. Certification certificates must be at the work site for review by
Shell and Regulators if required. A colour coding system is in place for the purpose of
identifying dates for inspection and/or testing. Additional information can be found at the
sites.
Shell and its contractors maintain Quality Management Systems to ensure that all
equipment conforms to the specifications. These systems include procurement of
materials, inspection and testing, witnessed by third parties where appropriate, and final
inspections prior to installation.
10.3 Management of Change
Figure 10.1 Management of Change
HSSE & SP risks related to process, procedural or organizational changes are

managed under Shell’s Management of Change (MOC) procedures. Shelburne HSSE &
SP procedures are reviewed whenever changes occur to relevant HSSE & SP CF
manual sections, or when business risk profiles change and approved by the
accountable leader.
Shell uses the MOC process detailed in the Shell Global Wells Management System
(GWMS) Manual (WS 38.80.31.11-Gen Rev 1). Stena uses the MOC process detailed
in Stena procedure “Management of Change Principle” – L2-PR-OPS-3389. Shell and
Stena are responsible to fully execute its respective MOC programs for changes that
they are responsible. Completed MOCs will be made available upon request by either
company.
Any MOC needed outside this scope will have the procedures identified through the
respective Bridging Documents. However, the minimum will be to follow Shell standards
until this has been identified. At a minimum the MOC processes shall be used to
manage permanent and temporary changes of the following types:
• Process (equipment, process control, and process condition)

• Procedural (affecting HSSE &SP)
• Organizational change (changes in critical role compliment and/or roles and
responsibilities)
• These requirements include the revision distribution and control of associated
documents.
MOC’s are not required for the following changes:
• Procedural changes that do not affect HSSE critical content

• Like For Like Replacement (equipment or personnel)
• Organizational changes that do not involve transfer of HSSE &SP Critical
Activities
Ongoing changes will be managed through the MOC process to ensure that the integrity
of the design is maintained throughout its life. All proposed changes covered by the
MOC Process are screened for their impact to health, safety, environment or regulatory
compliance, reviewed and approved.
This EPP will be a controlled document and subject to Shell’s MOC procedures.

11. MONITORING AND REPORTING
11.1 Performance Measurement and Compliance Monitoring
Compliance with Shell HSSE & SP requirements is checked through Management site
visits, onboard inspections, monitoring of proactive measures, and incident information,
and other assurance processes as described below. EPP specific considerations will be
added to these checks and observations prior to commencing operations. Specific
environmental monitoring programs to be implemented as part of the Project are further
discussed in Sections 12-13.
In association with Shell’s own Performance Monitoring and Reporting (PMR)

requirements under the HSSE CF, Shell measures and monitors performance of the
following environmental parameters:
• Energy Use
• Greenhouse Gas (GHG) Emissions
• Flaring and Other Emissions
• Water Use
• Oil Discharged to Surface Water
• Waste
• Unintended Emissions and Discharges (i.e., hydrocarbon spills)
• Biodiversity
These measures are recorded in Shell’s online reporting tool. Overall effectiveness of
the EPP and environmental performance of operations shall be measured against these
parameters as well as inputs such as non-compliance reports and discussions during
any of the above process activities.
A formal project review will be carried out at the end of operations. Intermediate reviews
may be initiated based on audit findings, site inspections and incident / accident reports.
11.2 Audits and Inspections
Project activities will be subjected to planned inspections and audits to identify potential
environmental and safety problems or non-compliances. The purpose of the inspection
and audit process is to ensure continued compliance with regulations, operational plans,
company plans and regulatory commitments. Audits are carried out in compliance with
Shell Assurance as well as local assurance and self-assessments. The auditor’s
requirements are defined in the HSSE & SP Control Framework.

The following is a summary of various planned audits:
• Pre-Start Up Reviews – e.g., including Drilling, Marine, and Aviation Vessels

• Internal Audits – e.g., Shell HSE Audits, Self-Assessments / Inspections
o LOD1 self-assurance is an asset or venture led assessment of all or part
of the HSSE & SP CF within that asset.
o LOD2 audits are performed by independent assurance providers from the
Wells business, are integral to the LoB Audit Plan and requested by the
business and/or business unit.
o LOD3 are independent audits performed by Group and external assurance
providers. LOD3 audits will include Group level assurance activities [e.g.,
Shell Internal Audit (SIA), Shell Maritime Business Review (SMBR) audits]
o On an annual basis, each LoB will establish, maintain, and execute HSSE
& SP self-assessments in support of the HSSE & SP Assurance Plan
• Independent and External audits (e.g., CNSOPB and Transport Canada
Inspections, and Third Party Verifications)
• Contractor HSSE Audits
• All audits are tracked in Fountain Assurance
All audit processes (local, internal, and external) are used to facilitate continuous
improvement of HSSE &SP based on the lessons learned and experiences gained from
the findings. The audit findings allow specific HSSE &SP issues to be identified early
and corrective actions to be taken, as well as providing assurance that the management
system remains current.
11.3 Managing Non-Conformities
Inspections and audits document outcomes and any resulting non-conformances.

Corrective actions are created and followed through completion. Noted non-
conformances are prioritized, assigned action parties, corrective actions, targeted
completion dates and then tracked to final close-out. Management regularly reviews the
status of corrective actions and ensures that they are implemented. Stena Ice Max will
follow Non-Conformance and Corrective Action Procedure (L2-DOC-LPD-0191) for
compliance.
Typical sources for corrective actions include:
• Audit and self-assessment results

• HSSE MS reviews
• operational monitoring activities
• adverse trends in performance indicators and reporting data
• incident investigations or inspections

• non-completion of agreed and planned HSSE improvements
• failure to meet established targets/limits
• observations
• regulatory/environmental non-compliances
Corrective actions generated during audit and assurance processes, and incident
investigations are compiled and agreed with the affected discipline lead. The compiled
actions are prioritized, responsible parties are assigned, and target completion dates
are established and tracked to final closeout in Fountain Assurance.
Outcomes of these activities will be reviewed and progressed against follow-up

monitoring at various levels of management to ensure adequate actions have taken
place in order to close the event out.
Each location will maintain a Master Action List to track all audits, assurances, incident
investigations, inspections, and preventative maintenance issues that could result in a
problems associated with procedures and equipment. It is the responsibility of the
person in command (PIC) at each location to ensure that the Master Action List are up
to date and being addressed in a timely manner.
11.4 Records Management
The management of Project records will be conducted in accordance with external

requirements for record retention as well as Shell’s Group Records Management
guidelines. The following list provides examples of the types of records maintained to
demonstrate environmental protection and conformity to the management system
covered at different locations:
• Legally required records

• Preventative/corrective maintenance
• Records of HSE critical equipment and tasks
• HSE training records
• Results of audits, reviews, and inspections
• Results of emergency drills and exercises
• performance and compliance monitoring reports
• regulatory/environmental approvals inclusive of commitments
• Records of environmental incidents or non-compliance
These records are stored at each site in such a way that they are readily retrievable by
heads of departments. They are protected against loss or damage and are traceable to
the work-site, activity, product or service involved.

11.5 Continual Improvement
Shell uses feedback from all parts of the management system to provide for continual
Improvement. The term “Management Review” is used to describe the process of
reviewing the feedback and taking action to improve.
Performance management is structured on the Continual Improvement Cycle shown in

Figure 11.1 below and involves the following:
• Plan: Identify performance targets in accordance with the Shelburne Basin

objectives or regulatory requirements/commitments
• Implement: Put performance management resources, processes and
procedures into practice
• Check: Monitor and measure performance against targets and the effectiveness
of the HSE Management system
• Review: take action to improve performance and if necessary the HSE
Management system
Figure 11.1 Shell’s continual Improvement Cycle

Management Reviews are conducted monthly with the Project VLT. At a minimum the
following topics will be reviewed:
• KPI’s/Performance/Objective Targets
• Contractor HSE Management Performance
• Due Diligence
• Status of (serious & high) incidents
• Audit actions (completion)
• Legislative updates
• New Opportunities (performance/ procedural improvement)
• Review of CNSOPB Reports (Environmental and Safety)
During the review, Stakeholder feedback, including complaints and concerns
• Review compliance with laws and regulations (including fines)

• Review compliance with the Shell Group Standards for HSSE & SP, and other
Shell mandatory requirements
• Review timeliness of implementing HSSE & SP corrective actions
• Verify that all elements of the Shell HSSE & SP CF receive adequate focus and
management attention.
Corrective actions from the Management review will be included in the Business
Improvement Plan (BIP) and tracked by Fountain Assurance and a status report
provided to the Shelburne Basin Venture Leadership Team.
11.6 Environmental Reporting
As outlined in the Shelburne Basin Venture Incident Reporting and Investigation

Guidelines (EP201504207396) and in accordance with the Drilling and Production
Regulations, the operator shall ensure that no later than March 31 of each year, an
annual environmental report relating to the preceding year is submitted to the CNSOPB.
Detailed guidance on the requirements for this report are provided in Sections 87 (1) of
the Drilling and Production Regulations.
Additionally for each drilling installation for an exploration or delineation well, Shell will
ensure that an environmental report relating to each well is submitted to the Board
within 90 days after the rig release date and includes:

• a description of the general environmental conditions during the drilling program
and a description of ice management activities and downtime caused by weather
or ice; and
• a summary of environmental protection matters during the drilling program,

including a summary of spills, discharges occurred and waste material produced,
a discussion of efforts undertaken to reduce them, and a description of
environmental contingency plan exercises.

12. ENVIRONMENTAL PROTECTION AND COMPLIANCE
MONITORING OF WASTE STREAMS
Shell and Stena will seek to identify opportunities for minimizing waste generation in
association with Project activities wherever feasible. The Shell and Stena policies and
procedures which apply to these objectives include:
• Shell’s HSSE & SP Control Framework – Environmental Manual for Waste

• Shell’s HSSE & SP Control Framework – Specification for Discharge to Water
• Shelburne Basin Venture Exploration Drilling Project Waste Management Plan
• Waste Management -Stena Ice Max L4-DOC-ICE-4320
• Stena IceMax - Discharges to Sea (Environmental) L2-DOC-LPD-0215
The environmental protection measures outlined within Section 12 are based on best
management practices to reduce and prevent the generation and/or discharge of waste
into the marine environment. All offshore waste discharges associated with the Project
will be managed in compliance with the Fisheries Act, the International Convention for
the Prevention of Pollution from Ships (MARPOL) of which Canada has incorporated
provisions under various sections of the Canada Shipping Act and its regulations, and
treated in accordance with the Offshore Waste Treatment Guidelines (OWTG) as
applicable (NEB et al. 2010) prior to discharge.
Wastes destined for onshore treatment, recycling and/or disposal will be managed in
accordance with the Nova Scotia Solid Waste-Resource Management Regulations and
will comply with any applicable federal and provincial waste requirements as well as
municipal by-laws. A third-party waste management contractor will manage and dispose
of wastes transported onshore in existing approved disposal facilities.
In addition to the waste-related environmental protection measures and compliance

monitoring requirements outlined below, Shell will develop and implement a separate
Project-specific Waste Management Plan. The Waste Management Plan will
incorporate waste management policies, procedures, practices, and plans from Shell’s
HSSE & SP Control Framework – Environmental Manual for Waste, the Stena IceMax,
OSVs, and the onshore supply base to provide comprehensive guidance for waste
management for the Project.
12.1 Offshore Production Waste Streams
The OWTG specify the waste discharges as authorized under the CNSOPB which are
subject to compliance measurements, monitoring and/or reporting for specific
measurements. Relevant waste streams for the Shelburne Basin Venture Exploratory
Drilling Program are described below.

12.1.1 Summary of Offshore Waste Streams
Table 12.1 below includes a summary of normal operational discharges from the Stena
IceMax. The far right hand column indicates the section of the EPP where the discharge
is further described.
Table 12.1 Summary of Operational Discharges
CNSOPB
Collected & Discharge Guidelines Addressed
Discharge Treated Prior Phase Applicable
Waste Stream in EPP
Type(s) to Discharge (Solid, Liquid, (Yes/No) Section
(Yes/No) Gas)
OWTG
Bilge & Sludge Oil in water Yes Liquid Yes 12.3
Ballast Water Seawater No Liquid No 12.3
Oil in water,
Deck Drainage Yes Liquid Yes 12.4
Residual chemicals
Drill Cuttings
Cuttings, Muds,
Cleaning Yes Solid Yes 12.7
Chemical residuals
System
Sewage Aerobically
digested sewage.
(Grey & Black Yes Liquid Yes 12.5
Grey water,
Water) Chorine residual
Macerated Food
Food Waste Yes Solid Yes 12.5
Waste
Cooling Water Seawater No Liquid Yes 12.6
Seawater,
Firewater & AFFF(Aqueous
No Liquid Yes 12.9
Fire Protection Film Forming
Foams)
Fresh/Potable
Water No Liquid No ~
Water
Power
CO, CO2, SOx,
Generation/ No Gas Yes 12.2
NOx
Flare and Vent
Glycol based
BOP Fluids No Liquid Yes 12.8
hydraulic fluid
BOP Seal Monoethylene
No Liquid Yes 12.8
Fluids Glycol
12.1.2 Authorized Discharges Subject to Compliance Monitoring/Reporting
Various authorized discharges to the marine environment from a drilling installation are
subject to specific compliance monitoring requirements including:

• Bilge and/or ballast water
• Deck drainage including storm water that is or is likely to be subject to
hydrocarbon contamination at concentrations >15 mg/L
• Drill cuttings separated from synthetic fluids
• Well treatment fluids
• Cooling or wastewater effluents treated with biocides (e.g., chlorinated
discharges).
12.1.3 Authorized Waste Discharges Requiring Routine Reporting but not Compliance
Monitoring
Authorized discharges under the OWTG which require regular reporting to the CNSOPB
but are not subject to monitoring for compliance to specific discharge limits include air
emissions, specifically greenhouse gases (GHGs) and volatile organic compounds
(VOCs).
Specific reporting requirements are outlined in the “Reporting” subsection of each

specific waste discharge section below.
12.1.4 Authorized Waste Discharges Not Requiring Compliance Monitoring or Routine

Reporting
Authorized discharges identified in the OWTG which are subject to specific treatment or
handling criteria but are not subject to monitoring or compliance to specific discharge
limits or routine reporting include:
• Drill cuttings separated from water-based drilling fluids

• Sanitary and food wastes that have been macerated to an average of 4 mm
particle size prior to discharge (unless chlorinated)
• Cooling water not treated with a biocide
• Fire water
• Desalination brines.

12.1.5 Prohibited Discharges or Discharges Requiring Case by Case Authorization
Some waste streams identified in the OWTG, are not to be discharged under any
circumstance, or if they are to be discharged, require individual approvals from the
CNSOPB. Prohibited waste streams not specifically permitted for discharge under the
OWTG including:
• Oil-based drilling muds or drill cuttings contaminated with such muds with greater
than 6.9g/100g oil on wet solids (synthetic on cuttings concentration)
• Whole synthetic or enhanced mineral oil-based muds
• Any other substances not permitted under the OWTG (e.g., sludges from oil-
water separator systems, spent lubricants, all plastics, excess or damaged
supplies of chemicals, etc.)
Waste streams requiring specific CNSOPB approval prior to discharge on a case by

case basis may include:
• Monoethylene glycol (MEG)

• Residual chlorine or other biocides in cooling water or other wastewater
discharges
• Naturally occurring radioactive materials.
12.2 Air Emissions
12.2.1 Overview
Anticipated air emissions for the Project will include exhaust emissions from diesel
engines powering the MODU and OSVs, potential flaring of solution or production gas
(i.e., dissolved gas in the wellbore or reservoir fluids) during routine well testing,
potential venting associated with non-routine encounters of hydrocarbons and
associated gas during drilling activities, and potential incineration of waste oil. These
emissions may include carbon monoxide (CO), sulphur oxides (SOX), nitrogen oxides
(NOX), particulate matter, carbon dioxide (CO2), and VOCs.
12.2.2 Environmental Objectives
The impact of air emissions from drilling operations will be minimized to the maximum
extent possible.
12.2.3 Environmental Protection Measures
• Shell will conduct ongoing monitoring, reporting and review of air emissions from
the Shelburne Venture Exploratory Drilling Project in support of efforts to reduce

Project-related emissions, comply with the Air Quality Regulations under the
Nova Scotia Environment Act, and meet the National Ambient Air Quality
Objectives under the CEPA, 1999.
• Shell will work with Stena to gather the required data to accurately reflect an air
emissions inventory from the operations of the Project. The air emissions
inventory will meet the requirements of the annual reporting to the CNSOPB.
• Stena manages and monitors air emissions in accordance with its procedure
entitled Environmental Signposts (Doc. No. L2-DOC-LPD-3810) which promotes
the minimization of power generation and flaring where possible and
maintenance of baseline records of emissions. The Stena IceMAX also maintains
a current International Air Pollution Prevention Certificate (Cert No. 30052) which
is valid through June 21, 2012 to April 16, 2017.
12.2.4 Compliance Monitoring Requirements
There are no specific compliance monitoring requirements associated with air emissions
which apply to drilling operations.
12.2.5 Reporting
Shell will calculate GHG emissions associated with the Project on an annual basis and
report the results to the CNSOPB in accordance with the OWTG. Shell will also
determine the type and significance of VOC emissions and report them in accordance
with existing best management practices for oil and gas operations in Canada in
accordance with the OWTG.
12.3 Bilge and Ballast Discharges
12.3.1 Overview
The Stena IceMAX employs conventional MARPOL compliant equipment to manage

bilge discharges. A bilge holding tank equipped with a 5 cubic meter per hour separator
in the centre engine room accepts bilge from the engine and thruster rooms and the
bilge separator. Collected oil may be incinerated or directed to a separated bilge tank
from which oil can be transported to shore in a tote tank for disposal.
Ballast water is contained in segregated tanks and is exchanged as required. Ballast

water exchanges are routinely carried out during transit between well locations in
accordance with local and international requirements.
A detailed description of the Stena IceMAX bilge and ballast system operations are
found in Remote and Local Manual Operation of Ballast-Bilge System Valves – Stena
IceMAX (Doc. No. L5-DOC-ICE-5015)

Bilge water discharges will be treated in compliance with the OWTG such that the
residual oil concentration does not exceed 15 mg/L.
• The Stena IceMAX has a separate bilge system which drains the ships
machinery spaces and is equipped with an oil-water separator as well as a high
concentration of oil in water alarm. Treated water from the oil-water separator will
be discharged from the bilge separation tank in the engine room.
• Oil concentrations in bilge water will be discharged in compliance with the

OWTG, while in operation and MARPOL 73/78, while in transit.
• Ballast water in the MODU is kept in segregated tanks, and as a result, no

chemicals will interact with the water.
• Ballast water will be managed in accordance with the Ballast Water Control and
Management Regulations made pursuant to the Canada Shipping Act, 2001 to
minimize the uptake and transfer of sediment and non-indigenous organisms.
These regulations are harmonized with the International Convention for the
Control and Management of Ships Ballast Water and Sediment (not yet in force).
• The Stena IceMAX shall conduct mid-ocean ballast water exchange during
ballast-laden voyages in an area 200 nautical miles from any shore and in water
2,000 meters deep whenever possible, prior to entering waters under Canadian
jurisdiction. If this is not possible, saltwater flushing of empty ballast water tanks
shall occur in an area 200 nautical miles from any shore, whenever possible.
• Canadian vessels registered under the Canada Shipping Act, 2001 (e.g., OSVs)
shall maintain a ballast water management plan and adhere to the Ballast Water
Control and Management Regulations as applicable.
There are no compliance monitoring requirements for ballast water, although under the
Ballast Water Control and Management Regulations, Transport Canada may undertake
inspections and samples to verify compliance with the provisions of the Regulations.
12.3.5 Reporting
The volume of bilge water discharged to the marine environment via the oil-water
separator will be reported on a monthly basis in the Compliance Monitoring Report for
the MODU.

If there is a situation in which bilge discharges exceed 15 mg/L of oil in water, the
CNSOPB will be notified immediately (i.e., within 24 hours) of the steps being taken to
solve the situation and the Oil Spill Response Plan will be implemented to address the
situation. Any spills into the marine environment will be reported to the Canadian Coast
Guard and the CNSOPB as required as outlined in Shell’s Oil Spill Response Plan.
12.4 Deck Drainage
12.4.1 Overview
The Stena IceMAX has bilges which collect deck drainage and pump liquids to their
respective disposal areas. The bilge water from the exposed decks is collected in a
drain line and received into the deck drain tank (985 m3) through oil-in-water detectors.
The oil-in-water detectors installed on the port and starboard side route the deck drains
into deck drain tank through remotely operated valves based upon the detected oil
content in the drains. If the oil concentration is below 15 mg/L, then the drains can be
routed overboard through remotely operated valves. If oil concentration above 15 mg/L
is detected, the drains are routed to the deck drain tank. The drains from the port and
starboard decks is received into the deck drain tank through U-seals. Each U-seal is
fitted with high and low level switches. These switches are directly interfaced to the oil-
in-water detectors. During normal operations, the drains direct deck water into the deck
drain tank.
Drains from the drill floor and well test areas direct collected water to the topside drain
tank (985 m3 capacity). This tank is fitted with three drain valves which drain into the
drain holding tank. The control of these drain valves is carried out by the Integrated
Automated System (IAS). The contents of these tanks are transferred through an oil-
water separator which removes the oil from the bilge water, discharges clean bilge
water (< 15 mg/L) overboard, and returns the oily bilge water to the recovered oil tank.
The separated oil in the topside drain tank is periodically drained into the separated
bilge oil tank. The waste oil in the bilge oil tank will be disposed of onshore or may be
incinerated.
Deck drainage discharges shall be treated such that the residual oil concentration does
not exceed 15 mg/L prior to ocean discharge.
• Deck drainage will only be discharged in compliance with the OWTG.
• Stena will ensure that all oil-water separation equipment is in good working
condition and will maintain applicable certification for such equipment.

• If maintenance activities occur outside of bunded areas where the release of
hazardous materials could occur, spill collection materials will be used to
minimize the exposed area in the event of a spill or release of materials. All spills
will be cleaned up and the oily debris will be treated appropriately as solid waste.
The deck drainage system of the Stena IceMAX accepts drainage from various areas of
the topsides of the ship, including drilling areas. As a result, there is a need to ensure
that the oil-in-water meter used to monitor the quality of discharge with respect to the 15
mg/L discharge limit is functioning properly. As a result, Shell and Stena will implement
a sampling and analysis protocol onboard the Stena IceMAX to ensure that the water
discharged from deck drainage has an oil-water content of < 15mg/L. The Chief
Engineer is responsible for ensuring all monitoring and measurement associated with
the drainage system is carried out. This sampling and analysis protocol will be
implemented by trained personnel prior to and during drilling operations. The analysis
procedure will be consistent with Standard Methods for the Examination of Water and
Wastewater, 20th Edition, 5520 Oil and Grease, 5520 C Partition-Infrared Method and
5520 F Hydrocarbons.
Should the monitoring protocol described above detect that the 15 mg/L limit is being
exceeded, regardless of the information provided by the oil-in-water meter, the
discharge will be stopped and drainage water re-circulated until the cause of the
exceedance is determined and corrected. The CNSOPB will be notified of this
circumstance should it arise, as described below.
12.4.5 Reporting
On a monthly basis, the total volume (m³) of any deck drainage discharged in
conjunction with the oil-in-water levels determined by the sampling and analyses
described above will be provided in the monthly compliance monitoring report.
Should there be an upset condition or abnormal event that causes deck drainage
discharges to exceed 15 mg/L of oil in water or if a visible hydrocarbon sheen is
observed on the sea surface, the CNSOPB will be notified immediately as per the
reporting process in the Oil Spill Response Plan which will include communication of
being taken to remedy the situation.
Spills to the marine environment will be immediately reported to the Canadian Coast
Guard and the CNSOPB as required and outlined in the Shell Canada Oil Spill
Response Plan and the CNSOPB Incident Reporting and Investigation Guidelines.

12.5 Sewage and Grey Water
Sewage and grey water discharges will comply with the OWTG. All sewage and food
wastes will be reduced through maceration to an average particle size of 4 mm prior to
discharge at sea.
• Sewage will be discharged via two sewage treatment systems and will be subject
to both automatic chlorine and non-chlorinated disinfection. The majority of the
sewage and grey water produced on the vessel will be passed through the non-
chlorinated system. Sewage that will be chlorinated will be injected as a 15%
solution on demand when the discharge pump is activated. The chlorine will be
substantially consumed during the disinfection process.
• A sampling port is available in the system to enable sampling of the waste

stream prior to discharge. Entrained solids will comply with the particle size
required by the OWTG.
There are no compliance monitoring requirements for this waste stream.
12.5.4 Reporting
There are no reporting requirements for this waste stream.
12.6 Cooling Water
12.6.1 Overview
Seawater may be used as cooling water and if so will be discharged without treatment.
No biocides will be added in seawater if used as cooling water.
No biocides will be added if seawater is used as cooling water.
There are no compliance monitoring requirements for this discharge stream.

12.6.4 Reporting
There are no reporting requirements for this discharge stream.
12.7 Drilling Discharges
12.7.1 Overview
The drilling of each offshore well can be broken into two components, starting with
riserless drilling (i.e., an open system with no direct drill fluid return connection to the
MODU) and continuing with riser drilling (i.e., closed loop system with direct drill fluid
return connection to the MODU). Each well is anticipated to take approximately 170
days to drill to true vertical depth (TVD).
During the drilling of the initial sections of the well, there is no close loop fluid (riser)
system in place to return drilling fluid back to the MODU (i.e., riserless drilling). As such,
the associated drilling fluids, excess cement and cuttings are directed to the seabed and
released directly to the seafloor. During this phase, the drilling fluid consists of seawater
or water-based drilling mud (WBM) to cool the drill bit as well as transport the cuttings to
the seabed. Riserless drilling will be used for the initial drill sections (conductor and
surface strings) of each well, prior to connection of a riser system for drilling the
additional sections to target depth.
Following the installation casing and the blowout preventer (BOP) stack to the wellhead,
the riser system creates a conduit to capture the associated drilling fluids and cuttings
and transport them back to the MODU for further processing.
During this phase of drilling, the remaining well sections are drilled to TVD using either a
WBM or synthetic-based mud (SBM). Drill cuttings will be separated from the drilling
fluid utilizing the ships solid control system. The separated cuttings will be processed
through the cuttings dryer prior to being discharged approximately 2 m below the sea
surface. Only synthetic based fluid adhering to cuttings after processing will be
discharged at sea in accordance with the OWTG. In the event of a system malfunction
SBM cuttings will be captured in containers.
Drill waste discharges will be in compliance with the OWTG:
• Drill cuttings from synthetic –based mud drilling operations will be treated to meet
a 48 hour mass weighted average of retained “synthetic-on-cuttings” not
exceeding 6.9g/100g oil on wet solids
• The total volume of synthetic-based drill muds discharged to the marine

environment will be minimized

• WBM will be used where is it technically feasible
• The need to discharge whole water based muds shall be minimized.
• Drilling discharges shall be treated in accordance with the requirements of the

OWTG.
• Drill cuttings shall not exceed the 48-hour mass average of retained “synthetic-
on-cuttings” or “enhanced mineral oil-on-cuttings” discharged to sea of 6.9
g/100g oil on wet solids criteria.
• No whole SBM or whole mud containing SBM as a base fluid shall be discharged
at sea.
• Spent SBM drilling mud that is returned to the MODU during riser drilling and
cannot be reused shall be transported to shore for disposal.
• Surplus cement used during riserless drilling shall be disposed on the seabed.
• Spent and surplus cement used during riser drilling shall be transported to shore
for disposal in an approved facility.
The concentration of SBM retained on discharged drill cuttings shall be measured every
12 hours in accordance with the Procedure for Field Testing Oil Based Drilling Muds
(API 1991). A mass-weighted rolling 48-hour average shall be calculated in grams of
synthetic fluid per 100 grams wet solids.
In accordance with the Data Acquisition and Reporting Guidelines and Drilling and
Production Guidelines, Shell will provide a Well History Report to the CNSOPB for every
well drilled under the Well Approval within 90 days of the rig release date. The report
will include the following details:
• the type of drilling fluid and summary of the properties maintained for each phase
of the hole
• information on the total quantity of SBM consumed during drilling
• a calculation of the total amount of mud-derived synthetic fluid discharged with

cuttings
• a description of the effectiveness of cuttings treatment with reference to weekly

measurements of synthetic fluid retention on cuttings (i.e., grams of synthetic

fluid per 100 grams of cuttings, types and sizes of cuttings, and number of
samples)
• a summary and description of any drilling fluid losses
• any fluid disposal downhole, including volumes, rates, pressures, dates, and
nature of the fluid
12.7.5 Reporting
In accordance with the OWTG, raw and averaged data as described in Section 12.7.4
shall be provided to the CNSOPB on a monthly basis. Daily analysis of retained
“synthetic on cuttings” discharged to sea will be recorded and reported to the CNSOPB
daily.
Shell, in accordance with CEAA condition 3.12.1, will measure and report
concentrations in excess of the limits to the CNSOPB within 24 hours and adjust
treatments as necessary to prevent further exceedances.
12.8 Blowout Preventer Fluids
12.8.1 Overview
The Stena IceMAX carries two BOP units onboard. The purpose of the BOP stack is to
contain well fluids in the event that the primary well control method proves to be
inadequate. The IceMAX has two Cameron 18 ¾ “ 15,000 psi BOP assemblies
consisting of a Lower Marine Riser Package (LMRP) and a Lower BOP Stack. The BOP
is used to shut in the well, strip out drill pipe under moderate wellbore pressure, and in
an emergency, the BOP can shear off the drill string and seal the wellbore pressure.
The BOP stack can control wellhead pressure in all phases of drilling.
The BOP system is a dual redundant electro-hydraulic system which utilizes electronic
signals to activate hydraulic valves for the BOP functions. All functions on the lower
marine riser package (LMRP) and the BOP stack are electro-hydraulically controlled
from remote control panels located at the surface on the drilling unit.
The hydraulic fluid used to control and operate the BOP is produced in a mixing unit on
the surface and pressurized by a hydraulic pumping unit (HPU) for transfer to the
subsea. The HPU consists of six electric motors which pump a water/glycol mixture
from the HPU supply tank to the goose-necks in the moon-pool and down conduit lines
on the riser string.
BOP control fluid contains 4% Erifon HD603 HP, 10% Glycol and 86% water. Erifon
HD603 contains the following constituent components:

• Ethylene glycol (25-35%)
• Tall oil amide (15-25%)
• Oxazolidine (1-5%)
• Sodium N-lauroylsarcosinate (1-5%)
Erifon has low aquatic toxicity; one of the constituents, Oxazolidine (1-5%), is
considered harmful to aquatic organisms.
The Stena IceMax is equipped with a return line so that “high volume” BOP functions do
not discharge control fluid to sea. This is a rare setup as most subsea BOP control
systems discharge to sea for every function. Instead, during routine functions/ testing
the BOP control fluid can be returned to the drill ship. “High Volume” functions are
defined as functions of the Ram/Annular preventors. The low volume functions (choke
and kill valves) however discharge BOP control fluid to sea.
The volume of BOP control fluid discharged to sea from the Stena IceMax is typically
110-130 litres (L)/week. However, based on the composition, this amounts to
approximately 5 L of Erifon discharged per week.
An additional discharge source relating to the BOP is around the area where the BOP
connects to the wellhead. Hydrate build up around this seal has the potential to prevent
the BOP from being disconnected from the wellhead. To prevent the buildup of
hydrates, approximately 5 gallons of monoethylene glycol will be pumped every 2 days
into this seal. This equates to 17.5 gallons per week (approx. 67 litres/week) of hydrate
seal glycol, while the BOP is connected. The glycol is discharged to sea through the
seal, removing any hydrates that may be present.
BOP fluids will be screened through a chemical management system in accordance

with the OCSG to identify low toxicity fluids. The amount of fluids discharged to the
marine environment will be minimized.
• Return line decreases volume of discharges from weekly testing.
• During a failure of the primary BOP control system at the surface, secondary
independent control systems will be used. In this situation fluid may be
discharged to the marine environment. Quantities of BOP fluid discharged will be
monitored and reported as per Stena’s Discharges to Sea (Environmental) (Doc.
No. L2-DOC-LPD-0215).

The Subsea Engineer will be responsible for monitoring and measuring any discharges
of fluids to the marine environment associated with the operation of the BOP. Quantities
of BOP control fluid used and discharged is monitored using flow meters and recorded
by stock level balance checks on a continuous basis. The calibration of flowmeter
equipment to ensure accuracy and relevant records are maintained according to
Stena’s Planned Maintenance System. Monitoring will be carried out as described in
Stena’s Discharges to Sea (Environmental) (Doc. No. L2-DOC-LPD-0215).
12.8.5 Reporting
In accordance with the OWTG, the volume and types of any fluids discharged into the
marine environment will be reported to the CNSOPB on a monthly basis.
12.9 Firewater and Fire Protection
12.9.1 Overview
The Stena IceMax carries a fire suppression system consisting of 9 tanks that contain
the fire extinguishing agent Aqueous Film Forming Foam (AFFF). The AFFF to be used
is Ansulite 3% AFFF Freeze Protected. It contains 55% proprietary mixture of
hydrocarbon surfactants, fluorosurfactants, inorganic salts and water, 15% Diethylene
Glycol Monobutyl Ether and 30% Ethylene Glycol.
Onboard the IceMax, four tanks (450L each) supply the helideck, four tanks (2000L
each) supply the well test deck, and one 8000L main storage tank for foam supply to the
shaker house and pit rooms. Additionally, there are approximately fifteen 20L drums of
foam to be used at fire hydrants. Dispersal from the tanks is either through fire monitors
or sprinklers. Dispersal from the drums is via a fire hose. The system is tested monthly,
but no foam is used. The system is tested with seawater only.
During standard operation (non-fire events), the volume of Ansulite discharged to sea
from the IceMax is approximately 20 litres/month or 100L over the course of the drilling
activity for each well. The discharge is due to the annual sampling/chemical analysis of
the foam from all storage tanks as well as from training exercises. To the extent
possible, produced foam will be contained onboard and returned to the drain tanks.
The amount of foam discharged to the marine environment will be minimized.
• The fire protection system will be tested monthly, however no foam will be used.

• Used foam from sampling and training exercises will be contained as much as
possible onboard and returned to the drain tanks.
• In accordance with the Offshore Waste Treatment Guidelines (OWTG), water for
testing fire control systems may be discharged without treatment.
• There are no compliance monitoring requirements for this discharge stream.
12.9.5 Reporting
In accordance with the OWTG, prior to conducting scheduled testing of the fire
suppression system, and where fire suppression chemicals are expected to be
discharged to sea, Shell will notify the CNSOPB when this discharge is expected to
occur.

13. ADDITIONAL ENVIRONMENTAL PROTECTION
CONSIDERATIONS
13.1 Handling of Helifuel
13.1.1 Overview
The helifuel system is comprised of:
• 2 storage tanks
• a flexible steel hose
• a pneumatic/electric pump
• a dispenser unit with filter separation/monitoring and
• a hose reel.
The helifuel storage area is located on the starboard side of the accommodation block,
behind the firewall. The area is protected from deluge.
Due to the combustible nature of helifuel, and to ensure the safety of operators, the
drainage from the helideck is routed directly overboard without treatment. All spills and
releases of helifuel and other hazardous materials in the helideck area will be minimized
where possible and will be cleaned up and treated as solid waste. Helifuel is transported
in portable tanks that are sealed until in place in the bunded area where one tank at a
time is connected to the refueling pump.
Shell’s and Stena’s objective is to avoid any loss of fuel from the helideck into the
marine environment during normal operations.
• Spill containment materials for minor hydrocarbon spills will be available and
firefighting precautions will be in place at the helideck during helicopter refueling
operations. Where it is safe to do so, spills of aviation fuel on the helideck will be
contained and cleaned up immediately.
• In the event of a release of helifuel into the marine environment, response

activities will be conducted in accordance with the Shell Canada Oil Spill
Response Plan.

There are no compliance monitoring requirements associated with this activity.
13.1.5 Reporting
All helifuel spills to the marine environment will be immediately reported to the Canadian
Coast Guard and the CNSOPB as required and outlined in the Shell Canada Oil Spill
Response Plan.
13.2 Transfer of Fuel, Bulk Drilling Fluids and Liquid Wastes between Vessels
and Rig
Bulk transfers of fuel, fluids, and wastes between OSVs and the MODU are carried out
in strict compliance with procedures to avoid spills of materials being transferred.
Strict compliance with Shell Canada Marine Operations Manual (OPS0011) is the basis
for environmental protection in these operations. Stena’s requirements for this operation
are consistent with these requirements and include but may not be limited to:
• Routine preventive maintenance on bulk product hose system components (e.g.,

overfill alarms, valves, fittings, pumps, transfer lines, hoses, etc.) to ensure
equipment is in good working order.
• Prior to beginning transfer of bulk products, check liquid levels, flows (including
direction of transfer), pressures and temperatures throughout the system. In
addition, confirm that monitoring devices and alarm systems are fully operational
and pumps and transfer lines are working properly.
• The drill rig will use floating hoses that are equipped with dry break connections
for fuel transfers.
• All transfers of fuel and other petroleum based products (e.g., SBM) will be
continuously monitored by operations personnel. Operations personnel will line
walk the system to visually inspect for leaks, damage and/or system
abnormalities. Any irregularities must be reported immediately.
• The Barge Master will maintain all records relating to bulk transfers and ensure
that relevant transfers are recorded in the oil record book as required.
• Maintain spill response materials in the area of the transfer.

If an event occurs that results in a spill into the marine environment, response activities
will be conducted in accordance with the Shell Canada Oil Spill Response Plan.
There are no compliance monitoring requirements associated with this activity.
13.2.4 Reporting
All spills to the marine environment will be immediately reported to the Canadian Coast
Guard and the CNSOPB as required and outlined in the Shell Canada Oil Spill
Response Plan.
13.3 Vessel Operations
The MODU and OSVs will adhere to standard operating and navigation procedures and
comply with the Canada Shipping Act, MARPOL, all applicable regulations, and
Canadian Coast Guard requirements.
Offshore waste streams, including those associated with vessel operations, are
summarized in Section 10.1 along with applicable reporting and/or monitoring
requirements and discharge prohibitions. Procedures for environmental protection and
compliance monitoring of waste streams from vessel-related air emissions, bilge and
ballast discharges, deck drainage, sewage and grey water, cooling water, and drilling
discharges are described in Sections 10.2 through 10.7. Transfers of fuels and bulk
liquids, including wastes, between OSVs and the MODU are addressed in Section 11.2
of this EPP. Any spills to the marine environment from the MODU or OSVs will be
immediately reported to the Canadian Coast Guard and the CNSOPB as required (refer
to Section 15 of this EPP for more information about environmental incidents).
Local metocean conditions will be monitored and extreme weather conditions that are
outside the operating envelope of the MODU or OSVs will be avoided if necessary.
Pilots will have the authority and obligation to suspend or modify operations in case of
adverse weather that compromises the safety of OSV or MODU operations. The
implementation of standard operating procedures, such as reducing vessel speed, using
appropriate sound and/or light signals, and relying on radar and navigation equipment
as appropriate, will help OSVs to navigate safely during foggy conditions. Icing
conditions and accumulation rates on OSVs and the MODU will be monitored during fall
and winter operations, particularly when gale-force winds may be combined with air
temperatures below -2 °C.

13.3.1 Mobile Offshore Drilling Unit (MODU)
The MODU selected for the Project is the Stena IceMAX, a dual mast, dynamically
positioned, Polar Class 4, harsh environment, ultra-deepwater drillship, designed and
certified for year-round worldwide operations.
The Stena IceMAX is equipped with a Kongsberg Maritime Automation System (IAS), a
distributed monitoring and control system built for marine and offshore applications. The
IAS covers all important functions onboard the MODU, including:
• power management
• auxiliary machinery control
• ballast/bunkering monitoring
• fire and gas detection
The Stena IceMAX was designed according to the following operating criteria (Table
13.1).
Table 13.1 Operating Criteria for Stena IceMAX
Parameter Survival Stand-by Connected Max Drilling

Significant wave height,
16.0 11.5 6.7
Hs (m)
Zero up-crossing period,
11.0–15.0 8.0–11.0 7.0–10.0
Tz (s)
Wind speed
41.0 31.0 27.0
(10 m, 10 min) (m/s)
Source: Stena IceMAX HSE Case, Part 3 – Vessel Description (Doc. No. L4-DOC-ICE-4128)
Additional information about operational limits for the Stena IceMAX and appropriate
procedures are summarized in Environmental Effects and Operational Limits – DrillMAX
and IceMAX Class Vessels (Doc. No. L2-DOC-OPS-4834).
Shell and its contractors will adhere to all applicable mitigations identified within the
CEAA Decision Statement as well as the mitigation commitments made in the EIS,
including the following:
• Offshore waste discharges and emissions associated with the Project (e.g.,
operational discharges and emissions from the MODU) will be managed in
compliance with MARPOL and treated in accordance with the OWTG, as
applicable.
• A 500-m radius safety zone will be maintained around the MODU during Project
operations. No persons will be allowed within the safety zone without the
permission of the Master/ OIM. The Master/OIM has the authority, granted by the

Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act,
to enforce exclusion and safety zones. Under the Nova Scotia Offshore Drilling
and Production Regulations, reasonable measures will be taken to warn persons
in charge of vessels and aircraft regarding the safety zone boundaries, the
facilities within the safety zone, and any related potential hazards. Shell will
provide details of its operation, including the safety zone during drilling and
testing, to the Marine Communications and Traffic Services for broadcasting and
publishing in the “Notice to Shipping” and “Notice to Mariners”.
• Other ocean users with potential to be affected by the Project will be notified
regarding the timing and location of Project activities and components (e.g.,
through direct communications and/or the issuance of Notices to Shipping) to
mitigate potential disruption.
13.3.2 Offshore Support Vessels (OSVs)
The key manageable environmental risks related to OSV operations are associated with
vessel transiting (which has potential to affect marine mammals and sea turtles, Special
Areas, and commercial and Aboriginal fisheries and other offshore users) and routine
operational discharges (which have potential to affect fish and fish habitat, marine
mammals and sea turtles, marine birds, and Special Areas).
Shell and its contractors will adhere to all applicable mitigations identified within the
CEAA Decision Statement as well as the mitigation commitments made in the EIS,
including the following:
• In preparation for the Project, OSVs will undergo Shell’s internal audit process as
well as additional external inspections/audits, including the CNSOPB pre-
authorization inspection process, during Q2/Q3 of 2015.
• Offshore waste discharges and emissions associated with the Project (e.g.,
operational discharges and emissions from OSVs) will be managed in
compliance with MARPOL and treated in accordance with the OWTG, as
applicable.
• OSVs will be compliant with the Canada Shipping Act and national and
international regulations while at sea, Eastern Canadian Vessel Traffic Services
Zone Regulations when operating in nearshore or harbour areas, and applicable
Port Authority requirements when in a port. Ship operations will also adhere to
Annex I of MARPOL, of which Canada has incorporated provisions under various
sections of the Canada Shipping Act and its regulations.
• OSVs transiting to and from the MODU will use existing shipping routes, adhere
to standard navigation procedures, and travel at vessel speeds not exceeding 22

km/hour (12 knots). During transiting activities outside the Project Area, OSVs
will reduce speed in the event that a marine mammal or sea turtle is noted in
proximity to the vessel. OSVs will reduce speeds to 18.5 km/hour (10 knots) at all
times within the Project Area.
• OSVs will avoid the Gully, as per the Gully Marine Protected Area Regulations,
when travelling to and from the MODU; will avoid other critical habitat for the
northern bottlenose whale (Shortland and Haldimand canyons); and will avoid
critical habitat for the North Atlantic right whale (Roseway Basin) from June 1 to
December 31.
• OSVs will maintain a 2 km avoidance buffer around Sable Island.
13.4 Helicopter Operations
Project activities will require helicopter support for transfer of crew and light supply.
Helicopter routes take into account avoidance of a military “no fly” zone, which would
prohibit flying a straight line to the centre of the Project Area, and also avoid Roseway
Basin and Sable Island.
All helicopter operations will be conducted in strict adherence to Transport Canada and
International Aviation requirements. Transport of potentially hazardous materials will be
carried out in compliance with International Air Transport Association (IATA) and
Transportation of Dangerous Goods (TDG) requirements.
The key manageable environmental risk associated with helicopter operations offshore
is associated with refuelling on the MODU and the risk of spillage of fuel during
refuelling or in transport of fuel to the helipad from its storage location. Procedures for
environmental protection and compliance monitoring of waste streams from the
handling of helifuel are described in Section 11.1. Any spills to the marine environment
from Project helicopters will be immediately reported to the Canadian Coast Guard and
the CNSOPB as required (refer to Section 14 of this EPP for more information about
environmental incidents).
Operational limitations for helicopters will depend on the type of aircraft used. In
general, the following limits are applied for routine operations (Table 13.2).
Table 13.2 Operating Criteria for Helicopters
Parameter Limit
Roll + or -3 degrees
Pitch + or -3 degrees
Rate of heave 1.3 m/s
Wind 50 knots

Visibility Horizontally 250 metres
Source: Stena IceMAX HSE Case, Part 3 – Vessel Description (Doc. No. L4-DOC-ICE-4128)
Additional information about operational limits for helicopters and appropriate

procedures are summarized in Environmental Effects and Operational Limits – DrillMAX
and IceMAX Class Vessels (Doc. No. L2-DOC-OPS-4834).
Extreme weather conditions that are outside the operating envelope of Project
helicopters will be avoided if necessary. Pilots will have the authority and obligation to
suspend or modify operations in case of adverse weather that compromises the safety
of helicopter operations. The implementation of standard operating procedures, such as
reducing helicopter speed and/or adjusting flight altitude, using appropriate sound
and/or light signals, and relying on radar and navigation equipment as appropriate, will
help helicopters to navigate safely during foggy conditions. Icing conditions and
accumulation rates on helicopters will be monitored during fall and winter operations,
particularly when gale-force winds may be combined with air temperatures below -2 °C.
Shell and its contractors will adhere to all applicable mitigation commitments made in
the EIS, including the following:
• Except in the case of an emergency, Project helicopters will avoid flying over
Roseway Basin and Sable Island.
• Helicopters transiting to and from the MODU will fly at altitudes greater than 300
m and at a lateral distance of 2 km from active colonies when possible.

14. CHEMICAL SELECTION AND MANAGEMENT
The selection and management of chemicals for the Project will be conducted according
to a Chemicals Selection and Management Procedure which will be developed and
implemented prior to the Project commencement. The Plan will be in compliance with
applicable regulation and will follow the OCSG (NEB et al. 2009) for selection of
chemicals. At this stage in Project planning, Shell has not yet completed full chemical
selection.
14.1 Chemical Selection
Globally, Shell manages chemicals in accordance with the hierarchy of elimination,

substitution and minimization. In accordance with Shell’s Product Stewardship
Standard, purchased products, inclusive of chemicals, are risk assessed based on
potential risks to people and the environment as well as potential for release or
exposure and assigned a RAM ranking. The outcome of the assessment is established
to overestimate and conservatively identify the risk. For those chemicals identified as
having a Yellow or Red RAM rating, the following control hierarchy is implemented:
• Eliminate the use of the product

• Substitute with a product of lower risk
• Apply the requirements of managing risk
Shell will preferentially select the lowest toxicity alternatives, and chemicals that
minimize residual impact if released into the environment (e.g., biodegradable, non-
chlorinated, etc.
Stena carries out a Control of Substances Hazardous to Health (COSHH) assessment

for all hazardous chemicals that are stored, handled or used on board its vessels to
evaluate their potential health risks and identify appropriate protective measures. The
assessments are based on Material Safety Data Sheets (MSDS) provided for each
chemical and information contained in Stena’s SYPOL database. The vessel’s Medic is
the designated COSHH coordinator and is responsible for ensuring compliance with the
policies and process established by Stena for conducting COSHH assessments. These
policies, as well as the assessment process map, are described in Stena’s Hazardous
Substance Principle (Doc No. L2-PR-LPD-0285) and Offshore COSHH Assessment
(Doc. No. L2-PM-LPD-0751) documents, respectively. Other Stena procedures relevant
to chemical management on the MODU are: Hazardous Goods Handling Procedure
(Doc. No. L2-DOC-MAT-0180) and Handling of Toxic and Other Dangerous Chemicals
(Doc No. L4-DOC-CAR-1288).
14.2 Offshore Chemical Management
Stena’s Heads of Departments are responsible for the storage of oil and chemicals
within their specific areas, while Stena’s Bargemaster and the Chief Engineer are

responsible for monitoring and measurement associated with the storage of oil and
chemicals. As per Stena’s Discharges to Sea (Environmental) document (Doc. No. 12-
DOC-LPD-0215), the following environmental protection and monitoring procedures will
be implemented with respect to the storage of oil and chemicals in permanent storage
tanks:
• Permanent storage tanks should be clearly labelled to identify the substance

contained within.
• High level alarms and overflow return pipes should be fitted, where possible, to
prevent spillage during filling and maintained through the Planned Maintenance
System (PMS).
• The volume indicators and the high level alarms should be calibrated to ensure
accuracy according to the PMS.
• Bunds should be present around permanent storage tanks, where possible,

including helifuel tanks. As a guide, bunds should be able to hold 110% of the
tank volume or if multiple tanks, 110% of the largest tank volume or 25% of the
total capacity of all tanks, whichever is greater.
• Bunds should be inspected under the PMS.
• Spill kits should be located near to permanent storage containers and any
materials replaced if used. Personnel should be fully trained in the use of spill kit
materials.
• Adequate protection should be provided where tanks are situated in a position

where potential damage is possible by moving machinery.
Use of temporary containers/tanks to store hydrocarbons will be avoided wherever

possible. However, Stena’s Discharges to Sea (Environmental) document (Doc. No. 12-
DOC-LPD-0215) outlines additional procedures that will be implemented if temporary
containers/tanks are used to store hydrocarbons for any reason.
14.3 Reporting
In accordance with the OCSG, an annual report detailing chemical usage and discharge
quantities for the Project will be prepared and submitted to the CNSOPB.

15. WASTE MANAGEMENT
Offshore waste discharges associated with the Project will be managed in compliance
with MARPOL, of which Canada has incorporated provisions under various sections of
the Canada Shipping Act, 2001 and its regulations, and treated in accordance with the
OWTG. Further information regarding offshore waste objectives and practices are
detailed in the Shell Canada Shelburne Basin Venture Waste Management Plan
included as Appendix C.
Wastes destined for onshore treatment, recycling and/or disposal shall be managed in
accordance with the Nova Scotia Solid Waste-Resource Management Regulations and
will comply with any applicable federal and provincial waste requirements as well as
municipal by-laws. A third-party waste management contractor will manage and dispose
of wastes transported onshore in existing approved disposal facilities. Please refer to
the Shelburne Basin Venture Waste Management Plan (EP201505209133).

16. SPECIALIZED OPERATIONS
Additional operational procedures and relevant documents that are implemented to
achieve environmental protection are discussed below.
16.1 Routine Testing of Blowout Preventer
A full BOP function test will be conducted weekly to ensure proper functioning of this
piece of equipment. During these routine testing activities, approximately 100 to 130L of
BOP fluid will be discharged to sea in accordance with the OWTG. See Section 12.8 of
the EPP for further information on the composition of the BOP fluid to be used in
association with the Project.
16.1.1 BOP Seal Hydrate Buildup Prevention
See Section 12.8 of the EPP for further information on this activity.
16.2 Routine Testing of Fire Suppression System
The fire suppression system onboard the MODU will be tested in accordance with the
procedure outlined in Stena’s Fire Systems Test Guidance – Stena IceMAX, Marine
RSWM (Doc No. L5-DOC-ICE-4098) document. During monthly testing activities,
approximately 20L of fire suppression chemical will be discharged to sea. See Section
12.9 of the EPP for further information on the composition of the fire suppression fluid to
be used in association with the Project.
16.3 Vertical Seismic Profiling
VSP surveys will adhere to mitigation measures described in the SOCP and outlined in
Shell’s EA for the Shelburne Basin 3D Seismic Survey (LGL 2013) as well as those
identified within the CEAA Decision Statement for the Project.
Because avoidance behaviour occurs at lower thresholds, a ramp-up procedure (i.e.,

gradually increasing seismic source elements over a period of approximately 30
minutes until the operating level is achieved) will be implemented before any VSP
activity begins. Additionally, shutdown procedures (i.e., shutdown of source array) will
be implemented if a marine mammal or sea turtle species listed on Schedule 1 of
SARA, as well as all other baleen whales (i.e., mysticetes) and sea turtles are observed
within 1 km of the wellsite (refer to Section 18.2 for information regarding marine
mammal monitoring).
16.4 Well Abandonment
Wells drilled during the first campaign that are required for testing in the second
campaign will be suspended for potential future re-entry. Abandonment will take place
immediately following drilling or well testing, if required and will be done in compliance

with Shell’s internal procedures and CNSOPB regulatory requirements. Abandonment
of individual exploration wells would include the installation and testing of multiple
barriers (cement and mechanical) in the wellbore and take approximately seven to ten
days per well.
In association with well abandonment, approval may be sought to leave the wellhead in
place. If approval to leave the wellhead in place is provided by CNSOPB, the associated
subsea infrastructure that would be left in place would be a portion of the conductor
casing as well as the well head and would extend approximately 4–5m above the
seabed. As per CEAA Condition 5.3, if the abandoned wellheads are left on the
seafloor, Shell shall provide the location of the abandoned wellheads to the Marine
Communications and Traffic Services for broadcasting and publishing in the Notices to
Shipping.
Under Section 58 of the Nova Scotia Offshore Petroleum Drilling and Production
Regulations, the seafloor must be cleared of any material or equipment that may
interfere with other commercial uses of the sea. As such, a key consideration in
determining whether or not to remove or leave the wellhead in place will be the potential
for any interaction with other commercial users. Individual abandonment plans will be
developed and subject to approval by the CNSOPB on a case-by-case basis. Shell will
engage with commercial fisheries in regards to any planned abandonment activities and
will also seek approval from the CNSOPB for abandonment plans. All abandoned well
locations will be noted on nautical charts for future reference. Should well heads be left
in place on the seabed, this detail would be noted in association with the well locator to
reduce the potential for any subsea interaction. As per CEAA condition 5.2, if the
wellhead is proposed to remain in place on the seafloor , Shell will prepare a well
abandonment plan and consult with Aboriginal and commercial fishers on the plan.

17. ENVIRONMENTAL INCIDENTS
17.1 Incident Reporting and Investigation
Shell will take all reasonable measures to prevent accidents and malfunctions that may
result in adverse environmental effects and shall implement emergency response
procedures and contingency plans developed in relation to the Project as per CEAA
condition 6.1. The Incident Reporting and Investigation Guideline (referred to throughout
as “the Guidelines”) (C-NLOPB and CNSOPB 2012) define an incident as: “Any event
that caused or, under slightly different circumstances, would likely have caused harm to
personnel, an unauthorized discharge or spill or an imminent threat to the safety of an
installation, vessel or aircraft. It also includes any event that impairs the function of any
equipment or system critical to the safety of personnel, the installation, vessel or aircraft
or any event that impairs the function of equipment or systems critical to the protection
of the natural environment.” All incidents and near misses that occur in relation to the
Project will be reported to the CNSOPB and other applicable authorities in accordance
with the Guide.
External Reference: Shelburne Basin Venture Incident Reporting and Investigation

Guide (EP201504207396)
Any Shell or contractor or employee that becomes aware of a hazard or incident during
the course of Project activities is expected to immediately report the occurrence to the
Shell Drilling Supervisor and the Stena Master/OIM. The Drilling Supervisor will be
responsible for ensuring that all incidents are investigated and reported in compliance
with regulatory and Shell requirements.
17.1.1 Incident Reporting to the CNSOPB
The Project will notify the CNSOPB of incidents, as required. There are three types of
notifications, immediate verbal, immediate written, and written notification (within 24
hours), as described in the Guidelines.
17.1.1.1. Immediate Verbal Notification
CNSOPB Duty Officers can be contacted for immediate verbal notification of an incident
24 hours a day, seven days a week at < Redacted>. The following incidents must be
reported immediately to the CNSOPB on-call Duty Officer:
• Fatality
• Missing person
• Major injury
• Medical evacuation (MEDEVAC)
• Fire/explosion

• Flooding (uncontrolled)
• Collision
• Loss of well control
• Major hydrocarbon release
• Unauthorized discharge or spill greater than 25 L
• Adverse environmental conditions
• Security threat or breach
• Implementation of emergency response plans
• Major impairment/damage
• Near Miss with potential for fatality
Incidents will be reported by the PIC of a location. The PIC will use standard forms for
reporting of incidents available under their company HSSE &SP MS.
As soon as reasonably practicable following the verbal notification written notification

will be provided to the CNSOPB.
17.1.1.2. Immediate Written Notification
The following incidents must be reported to the CNSOPB immediately by e-mail to

incident@cnsopb.ns.ca:
• Well Control Incident

• Unauthorized Discharge or Spill of 25 L or less
17.1.1.3. Written Notification
For all incidents written notification will be provided to the CNSOPB as soon as
reasonably practicable but no later than 24 hours after Shell becomes aware of any
incident.
17.1.2 Incident Reporting to Other Authorities
After completing the mandatory indent reporting to the CNSOPB, in some instances,
direct contact by an operator with other authorities may be required at the request of
those agencies (e.g., federal or provincial departments or other regulatory agencies).
Shell is responsible for ensuring that all authorities are appropriately contacted. If a
health, safety, or environmental occurrence does not directly trigger incident-reporting to
the CNSOPB, but requires written notification to another authority, Shell will also notify
the CNSOPB and provide a copy of the written notification.

Some of the other authorities that may require notification are listed in Table 17.1
below.
Table 17.1 Other Authorities
Authority Service/Contact
Joint Rescue Coordination Centre (JRCC) To be contacted immediately if the incident

involves, or has the potential to involve,
marine search and rescue or MEDEVAC.
The JRCC’s 24-hour emergency phone
numbers for Nova Scotia are 1-800-565-
1582 or 902-427-8200.
The Canadian Coast Guard (CCG) To be contacted immediately for all marine
pollution incidents. The CCG’s 24-hour
emergency phone number for Nova Scotia
is1-800-565-1633.
CCG Regional Operations Centre Contact for all incidents involving fatalities,
missing persons or injury/illness to
personnel working on a Canadian flagged
vessel or installation (1-800-565-1633 or
902-426-6030), CCG will then transfer
notification to Transport Canada Marine
Safety. The CCG Regional Operations
Centre should also be contacted to report
pollution of any type (to land, sea and air),
defective aids to navigation/hazards to
navigation, environmental emergencies,
and fisheries-related incidents.
Transport Canada Marine Safety To be contacted for all incidents involving

damage affecting the seaworthiness or
efficiency of a Canadian flagged vessel.
Report directly to the regional director of
Transport Canada Marine Safety at 902-
426-2060.
Transport Canada Civil Aviation Contingency Contact for all aviation emergencies and
Operations (CACO) incidents at 1-613-947-5140 (from 0800–
1600 Monday to Friday, excluding statutory
holidays) or 1-877-992-6853 (24-hour

Table 17.1 Other Authorities
Authority Service/Contact
emergency line).
Royal Canadian Mounted Police (RCMP) Contact for all incidents involving criminal
activity (including serious injuries),
terrorism, fatalities or missing persons at
902-426-7766 in Nova Scotia.
Environment Canada Administers regulations concerning various

chemical substances and classes of
substances under CEPA, 1999. All
incidents reported to Environment Canada
in compliance with a federal regulation
(e.g., halocarbon releases) should also be
reported in writing to the CNSOPB.
Workers’ Compensation Board (WCB) of Contact to report injuries and illnesses .

Nova Scotia Reporting is mandatory where
circumstances may entitle a worker to
compensation.
Certifying Authority and CNSOPB In accordance with the regulations, any

deterioration of the installation or any
impairment or damage to critical equipment
that could impair the safety of the
installation or damage the environment
should be reported to the Certifying
Authority and to the CNSOPB.
Marine Animal Response Society (MARS), In the event of a vessel collision with a
CNSOPB and Canadian Coast Guard marine mammal or sea turtle, or any other
incident involving stranded, injured or dead
marine mammals, Shell will promptly report
to the CNSOPB through the Canadian
Coast Guard Radio, in accordance with
CEAA Condition 3.11. Additionally, Shell
will notify the Marine Animal Response
Society (MARS) (1-866-567-6277) of any
collision incidents of this nature.

17.1.3 Incident Investigation
All incidents will be investigated to find the underlying or root causes as well as to
identify remedial actions to prevent future recurrence of the incident or similar incidents
in the future. Such investigations will be conducted in accordance with Section 7 of the
Guide.
• Shell and CNSOPB standard forms shall be available for incident reports and
these shall be issued within agreed time frames following an incident (generally
within 24 hours).
• Incidents will be reported by the Person In Command (PIC) of a location. The

PIC will use standard forms for reporting of incidents available under their
company HSSE &SP MS.
• In addition to the Contractors and Shell’s Reporting criteria the CNSOPB also
mandates Incident and Investigation Reporting. The CNSOPB Drilling and
Production Guidelines identify the reporting requirements in Section 76 titled
‘Incidents’ which states:
o CNSOPB is notified of any accident or near-miss as soon as the
circumstances permit
o CNSOPB is notified at least 24 hours in advance of any press release or
press conference concerning any incident or near-miss
• Any communication of events, questions or concerns regarding incidents or near

misses to the CNSOPB or other Nova Scotia governmental regulators shall be
through the Shell Halifax office via a designated representative.
• The Nova Scotia Offshore Petroleum Occupational Health & Safety

Requirements, Part 13 of Element 1 will be applicable.
• Investigation by Shell will be conducted by (a team of) persons suitably qualified

and authorized to do the investigation and ensure appropriate action is taken.
The (potential) consequence categories of the Risk Assessment Matrix are used
as a guideline to indicate the staff levels that shall be involved in the
investigation:
• Shell will review all incidents and near misses reported to determine the need for
further detailed reports produced by the Contractor. The investigation process
will include the Contractors Investigation Team and the inclusion of any Shell
individual assigned by Shell on shore management. Shell’s expectations are to
conduct a joint investigation with our contractors to fully understand the root
cause.

• The Investigation Report will include a summary, time line of events, basic and
root causes and identify lessons learned with corrective actions.
• Upon determination of the need for an Investigation Report the Contractor will
produce a satisfactory report within 7 days of request.
• In addition to the Shell requirements, any incident or near miss meeting the
below criteria will require an investigation report that will be submitted to
CNSOPB no later than 21 days after the incident has occurred:
• A lost or restricted workday injury,
• Death,
• Fire or explosion,
• A loss of containment of any fluid from a well,
• An imminent threat to the safety of a person, installation or support craft,
or
• A significant pollution event.
Incident learnings and applicable information will be disseminated through the venues of
HSSE &SP meetings (whether formal Safety meetings, Pre-Job meetings, Department
meetings or other group communication opportunities), safety ‘alerts’, industry
notifications, newsletters, and other industry publications. Lagging and leading
indicators are gathered, analyzed and circulated within the Shell, contractors and other
Partners in Safety on an ongoing basis.
17.1.4 Exceedances and Sheens
In accordance with the Guidelines for the Reporting and Investigation of Incidents any
discharge that exceeds the limits prescribed in the EPP is considered an “unauthorized
discharge” and will be immediately reported to the CCG and CNSOPB as an incident.
If any exceedances or spills result in a visible sheen this will be included in the
unauthorized discharge or spill incident report. Sheens may also be observed during
normal operating conditions (i.e., discharges within approved operational criteria with no
hydrocarbon spill), Shell will immediately notify the CCG and CNSOPB for information
purposes. Sheens observed in the course of approved discharge will not be reported as
incidents.
For further information, please refer to the Incident Reporting and Investigation Guide
(EP201504207396).

18. ADDITIONAL ENVIRONMENTAL MONITORING
18.1 Stranded Bird Monitoring and Handling
Shell will undertake the Project in a manner that protects and avoids harming, killing or
disturbing migratory birds or taking their nests or eggs. In this regard, Shell shall take
into account Environment Canada's Avoidance Guidelines and actions in applying the
Avoidance Guidelines shall in be in compliance with the MBCA, 1994 and with SARA.
Routine checks for stranded birds will be conducted on the MODU and OSVs and
appropriate procedures for release will be implemented. If stranded birds are found
during routine inspections, they will be handled using the protocol outlined in The
Leach’s Storm Petrel: General Information and Handling Instructions (Williams and
Chardine 1999) (Appendix B) and in accordance with the terms and conditions of the
bird salvage/handling permit obtained from the Canadian Wildlife Service (CWS). The
draft Environment Canada document Best practices for stranded birds encountered
offshore Atlantic Canada – Draft 2 (April 17, 2015) may be referenced. Activities will
comply with the requirements for documenting and reporting any stranded birds to CWS
during the drilling program. To differentiate between Wilson’s Storm-Petrel and Leach’s
Storm-Petrel, photographs depicting their differences will be provided to crew members
trained to check for and handle stranded birds.
Bird mortalities will also be documented and reported to the CWS Atlantic Regional
Office:
Atlantic Region
Canadian Wildlife Service
Environment Canada
17 Waterfowl Lane, P.O. Box 6227
Sackville NB
E4L 1G6
Phone: 506-364-5044
Fax: 506-364-5062
E-mail: nature@ec.gc.ca
In the unlikely event of an accidental spill, oiled birds will be collected and rehabilitated
as practical. As part of spill response, hazing techniques may be used if deemed
necessary to deter birds and marine mammals from entering affected areas and prevent
further oiling.
There will be no flaring associated with well testing during the initial drilling campaign for
the Project. The EPP will be updated accordingly for the follow up campaigns and
phases of the Project if flaring is to occur. Mitigation measures associated with flaring

will include: 1) restricting flaring to the minimum required to characterize the well’s
hydrocarbon potential and as necessary for the safety of the operation; 2) minimizing
flaring during night time and during periods of bird vulnerability such as fledging or
foraging; and 3) operating a water-curtain barrier during flaring, will be implemented to
prevent harm to or killing of migratory birds as per CEAA condition 4.3.
18.2 Marine Mammal Monitoring
Marine Mammal Observers (MMOs) will be employed to monitor and report on marine
mammal and sea turtle sightings during VSP surveys to enable shutdown or delay in the
presence of a marine mammal or sea turtle species listed on Schedule 1 of SARA, as
well as all other baleen whales and sea turtles (refer to Section 14.3). Monitoring will be
accomplished through visual observations. Passive acoustic monitoring (PAM) may be
used if other operational mitigation options (i.e. no shut downs or start ups during night
or poor visibility) cannot be implemented.
MMO duties will involve watching for and identifying marine mammals and sea turtles;
recording their numbers, distances and reactions to the VSP survey; initiating mitigation
measures when appropriate (e.g., shutdown), and reporting results. Following the
program, copies of the marine mammal and sea turtle observer reports will be provided
to DFO.
Should it be used, PAM would be utilized during periods of low visibility (e.g., fog and
darkness) to detect vocalizing marine mammals. Access to PAM data, where available,
will be provided to DFO to help inform knowledge of marine mammals in the area.
18.3 Spill Environmental Effects Monitoring
In the unlikely event of an accidental event, Shell will implement measures outlined in its
ERP and integrated contingency plans (refer to Section 4.3.2) as applicable. Depending
on the incident, specific monitoring (e.g., environmental effects monitoring (EEM)) and
follow-up programs may be required and would be developed in consultation with
applicable regulatory agencies, Aboriginal groups, fisheries and other stakeholders, and
the public. In general, this may involve monitoring various aspects of the marine
environment until specific endpoints are achieved and residual hydrocarbons reach
acceptable background levels. In addition, records of marine mammals, sea turtles, and
birds encountered and any evidence of visible oiling would be maintained.
Any records of visibly oiled marine mammals, sea turtles and birds collected as a result
of any offshore accidental events, would be submitted to the CNSOPB to be made
available to the appropriate regulatory agencies. Frequency of provision would depend
on the nature and scale of an incident. In the event of a small scale, short-term incident,
records would be provided following clean-up and response. In the event of a larger
scale, longer term spill event, records would be provided at a frequency decided

appropriate by Shell, CNSOPB and the respective regulatory agencies at the time of an
incident.
Additional EEM for birds may include monitoring of behaviour relative to the spill (i.e.,
attraction, avoidance, preening), number and percentage of oiled individuals and
documenting number, percentage and timing of dead birds.
With respect to effects on fisheries, post-spill EEM would be conducted to measure

levels of contamination in fish species with results integrated in a human health risk
assessment to inform fishing area closure status. This monitoring program would be
developed in consultation with applicable regulatory agencies and may include sensory
testing of seafood for “taint” (a smell or taste of oil) and/or chemical analysis for oil
concentration, as deemed necessary by government authorities. The results of this
monitoring program, along with measurable oil sheen observations and scientific
predictions for future exposure, would likely inform regulators in the decision to reopen a
fishing area.

19. PUBLIC AND STAKEHOLDER COMMUNICATION
19.1 Communication with the Public
As part of the EA process under CEAA, 2012, the public has been engaged through
invitation to review various EA-related documents prepared by Shell and by the
Canadian Environmental Assessment Agency (CEA Agency). Such documents,
including this EPP, will continue to be made available to the public via the Canadian
Environmental Assessment Registry (CEAR) website. This EPP and other documents
required in support of drilling authorizations will also be posted to the CNSOPB website.
19.2 Communication with Commercial and Aboriginal Fisheries
Shell will develop and implement a Fisheries Communication Plan (FCP) for commercial
and Aboriginal fisheries representatives that will facilitate coordinated communication
around routine Project activities and components as well as accidental events.
The FCP will include a commitment to provide ongoing notifications and operational
updates during Project activities. Notification during operations will use a combination of
Notices to Shipping (NOTSHIP) and Notices to Mariners (NOTMAR) as well as
individual e-mail notices sent directly to parties such as commercial fisheries
organizations and Aboriginal groups (i.e., potentially affected and interested First
Nations). These notifications will be disseminated weekly, and will include specific
details such as associated vessel/rig contact information, rig location and deployment
routes, and Shell personnel contact information in case potentially affected and
interested parties have concerns or impacts to report.
Development of the FCP to date has been based on input provided by numerous
members of the fishing industry, including commercial and Aboriginal fisheries contacts.
Active fisheries have numerous forums via the FCP to communicate with both Shell and
the operations crew regarding questions, concerns and information pertinent to their
activities. Input and information provided by fisheries stakeholders is then considered
and incorporated as necessary by the Project and operations staff. Specific questions or
concerns raised by active fisheries stakeholders are followed up and responded to in a
timely matter by Shell’s fisheries consultation representative.
The FCP will include the following two components:
• The first component of the FCP refers to proposed communications prior to and
during routine operations. It indicates Shell’s commitments with respect to
methods and frequencies of communications with fishers, as well as well as
types of information provided.
• The second component of the FCP will be designed to guide communications in

the event of an accident, and will effectively expand on the first component with

more robust communication protocols. Shell is currently working with Nova
Scotia commercial, Aboriginal and aquaculture fisheries representatives to
develop this second aspect of the FCP throughout the remainder of 2014 and
into early 2015.
Shell will review both of these components of the FCP with potentially affected and
interested First Nations prior to the commencement of drilling in 2015 (pending
regulatory approval), specifically by seeking input on the content of the FCP,
appropriate contacts, and preferred communication channels.
The FCP is intended to be a two-way forum that facilitates engagement between Shell
and fisheries stakeholders, including the provision of updates and feedback as well as
the communication of, and response to, questions or concerns.
Fisheries stakeholders are welcome to contact Shell at any time during the life of the
Project to raise any questions, concerns, suggestions or feedback to help improve the
effectiveness of the FCP.
Shell believes that regular, ongoing engagement with Aboriginal fishing interests
throughout the life of the Shelburne Basin Venture will allow Shell to receive any
feedback on any Project effects or concerns from Aboriginal fishers. In the event that
issues and concerns are raised, monitoring and/or mitigation will be developed as
appropriate in consultation with applicable Aboriginal interests.
Shell will respond to any assertions of impacts to Aboriginal rights or commercial fishing
activities. Should an impact be reported, a Shell representative would seek to discuss
the situation with the complainant through direct contact (e.g., phone call, meeting). The
appropriate response to, and measures taken to address the identified impact would
depend upon the specific situation. For example, if a fisheries stakeholder indicated that
Shell damaged fishing gear, Shell would discuss the specific circumstances with the
applicable fisheries representative(s). Depending on the circumstances, specific
measures taken in response could include providing appropriate compensation, revising
the FCP, and potentially modifying aspects of Project activities. If a First Nation
indicated Shell’s operations prevented access to a preferred area for exercising
Aboriginal rights, depending on the circumstances, the specific measures taken in
response could include re-considering the routing of Project activities or modifying the
timing of Project activities in order to try to avoid the areas or times when conflicting
fishing activities would occur. In any event, Shell would respond by seeking to take
steps and implement reasonable measures to prevent such
damage/interference/impacts from reoccurring.
Shell is willing to review this EPP with First Nations and fisheries interests prior to its
implementation during the drilling program. The ERP and supporting contingency plans
referred to in Section 4.3.2 are currently being drafted for final submission to the

CNSOPB in 2015. As part of Shell’s ongoing engagement with all potentially affected
and interested First Nations in regards to Project activities, Shell will provide an
overview of the associated plans and their contents to allow for an opportunity for
feedback and input from First Nations. As noted above, a component of the FCP will
address communication during an accident/incident scenario. This component of the
FCP is currently being drafted, but Shell will seek input on its design and content in
advance of finalization to ensure the appropriate contacts and communication channels
are included.
19.3 Communication with Regulatory Agencies
Regulatory agencies that participated in the EA process include the CEA Agency, the
CNSOPB, the Nova Scotia Department of Energy, Environment Canada, DFO,
Transport Canada, and the Nova Scotia Office of Aboriginal Affairs.
Applicable regulatory agencies will be kept informed of the Project through review of this
EPP as well as applications for regulatory approval and the results of follow-up and
monitoring activities (including compliance monitoring and spill EEM if required). In the
event of an incident, the appropriate authorities will be notified as summarized in
Section 15.2.
Shell has provided draft versions of various Project plans and other documents
(including this EPP, the Safety Plan, Waste Management Plan, and the emergency
preparedness and response plans referred to in Section 4.3.2) to the CNSOPB to obtain
feedback and to ensure input from the CNSOPB and any other regulatory agencies are
considered. As part of CNSOPB’s review, they will facilitate review and acquire the
appropriate input from other relevant regulatory agencies. Shell will meaningfully
consider and address input as provided through this review process. Final versions of
these documents will be submitted to the CNSOPB prior to drilling.
Further, Shell completed a Major Tier III Oil Spill Response full day table-top exercise,
which took place in Halifax the week of April 20, 2015. As part of the planning for this
exercise, Shell hosted several planning meetings and workshops, attended by relevant
regulatory monitoring and response agencies. The purpose of these planning meetings
and workshops was to obtain valuable input from key regulatory agencies to ensure
Shell’s plans are functional, effective and ready for use, if required.

20. REFERENCES
API [American Petroleum Institute]. 1991. Procedure for Field Testing Oil Based Drilling
Muds. API Recommended Practice RP 13B-2, Appendix B (as amended or
updated). Available from: API Publications, IHS, 15 Inverness Way East, c/o
Retail Sales, Englewood, CO 80112-5776.
DFO [Fisheries and Oceans Canada]. 2007a. Statement of Canadian Practice with
Respect to the Mitigation of Seismic Sound in the Marine Environment. Available
from: http://www.dfo-mpo.gc.ca/oceans/management-
gestion/integratedmanagement-gestionintegree/seismic-sismique/pdf/statement-
enonce-eng.pdf.
C-NLOPB, CNSOPB [Canada-Newfoundland and Labrador Offshore Petroleum Board

and Canada-Nova Scotia Offshore Petroleum Board]. 2002. Compensation
Guidelines Respecting Damages Relating to Offshore Petroleum Activity.
Available from: http://cnsopb.ns.ca/sites/default/files/pdfs/CompGuidelines.pdf.
C-NLOPB, CNSOPB [Canada-Newfoundland and Labrador Offshore Petroleum Board

and Canada-Nova Scotia Offshore Petroleum Board]. 2012. Incident Reporting
and Investigation Guidelines. Available from:
http://www.cnsopb.ns.ca/sites/default/files/pdfs/c-
nlopb_cnsopb_incident_reporting_and_investigation_guidelines_november_30_2
012_finalized_version.pdf.
LGL [LGL Limited]. 2013. Environmental Assessment of Shell Canada Limited’s

Shelburne Basin 3D Seismic Survey in Exploration Licenses 2423, 2424, 2425,
and 2426. Prepared for Shell Canada Limited LGL Rep. SA1175. 127p + App.
NEB, C-NLOPB, CNSOPB [National Energy Board, Canada Newfoundland and

Labrador Offshore Petroleum Board and Canada-Nova Scotia Offshore
Petroleum Board]. 2008. Guidelines Respecting Physical Environmental
Programs during Petroleum Drilling and Production Activities on Frontier Lands.
Minister of Public Works and Government Services Canada. September 2008.
NEB, C-NLOPB, CNSOPB [National Energy Board, Canada-Newfoundland and

Petroleum Board]. 2009. Offshore Chemical Selection Guidelines for Drilling and
Production Activities on Frontier Lands. iii + 13 pp. Available from: http://www.C-
NLOPB.nl.ca/pdfs/guidelines/ocsg.pdf.
NEB, C-NLOPB, CNSOPB [National Energy Board, Canada-Newfoundland and

Petroleum Board]. 2010. Offshore Waste Treatment Guidelines. Available from:
http://www.C-NLOPB.nl.ca/pdfs/guidelines/owtg1012e.pdf.

Stantec [Stantec Consulting Ltd.]. 2014. Shelburne Basin Venture Exploration Drilling
Project. Volume 1 Environmental Impact Statement. Available from:
http://www.ceaa-acee.gc.ca/050/document-eng.cfm?document=99337.
Williams, U., Chardine, J. 1999. The Leach’s Storm Petrel: General Information and
Handling Instructions. 4 pp. Available from:
http://www.cnlopb.nl.ca/pdfs/mkiseislab/mki_app_h.pdf.

APPENDIX A – SHELBURNE BASIN VENTURE ORGANIZATION CHART
< Redacted >

APPENDIX B – LEACH’S STORM PETREL: GENERAL
INFORMATION AND HANDLING INSTRUCTIONS (WILLIAMS AND
CHARDINE 1999)

The Leach's Storm-Petrel:
General information and handling instructions
Urban Williams (Petro-Canada)

&
John Chardine (Canadian Wildlife Service)
The Grand Banks is an area that is frequented by

large numbers of seabirds, representing a variety
of species. Large populations are found in this
area in both summer and winter, and come from
the Arctic, northern Europe, and the south
Atlantic, as well as from colonies along the
Newfoundland Coast. One of the species found
in the area of the Terra Nova Field is the
Leach’s Storm-Petrel (Oceanodroma
leucorhoa).
The Bird:
Leach’s Storm-Petrels are small seabirds, not
much bigger than a Robin. They have relatively
long wings and are excellent fliers. Leach’s
Storm-Petrels are dark brown in colour and
show a conspicuous white patch at the base of
the tail. In the hand, you can easily notice a
small tube at the top of their bill, and you will
also notice that the birds have a peculiar, not unpleasant smell (although some Newfoundlanders
call these birds “Stink Birds”). Storm-Petrels are easy prey for gulls and other predators, and so
to protect themselves from predation, Leach’s Storm-Petrels are only active at night when on
land at the breeding colonies.
Nesting Habitat:
Leach’s Storm-Petrels are distributed widely in the northern hemisphere, however, their major
centres of distribution are Alaska and Newfoundland. The bird breeds on offshore islands, often
in colonies numbering tens or hundreds of thousands of pairs, even millions at one colony in
Newfoundland. The nest is a chamber, sometimes lined with a some grass, located at the end of a
narrow tunnel dug in the topsoil.. Depending on the colony, burrows may be under conifer or
raspberry thickets or open grassland.
1
Reproduction:
In Newfoundland, Leach’s Storm-Petrels lay their single egg in May and June. The egg is
incubated by both parents alternately, sometimes for stretches exceeding 48 hours. The egg is
incubated for 41-42 days, which is a long time for such a small egg. The peak hatching period is
in the last half of July. The young petrel remains in the tunnel for about 63-70 days. Once
breeding is over in late-August or early September, the birds disperse from the colonies and
migrate to their wintering grounds in the Atlantic. September is the most important period for
migration of Storm-Petrels to the offshore areas such as near the Terra Nova field.
Populations:
Canada alone supports more than 5 million pairs of Leach's Storm-Petrels. Most of them are
found in Newfoundland. The Leach’s Storm-Petrel colony located on Baccalieu Island is the
largest known colony of this species.
Nesting sites for Leach’s Storm-Petrels are found along the southeast coast of Newfoundland.
These are - i) Witless Bay Islands (780,00 nesting pairs), ii) Iron Island (10,000 nesting pairs),
iii) Corbin Island (100,000 nesting pairs), iv) Middle Lawn Island (26,000 nesting pairs), v)
Baccalieu Island (3,336,000 nesting pairs), vi) Green Island (72,000 nesting pairs), and vii) St.
Pierre Grand Columbier (100,000 nesting pairs).
Feeding Habits:
Leach’s Storm-Petrels feed at the sea surface, seizing prey in flight. Prey usually consists of
myctophid fish and amphipods. The chick is fed planktonic crustaceans, drops of stomach oil
from the adult bird, and small fish taken far out at sea. Storm-Petrels feed far out from the colony
and it would be reasonable to assume that birds nesting in eastern Newfoundland can be found
feeding around the Terra Nova site.
The Problem:
As identified in the C-NOPB Decision 97-02, seabirds such as Leach’s Storm-Petrels are
attracted to lights on offshore platforms and vessels. Experience has shown that Storm-Petrels
may be confused by lights from ships and oil rigs, particularly on foggy nights, and will crash
into lighted areas such as decks and portholes. Fortunately, this type of accident does not often
result in mortality, however, once on deck the bird will sometimes seek a dark corner in which to
hide, and can become fouled with oil or other contaminants on deck.
Period of Concern:
Leach’s Storm-Petrels are in the Terra Nova area from about May until October and birds could
be attracted to lights at any time throughout this period. The period of greatest risk of attraction
2
to lights on vessels appears to be at the end of the breeding season when adults and newly
fledged chicks are dispersing from the colonies and migrating to their offshore wintering
grounds. September is the most important period for migration of storm-petrels to the offshore
areas. Past experience suggests that any foggy night in September could be problematic and may
result in hundreds or even thousands of birds colliding with the vessel.
The Mitigation:
On nights when storm-petrels are colliding with the vessel, the following steps should be taken to
ensure that as many birds as possible are safely returned to their natural habitat.
• All decks of the vessel should be patrolled as often as is needed to ensure that birds are picked up
and boxed (see below) as soon as possible after they have collided with the vessel. After
collision, birds will often “freeze” below lights on deck or seek dark areas underneath machinery
and the like.
• Birds should be collected by hand and gently placed in small cardboard boxes. Care should be
taken not to overcrowd the birds and a maximum of 10-15 birds should be placed in each box,
depending upon its size. The birds are very easy to pick up as they are poor walkers and will not
fly up off the deck so long as the area is well-lit. They will make a squealing sound as they are
picked up- this is of no concern and is a natural reaction to be handled (the birds probably think
they have been captured to be eaten!).
• When the birds are placed in the box the cover should be put in place and the birds left to recover
in a dark, cool, quiet place for about 5-10 minutes. The birds initially will be quite active in the
box but will soon settle down.
• Following the recovery period, the box containing the birds should be brought to the bow of the
boat or to some other area of the vessel that has minimal (if any) lighting. The cover should be
opened and each bird individually removed by hand. The release is usually accomplished by
letting the bird drop over the side of the vessel. There is no need to throw the bird up in the air at
release time. If the birds are released at a well-lit part of the vessel they usually fly back towards
the vessel and collide again.
• If any of the birds are wet when they are captured (i.e. they drop into water on the deck) then
they should be placed in a cardboard box and let dry. Once the bird is dry it can be released as
per the previous instruction. Also, temporarily injured birds should be left for longer to recover
in the cardboard box before release.
• Any birds contaminated with oil should be kept in a separate box and not mixed with clean birds.
Contact Canadian Wildlife Service at (709) 772-5585 for instructions on how to deal with
contaminated birds.
• In the event that some birds are captured near dawn and are not fully recovered before daylight,
they should be kept until the next night for release. Storm-Petrels should not be released in
daylight as at this time they are very vulnerable to predation by gulls. Birds should be kept in the
cardboard box in a cool, quiet place for the day, and do not need to be fed.
• Someone should be given the responsibility of maintaining a tally of birds that have been
captured and released, and those that were found dead on deck. These notes should be kept with
other information about the conditions on the night of the incident (moonlight, fog, weather),
3
date, time, etc). THIS IS A VERY IMPORTANT PART OF THE EXERCISE AS IT IS THE
ONLY WAY WE CAN LEARN MORE ABOUT THESE EVENTS.
Handling Instructions:
• Leach’s Storm-Petrels are small, gentle birds and should be handled with care at all times.
• It is recommended that the person handling the birds should wear thin rubber gloves or clean,
cotton work gloves. The purpose of the gloves is to protect both the Storm-Petrel and the
worker.
• As mentioned Storm-Petrel’s have a strong odor that will stick to the handler’s hands.
Washing with soap and water will remove most of the smell.
• Handling Leach’s Storm-Petrels does not pose a health hazard to the worker, however some
birds may have parasites on their feathers, such as feather lice. These parasites do not present
any risk to humans, however, as a precaution we recommend wearing cotton work gloves or
thin rubber gloves while handling birds and washing of hands afterwards.
Wilson’s Storm Petrels:
A relative of the Leach’s Storm-Petrel is the Wilson’s Storm-Petrel. They breed in the south
Atlantic and Antarctica and migrate north in our spring to spend the summer in Newfoundland
waters. This species is very numerous on the Grand Banks in the summer, and shares the same
nocturnal habits as the Leach’s Storm-Petrel. Thus it is possible that Wilson’s Storm-Petrels may
also be attracted to the lights of a vessel at night. The two species are very similar and should be
handled in the same way as described above for our Leach’s Storm-Petrel.
Permits:
A permit to handle storm-petrels issued by the Canadian Wildlife Service will be held on board
the vessel to cover personnel involved in bird collision incidents.
4
APPENDIX C – SHELBURNE BASIN VENTURE WASTE
MANAGEMENT PLAN (EP201505209133)

Shelburne Basin Venture Exploration Drilling Project
Waste Management Plan
Project Shelburne Basin Venture Exploration Drilling Project
Document Title Waste Management Plan
Document Number EP201505209133
Document Revision 06A
Document Status Issued for Use
Document Type Controlled
Owner / Author Faisal Arman/Candice Cook-Ohyrn
Issue Date October 21, 2015
Expiry Date December 31, 2016
Security Classification Unrestricted
Disclosure None
Document Number: EP201505209133
Date of Issue: September 16, 2015
Custodian: Logistics Lead Faisal Arman
Approved by: Venture Manager – Christine Pagan
Document History
REVISION STATUS APPROVAL
Rev. Date Description Preparer Reviewer Approver
1 19-Jan-15 Initial Draft F.Arman C.Cook-Ohryn C. Pagan
2 4-May-15 2nd Draft F.Arman C.Cook-Ohryn C. Pagan

C.Cook-Ohryn
3 21-May-15 3rd Draft F.Arman C. Pagan
P. Beaudin
C.Cook-Ohryn
4 3-June-15 4th Draft F.Arman C. Pagan
P. Beaudin
C.Cook-Ohryn
5 16-Sept-15 Final F.Arman C. Pagan
P. Beaudin
C.Cook-Ohryn
6 21-Oct-15 Final - Redacted F.Arman C. Pagan
P. Beaudin
EP201505209133 -2- October 21, 2015
Revision 06 Unrestricted
Table of Contents
1.0 INTRODUCTION ........................................................................................................................................ 4
1.1 Purpose ......................................................................................................................................... 4
1.2 Reference Documents .................................................................................................................. 4
1.3 Waste Management Principles ..................................................................................................... 5
1.4 Scope and Organization ................................................................................................................ 5
1.5 Target Audience ............................................................................................................................ 6
2.0 WASTE CLASSIFICATIONS ..................................................................................................................... 7
2.1 Waste Definition ............................................................................................................................ 7
2.2 Waste Classification ...................................................................................................................... 7
3.0 WASTE MANAGEMENT PROCEDURES ............................................................................................... 10
3.1 Waste Identification and Management ........................................................................................ 10
3.2 Waste Transport Manifest ........................................................................................................... 11
3.3 Waste Disposal Record ............................................................................................................... 11
3.4 Waste Records ............................................................................................................................ 11
3.5 Waste Reporting ......................................................................................................................... 11
3.6 Waste Management Facilities ..................................................................................................... 12
3.7 Audits .......................................................................................................................................... 12
3.8 Waste Segregation and Transport Schematics .......................................................................... 12
4.0 ROLES AND RESPONSIBILITIES .......................................................................................................... 15
5.0 WASTE MANAGEMENT OVERVIEW ..................................................................................................... 18
APPENDIX A – WASTE MANIFEST (EXAMPLE) – OFFSHORE.................................................................. 23
APPENDIX B - MASTER WASTE DISPOSAL RECORD .............................................................................. 24
EP201505209133 -3- October 21, 2015
1.0 INTRODUCTION
1.1 Purpose
In association with Shell Canada Limited’s (Shell) proposed Shelburne Basin Venture
Exploration Drilling Project (the Project), an Environmental Protection Plan (EPP)
(EP201409207550) has been developed to outline the environmental management and
protection components for Project operations. In accordance with Section 9(h) of Nova
Scotia Offshore Drilling and Production Regulations (SOR/2009-317), the EPP outlines high
level waste management requirements for the Project inclusive of a commitment to prepare
and implement this WMP.
The purpose of this Waste Management Plan (WMP) is to detail the management processes
and procedures for waste that is generated in association with the Project. Shell endorses a
waste management philosophy of reduce, reuse and recycle wherever possible. As such, in
addition to compliance with all environmental laws and regulations, this WMP is established
to ensure that all waste associated with the Project is handled, transported and disposed of
in an environmentally sound manner.
1.2 Reference Documents

Waste management onshore is regulated by federal, provincial and municipal government
requirements. Offshore waste management is regulated by the Canada-Nova Scotia
Offshore Petroleum Board (CNSOPB), federal legislation as well as international standards
and codes. This WMP has been developed in accordance with relevant regulations and
standards as well as Shell policy. The following regulations and standards have been
considered in preparation of this WMP:
• International Convention for the Prevention of Pollution from Ships (MARPOL) -
Annex V
• International Maritime Dangerous Goods Code
• International Air Transport Association Code
• CNSOPB Offshore Waste Treatment Guidelines (OWTG)
• Transportation of Dangerous Goods Act
• Transportation of Dangerous Goods Regulations
• Export and Import of Hazardous Waste and Hazardous Recyclable Materials
Regulations
• Fisheries Act Nova Scotia Environment Act
• Dangerous Goods Management Regulations
• Solid Waste-Resource Management Regulations
• Used Oil Regulations
In addition, the following documents were utilized in the preparation of this WMP:
• Stena IceMax Waste Management Procedure (L4-DOC-ICE-4320);
EP201505209133 -4- October 21, 2015
• Stena IceMax Waste Management of Waste Offshore (L2-DOC-LPD-0102);
• Standby and Supply Vessel Waste Management Procedures;
• Shell HSSE & SP Control Framework – Environment Manual for Waste;
1.3 Waste Management Principles

In line with Shell’s waste management philosophy to minimize the generation and optimize the
reuse, recycling and disposal of waste, the following waste management principles have guided
the development of this WMP:
• Compliance with all applicable statutes, regulations, standards and codes of
practice
• Incorporate controls to reduce waste generation into procedures and working
practices
• Identify opportunities to reuse waste for the same or alternative applications
• Identify recycling and recovery opportunities for waste material
• Identify, segregate and store waste
• Transport and dispose of waste safely
• Retain waste tracking records for periods defined by local legal requirements and
Shell’s Records Management System.
In addition to the above outlined principles, the following working practices will also be
implemented to reduce the amount of waste generated:
• Complete use of materials and contents of containers
• Adequate storage to avoid spoilage
• Use of oldest supplies to avoid disposal due to expiry
• Reduction of paper waste through use of electronic media
• Reuse of waste material and products where possible in additional operational
activities
• Using non-hazardous alternatives where possible
• Return of unused materials to suppliers where possible
1.4 Scope and Organization 1

This WMP is intended to function as the Project level WMP and as such is the primary and
overarching WMP for all Project activities and operations. This WMP applies to all solid and
liquid wastes generated on the MODU, Stena IceMax, as well as on the supply and standby
vessels, which will be transported to the Blue Water shore base for final transport and
disposal. Although discussed, effluent and other drilling waste disposed of offshore are not
1
This WMP addresses waste management associated with routine offshore exploration activities only. This WMP does not
address waste management associated with oil spill response. Such activities, should they occur, will be governed by
Shell’s Oil Spill Response Plan (OSRP) and an incident specific WMP created at the time of an incident.
EP201505209133 -5- October 21, 2015
covered by this WMP and are addressed in the Environmental Protection Plan (EPP)
(EP201409207550) issued for this Project.
Where waste management plans and procedures are already in place for contracted
parties, these have been reviewed to ensure consistency with this WMP and compliance with
relevant regulatory requirements and standards. Where relevant, these existing waste
management plans and procedures have been referenced as part of this WMP.
The collection, segregation, handling, storage, labelling, manifesting and transport of all
waste generated on the Stena IceMax and the standby and supply vessels in association with
the Project will be conducted in accordance with this plan.
Waste arriving from the Stena Icemax, and offshore supply and standby vessels for onshore
management and disposal onshore will utilize this WMP.
Final disposal of Project wastes transported to the Blue Water shore base located in
Dartmouth, Nova Scotia will follow the prescribed methods identified by this plan. Project
waste generated onshore at the Blue Water base will be managed in accordance with the
existing waste management procedures outlined in the Blue Water Shore Base WMP.
This WMP is a five part plan comprising the following:
Section 1 – Overview and scope of the WMP;
Section 2 – Identification and classification of wastes anticipated for the Project;
Section 3 – Waste management summary and schematics;
Section 4 – Waste management roles and responsibilities; and
Section 5 – Waste management process
1.5 Target Audience

Principal users of this plan will be Terrapure (waste management contractor), Blue Water,
Shell Logistics, Operational and Health, Safety, Security and Environment (HSSE) staff.
EP201505209133 -6- October 21, 2015
2.0 WASTE CLASSIFICATIONS
This section provides a definition of waste as well as a description of how the waste streams
in association with the Project are classified for the purposes of this WMP.
2.1 Waste Definition

For the purposes of this WMP, waste is defined in accordance with the OWTG, which
defines it as “any garbage, refuse, sewage or waste well fluids or any other useless material
that is generated during drilling, operations, including used or surplus drilling fluid and drill
cuttings”.
For the purposes of this WMP, Waste will be classified into two categories, hazardous waste
and non-hazardous waste. Non-hazardous waste will be further divided into recyclable
waste and non-recyclable waste.
Further details of the anticipated waste streams for the Project are provided in section 5 of
this WMP.
2.2 Waste Classification

There are three general classes of waste anticipated to be generated during Project
operations. These three general classes are:
• Effluent Waste
• Non-Hazardous Waste
• Hazardous Waste
Effluent wastes discharged from the MODU and/or supply and standby vessels are not
covered by this WMP. These waste streams are covered in the EPP (EP201409207550) and
include:
• Grey water / Black water;
• Drill cuttings (SBM under 6.9% ROC) (Stena IceMax only)
• Drill fluids and cuttings (Water Based Mud) (Stena IceMax only)
• Bilge and deck drainage water
• BOP fluids (Stena IceMax only)
• Cooling water
• Ballast water
• Fire control system test water
• Food waste (organic)
EP201505209133 -7- October 21, 2015
Hazardous Waste: Are waste that are regulated as dangerous goods under the
Transportation of Dangerous Goods Act. Classes of hazardous waste include flammable
liquids, flammable solids, oxidizing substances, poisonous and infectious substances,
radioactive materials, corrosives and miscellaneous substances. Hazardous waste can
present risks to personnel, public health and to the environment if not handled and disposed
of adequately. Examples of hazardous wastes that may be generated include, but are not
limited to:
• Waste oil
• Waste chemicals
• Oily solid waste;
• Paint residues and thinners;
• Batteries;
• Acids;
• Fluorescent lamps
• Medical waste.
Non-hazardous Waste: Non-hazardous wastes are those that are not considered dangerous
under the Transportation of Dangerous Goods Act, International Maritime Dangerous Goods
Code, and the International Air Transport Association Code. They are further divided into
two categories, those that are recyclable, and those that are non-recyclable.
Non-Recyclable: Waste not classified as hazardous, but, upon decomposition by
microorganisms or by action of water, can release pollutants to the environment (i.e. dirty
waste). This is waste that is disposed in approved landfills for decomposition. Examples
include:
• Domestic garbage
• General refuse
• Galley waste
• Food wastes
• Food packaging
Recyclable: Waste that can be changed into new products through existing recycling
processes or facilities and/or waste that does not release pollutants to the environment in
significant concentrations upon decomposition or by action of water (i.e. clean waste).
Examples include:
• Clean plastic
• Clean metal
• Clean glass
• Wood
• Paper/Cardboard.
EP201505209133 -8- October 21, 2015
Table 2.1 below summarizes the various waste streams anticipated to be generated bythe
Project and to be transported onshore for management and disposal. Further details
regarding these waste streams can be found in section 5 of this WMP.
Table 2.1: Summary of Non-Hazardous and Hazardous Wastes Generated from the
Project
Waste Description Classification

Domestic Wastes Non-Hazardous/Non-recyclable
Scrap Wood Non-Hazardous/ Recyclable
Scrap Metal Non-Hazardous/Recyclable
Recyclables (Glass, Paper, Plastic, and Aluminum) Non-Hazardous/Recyclable
Miscellaneous Non-hazardous Wastes Non-Hazardous/Non-recyclable
Cooking Oil Non- Hazardous/Non-recyclable
E-Waste (Phones, computers, monitors, UPS Batteries, etc.) & Non-Hazardous/Non-recyclable
Toner Cartridges and Recyclable (scrap)
Oil/Fuel Filters Hazardous
Waste Oil Hazardous
Oily Rags/Gloves Hazardous
Oil Contaminated Sludge Hazardous
Batteries Hazardous
Medical Waste Hazardous
Fluorescent Tubes Hazardous
Empty Oil/Chemical Drums Hazardous
Empty Paint Cans Hazardous
Empty Aerosol Cans Hazardous
Paints/Thinners/Spent Chemicals Hazardous
Waste Chemicals Hazardous
Residual Synthetic Based Mud (SBM) Hazardous
Drill cuttings (SBM over 6.9% ROC) Hazardous
EP201505209133 -9- October 21, 2015
3.0 WASTE MANAGEMENT PROCEDURES
3.1 Waste Identification and Management
All waste materials will be properly classified, labeled and segregated to ensure all
personnel in the waste management chain can follow appropriate safety, handling and
disposal practices. Waste classification will follow procedures outlined in the Transportation
of Dangerous Goods Act to appropriately label, handle and package waste for shipment.
In the case of hazardous waste, Material Safety Data Sheets (MSDS) will be consulted to
identify the hazardous characteristics of the waste being handles or transported.
A waste management table is provided in section 5 outlining all potential offshore
exploration waste streams and detailing the following:
• A description of the waste material
• The waste classification
• Whether any treatment offshore is conducted
• How the waste is segregated and stored
• How the waste is labeled (all 45 gallon steel DOT drums and one tonne big bags will be
have labels attached/fixed to them that indicates the waste stored, and/or any TDG
required labels. All waste skips that have identification markings, will have the waste
detailed on the manifest under the skip identification number).
• Whether the waste is disposed of offshore or transported onshore for management and
disposal
• Onshore disposal/recycling method
• Onshore disposal/treatment/recycling facility
Section 3.7 provides two schematics summarizing the hazardous and non-hazardous waste
stream segregation, packing, and transport to shore base process.
Safety
Safety is a key consideration in association with any handling and storage of wastes. The
MSDSs must be consulted to ensure an adequate level of personal protective equipment is
used during the handling of all waste materials.
All personnel handling hazardous waste must have adequate Workplace Hazardous
Materials Information System (WHMIS) training to match the hazards involved. Personnel
responsible for the shipment of hazardous wastes will also have training in Transportation of
Dangerous Goods as appropriate.
EP201505209133 - 10 - October 21, 2015
3.2 Waste Transport Manifest
A waste transport manifest (Appendix A) will be issued for every waste shipment which is
transferred for onshore recycling, treatment and disposal (e.g. Stena IceMax and offshore
vessels to shore base, shore base to disposal facility). The transport manifest will be in
accordance with the Transportation of Dangerous Good Act requirements and document the
transfer of each waste shipment from the MODU, supply/standby vessels, and shore base to
final disposal.
The rig and each vessel will have waste manifest forms onboard to record waste generated
and transported to the shore base for disposal. All manifest forms for the transportation of
waste to shore base, will be held by the Terrapure Waste Coordinator as each waste
shipment is received and verified. The manifesting and transport of waste from the shore
base to final disposal/recycling facilities will utilize Terrapure’s procedures and forms or
contractor supplied manifests.
3.3 Waste Disposal Record

Following receipt of the waste shipment at the supply base and verification of the waste
transport manifest, Terrapure will summarize the waste type, amount, transport, and final
disposal location and detail this information on the Master List Waste Disposal Record. A
Master List Waste Disposal Record is included in Appendix B of this WMP. The Master List
Disposal Record will record the specific waste transport manifest numbers received from the
MODU, standby and supply vessels, and cross reference them with the Terrapure generated
manifest for transport to final disposal/recycling. The waste disposal certificate for each
category of waste will be attached to each respective manifest to complete the “cradle to
grave” (from generation, transportation and disposal) documentation cycle. The waste
disposal certificate number will also be added to the Master List for each manifest listed (for
quick reference).
3.4 Waste Records

All hazardous waste records (waste transport manifests and waste disposal records) will be
retained and kept on site for two years in accordance with the requirements under the
Transportation of Dangerous Goods Act. All waste records must then be transferred to an
offsite Shell storage facility to be stored indefinitely to be in compliance with the Shell Group
Records Management guidelines.
3.5 Waste Reporting

Terrapure, the third party waste management contractor, will be required to provide monthly
summaries to Shell’s Logistics HSSE Lead detailing the type and quantity of waste received
and the associated disposal method used. Review of these reports will ensure ongoing
compliance with this WMP as well as facilitating continuous improvement in waste
management practices.
EP201505209133 - 11 - October 21, 2015
3.6 Waste Management Facilities
All waste management facilities that will be used to treat, store, dispose or recycle Project
waste streams will be reviewed and approved through the Shell Offsite Residuals
Management audit process. After the initial approval, facilities will be reviewed every 5
years to ensure continued compliance. Only those waste management facilities on the
approved list are to be utilized during in support of Project waste management.
3.7 Audits
Internal audits on the waste management processes and procedures will be conducted by the
Shell HSSE Lead on a quarterly basis. Audits will review waste management practices and
confirm that wastes are being managed in accordance with this WMP and in a safe and
environmentally responsible manner.
3.8 Waste Segregation and Transport Schematics

Figure 3.1 summarizes the non-hazardous waste stream segregation, packing, and transport
to shore base process.
Figure 3.2 summarizes the hazardous waste stream segregation, packing, and transport to
shore base process.
EP201505209133 - 12 - October 21, 2015
Non Hazardous Waste
(Domestic and General Waste)
Non
Recyclable Recyclable
Scrap metal,
scaffolding,
Non macerated Aluminium – cans grinding waste,
Paper products, Plastics – bottles,
organics (coffee Glass – all glass And all aluminium Cigarette butts, toothpicks,
cardboard packing, bags, cups, etc. electrical cables,
filters, teabags, etc.) waste material contaminated
and waste paper scrap wood,
Compostibles with organic matter or
construction debris
mixed material
Collected in clear bags Collected in clear bags Collected, stored in Collected in clear Collected in big
Collected and clear bags and
and shipped in big and shipped in big bags. Shipped in bags labelled as
compacted. shipped in big bags
bags in waste skip bags in waste skip big bags Metal Compact waste
Stored in clear in waste skips. Collect in clear bags
bags. Placed in big
bags transported in
waste skip Transfer to waste skip for
Compact in batch onshore disposal.
and transfer to Complete manifest with type and quantity
waste skip for Transfer to big bags
onshore disposal Place in waste skip
for onshore disposal
Complete manifest with type and

quantity of waste .
Transport by supply boat to Shore Base
for onward transport to final disposal
recycling or compost facility
Figure 3.1 Non Hazardous Waste Segregation, Packing and Transport Process
EP201505209133 - 13 - October 21, 2015
Hazardous Waste
Oil contaminated rags, Chemical contaminated

Synthetic based mud Used/waste oil,
Synthetic based mud containers, filters, rags, containers, sacks, Used fluorescent bulbs Clinical
cuttings in excess cooking oil, and grease Batteries Sharps
(residual) drums and other oil drums, pails, cans, aerosols Low wattage bulbs Waste
of 6.9% ROC from grease trap
contaminated solid waste and other solid waste
Collected in 45 gallon Collected in 45 gallon Collected in 45 gallon Collected in cardboard Placed in

Collected in cuttings Steel DOT drums Steel DOT drums Steel DOT drums lamp box. Placed in waste Collected in lined big bags a Sharps
Transfer to OSV tanks
skips and labelled as and labelled as and labelled as skip and labelled as and labelled as Batteries Box
Waste Oil Oil Contaminated Waste Chemical Contaminated Fluorescent Bulbs
(option to incinerate Waste
waste oil offshore)
Collected and transported in

medical bio-hazard bin bags. Bin bags
will be placed in steel drums labelled
Clinical Waste for onshore disposal
Transfer to waste skip

for onshore disposal.
Manifest type of waste and quantity.
Generate IMDG TDG Declaration for
each category of hazardous waste.
Transport by supply vessel to

Blue Water base for onward transport to
final disposal or treatment facility
Figure 3.2 Hazardous Waste Segregation, Packing and Transport Process
EP201505209133 - 14 - October 21, 2015
4.0 ROLES AND RESPONSIBILITIES
The overall responsibility for the development of this WMP lies with the Health, Safety,
Security and Environment (HSSE) Team. Specifically, responsibility lies with the Logistics
HSSE and Technical Lead as well as the Environmental Lead for the Project.
The roles and responsibilities for the implementation of this WMP are outlined in the tables
below for each of the contractors previously mentioned
Table 4-1 Roles and Responsibilities - Stena IceMax
STENA ICE MAX
ROLE RESPONSIBILITY
Offshore Installation • Accountable for all aspects of waste management and responsible
Manager (OIM) for assuring that all aspects of this WMP are adhered to as relevant
to the MODU.
• Allocate duties to individuals and make arrangements for monitoring
compliance with the procedures and practices outlined in this WMP.
DECK SUPERVISOR • Responsible for coordination of waste shipment to shore including
ensuring that all waste collected onboard is appropriately
segregated, packed, labelled, and accompanied by the appropriate
paperwork (e.g., Waste Transport Manifest and Material Safety
Data Sheets (MSDS)) before being shipped ashore.
• Responsible for ensuring adequate and appropriate storage of
wastes on the deck and for maintaining the storage area.
DECK LEAD • Responsible for filling out the Waste Transport Manifest, checking
information on wastes to be manifested and for ordering of material
(as indicated by the Deck Supervisor) necessary for the management
of waste onboard (containers, bags, etc.).
DECK CREW • Responsible for labelling waste and storage containers and ensuring
that all wastes on deck are appropriately segregated, packed and
identified.
STENA HSE ADVISOR • Responsible for assisting the OIM and personnel on board in
regards to implementation of this WMP.
• Responsible for conducting regular inspections and audits of waste
management onboard with Shell department support as required.
SHELL LOGISTICS HSE • Responsible for assisting the OIM and other personnel on board in
LEAD the adequate implementation of this WMP.
• Responsible to monitor the effectiveness of this WMP.
MEDIC • Responsible for ensuring that all wastes from clinic and galley are
appropriately segregated, packed and identified.
ALL PERSONNEL • Responsible for ensuring that all wastes are segregated and
disposed of in accordance with this WMP.
EP201505209133 - 15 - October 21, 2015
Table 4-2 Roles and Responsibilities – Supply/Standby Vessels
SUPPLY/STANDBY VESSELS
ROLE RESPONSIBILITY
VESSEL MASTER • Vessel Masters have overall accountability for the segregation,
handling, storage and disposal of wastes on their vessel in
accordance with this WMP where relevant.
• Allocate duties to individuals and make arrangements for monitoring
compliance with the procedures and practices outlined in this WMP..
• Responsible for reporting to Shell Logistics on the status of onboard
waste management.
FIRST OFFICER • Responsible for coordination of waste shipment to shore including
ensuring that all waste is appropriately segregated, packed, marked
and accompanied by the appropriate paperwork (e.g., Waste
Transport Manifest and Material Safety Data Sheets (MSDS)) before
being shipped ashore.
DECK SUPERVISOR • Responsible for ensuring adequate and appropriate storage of
wastes on the deck and for maintaining the storage area.
DECK CREW • Responsible for labelling waste and storage containers and ensuring
that all wastes on deck are appropriately segregated, packed and
identified.
SAFETY OFFICER • Responsible for filling out the Waste Transport Manifest, checking
information on wastes to be manifested and for ordering of material
(as indicated by the Deck Supervisor) necessary for the management
of waste onboard (containers, bags, etc.).Responsible to inspect the
waste segregation and storage in the accommodations and external
areas.
• Responsible for ensuring that all wastes from galley and
accommodations are appropriately segregated, packed and
identified. Responsible to provide training, reviews, inspections and
audits with Shell Canada Logistics HSE support.
ALL PERSONNEL • Responsible for ensuring that all wastes are handled, segregated
and disposed of in accordance with this WMP.
SHELL LOGISTICS HSE • Responsible for assisting the Master and other personnel on board in
LEAD the adequate implementation of this procedure.
EP201505209133 - 16 - October 21, 2015
Table 4-3 Roles and Responsibilities – Third Party Waste Contractor
TERRAPURE - WASTE MANAGEMENT CONTRACTOR
ROLE RESPONSIBILITY
SHELL HSE LEAD • Overall accountability for all aspects of waste management and for
the effective implementation of Shell Canada’s WMP.
• Responsible for the continuing coordination and communication with
Terrapure to ensure that receipt, transport and disposal of waste
from the MODU and supply/standby vessels is in accordance with
regulatory requirements, and this WMP.
• Responsible for conducting inspections of the waste management
area, and of Terrapure to ensure that activities and practices are in
accordance with this WMP.
THIRD PARTY WASTE • Responsible for ensuring that all waste received is properly
MANAGEMENT segregated, packed, and identified.
CONTRACTOR • Communicates any waste management issues or non-conformances
to the Shell HSSE Logistics Lead.
• Document all waste received by manifest number in the Master List.
• File all waste manifests received.
• Responsible for recording the quantity and type of waste received,
handling of waste at the shorebase, and onward transport to the
appropriate disposal facility.
• Ensuring that all waste transported for final disposal is properly
packed and labeled.
• Coordinating transport of waste to disposal/recycling/treatment
facility with all the appropriate and required documentation.
• Responsible for verification of receipt of waste by the
disposal/recycling/treatment facility.
• Responsible to maintain all records related to the receipt of waste
onshorein paper and/or electronic format.
• Responsible for developing a monthly summary of waste received
and managed to the Shell Logistics HSSE Lead. This will be done on
the Shell Master List
• Responsible for providing training to crews and transport providers
on the handling of wastes at the shorebase, and transport to
disposal facilities.
EP201505209133 - 17 - October 21, 2015
5.0 WASTE MANAGEMENT OVERVIEW
Table 5.1 below provides an overview of the waste management process for each type of waste anticipated to be generated as
part of the Project and transported onshore for final disposal.
Table 5.1 Waste Management Summary Table
Material Classification Treatment/ Segregation & Labelling Transport Offsite Disposal/Recycle

Disposal Storage Disposal Facility
Offshore /Recycling
Waste Oil Hazardous Incineration 45 gallon metal Waste Oil Supply Vessel to Recycle Terrapure- Sussex
(Optional) DOT drums (in accordance shore base 17 Jones Court, Sussex, NB
- Used Lube Oil (Sealed) with TDG)
- Hydraulic Oil
- Fuel Filters
- Recovered oil from
O/W Separator
Oil Contaminated Hazardous None 45 gallon metal Oil Supply Vessel to Incinerate Terrapure- Sussex
Waste DOT drums Contaminated shore base 17 Jones Court, Sussex, NB
(Sealed) Waste
- Filters, Rags, Gloves,- (in accordance
Drums, containers with TDG)
- Etc.
Waste Chemicals Hazardous None 45 gallon metal Waste Chemicals Supply Vessel to Depends on Terrapure Chateaugay
- Paint/thinners DOT drums (in accordance shore base specific waste 125 Rue Belanger
- spent chemicals (Sealed) with TDG) type Chateaugay, Quebec
EP201505209133 - 18 - October 21, 2015
Offshore /Recycling
Chemical Hazardous None 45 gallon metal Chemical Supply Vessel to Depends on Terrapure- Sussex
Contaminated Waste DOT drums Contaminated shore base specific waste 17 Jones Court, Sussex, NB
(Sealed) Waste type
- Filters, Rags, Gloves, (in accordance
- Drums, containers with TDG)
- Etc.
Fluorescent Bulbs Hazardous None Lamp Cardboard Fluorescent Bulbs Supply Vessel to Landfill Terrapure- Sussex
Low wattage bulbs Boxes (or similar), (in accordance shore base Disposal 17 Jones Court, Sussex, NB
placed in waste with TDG)
skips
Used Batteries Hazardous None Big Bags (Lined) Used Batteries Supply Vessel to Recycle Terrapure- Sussex
(standard household (in accordance shore base 17 Jones Court, Sussex, NB
cells) with TDG)
Medical Waste Hazardous Place Place sharps box Clinical Waste Supply Vessel to Incinerate Stericycle
sharps in a and/or bio- w/Biohazard shore base 45 wright Ave, Dartmouth,
sharps box. hazards bin bags labels NS
Medical in 45 gallon metal (in accordance
waste in DOT drums with TDG)
bio-hazard
bin bags
Used Cooking Oil Non None 45 gallon metal Used Cooking Supply Vessel to Recycle BD Rae environmental
Hazardous DOT drums Oil shore base 31 Lacewood dr, Halifax, NS
Electronic Waste Hazardous None One tonne big Electronic Waste Supply Vessel to Recycle Aces recycling
and Non bags (in accordance shore base 99 Woodlawn rd,
- Phones, Monitors, Hazardous with TDG) Dartmouth, NS
CPUs, Etc.
- Toner Cartridges
EP201505209133 - 19 - October 21, 2015
Offshore /Recycling
Empty Paint Cans Hazardous None Big Bags (Lined) or Empty Supply Vessel to Recycle Terrapure - Sussex
Empty Aerosol Cans 45 gallon metal Paint/Aerosol shore base 17 Jones Court, Sussex, NB
DOT drums Cans
(Sealed) (in accordance
with TDG)
Recyclables Non- None Segregate each Label each big Supply Vessel to Recycle Miller Waste
Hazardous recyclable bag as per shore base 20 Horseshoe Lake Drive,
- Paper
separately. contents (paper, Halifax, NS
- Plastic (cups, pails,
plastic,
drums) Place each
aluminum, glass)
- Glass category of waste
- Aluminum in one tonne bags
Scrap Metal / Metal Non- None Waste skips Metals Supply Vessel to Recycle John Ross & Sons
Chips Hazardous (depending on shore base 21 Mills Dr,
volume) Goodwood, NS
Scrap Wood Non- None Waste skips Scrap Wood Supply Vessel to Recycle Halifax C&D recycling
Hazardous (depending on shore base 16 Mills Dr, Goodwood, NS
volume)
Miscellaneous Non- Non- None One tonne big Miscellaneous Supply Vessel to Depends on Otter Lake Waste Processing
Hazardous Waste Hazardous bags Non-Hazardous shore base specific waste and Disposal Facility
Materials type 600 Otter Lake Drive
- Useless cement
Halifax, NS
- Bentonite/barite
- Non-hazardous
chemicals
- Other Domestic
Wastes
EP201505209133 - 20 - October 21, 2015
Offshore /Recycling
Drill Cuttings (SBM) In Hazardous None Cuttings Skips SBM Drill Supply Vessel to Onshore Terrapure - Beechill
Excess of 6.9% ROC Cuttings Shore Base Disposal 1460 Beech Hill Rd,
Antigonish, NS
Clean Earth Technologies

203 Aerotech Drive
Halifax, NS
Synthetic Based Mud Hazardous None Transfer to OSV Manifest as SBM Supply Vessel to Treatment and Terrapure - Beechill
(Residual) mud tanks Shorebase remediation 1460 Beech Hill Rd,
Antigonish, NS
Lafarge Canada
Pleasant Valley Rd
Brookfield, NS
Bentonite/Barite Non None Transfer to OSV Manifest as Supply Vessel to Disposal at Conrads/ SRT Soil
(Residual) Hazardous dry bulk tanks product Shorebase licensed Remediation Technologies
facility/recycle 31 Cono Dr
with vendor or Dartmouth, NS
other user
Cement (Residual) Non None Transfer to OSV Manifest as Supply Vessel to Disposed of as Conrads
Hazardous dry bulk tanks product Shorebase per provincial 31 Cono Dr, Dartmouth, NS
regulatory
requirements
Lafarge Canada
Pleasant Valley Rd
Brookfield, NS
EP201505209133 - 21 - October 21, 2015
Offshore /Recycling
Mud/Cement Hazardous None Segregate plastic WHMIS Supply Vessel to Reuse/Return Return to Vendor
Additives pails into lined big Shorebase pails to vendor.
bags.
Recycle sacks.
Store empty sacks
into big bags
Casing Protectors Non None Placed in one Casing Protectors Supply Vessel to Plastic and Plastic: Miller Waste
Hazardous tonne big bags Shore Base metal 20 Horseshoe Lake Dr
components Halifax, NS
separated and
then recycled Metal: John Ross & Sons
21 Mills Dr
Goodwood, NS
Non Macerated Non None Placed in clear Compostible Supply Vessel to Compost Miller Group
Organics Hazardous bags (double Material Shore Base Facility 80 Gloria McCluskey Ave
bagged) and then Dartmouth, NS B3B 2A4
sorted in one tonne
big bags
EP201505209133 - 22 - October 21, 2015
Appendix A – Waste Manifest (Example) – Offshore
EP201505209133 - 23 - October 21, 2015
Appendix B - Master Waste Disposal Record
QUANTITY MANNER OF TRANSPORTED /

DATE TYPE OF WASTE REFERENCE / MANIFEST NO.
DISPOSED DISPOSAL COLLECTED BY:
EP201505209133 - 24 - October 21, 2015
APPENDIX D – SUMMARY OF MITIGATION, MONITORING AND
FOLLOW UP COMMITMENTS
Table D.1 Summary of Commitments (Source Stantec 2014)

No. Proponent Commitment
General
1 Shell will comply with the terms and conditions of approval, for all permits, authorizations, and
licences obtained in support of the Project
2 Prior to mobilization at the selected drilling site, the MODU will undergo the required regulatory
inspections to demonstrate that it meets Canadian and CNSOPB safety and technical
specifications.
3 Shell will obtain a Certificate of Fitness from an independent third party Certifying Authority for
the MODU prior to commencement of drilling operations in accordance with the Nova Scotia
Offshore Certificate of Fitness Regulations.
4 All operations relating to the Project will be required at a minimum to comply with Shell
standards and with external regulatory standards. Where requirements differ, the more stringent
requirement will apply. Shell will require contractors to demonstrate that they have in place a
Health, Safety and Environment Management System compatible with these standards, and that
they are committed to implementing it.
5 The observation, forecasting and reporting of physical environment data will be conducted in
accordance with the Offshore Physical Environment Guidelines (NEB et al. 2008) to promote the
safe and prudent conduct of routine operations and emergency response.
6 The following Project-specific management plans will be developed and submitted to the
CNSOPB for review and approval:
• Environmental Protection Plan
• Safety Plan
• Emergency Response Plan, Well Control Plan, Oil Spill Response Plan, and Relief Well
Contingency Plan
• Waste Management Plan
OSVs and Helicopters
7 OSVs will be compliant with the Canada Shipping Act and national and international regulations
while at sea, Eastern Canadian Vessel Traffic Services Zone Regulations when operating in
nearshore or harbour areas, and applicable Port Authority requirements when in a port. Ship
operations will also adhere to Annex I of MARPOL, of which Canada has incorporated
provisions under various sections of the Canada Shipping Act and its regulations.
8 In preparation for the Project, OSVs will undergo Shell’s internal audit process as well as
additional external inspections/audits, including the CNSOPB pre-authorization inspection
process, during Q4 of 2014 or Q1 of 2015.
9 OSVs will avoid the Gully, as per the Gully Marine Protected Area Regulations, when travelling
to and from the MODU.
10 Fuelling of OSVs will be conducted at a permitted facility and in accordance with fuelling
procedures, reducing the risk of a spill during transfer operations.
11 OSVs will use existing shipping routes when travelling to and from the MODU, adhere to
standard navigation procedures, and reduce speeds to 18.5 km/hour (10 knots) within the

Project Area.
12 To reduce risk of collision, Project OSVs will avoid critical habitat for the northern bottlenose
whale (The Gully, and Shortland and Haldimand canyons) and will avoid critical habitat for the
North Atlantic right whale (Roseway Basin) from June 1 to December 31. OSVs will also
maintain a 2 km avoidance buffer around Sable Island.
13 Except in the case of an emergency, Project helicopters will avoid flying over Roseway Basin
and Sable Island.
14 Helicopters transiting to and from the MODU will fly at altitudes greater than 300 m and at a
lateral distance of 2 km from active colonies when possible.
15 Measures will be taken as appropriate to monitor and mitigate effects of the environment (e.g.,
icing, fog) on OSV and helicopter transportation. Pilots and OSV operators will have the
authority and obligation to suspend or modify operations in case of adverse weather that
compromises the safety of helicopter or OSV operations.
16 Stranded birds found during routine inspections on OSVs will be handled using the protocol
outlined in The Leach’s Storm Petrel: General Information and Handling Instructions (Williams
and Chardine 1999) and in accordance with the terms and conditions of the bird
salvage/handling permit obtained from the Canadian Wildlife Service (CWS).
Project Design
17 Engineering design for the Project will adhere to national/international standards for site-specific
normal and extreme physical environmental conditions.
18 Lighting on Project infrastructure will be reduced to the extent that worker safety is not
compromised.
19 Well design reviews will be carried out and approved by appropriate qualified internal discipline
authorities and technical experts. The same principles apply to the input parameters, which are
used as the basis for the well design.
20 The transfer of SBM to the OSV and spent SBM from the OSV will occur through a closed
system thereby minimizing the risk of spillage to the marine or terrestrial environment.
21 The results of the seabed survey conducted in the spring of 2014 and pre-drill ROV surveys
conducted at each potential wellsite will inform the selection of drilling locations that avoid areas
where known heritage resources, coral concentrations, or other sensitive or unique benthic
habitat are present.
22 Once the MODU is in position, pre-drill site surveys will be conducted using an ROV deployed to
the seabed. These surveys will be conducted to confirm that no potential surface seabed
hazards or sensitivities are present at the drilling location.
23 Two independent barriers will be maintained at all times once the BOP is installed on the
wellhead. These barriers will be verified by testing both prior to and following installation; should
one barrier be lost, operations will be stopped and the focus of operations will shift to regaining
a two-barrier status.
Wastes/Discharges
24 The OCSG will be applied in selecting chemicals for drilling, as well as to guide the proper
treatment and disposal of chemicals selected.
25 Constituents in drilling muds will be screened using the OCSG to assess the viability of using
lower toxicity chemicals.

26 Offshore waste discharges and emissions associated with the Project (i.e., operational
discharges and emissions from the MODU and OSVs) will be managed in compliance with
MARPOL and treated in accordance with the OWTG, as applicable.
27 In accordance with the OWTG, drilling solids associated with the use of SBM will be treated
prior to marine disposal such that the “synthetic-on-cuttings” does not exceed 6.9 g/100 g oil on
wet solids. Shell, in accordance with CEAA condition 3.12.1, will measure and report
concentrations in excess of the limits to the CNSOPB within 24 hours and adjust treatments as
necessary to prevent further exceedances.
28 No whole SBM base fluid or any whole mud containing SBM as a base fluid will be discharged
at sea.
29 Waste discharges that do not meet OWTG requirements will not be discharged to the ocean, but
brought to shore for disposal.
30 Hazardous wastes, including any waste dangerous goods, generated during the Project will be
stored in the appropriate containers/containment and in designated areas on board the MODU
for transportation to shore.
31 The transportation of any dangerous goods, waste dangerous goods or hazardous substances
will occur in compliance with the Transportation of Dangerous Goods Act and its associated
regulations.
32 Wastes destined for onshore treatment, recycling and/or disposal will be managed in
accordance with the Nova Scotia Solid Waste-Resource Management Regulations and will
comply with any applicable federal and provincial waste requirements as well as municipal by-
laws.
33 A third-party waste management contractor will manage and dispose of wastes transported
onshore at existing approved disposal facilities.
34 The air emissions from the Project will comply with the Air Quality Regulations under the Nova
Scotia Environment Act, and meet the National Ambient Air Quality Objectives under CEPA,
1999.
35 Prior to transiting into Canadian waters, the MODU will undergo normal ballast tank flushing
procedures, as required under IMO’s Ballast Water Management Convention and Transport
Canada’s Ballast Water Control and Management Regulations.
36 In accordance with the OWTG, the volume and types of any fluids discharged into the marine
environment will be reported to the CNSOPB on a monthly basis.
Accidental Events
37 Shell and its contractors will have measures in place to reduce the potential for vessel spills.
This includes:
• All activities adhering to Annex I of MARPOL
• Adherence to standard navigation procedures, Transport Canada regulations and CCG
requirements, and
• Special attention to activities presenting increased risks for marine traffic including loading and
offloading, docking and extreme weather events
38 Spills to the marine environment will be immediately reported to the Canadian Coast Guard and
the CNSOPB as outlined in the Shell Canada Oil Spill Response Plan and the CNSOPB
Incident Reporting and Investigation Guidelines.

39 A Dispersants Operations Plan will be developed as part of the OSRP, which will outline the
process and procedures for determining whether to utilize dispersants and initiate deployment of
dispersants in the unlikely event of an oil spill incident in the Project Area.
40 Shell will have available local staff and agencies, and Aboriginal representatives trained in
accordance with its Incident Command System and able to respond to accidental spills.
Dependent on the size and scale of the incident, Shell will draw on various support
organizations/agencies to provide the appropriate and necessary resources and response.
41 Personnel potentially involved in oil spill response will receive specialized training, and drills will
be conducted periodically to familiarize personnel with on-site equipment, proper deployment
techniques and maintenance procedures, and management of incidents.
42 Shell will work with the appropriate government agencies and undertake a Net Environmental
Benefits Analysis (NEBA) to evaluate the risks and benefits of dispersing oil in the water
column.
43 If required, for a nearshore spill, shoreline clean-up and possible collection and cleaning of fur-
bearing marine mammals and oiled marine birds would be conducted.
44 As part of spill response, marine mammal and marine bird hazing techniques may be used if
deemed necessary to deter animals from entering affected areas and prevent further oiling.
45 In the event that a vessel collision with a marine mammal or sea turtle occurs, Shell will contact
the CNSOPB, the Marine Animal Response Society (MARS) and the Coast Guard to relay the
incident information.
46 Incidents will be reported in accordance with the Incident Reporting and Investigation
Guidelines(C-NLOPB and CNSOPB 2012).
47 In the unlikely event of an accidental spill, specific monitoring (e.g., environmental effects
monitoring) and follow-up programs may be required and will be developed in consultation with
applicable regulatory agencies.
48 As part of any spill monitoring, records will be kept of any marine mammals or sea turtles
encountered and any evidence of visible oiling.
49 Project-related damage to fishing gear, if any, will be compensated in accordance with the
Compensation Guidelines with Respect to Damages Relating to Offshore Petroleum Activity (C-
NLOPB and CNSOPB 2002).
Vertical Seismic Profiling

50 VSP surveys will adhere, at a minimum, with mitigation measures described in the SOCP.
51 A ramp-up procedure will be implemented before any VSP activity begins. Additionally, VSP
shutdown procedures will be implemented if a marine mammal or sea turtle species listed on
Schedule 1 of SARA, as well as all other baleen whales and sea turtles are observed within 1
km of the wellsite.
52 MMOs will be employed to monitor and report on marine mammal and sea turtle sightings
during VSP surveys to enable shutdown or delay in the presence of a marine mammal or sea
turtle species listed on Schedule 1 of SARA, as well as all other baleen whales and sea turtles.
Monitoring will involve visual observations. Following the program, copies of the marine
mammal and sea turtle observer reports will be provided to DFO.
Consultation and Engagement

53 Shell will communicate with fishers before, during, and after drilling programs. Details of safety
zones will be published in Notices to Mariners and Notices to Shipping, which will allow fishers
and other ocean users to plan accordingly. Shell will provide the details of its operation,
including the safety zone during drilling and testing, to the Marine Communications and Traffic
Services for broadcasting and publishing in the Notices to Shipping, and the location of the
abandoned wellheads if left on the seafloor.
54 Shell will continue to engage commercial and Aboriginal fishers to share Project details as
applicable. A Fisheries Communications Plan will be used to help facilitate coordinated
communication with commercial and Aboriginal fishers.

APPENDIX E – CEAA DECISION STATEMENT CONDITIONS
Number CEAA Condition
2 General Conditions
2.1 The Proponent shall, throughout all phases of the Designated Project, ensure its
actions in meeting these conditions are informed by the best available information
and knowledge, based on validated methods and models, undertaken by qualified
individuals and apply the best available economically and technologically feasible
strategies.
2.2 The proponent shall where consultation in a requirement of a conditions set out in
this decision statement
2.3. The proponent shall, where Aboriginal consultation is a requirement of a condition
set out in this decision statement, first consult each Aboriginal group on the most
appropriate manner in which to conduct the consultation.
2.4 The Proponent shall, within 90 days after each well is suspended and/or
abandoned, submit to the Board a report including an executive summary of the
report in both official languages. The Proponent shall document in the report:
2.4.1 implementation activities undertaken for each of the conditions;
2.4.2 how it met condition 2.4.1 in the implementation of the conditions set out in
this decision statement;
2.4.3 for conditions set out in this decision statement for which consultation is a
requirement, how it has considered any views and information received;
2.4.4 the results of the follow-up program requirements identified in conditions
3.12, and 4.4; and
2.4.5 any corrective actions taken by the Proponent, or proposed in relation to
subsequent wells to be drilled as part of the Designated Project, should the
predictions of environmental effects prove to be inaccurate or the mitigation
measures prove not to be effective.
2.5 The Proponent shall make the report, the executive summary referred to in
conditions 2.4 as well as the implementation schedule referred to in condition 7
available on its website when the report or schedule is submitted to the Board.
The proponent shall keep these documents available on its website for a
minimum of 5 years after completion of the Designated Project unless otherwise
specified by the Board.
2.6 The Proponent shall notify the Board as soon as possible if the Designated
Project is expected to be undertaken by another party due to a sale, a transfer, or
other circumstances that arise and would result in a new proponent taking over
the Designated Project in whole or in part.
3 Fish (including marine mammals and sea turtles) and fish habitat
3.1 The Proponent shall treat all discharges from the drilling unit into the marine
environment in compliance with the Offshore Waste Treatment Guidelines issued
jointly by the National Energy Board, the Canada-Newfoundland and Labrador
Offshore Petroleum Board and the Canada-Nova Scotia Offshore Petroleum
Board, and in accordance with the requirements of the Fisheries Act, the
Migratory Convention Act, 1994 and any other applicable legislation.

3.2 The Proponent shall apply the Offshore Chemical Selection Guidelines for Drilling
& Production Activities on Frontier Lands issued jointly by the National Energy
Board, the Canada- Newfoundland and Labrador Offshore Petroleum Board and
the Canada-Nova Scotia Offshore Petroleum Board to select lower toxicity
chemicals that would be used and discharged into the marine environment,
including drilling fluid constituents, and shall submit any necessary risk
justification as per Step 10 of the Guidelines to the Board for acceptance prior to
use.
3.3 The Proponent shall treat all discharges from support vessels into the marine
environment in compliance with the International Convention for the Prevention of
Pollution from Ships.
3.4 The Proponent shall conduct a pre-drill survey at each well site to determine the
presence at any Military Unexploded Ordnance if any such ordinance is detected
the proponent shall consult the Board to determine an appropriate course of
action prior to commencing drilling.
3.5 The Proponent shall conduct a pre-drill survey to identify any aggregations of
habitat-forming corals or sponges, or species at risk at each well site prior to
drilling and report results to the Board within 48 hours of the completion of the
survey.
3.6 If aggregations of habitat-forming corals or sponges, or species at risk are
confirmed, the Proponent shall move the drilling unit to avoid affecting them,
unless in doing so would not be technically feasible. If not technically feasible, the
Proponent shall consult with the Board prior to commencing drilling to determine
an appropriate course of action to the Board’s satisfaction.
3.7 The Proponent shall apply Fisheries and Oceans Canada’s Statement of
Canadian Practice with Respect to the Mitigation of Seismic Sound in the Marine
Environment during vertical seismic profiling surveys.
3.8 The Proponent shall submit a Marine Mammal Observer Program to the Board for
acceptance at least 30 days prior to the commencement of any vertical seismic
profiling activity that;
3.8.1 demonstrates that Marine Mammal Observers are trained to identify
different species of marine mammals and sea turtles that may be present in the
safety zone through either visual observation or cetacean detection technology,
such as Passive Acoustic Monitoring, if used;
3.8.2 demonstrates that Marine Mammal Observers have the ability to view the
entire safety zone; and
3.8.3 provides, if used during vertical seismic profiling, the specific Passive
Acoustic Monitoring configuration.
3.9 The Proponent shall record and report the results of the Marine Mammal
Observer Program to the Board within 30 days of the completion of the survey.
3.10 The Proponent shall implement measures to prevent or reduce the risks of
collisions between support vessels and marine mammals and sea turtles,
including:
3.10.1 establishing a speed limit of 10 knots for support vessels operating in the
project area, as well as when marine mammals or sea turtles are observed or
reported to be in the vicinity of the vessel; and
3.10.2 requiring support vessels to use established shipping lanes, where they
exist.

3.11 The Proponent shall promptly report any collisions with marine mammals or sea
turtles to the Board, and through Canadian Coast Guard Radio.
3.12 The Proponent shall monitor effects on fish and fish habitat, including marine
mammals and sea turtles, to verify the accuracy of the predictions made during
the environmental assessment and to evaluate the effectiveness of mitigation
measures identified under conditions 3.1 to 3.11, including:
3.12.1 measuring and reporting to the Board the concentration of synthetic-based
drilling fluids retained on discharged drilling cuttings as described in the Offshore
Waste Treatment Guidelines to verify that the discharges meet the limits set out in
the guidelines. Concentrations in excess of the limits shall be reported within 24
hours to the Board and treatment adjusted as necessary to prevent further
exceedances.
3.12.2 collecting sediment deposition information during and after drilling activities
to verify modelling predictions and reporting to the Board within 90 after a well is
suspended and/or abandoned; and
3.12.3 verifying predicted underwater noise levels with field measurements during
the first phase of the drilling program. The proponent shall provide to the Board a
plan on how this will be conducted at least 30 days in advance of drilling and the
monitoring results within 90 days after a well is suspended and/or abandoned.
4 Migratory Birds
4.1 The Proponent shall carry out all phases of the Designated Project in a manner
that protects and avoids harming, killing or disturbing migratory birds or taking
their nests or eggs. In this regard, the proponent shall take into account
Environment Canada's Avoidance Guidelines. The proponent's action in applying
the Avoidance Guidelines shall in be in compliance with the MBCA, 1994 and with
SARA.
4.2 The Proponent shall notify the Board at least 30 days in advance of flaring to
determine whether the flaring would occur during a period of migratory bird
vulnerability, and how it plans to prevent harm to migratory birds.
4.3 The Proponent shall implement measures to prevent harm to or killing of
migratory birds such as:
4.3.1 restricting flaring to the minimum required to characterize the well’s
hydrocarbon potential and as necessary for the safety of the operation;
4.3.2 minimizing flaring during night time and during periods of bird vulnerability
such as fledging or foraging; and
4.3.3 operating a water-curtain barrier during flaring.
4.4 The Proponent shall monitor effects on migratory birds, including species at risk,
to verify the accuracy of the predictions made during the environmental
assessment and to determine the effectiveness of mitigation measures. The
proponent shall document and submit to the Board the results of any monitoring
carried out under conditions 4.1, 4.2 and 4.3. The documentation shall
demonstrate whether the mitigation measures have proven effective and if
additional measures are required to comply with condition 4.1.
5 Aboriginal and Commercial Fishing
5.1 The Proponent shall consult with Aboriginal and commercial fishers to minimize
the potential for conflicts between the Designated Project and fishing activities,

including by developing and implementing a Fisheries Communications Plan to
address communications prior to and during drilling, testing and abandonment of
each well. The plan shall include procedures to notify fishers a minimum of two
weeks prior to starting each well and to communicate with fishers in the event of
an accident or malfunction that may result in adverse environmental effects and
requires measures to be taken in relation to conditions 6.9 and 6.10.
5.2 The Proponent shall prepare a well abandonment plan and consult with Aboriginal
and commercial fishers on the plan if it is proposed that a wellhead be abandoned
on the seafloor. The Proponent shall submit the plan, including result of any
consultation, to the Board for acceptance at least 30 days prior to each well being
abandoned.
5.3 The Proponent shall provide the details of its operation, including the safety zone
during drilling and testing, to the Marine Communications and Traffic Services for
broadcasting and publishing in the Notices to Shipping, and the location of the
abandoned wellheads if left on the seafloor.
6 Accidents and Malfunctions
6.1 The Proponent shall take all reasonable measures to prevent accidents and
malfunctions that may result in adverse environmental effects and shall implement
emergency response procedures and contingency plans developed in relation to
the Designated Project.
6.2 The Proponent shall prepare an Oil Spill Response Plan and a Well Containment
Plan in accordance with the Board’s requirements and submit the Plan to the
Board for acceptance at least 90 days prior to drilling.
6.3 The Oil Spill Response Plan shall include:
6.3.1 procedures to respond to an oil spill (e.g. oil spill containment, oil recovery);
6.3.2 measures for wildlife response, protection, and rehabilitation (e.g., collection
and cleaning of marine mammals, birds, and sea turtles) and measures for
shoreline protection and clean-up ; and
6.3.3 procedures to notify the Board and other relevant regulatory agencies on the
occurrence of any oil spill to water in accordance with applicable reporting
requirements.
6.4 The Proponent shall conduct an exercise of the Oil Spill Response Plan prior to
the commencement of drilling and adjust the plan to the satisfaction of the Board
to address any deficiencies identified during the exercise.
6.5 The Proponent shall review the Oil Spill Response Plan and update it as required
following completion of each well.
6.6 The Well Containment Plan shall include:
6.6.1 A Relief Well Contingency Plan; and
6.6.2 Well Capping Plan describing the plan to mobilize and deploy a capping
stack, if required.
6.7 The Proponent shall undertake a Net Environmental Benefit Analysis, to consider
all the available spill response options and identify those techniques, including the
possible use of dispersants, that will provide for the best opportunities to minimize
environmental consequences, and provide it to the Board for review 90 day prior
to drilling.
6.8 The Proponent shall consult with Aboriginal groups during the development of the

Oil Spill Response Plan, the Well Containment Plan and Net Environmental
Benefit Analysis and provide the approved versions to Aboriginal groups before
the start of drilling.
6.9 In the event of an accident or malfunction having the potential to cause adverse
environmental effects, the Proponent shall implement its Oil Spill Response Plan,
including:
6.9.1 monitoring the effects of oiling on components of the marine environment to
be identified by the Board until specific endpoints identified in consultation with
expert government departments are achieved. As applicable, monitoring may
include:
6.9.1.1 sensory testing of seafood for taint, and chemical analysis for oil
concentrations and any other substances, as applicable ;
6.9.1.2 measuring levels of contamination in recreational and commercial fish
species with results integrated into a human health risk assessment to determine
the fishing area closure status; and
6.9.1.3 monitoring for marine mammals, sea turtles, and birds with indicative
signs of oiling and reporting results to the Board.
6.10 In the event of a sub-sea well blowout, the Proponent shall, in addition to
condition 6.9, implement its Well Containment Plan and begin the immediate
mobilization of primary and back- up capping stacks and associated equipment to
the project area to stop the spill.
6.11 In the event of accidents and malfunctions, the Proponent shall comply with the
Compensation Guidelines with Respect to Damages Relating to Offshore
Petroleum Activity issued jointly by the CNLOPB and the CNSOPB.
7 Implementation Schedule
7.1 The Proponent shall submit an implementation schedule for conditions contained
in this decison statement to the Board at least 30 days prior to the start of drilling.
The implementation schedule shall indicate the commencement and completion
dates for each activity relating to conditions set out in this decision statement with
sufficient detail to allow the Board to plan compliance verification activities.
7.2 The Proponent shall notify the Board of any changes to the implementation
schedule required under condition 7.1 at least 30 days prior to implementation of
the changes, if feasible, and shall not implement the changes unless accepted by
the Board.
8 Record Keeping
8.1 The Proponent shall record, retain and make available to the Board, upon
request, at a facility in Nova Scotia, information related to the implementation of
the conditions set out in this decison statement including:
8.1.1 the place, date and time of any sampling that was conducted;
8.1.2 the dates any analyses were performed;
8.1.3 the sampling and analytical techniques, methods or procedures used;
8.1.4 the names and professional certifications of the persons who collected or
analyzed each sample; and
8.1.5 the results of the sampling and analyses.
8.2 The Proponent shall retain and make available upon request to the Board the

information contained in condition 8.1 for a minimum of 5 years after completion
of the Designated Project unless otherwise specified by the Board at a facility in
Nova Scotia (or at a location within Canada and agreed upon by the Board,
should the local facility no longer be maintained).


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Shelburne Basin Venture Exploration Drilling Project

Environmental Protection Plan

Project Shelburne Basin Venture Exploration Drilling Project

Document Title Environmental Protection Plan

Document Number EP201409207550

Document Revision O4A

Document Status Final - Redacted

Document Type Controlled

Owner / Author Candice Cook-Ohryn/Lara Smandych

Issue Date October 21, 2015

Expiry Date None

Date of Issue: October 16, 2015

Custodian: Environmental Lead – Candice Cook-Ohryn/Lara Smandych

Approved by: Venture Manager – Christine Pagan

REVISION STATUS APPROVAL

Rev. Date Description Originator Reviewer Approver

1 20-Feb-15 Initial Draft C. Cook-Ohryn G. Krauss C. Pagan

2 27-May-15 2nd Draft C. Cook-Ohryn G. Krauss C. Pagan

3 30-July-15 3rd Draft L. Smandych G. Krauss C. Pagan

4 16-Oct-15 Final L. Smandych G. Krauss C. Pagan

5 21-Oct-15 Final-Redacted L. Smandych G. Krauss C. Pagan

Signatures for this Final revision

Document # EP201409207550 -2- October 21, 2015

Accord Acts ....................... ..Canada-Nova Scotia Offshore Petroleum Resources

Document # EP201409207550 -3- October 21, 2015

Document # EP201409207550 -4- October 21, 2015

Document # EP201409207550 -5- October 21, 2015

Document # EP201409207550 -6- October 21, 2015

Document # EP201409207550 -7- October 21, 2015

• may set requirements supplemental to applicable law and policy. However,

Document # EP201409207550 -8- October 21, 2015

Document # EP201409207550 -9- October 21, 2015

Document # EP201409207550 - 10 - October 21, 2015

Document # EP201409207550 - 11 - October 21, 2015

Document # EP201409207550 - 12 - October 21, 2015

Document # EP201409207550 - 13 - October 21, 2015

Document # EP201409207550 - 14 - October 21, 2015

This Environmental Protection Plan (EPP) (EP201409207550) is intended to provide the

The EPP is established to identify and outline the environmental management

Document # EP201409207550 - 15 - October 21, 2015

SEC # CNSOPB EPP GUIDELINES SEC # SHELL EPP

4.6.3 AWARENESS, COMPETENCE, AND TRAINING

4.6.3.1 AWARENESS 8.1 AWARENESS

Document # EP201409207550 - 16 - October 21, 2015

SEC # CNSOPB EPP GUIDELINES SEC # SHELL EPP

4.6.6 OPERATIONAL CONTROL

4.6.9 MANAGEMENT OF CHANGE 10.3 MANAGEMENT OF CHANGE

4.6.10 ENVIRONMENTAL INCIDENTS

Document # EP201409207550 - 17 - October 21, 2015

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This EPP is aimed at outlining Project-specific environmental protection and

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Figure 3.1 Project Location

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3.3 Stena IceMax Drillship

3.4 Helicopter Support

3.5 Onshore Supply Base

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Shell Canada Limited

24 hour Duty Officer – <Redacted>

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The key Acts, Regulations and Directives relevant to environmental management of

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