E4276 v1 Banda Field Development - Gas Project Environmental Impact Assessment August 2013 www.erm.com FINAL REPORT Tullow Petroleum (Mauritania) Pty Ltd Banda Field development - Gas Project Environmental Impact Assessment August 2013 Prepared by Environmental Resources Management For and on behalf of Environmental Resources Management Approved by: Camille Maclet Signed: Position: Partner Date: 14 August 2013 This report has been prepared by ERM, the trading name of Environmental Resources Management France SAS, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk. TABLE OF CONTENTS 1 INTRODUCTION 1 1.1 BACKGROUND 1 1.2 PURPOSE OF THIS REPORT 3 1.3 SCOPE OF THIS EIA 3 1.4 PRESENTATION OF THE PROJECT PROPONENT 3 1.5 PRESENTATION OF THE EIA CONSULTANTS 4 1.6 PURPOSE OF THE EIA 5 1.7 SUMMARY OF THE EIA PROCESS 6 1.8 STRUCTURE OF THIS REPORT 11 2 ADMINISTRATIVE AND REGULATORY FRAMEWORK 13 2.1 INTRODUCTION 13 2.2 NATIONAL ADMINISTRATION 13 2.3 ENVIRONMENTAL POLICY IN MAURITANIA 16 2.4 NATIONAL LEGISLATION 17 2.5 RELEVANT INTERNATIONAL CONVENTIONS AND AGREEMENTS 21 2.6 TULLOW EHS POLICIES AND GUIDANCE 26 2.7 INTERNATIONAL AND INDUSTRY GOOD PRACTICE AND GUIDANCE 29 3 PROJECT DESCRIPTION 37 3.1 INTRODUCTION 37 3.2 DRILLING AND COMPLETIONS 40 3.3 SUBSEA INSTALLATION 48 3.4 ONSHORE INSTALLATION 53 3.5 OPERATIONS 60 3.6 DECOMMISSIONING 62 3.7 EMISSIONS, DISCHARGES, WASTES AND NOISE 62 3.8 REVIEW OF PROJECT ALTERNATIVES CONSIDERED BY TULLOW 72 4 ENVIRONMENTAL AND SOCIO-ECONOMIC BASELINE 76 4.1 INTRODUCTION 76 4.2 BASELINE STUDY AREA 77 4.3 PHYSICAL ENVIRONMENT 79 4.4 MARINE BIOLOGICAL ENVIRONMENT 102 4.5 TERRESTRIAL ECOLOGY 119 4.6 PROTECTED AREAS FOR NATURE CONSERVATION 139 4.7 FISH AND FISHERIES 141 4.8 NON FISHING MARINE USERS 156 4.9 SOCIO-ECONOMIC BASELINE 157 4.10 CULTURAL HERITAGE 173 5 IMPACT IDENTIFICATION AND ASSESSMENT 180 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD I 5.1 APPROACH TO THIS ASSESSMENT 180 5.2 IMPACT ASSESSMENT METHODOLOGY 180 5.3 SCREENING/PRELIMINARY IDENTIFICATION OF IMPACTS 185 5.4 PRELIMINARY ASSESSMENT OF IMPACTS 187 5.5 KEY IMPACTS IDENTIFIED- OFFSHORE DRILLING AND INSTALLATION PHASE 215 5.6 K,:;Y IDENTIFIED IMPACTS- ONSHORE CONSTRUCTION PHASE 245 5.7 KEY IDENTIFIED IMPACTS- OPERATIONAL PHASE 249 5.8 CUMULATIVE IMPACTS 270 6 ENVIRONMENTAL MANAGEMENT PLAN 275 6.1 INTRODUCTION 275 6.2 EMP OBJECTIVES 275 6.3 CONSISTENCE WITH TULLOW EHS MANAGEMENT STANDARDS 275 6.4 SPECIFIC MANAGEMENT PROCEDURES 276 6.5 IMPLEMENTING THE EMP 281 6.6 MANAGEMENT OF CHANGE 281 6.7 DETAILS OF THE EMP 282 7 PUBLIC CONSULTATION 299 7.1 REGULATORY FRAMEWORK 299 7.2 PUBLIC CONSULTATION AND STAKEHOLDER ENGAGEMENT FOR THE EIA 300 7.3 PUBLIC CONSULTATION MEETING 302 7.4 ADDRESSING STAKEHOLDER CONCERNS 303 7 REFERENCES 305 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTY LTD II LIST OF FIGURES Figure 1.1 Location of the Banda Field 2 Figure 1.2 Generic Overview of the Impact Assessment Process 7 Figure 2.1 Procedure for the Development, Implementation and Regulatory Approval of EIAs in Mauritania 18 Figure 2.2 Tullow Oil Environmental Standards 26 Figure 2.3 Tullow' s Corporate EHS Policy 28 Figure 3.1 Project Location 38 Figure 3.2 Base Case Production Profile 39 Figure 3.3 Typical third generation MODU, Byford Dolphin 41 Figure 3.4 Circulation of Fluid during Drilling 42 Figure 3.5 Well Schematic Diagram 43 Figure 3.6 Typical Additives in Drilling Fluids 44 Figure 3.7 Aerial View of Port of Nouakchott 46 Figure 3.8 Tullow's Facilities at Port of Nouakchott 47 Figure 3.9 Typical Support Helicopters 48 Figure 3.10 Proposed Subsea Configuration 49 Figure 3.11 Pipeline landfall and plant location 54 Figure 3.12 Provisional 3D Site Plan 55 Figure 3.13 Indicative Onshore Pipeline Installation Vehicles 59 Figure 3.14 Typical Process Flow Diagram for the Onshore Gas Plant 61 Figure 3.15 Schematics of Proposed Produced Water Treatment System 69 Figure 4.1 Determination of the Study Area 78 Figure 4.2 Prevailing Winds in the Atlantic Ocean 80 Figure 4.3 Air Temperature Statistics in Nouakchott, 2007-2012 80 Figure 4.4 Monthly Precipitation in Nouakchott, 1981-2012 81 Figure 4.5 Relative Humidity in Nouakchott, 2007-2012 81 Figure 4.6 Air Temperature Statistics at Banda 82 Figure 4.7 Joint Frequency Table of Wind Speed and Direction at Banda field 83 Figure 4.8 Wind speed statistics in Nouakchott, 2007-2012 83 Figure 4.9 Circulation of Currents off the Coast of West Africa 84 Figure 4.10 Current profile of maximum current speed 85 Figure 4.11 Total Significant Wave Height and Direction in Banda Area 86 Figure 4.12 Pipeline Route and Bathymetry 87 Figure 4.13 Bathymetric Profile of the Pipeline Route 88 Figure 4.14 Flooded Areas around the Proposed Location of the Project's Onshore Component 89 Figure 4.15 Schematic Geomorphology of the Mauritanian Coastline (North of Nouakchott) 90 Figure 4.16 Type of Sediments along the Pipeline Route 91 Figure 4.17 Sedimentology along the Offshore Pipeline Route 94 Figure 4.18 Monthly Mean Surface Water Temperature 95 Figure 4.19 Monthly Near-seabed Temperature in the Banda Field 96 Figure 4.20 Water Temperature and Turbidity Profiles in the Banda Field 97 Figure 4.21 Monthly Near-seabed Salinity in the Banda Field 97 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD III Figure 4.22 Pictures of the University of Nouakchott Construction Site (November 2012) 99 Figure 4.23 Noise Measurement Locations 100 Figure 4.24 Indicative Primary Productivity (mg Cm-3 per day) Offshore Mauritania in February 104 Figure 4.25 Individual Abundance at the Sampling Stations on the Pipeline Route 105 Figure 4.26 Abundance of Taxa at the Sampling Stations on the Pipeline Route 106 Figure 4.27 Location of Carbonate Mud Mounds (Colman et al, 2005) 107 Figure 4.28 Blue Whale Recorded during the 3D Seismic Study of nearby Block 2 111 Figure 4.29 Common Dolphin Recorded during 3D Seismic Study of the Nearby Block 2 113 Figure 4.30 Known Presence of Green Turtles and Loggerhead Turtles in West Africa 116 Figure 4.31 Green Turtle Recorded within the Licence Area during the 3D Seismic Study of Nearby Block 2 118 Figure 4.32 Olive Ridley Turtle Recorded within the Licence Area During the 3D Seismic Study of Nearby Block 2 118 Figure 4.33 Monitoring Tracks and Vegetation Plots 120 Figure 4.34 Land Cover in the Local Study Area (1 km) 121 Figure 4.35 Land Cover in the Regional Study Area (5 km) 122 Figure 4.36 Foreshore from the Landfall Site 123 Figure 4.37 Coastal Dune with Zygophyllum fontanesii and Calotropis procera 124 Figure 4.38 Sebkha 124 Figure 4.39 Temporarily Flooded Area 125 Figure 4.40 Bare Soil with Zygophyllum 125 Figure 4.41 Dune with Euphorbia balsamifera 126 Figure 4.42 Inland Dune 126 Figure 4.43 Example of Hedges of Euphorbia balsamifera and Satellite View of the Hedges 128 Figure 4.44 Location of the reforested areas 129 Figure 4.45 Flora Inventoried in the Study Area 131 Figure 4.46 Birds Observed during the Biodiversity Survey 135 Figure 4.47 Species of Acanthodactylus Obersved in the Study Area 137 Figure 4.48 Arabian Hare 138 Figure 4.49 Dromedaries 139 Figure 4.50 Protected Areas in the Vicinity of the Project Area 140 Figure 4.51 Typical Artisanal Fishing Fleet 145 Figure 4.52 Targeted Species for Artisanal Fishing 146 Figure 4.53 Nouakchott Fish Market 147 Figure 4.54 Fish Meal Factory at PK28, South of Nouakchott 147 Figure 4.55 Industrial and Artisanal Fish Landings (in Tons) 148 Figure 4.56 Industrial Fish Landings in Tons per Category of Species 149 Figure 4.57 Fishing Vessel Traffic within the Vicinity of the Banda Field 151 Figure 4.58 Fishing Vessels Travelling under 4 Knots 151 Figure 4.59 Shipping Routes within 30 Nautical .Miles of the Banda Field 152 Figure 4.60 Pirogue Captain and his Team 153 Figure 4.61 Traps for Cephalopod Fishing 154 Figure 4.62 Artisanal Fishermen Landing 154 Figure 4.63 Octopuses Caught by Artisanal Fishermen 155 Figure 4.64 Seasonal Calendar of Artisanal Fishing by Species 155 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD IV Figure 4.65 Shipping Density Grid in the vicinity of the Banda Oil Drilling Centre 157 Figure 4.66 Location of Surveyed Settlements 160 Figure 4.67 View of the Imraguen Village of M'haijratt 162 Figure 4.68 View of Fishermen Encampment at PK 28 163 Figure 4.69 Nearest Residential Areas to Project Site 164 Figure 4.70 Proposed pipeline route and exclusion zone at the highway crossing 167 Figure 4.71 Proposed pipeline route and exclusion zone at landfall 168 Figure 4.72 Land use in the Project Area 169 Figure 4.73 Ribat Albahr Preliminary Construction Works 173 Figure 4.74 Previously Identified Archaeological Sites in Mauritania 176 Figure 4.75 Locations of Cultural Heritage Recorded within the Project Footprint 179 Figure 5.1 Bottom Deposition Thickness 218 Figure 5.2 Bottom Deposition Thickness - 3D Perspective 218 Figure 5.3 Maximum TSS Concentration Exceeding Background Levels 219 Figure 5.4 TSS Concentration Exceeding Background Levels from Top Hole Release 220 Figure 5.5 Maximum Sedimentation Rate at the Seabed 221 Figure 5.6 Maximum Sedimentation Rate over Time 221 Figure 5.7 Weathering Processes for Oil at Sea 226 Figure 5.8 Oil Weathering Process 227 Figure 5.9 Probability of Visible Surface Oiling from Diesel Spill 228 Figure 5.10 Diesel Spill: Maximum Oil Thickness 229 Figure 5.11 Probability of Shoreline Oiling from Diesel Spill 230 Figure 5.12 Diesel spill: Maximum Shoreline Oiling Volume 230 Figure 5.13 Travel of Time of Diesel Slick 231 Figure 5.14 Example of the Evolution of a 1,200 m 3 Diesel Spill during 2 Weeks 232 Figure 5.15 Mass Balance Plot: Diesel Spill 233 Figure 5.16 Passing Powered Impact Energy Exceedence (from Anatec, 2012) 242 Figure 5.17 Passing Drifting Impact Energy Exceedence (from Anatec, 2012) 242 Figure 5.18 Infield Vessel Impact Energy Exceedence (from Anatec, 2012) 243 Figure 5.19 Passing Fishing Vessel Impact Energy Exceedence (from Anatec, 2012) 243 Figure 5.20 Geographical Risk Levels used to define the exclusion zone 251 Figure 5.21 Predicted Noise Levels Generated by the Project- Operation Phase 253 Figure 5.22 Receptors Identified in the Near Field around the Site 259 Figure 5.23 Operational Scenario: Predicted Annual Average Concentration for NOz 261 Figure 5.24 Operational Scenario: Maximum Predicted Hourly Concentration for N02 262 Figure 5.25 Operational Scenario: Predicted Annual Average Concentration for PM1o 263 Figure 5.26 Operational Scenario: Maximum Predicted Daily Concentration for PM1o 264 Figure 5.27 Emergency Scenario: Maximum Predicted Hourly Concentration for NOz 266 Figure 5.28 Emergency Scenario: Maximum Predicted Daily Concentration for PM1o 267 Figure 5.29 Time Series Of Noz Hourly Concentrations at Receptor NML8 (Settlement near Nouakchott- Nouadhibou Road) 268 Figure 5.30 Time Series of NOz Hourly Concentrations at Receptor NML9 (University) 268 Figure 5.31 Time Series of PM1o Daily Concentrations at Receptor NML8 (Settlement near Nouakchott- Nouadhibou road) 269 Figure 5.32 Time Series of PM1o Daily Concentrations at the Receptor NML9 (University) 269 Figure 6.1 Process for the management of change relating to the Project 282 Figure 7.1 Public consultation meeting in Nouakchott 302 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD v LIST OF TABLES Table 1.1 Tullow Equity in Mauritania 4 Table 1.2 Tullow's contact details 4 Table 1.3 EIA Report Structure 11 Table 2.1 Mauritanian Legislation Applicable to the Project 19 Table 2.2 MARPOL 1973/1978 Provisions Relevant to Oil and Gas Exploration 22 Table 2.3 List of the International Conventions Ratified by Mauritania 23 Table 2.4 IFC Performance Standards Considered in Developing the Project 30 Table 2.5 Oil Industry Exploration and Production Forum Guidelines 31 Table 2.6 Industry Good Practice Standards for Effluent Discharges 32 Table 2.7 IFC Guidelines for Ambient Noise Levels 34 Table 2.8 Air Quality Standards set by the IFC Guidelines for Air Emissions an Ambient Air Quality 35 Table 2.9 IFC guidelines for discharge to surface waters or to land 36 Table 3.1 Proposed Project Schedule 39 Table 3.2 Proposed Well Locations 40 Table 3.3 Proposed Designs of the Banda Gas Wells 43 Table 3.4 Estimated Drilling Wastes 45 Table 3.5 Estimated Seafloor Footprint of the Banda Gas Development 52 Table 3.6 Vessels Required for the Installation Phase 52 Table 3.7 Main Gas Plant Utilities 56 Table 3.8 Estimated Onshore Footprint of the Banda Gas Development 57 Table 3.9 Construction Schedule 57 Table 3.10 Construction Equipment 59 Table 3.11 Estimated Offshore Emissions During Construction Phase 63 Table 3.12 Estimated Emissions from Gas Plant Construction Phase 64 Table 3.13 Estimated Annual Emissions from Gas Plant Operation 64 Table 3.14 Expected Liquid Discharges during Offshore Drilling and Installation 66 Table 3.15 Produced Water Discharge Specification 68 Table 3.16 Estimated Waste Types and Estimated Generation Rates 70 Table 4.1 Results of Monitoring Measurements. Site Boundary 101 Table 4.2 Results of Monitoring Measurements near Identified Noise Sensitive Receptors 101 Table 4.3 Contribution of the Gross Taxonomic Groups at the Drilling Centre 105 Table 4.4 Marine Mammals Species Identified in the Project Area - Sightings Recorded during Seismic Surveys in Nearby Block C2 112 Table 4.5 Marine Turtle Species Identified in the Project Area- Sightings Recorded during Seismic Surveys in Nearby Block C2 117 Table 4.6 Land Cover Surface 120 Table 4.7 Habitats Concerned by the Reforestation Project in the Study Area 127 Table 4.8 Results of the Flora Survey 130 Table 4.9 Seabird Species Recorded During the 3D Seismic Survey of the Nearby Block 2 in May-June 2012 132 Table 4.10 Reptiles Identified in the Study Area 136 Table 4.11 Mammals Identified in the Study Area 137 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD VI Table 4.12 Fish Species Listed for Mauritania and Listed on the IUCN Red List 142 Table 4.13 Number of Recorded Industrial Fishing Vessels Operating in the Mauritanian EEZ 144 Table 4.14 Most Common Species in Fish Landings 149 Table 4.15 Maritime traffic at Nouakchott Port de 1' Arnitie 156 Table 4.16 Maritime traffic at Port Autonome de Nouadhibou 156 Table 4.17 Administrativ~ Framework of Surveyed Settlements 158 Table 4.18 Population per Municipality in the Study Area 161 Table 4.19 Population per Surveyed Settlement (Approximate Estimate) 161 Table 4.20 Analysis of Artefacts Found within Project Footprint 177 Table 5.1 Impact Characteristic Terminology 181 Table 5.2 Significance Matrix 183 Table 5.3 Impacts Screening Matrix for the Banda Gas Project 186 Table 5.4 Drill Cuttings and Drilling Fluid Volumes (Per Well) 216 Table 5.5 Oil Spill Simulation Scenarios 226 Table 5-6 Oil thickness descriptors 229 Table 5.7 Infield Vessel Collision Frequency Results for the Banda Field 241 Table 5.8 Noise Impact Magnitude for Residential Receptors. Construction Phase 247 Table 5.9 Predicted Construction Noise Levels 248 Table 5.10 Noise Impact Magnitude for Residential Receptors. Operational Phase 252 Table 5.11 Predicted Operational Noise Levels 254 Table 5.12 Increase in Background Noise Levels- Operational Phase 255 Table 5.13 Operational Scenario: Modelled Concentrations of Atmospheric Pollutants and Significance of Impacts on Local Air Quality 260 Table 5.14 Emergency Scenario: Modelled Concentrations of Atmospheric Pollutants and Significance of Impacts on Local Air Quality 265 Table 6.1 Mitigation Measures and Commitments Register- Offshore Drilling and Construction Phase 284 Table 6.2 Mitigation Measures and Commitments Register - Onshore Construction Phase 289 Table 6.3 Mitigation Measures and Commitments Register - Operational Phase 294 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD VII LIST OF ACRONYMS USED IN IRIS DOCUMENT ACE Africa Coast to Europe (optic fiber) AETs Apparent Effects Thresholds AEWA African-Eurasian Waterbirds Agreement ALARP As Low As Reasonably Practicable ARPA Automatic Radar Plotting Aid BID Islamic Development Bank (Banque Tslamique de Developpement) BOD Biological Oxygen Demand BOP Blow-Out Preventer BTEX Benzene, Toluene, Ethylbenzene and Xylenes Centre for Transport Studies for the Western Mediterranean (Centred' Etudes des CETMO Transports pour Ia Mediterranee Occidentale) CFSR Climate Forecast System Reanalysis CLC International Convention on Civil Liability (for Oil Pollution Damage) CMS Convention on Migratory Species COD Chemical Oxygen Demand COLREGs Convention on the International Regulations for Preventing Collisions at Sea COSIM Chemical/Oil Spill Impact Module CR Critical danger of extinction Protected and Coastal Areas Department (Direction des Aires Protegees et du DAPL Littoral) Resources Management and Oceanography Department (Direction de DARO l'Amenagement des Ressources et de l'Oceanographie) DCE Directorate for Environmental Control (Direction du Contr8le Environnemental) DCQ Daily Contract Quantity DHB Department of Crude Oil (Direction des Hydrocarbures Brut) DMM Commercial Shipping Department (Direction de Ia Marine Marchande) Artisanal and Coastal Fisheries Department (Direction des Peches Artisanales et DPAC C8tieres) DPI Industrial Fishing Department (Direction de Ia Peche Industrielle) Pollution and Environmental Emergencies Department (Direction de Ia Pollution DPUE et des Urgences Environnementales) Delegation to the Fisheries Monitoring and Control at Sea (Delegation aIa DSPCM Surveillance des Seches et au Contr8le en Mer) E&S Environmental and social EBS Environmental Baseline Survey EEZ Exclusive Economic Zone EFL Electrical Flying Leads EHS Environment Health and Safety EIA Environmental Impact Assessment EMP Environment Management Plan EMS Environmental Management System ERM Environmental Resources Management ERRV Emergency Response Rescues Vessel ESIA Environmental and Social Impact Assessment FAO Food and Agriculture Organization HC Hydrocarbon HFL Hydraulic Flying Leads HP High Pressure IBA Important Bird Area ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD VIII ICSS Integrated Control and Safety System IFC International Finance Corporation IFC EHS Environmental, health and safety guidelines issued by th~ International Finance Guidelines Corporation The International Finance Corporation's Performance Standards on Social & IFCPS Environmental Sustainability (current version at the date of issuing of this report is dated 01 January 2012) IMO International Maritime Organisation Mauritanian Institute for Oceanographic Research and Fisheries (Institut IMROP Mauritanien de Recherches Oceanographiques et des Peches) IPECA International Petroleum Industry Environmental Conservation Association ITCZ Inter Tropical Convergence Zone IUCN International Union for Conservation of Nature LP Low Pressure MBBR Moving Bed Biological Reactor Ministry for Environment and Sustainable Development (Ministere de MEDD l'environnement et du developpement durable) MEG Monoethylene Glycol MMI Mauritanian Investment Group MMscfd Million standard cubic feet per day MODU Mobile Offshore Drilling Unit MOU Memoranda of Understanding MP Medium Pressure Ministry of Fisheries and Maritime Economy (Ministere de la Piche et de MPEM l'Economie Maritime) MPEM Ministry of Oil, Energy and Mines (Ministere du Petrole, de l'Energie et des Mines) MSV Multi-purpose Support Vessel NADF Non-Aqueous Drilling Fluid NCEP National Centre for Environmental Prediction OGP International Association of Oil & Gas Producers (former E&P Forum) ONS National Office for Statistics (Office Nationale des Statistiques) OPRC Oil Pollution Preparedness, Response and Co-operation OSCP Oil Spill Contingency Plan Convention for the protection of the marine environment of the North East OSPAR Atlantic OSRL Oil Spill Response Limited PAH Poly Aromatic Hydrocarbons PANE National Action Plan for the Environment (Plan d'action national pour l'environnement) PANPA Nouakchott's Autonomous Harbor (Port de l'Amitie) PEC Predicted Environmental Concentration PLET Pipeline End Termination POPs Persistent Organic Pollutants PSC Production Sharing Contract ROV Remote Operated Vehicle RPS RPS Group, Environmental Consultancy SANS South African National Standards SBM Synthetic Base Mud SCM Subsea Control Module SMH Mauritanian Hydrocarbons Company (Societe Mauritanienne des Hydrocarbures) National Strategy for Sustainable Development (Strategic Nationale de SNDD Developpement Durable) SO LAS Safety Of Life at Sea ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD IX SOPEP Shipboard Oil Pollution Emergency Plan Electricity from Gas Production Company (Societe de Production d'Electricite a SPEG partir du Gaz) STCW Standards of Training, Certification, and Watch keeping for seafarers SWRI Short Wave InfraRed THC Total Hydrocarbon Content TOES Tullow Oil Environmental Standards TOP Take Or Pay TOR Terms of References TSS Total Suspended Solids UNCLOS United Nations Convention on the Laws Of the Sea UNEP United Nations Environmental Programme USAID United States Agency for International Development USEPA United States Environmental Protection Agency UTM Universal Transverse Mercator voc Volatile Organic Compound WBF Water-Based Fluids WHO World Health Organisation WTN Waste Transfer Notes ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD X Project proponent It was developed with a view to comply with the regulatory requirements of Mauritania and Tullow Petroleum Mauritania Pty Ltd (Tullow), a Tullow's corporate environmental and social 100% subsidiary of Tullow Oil Plc, proposes to management standards. International best develop the Banda gas field, offshore Mauritania practice, in particular the International Finance in Block PSC (Production Sharing Contract) A. Corporation's Performance Standards (2012), were also considered in developing this impact Tullow Oil Plc is an independent oil and gas assessment. exploration and production company, headquartered in London. Proposed project Field history The Banda field was discovered in 2002 and appraised by the then operator Woodside and the subsequent operator, Petronas. Tullow acquired operatorship of the field in November 2011. This field is located approximately 55 km off the Mauritanian coast, 20 km to the east of the Chinguetti field, currently under production by Petronas. Environmental impact assessment (EIA) An EIA is a systematic process that predicts and Project overuieiP evaluates the potential impacts a proposed project The Banda gas development will constitute an may have on aspects of the physical, biological, important milestone in Mauritania's oil and gas socio-economic and human environment. It also history, as it will be the first offshore development documents the mitigation measures to be to bring Mauritanian hydrocarbons to the shore. implemented to eliminate or reduce adverse impacts and, where practicable, to enhance It will involve the drilling and installation of two benefits. gas production wells, and their connection to an onshore gas processing facility, via a sub-sea There is a Mauritanian regulatory requirement for pipeline. The processing facility will be located at oil and gas developments to undertake an EIA approximately 9 km to the north of the city of and to report the findings to the Direction du Nouakchott. Controle Environnemental (DCE) of the Ministere de l'environnement et du developpement durable. Once processed to the required specification, the gas will be flowed to a nearby power station, to be This EIA was developed from June 2012 to April developed, owned and operated by a consortium 2013 by Environmental Resources Management called SPEG (Societe de Production d'Electricite a (ERM) an independent international sustainability partir du Gaz), jointly owned by the Government consultancy, in collaboration with Mauritanian of Mauritania, Somelec, SNIM, and international consultants Mr. Amadou Ba and Mr. Moustapha mining company Kinross. The proposed power Ould Taleb. station will provide energy for domestic and industrial customers within Mauritania as well as potential power export capabilities to neighbouring countries. The power generation project and associated transmission infrastructure are being developed separately by SPEG, and are not covered in this document. 0-1 Project overview ~[A ~overs ~be Mrd~ ~as upstre~rrt, :' . · Puits de production de gaz proposes .,,,.. ~lop~ent,fr&,rnth~i~~§'produc;~·ron:x&~!ls t~e !g - Trace du pipeline sous-marin propose Trace du pipeline terrestre propose ~~~~::~~~!:'~JivlL~...:TAL RFSOLRCCS \'1A\!ACFI'v11"'\iT TU.J.O\Y (\.li\U111AC\Iil) PrY Lm 0-4 The proposed pipeline crosses over the existing • environmental enhancement activities, with African Coast to Europe (ACE) subsea the recent planting of vegetation to establish a communication cable. "green belt" around Nouakchott. Pictures taken during the biodiversity and socio- The proposed pipeline will cross under the economic baseline surveys existing Nouakchott-to-Nouadhibou highway. Four important development projects were identified within the vicinity of the onshore component of the Project: • the proposed SPEG power plant adjacent to the gas plant; • the new university (under construction), 3 km to the southwest of the proposed gas processing facility; • the new airport (under construction), located approximately 20 km to the north of the proposed gas processing facility; and • a proposed tourism/residential development located between the coastline and the highway. In terms of cultural heritage, neolithic artefacts (mainly pottery fragments) were found within the Project footprint. These are relatively common at a regional level. No site of significant cultural or historical value was identified within the Project footprint. Onshore baseline oueruiew The onshore component of the Project is located Assessing and managing impacts on mostly undeveloped land, 5 km north of the lVIanaging offshore constmction impacts edge of the city of Nouakchott. The natural The majority of the impacts from the drilling, habitats within the plant layout and the pipeline completion, installation and commiSSIOning route were not found to be of particular activities were assessed as being Negligible or environmental sensitivity at a regional scale. Minor. There are no land users directly within the Project • Only the potential impacts resulting from an footprint; nearby housing (along the highway) unlikely spill of hydrocarbons at sea were were identified as mainly temporary and not assessed as Moderate. These would be relying on land for livelihoods. associated with an accidental loss of fuel from the mobile offshore drilling unit and / or the The EIA identified several usages of the area supply vessels used in the drilling, subsea generally located within 15 km north of installation or pipelay phases. As the drilling Nouakchott, encompassing the proposed Banda activities are only targeting gas, an oil spill site: associated with a loss of well control was not • some livelihood activities (herds of camels considered as a potential impact from this grazing within the area and crossing it Project. between Nouakchott and more remote In the unlikely event of a large diesel spill, locations; shell extraction in the dunes for Tullow' s proposed emergency response usage as construction material); procedure would likely prevent the majority of diesel reaching the shoreline. This was verified • some very sparse residential housing, with a in the ESIA through modelling of spill limited number of permanent buildings (only dispersion, weathering processes, distance to one shed identified within the pipeline shore, and travel time of the spill. exclusion zone) and a villa 300m south of the pipeline landfall point; and • Drilling activities will occur at a distance of 55 km away from the coast and are not expected to cause any significant impact on other sea users (navigation, fishing). [!T\.!VJRO>JkTl:'NTAL REStJt:RCES MAl\ACt'lvli-:\:T Tt:t.LOW (VIAt:RII ell;! A) FTY Ln.> 0-5 • Drilling and completion fluids will be selected infrastructure on both sides will prevent taking into account its concentration, toxicity, intentional or accidental damage to it. bioavailability and bioaccumulation potential with selection based on least environmental Conclusion potential hazard. In this EIA, no impacts were identified, that could • Liaison with other sea users and presence of not be avoided or reduced to acceptable levels fisheries liaison officers onboard the Project through the application of the proposed vessels will contribute to manage the impacts mitigation measures described in the associated with the nearshore pipelay Environmental Management Plan. activities. Environmental management plan (EMP) • The crossing of the existing ACE subsea The Project committed through the EIA to a communication cable will be managed in a conventional manner providing physical number of measures designed to mitigate adverse separation between the pipeline and the cable ' impacts and ensure benefits are delivered. These in coordination with the cable operator. are compiled in the EMP which defines the actions that will be taken for each phase of the 1\!Ianaging oushore construction impacts development. All onshore construction impacts were assessed as Negligible or Minor. In addition to the Project's EMP, specific • Construction noise contribution predicted procedures will be prepared prior to the start of through noise modelling did not identify any the construction activities: significant impacts according to international • a vessel emergency oil spill contingency plan; standards. • an onshore oil and chemical spills prevention • Potential archaeological finds will be managed and contingency procedure; in coordination with the Institut Mauritanien • a waste management plan; des Recherches Scientifiques. No burial site is • a maritime and fisheries liaison procedure; expected to be found within the Project • an archaeological chance finds procedure. footprint. • Crossing under the Nouadhibou road will be The implementation of the EMP will be managed in coordination with the Transport monitored by the Mauritanian authorities. authorities. Stakeholder engagement 1V1anaging operational impacts Stakeholder engagement activities started during Only the impact resulting from the pipeline the scoping stage of the Project and ran exclusion zone was assessed as Moderate. The throughout the EIA. The objective was to ensure presence of this 0,68 km2 exclusion zone creates that sources of existing information and expertise an additional constraint in a suburban area. are identified, legislative requirements are met and that stakeholder concerns and expectations In response to stakeholder concerns regarding the are addressed. 26 consultation meetings were held proximity of the proposed plant to some sensitive with stakeholder groups or organisations from receptors, such as the new university of Nouakchott and coastal communities in July 2012 Nouakchott currently being built 3km south west, and between November 2012 and February 2013. operational noise and air quality impacts were A public consultation meeting attended by nearly assessed in detail. 60 representatives of ministries, local • Operational noise contribution predicted governments, fishermen unions and Non- through noise modelling did not identify any Governmental Organisations was held on 201h significant impacts ·according to international March 2013 in Nouakchott. standards. Next steps • CO, N02 and PM1o concentrations modelled at the nearest receptors for operations and In accordance with the Mauritanian EIA emergency scenario accounts for less than 5% regulations, the EIA Report was submitted to the of the air quality standards set by the IFC DCE to obtain an avzs de faisabilite guidelines. environnementale. This submission will be • Physical monitoring of the trenched pipeline followed by a public enquiry designed to provide and a 60 m exclusion zone with no permanent all interested parties with an opportunity to understand and comment on the EIA. E~VlRONivltNTAr. RESOliR<:F5 iV1ANACFiv1E.\lT T\ 'I.I.OW (\,L\I.Rll c\', single 1(¥" II no 160 140 'C 120 l1oo E 80 ~· ~ 60 "' ~ 40 2.0 0 0 5 10 15 2.0 Time, years 1 Well Potential · · · · · · 2. Welts Potential 3 Wells Potential Daily Gas Production DCQ: Daily Contract Quantity. Multiplied by 365 it provides an annual ceiling for seller's obligation to deliver TOP :Take or Pay. Buyer's obligation to pay a minimum equivalent to the ToP even if actual nominations are lower 3.1.4 Schedule Table 3.1 presents the proposed Project schedule. The activities listed within this schedule are discussed in more detail the following sections. The drilling programme is planned to commence in the third quarter (Q3) of 2015, with upstream facilities ready to produce first gas early Q1 2016. The schedule may change, depending on the duration of the project approval process, fabrication times of various elements, and the availability of drilling and specialist construction vessels. Table 3.1 Proposed Project Schedule ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 39 3.1.5 Project Activities The Banda Gas development project will be undertaken in the following phases: • Offshore Drilling and completion will involve drilling the two wells to their total depth, installation of the sandface completions and production Xmas trees, and the preparation of the wells for production. • Subsea installation will involve the installation on the seabed of the manifold, the tree and manifold protection structures, jumper spools, and the laying of the pipeline and umbilical to shore. • Onshore construction will involve site clearance, materials transfer, construction activities for the gas plant and the laying of the onshore sections of the pipeline and umbilical. • Commissioning activities will_involve cleaning, checking, testing installed equipment to verify functionality prior to start of production. • Operation will include processing and production of hydrocarbon products for export to end users. • Decommissioning activities will be undertaken at the end of the field life. Each of these activities is described in greater detail in the following sections. 3.2 DRILLING AND COMPLETIONS 3.2.1 Well Locations The two Banda gas production wells will be drilled from a single drill centre. The nominal locations of the Banda gas wells and production manifold are provided in Table 3.2. The final spud locations may deviate from the proposed well locations as part of ongoing detailed engineering studies. The wells are located in water depths of approximately 230 m. Table 3.2 Proposed Well Locations ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 40 3.2.2 Drilling Vessel A moored semi-submersible Mobile Offshore Drilling Unit (MODU) will be used to drill and complete the planned two wells from a single drill centre. Moored MODUs are typically secured to the seabed using eight anchors and ballasted to a predetermined depth to maintain stability. Figure 3.3 shows a typical moored MODU, the Byford Dolphin. The MODU will be surrounded by a 500 m temporary safety exclusion zone. Additional services will also be provided such as cementing and pumping with dedicated bulk and fluid storage. The MODU will also be equipped with tanks for drill water, potable water, fuel and machinery oil storage. The main deck will be sufficient to provide racked stowage for drilling pipe and casing as well as providing an area for pre-checks of subsea Christmas trees and an area for a well clean-up package. The MODU will also include personnel accommodation. Figure 3.3 Typical third generation MODU, Byford Dolphin Source: Dolphin Drilling 3.2.3 Schedule Drilling is expected to take place in Q3 and Q4 2015. It is assumed that it will take up to approximately 45 days to drill and complete each well. Mobilisation of the MODU is expected to take 10 days; however, the timing may change depending on the vessel location at time of hire. Demobilisation of the drilling vessel may take up to approximately 10 days. 3.2.4 Drilling Process Description Drilling for oil and gas uses a rotating drill bit attached to the end of a drill pipe (the' drill string') to bore into the subsurface to reach trapped oil and/ or ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 41 gas. The first stage of drilling is to drill the well top hole, following which a conductor casing is lowered into the hole and cemented into place. The second well section, known as the surface section, is then drilled using a smaller drill bit and the surface casing lowered and cemented into place. At this stage a Blow-Out Preventer (BOP) and marine riser are installed onto the well. The marine riser connects the well to the MODU forming a closed loop system. Once in place, drilling continues using a series of progressively smaller diameter drill bits and casings as the well is drilled deeper. The casings are lowered down the hole through the previous larger diameter casing section and cemented into place. The rotating drill bit breaks off small pieces of rock (called drilling cuttings) as it penetrates rock strata. The cuttings typically range in size from clay to coarse gravel, and their composition will vary depending on the types of sedimentary rock penetrated by the drill bit. Drilling fluid, also known as drilling mud, is pumped down inside the drill string to lift the cuttings from the bottom of the well to the surface (see Figure 3.4). Additionally, the purpose of the drilling fluid is to maintain positive pressure in the well, to cool and lubricate the drill bit and to protect and support the exposed formations in the well. More information on drill cuttings and fluid is provided in Section 3.2.6. Figure 3.4 Circulation of Fluid during Drilling Formation being drilled Source: OGP 2003 3.2.5 Well Design The two Banda Gas wells will be simple' slant' wells of similar design and will be drilled from within 100 m of a single drill centre. A preliminary well design schematic is shown in Figure 3.5. The depth and section lengths for both of the gas wells are presented in Table 3.3. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 42 Figure 3.5 Well Schematic Diagram Mean Sea Level (25.00 m) 256.00 m TOC Mud Line [256,50 m) 334.00 m 36" Conductor Casing 365,76m 500.00 mTOC 1052.70 m 20", [171/2'1,202.000 ppf, X-60, Surface Ca~ing Connection: Swift DW-2 13 3/8'~ (17 1/2'1, 68,000 ppf. l-80, Surface Casing Connection: Vam Top 2450,00 m TOC 3450.95 m 9 5/8", (121/4'1, 53.500 ppf, l-80, Production (a$ing 3529.85 mTOC 7 5/8" Production liner 3529.B5m Table 3.3 Proposed Designs of the Banda Gas Wells Jet in 36" conductor 334 78 334 78 171/2 13%" casing 1,052 718 1,052 718 12% 9%" casing 3,426 2,374 3,055 2,003 81/2'' 7%" production liner 3,529 103 3,077 22 3.2.6 Drilling Fluids and Cuttings The first two sections will be drilled 'riserless' (ie without circulating drilling fluids from the MODU to the well), using seawater and 'sweep pills' (1). Cuttings from these sections will be discharged to the seabed. For the subsequent sections, a marine riser will be installed, allowing the fluids and cuttings to be returned to the MODU. At this stage, drilling will continue with (1) A relatively small volume of viscous fluid, typically a carrier gel, that is circulated to sweep, or remove, debris or residual fluids from the circulation system. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 43 either water bas.ed mud (WBM) or an improved synthetic based mud (SBM) for the remaining well sections. Fluids and cuttings returned to the MODU will be separated and cleaned using shale shakers. Shale shakers typically consist of large, flat sheets of wire mesh screens of various mesh sizes that shake cuttings across and off the screens as the drilling fluid flows through them and back into the drilling fluid system. For both types of drilling fluids (WBM and improved SBM), a variety of chemicals are added to the water or non-aqueous liquid to modify the properties of the fluid. Additives include clays and barite to control density and viscosity and polymers such as starch and cellulose to control filtration. The proportion of typical components in drilling fluids is shown in Figure 3.6. The type of drilling fluid used for a particular well or drilling programme will depend largely on the technical requirements of the well, local availability of the products and the contracted drilling fluid supplier. Figure3.6 Typical Additives in Drilling Fluids (a) Water based muds (a) Improved synthetic based muds Source: OGP 2003 NAF : Non Aqueous Fluid Improved SBMs are often required for particular well sections as they offer better well stability (particularly when drilling through water-sensitive formations such as shales). They also offer better lubricity and high temperature stability and reduce the formation of gas hydrates. In addition, using improved SBM results in more efficient drilling, fewer drilling problems and requirement for remedial work, thereby reducing the potential for health and safety risks. If improved SBM are used, Tullow is purposing the use of TOTAL Special Fluids EDC 99-DW, which is categorised as Group III on the OGP categorisation system having an aromatic content of 0.00005% and PAH content of 0%. Cleaned cuttings will be discharged overboard while the drilling fluid will be recycled and ultimately returned to the supplier. However, a portion of the drilling fluid usually adheres to the cuttings discharged to sea. The amount ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 44 will depend on the equipment used, but is generally in the region of 5% to 10% by weight. Estimated drilling wastes (discharged fluids and cuttings) for both gas wells are presented in Table 3.4. Table 3.4 Estimated Drilling Wastes 3.2. 7 Cement and Cement Chemicals Well casings will be cemented into place to provide structural integrity of the well and also to aid the drilling process. Cement slurries will be used to fill the annulus between the outer face of the casing and the wall of the formation. This is achieved by pumping the slurry down the drill string to the bottom of the section casing which then passes back up through the annulus between the casing and the formation. The cement slurry remaining within the casing is displaced with drilling fluid. After the cement within the casing is displaced the pumping stops and the slurry is allowed to set. To ensure the annulus is filled with quality cement it is common to pump down 100% excess for the first two sections with the excess discharged to the seabed. Following the installation of the riser the cement slurry will be circulated between the well and MODU. It is estimated that approximately 120 m3 of cement slurry will be discharged to sea for each well. The slurry will consist primarily of cement and freshwater with small quantities of chemicals to accelerate or delay the setting time, adjust the viscosity and minimise foaming. 3.2.8 Well Completions Once the well has been drilled and cemented, a process known as 'well completion' is undertaken to prepare the well for its operational function (ie gas production). The well completion consists of two parts: the lower completion and the upper completion. The lower completion refers to the portion of the well across the reservoir. For Banda Gas the plan is to complete this section using gravel pack to prevent sand flowing with the gas during production. The upper completion is the tubing that is set above the reservoir through which gas and condensate flow from the reservoir and up to the production tree at seabed. The tubing will ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 45 have a safety valve to shut-off production in case of failure of the production tree. Heavy fluids will be used to prevent the inflow of gas and /or condensate into the well during well completion. 3.2.9 Well Clean-up and Flaring Prior to production start-up, the drilling and completion fluids within the well must first be removed. This is referred to as well clean-up. Well clean-up is typically achieved by injecting nitrogen gas at the bottom of the well to lift the heavy fluids out of the well and thereby initiating an inflow of gas and condensate from the reservoir. As part of this process the returned fluids from the well flow back to the MODU where any gas and condensate are diverted to a disposal flare. Well testing and clean-up is estimated to last for up to approximately 24 hours /well. Once a stable production rate is achieved, the clean-up operation is ended. A well might be tested further during well shut-in. There will be no flaring of gas production effluents other than for well clean- up and testing. 3.2.10 Support Operations An estimated two supply vessels runs per week will be used to transfer materials (mud, casings, tools and water) from the onshore supply base to the MODU. Tullow will use an existing onshore support base located at the Port of Nouakchott, located at approximately 62 km northeast of the Banda field (Figure 3.7). The base has been in operation since 1986 and its lease has been transferred from its former contracting party (Petronas) to Tullow. Figure3.7 Aerial View of Port ofNouakchott ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 46 The facilities are located at a new quay at the Port of Nouakchott: Area 1 and Area 2 on Figure 3.7. Area 1 encompasses three warehouses with a total storage capacity of 3,425 m3, an office unit, a yard and a chemical decanting area. Area 2 encompasses a storage yard, a mud plant chemical storage shed, and concreted laydown areas. Pictures of the facilities at the Port of Nouakchott before Tullow's works are presented in Figure 3.8. Staff transfers between Nouakchott and the Banda field will be via helicopter. A typical offshore support helicopter is shown in Figure 3.9. It is estimated that up to two helicopter trips a day will be required during the drilling phase. 3.2.11 Personnel The number of personnel on the MODU will fluctuate between 60 and 110 depending on its operation (eg mobilisation, drilling, etc.), with approximately 95 during drilling, ramping up to 110 during completion operations. The onshore support base will be manned by about 10 dedicated personnel and a further 20 personnel will be required for logistical operations. The percentage of locally employed workforce will be approximately 5% for the MODU, 90% for the support base, and 25% for the logistics operations. Figure 3.8 Tullow's Facilities at Port of Nouakchott Former Cement Plant ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTYLTD 47 Figure 3.9 Typical Support Helicopters 3.3 SUBSEA INSTALLATION 3.3.1 Development Overview The subsea field configuration is shown in Figure 3.10. The two gas-producing wells will be connected by jumpers to a single manifold. Production from the wells will be transported from the manifold to the onshore gas plant via a gas pipeline. Definitions of subsea equipment terminology are provided in Box 3.1. The production manifold, jumpers, PLET, pipeline and umbilical will be designed to international standards. Box 3.1 Subsea Equipment: Definition of Terms ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 48 Figure 3.10 Proposed Subsea Configuration Shoreline 6" HFL ACE Cable I "' landfall wellsiot Site Gas Plant """ 73.8 km Power Gas Manifold ! I l Umbilical I 111Iii ! . - g;:_4·~~~. 1 'T \ ·- Jk_.--~ 2 x EFls L.,L.-1.-\-·- wellslot \ EPU . MCS UPS Control Room Offshore Abbreviations: EFL: Electrical Flying Leads; HFL: Hydraulic Flying Leads; PLET: Pipeline End Termination; ENVIRONMENTAL RESOURCES MANAGEMENT TULWW PETROLEUM (MAURITANIA) PTY LTD 49 3.3.2 Manifold A new 4-slot manifold will be installed in the field to serve as a gathering point for produced gas and distribution point for well services. Initially only two slots will be required for the project requirements, two spare slots will provide for future tie-ins. All the production valves on the manifold will be operated by a Remote Operated Vehicle (ROV) with only a single hydraulic valve controlling the injection of corrosion inhibitor. The manifold will be constructed using corrosion resistant piping and installed on a permanent foundation structure in order to provide a stable base. A protective structure will also be installed over the manifold to protect it from fishing activities and dropped objects. The protective structure will be designed to be" over-trawlable", such that it provides the optimal protection from trawling nets to the manifold, whilst presenting minimum risk to fishing activities in the area. The Banda Gas manifold will be installed by a multi-purpose support vessel (MSV) equipped with a suitable crane and remotely operated vehicle (ROV) facilities. The manifold base will be lowered to the seabed first and secured using suction piles. The manifold module will then be lowered onto the base frame and secured to the manifold base. 3.3.3 Production Wells A subsea production tree (commonly termed 'Christmas tree') will be installed on to each of the two wellheads. Each tree will carry control and monitoring equipment including a choke and a Subsea Control Module (SCM) for the operation and control of gas flow from the well. The trees will connect to the manifold with flexible jumpers. The trees will be installed from the MODU during the drilling and completions phase. 3.3.4 Jumpers and Flying Leads Flexible jumpers will be used to connect the subsea production trees to the manifold, and the manifold to the PLET. The jumpers and control flying leads will be installed by the MSV. They will be lowered to the seabed in a basket and the connections at each end will be pulled into place by a Remotely Operated Vehicle (ROV). All connections made subsea will be leak tested. 3.3.5 Pipeline Produced gas will be exported to shore via a 75 km long, 10 inch (25.4 em) subsea pipeline and a further 5.6 km by an onshore pipeline to the gas plant. The pipeline will be trenched, or protected by rock-dump for sections where trenching is not possible. The Banda field end of the pipeline will be terminated by a Pipeline End Termination (PLET). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTYLTD 50 The nearshore section will be trenched using back-hoe dredgers or other specialist trenching equipment and the offshore section will be trenched using a specialist trenching vessel to limit the risk of damage to fishing vessels. The pipeline will be installed by two pipe-laying vessels supported by a survey vessel. The shallow water pipe laying vessel will start at the shore end and lay the nearshore section (approximately 15 km). The deepwater pipe laying vessel will then continue to lay the pipeline from the nearshore section to the PLET (approximately 60 km). Rock dumping may be required for the approximately 12 km length of pipeline where trenching may not be possible as a result of hard substrate and/ or rocky outcrops. Installation of the rock will be either by the single- pass or multi-pass method using a dynamically positioned flexible fallpipe vessel. A pre-lay and post installation survey will also be undertaken to confirm position and target of the rock dump and to verify successful completion of work. The surveys and fallpipe positioning during the installation will be by a remote operated vehicle (ROV) attached to the lower end of the flexible fallpipe. It is envisaged that the rock material will be trans- shipped from Europe to Las Palmas, Canary Islands. 3.3.6 Subsea Control System The system will be controlled by a subsea control system operated from the onshore control room in the gas plant via a subsea umbilical. A new 75 km umbilical will be installed from the onshore umbilical connection to the manifold, where services are distributed to the wells using individual flying leads. The umbilical will provide electrical power and communications and hydraulic control fluids to the control modules on the subsea trees: it will also supply methanol, MEG and corrosion inhibitors to the wells. The umbilical will either be trenched or laid into in the same trench as the pipeline. Any untrenched sections will be protected using concrete mattressing. The umbilical will be laid alongside the gas pipeline either in its own trench or within the same trench as the pipeline using similar installation methods. The subsea control system will operate safety valves installed downhole in the wells, safety and control valves on the tree, and will also gather data on gas flow, pressure and temperature The control system utilises dual redundancy to maximise reliability and will be fully integrated into the gas plant control and safety system. 3.3.7 Seafloor Footprint The area of seafloor directly concerned by the installation of the subsea infrastructure will be approximately 750,600 m2. Seafloor disturbance will be caused by the installation of subsea production facilities, such as the manifold, ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 51 Christmas trees, umbilical and pipeline. The largest disturbance will be as a result of the trenching and rock-dumping operations. A summary of the subsea facilities and its expected footprint on the seafloor is provided in Table 3.5. Table 3.5 Estimated Seafloor Footprint of the Banda Gas Development Trench: • Pipeline (1) • Umbilical (1) 3.3.8 Vessel Requirements and Support Operations Tullow's onshore base at Nouakchott, used during the drilling and completions phase, may be retained for use by installation contractor during subsea installation. A summary of the vessels required and their purpose for the installation phase of the project is provided in Table 3.6. Table 3.6 Vessels Required for the Installation Phase Mutli-Purpose Support 40 Installation of manifold, pipeline and 41 Vessel (MSV) Xmas tree tie-in, support testing and commissioning Trenching/Pipelay Support 60 Trench pipeline, back-fill trench 71 Vessel Pipelay Vessel 120 Lay offshore pipeline 30 Rock Dumping Vessel 30 Rock dumping onto un-trenched 45 pipeline sections Umbilical Installation Vessel 60 Lay umbilical into pipeline trench 25 Shallow Water 100 Lay nearshore sections (15 km) of 52 Pipelay /Umbilical Vessel pipeline and umbilical Nearshore Dredging Vessel 100 the nearshore trer:tch sections 115 All construction and support vessels used by the project will be operated in compliance with their classification standards. Specialist vessels with ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY L TO 52 experienced crews will be required for the installation of the infra~tructure. Staff transfers will continue to be by helicopter. 3.3.9 Personnel Requirements The installation vessels will be manned as indicated in Table 3.6, giving a total number of offshore personnel of 510. The onshore support base and logistically operations will be the same as during the drilling and completions phase (10 and 20, respectively). It is envisaged that most offshore personnel will be expatriate workers. 3.4 ONSHORE INSTALLATION 3.4.1 Overview An onshore gas plant will be constructed to process the produced gas from the Banda field. The onshore gas plant will be located approximately 9 km north of Nouakchott and approximately 6 km inland. Onshore land take is likely to be in the order of 400 m x 325 m for the terminal within a 1 km x 1 km plot which includes the adjacent power plant. Location of the proposed onshore gas terminal is shown in the figure below. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 53 Figure3.11 Pipeline landfall and plant location Proposed landfall Proposed gas pipeline - Proposed onshore pipeline Banda Gas Mauritania Proposed power plant site Proposed gas processing facility Pipeline Landfall and Plant Location _\ N Oc5 1 km ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 54 3.4.2 Onshore Pipeline and Umbilical A 10-inch carbon steel with polyethylene coating pipeline will transport gas for 5.6 km from the offshore pipeline landfall to the onshore gas plant. An umbilical will be laid alongside the gas pipeline within the same trench. Once the umbilical has been laid the trench will then be backfilled. The pipeline and umbilical will cross under the Nouakchott -Nouadhibou road at 16°0'42,921"W 18°11'1,823"N which corresponds approximately to PK 9 on the Nouakchott -Nouadhibou road. 3.4.3 Gas Plant Facilities Figure 3.12 presents the provisional plan of the onshore gas plant. The plant will be designed to condition 65 MMscfd gas to provide fuel gas to an adjacent power station (operated by SPEG). The plant will include a three stage separation process (high pressure, medium pressure and low pressure) with direct gas export and export of stabilised condensate via tankers from a tanker loading area. Treated water discharge will be used for irrigation or may be exported to the adjacent power plant. The plant process description is provided in Section 3.5.1. Figure 3.12 Provisional 3D Site Plan Diesel Storage & Other Utilities Operations & Adminstration Building Closed Tanks Oil/Water Separator Warehouse Produced Water Treatment & Off Spec Tank Flare Stack Condensate Storage Compression In addition to the main processing facilities, the plant will provide utilities to support its operation, including LP fuel gas, flare system, instrument air, nitrogen, chemical injection, methanol, MEG regeneration, produced water treatment, service water and power generation. The subsea control system ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 55 will also be based at the gas plant. Key plant utilities are further described in Table 3.7. Table 3.7 Main Gas Plant Utilities LP Fuel Gas A small proportion of the treated gas will be used for onsite power generation, the HP /LP flare pilots and purges, and as blanket gas for the glycol flash drum. HP / LP Flare High pressure (HP) and low pressure (LP) will be used for the safe disposal of hydrocarbon gases released from the processing facilities during operation or under emergency conditions. The HP flare system will collect discharges from equipment with pressure >10 barg and the LP flare system from equipment with pressure <10 barg. Instrument Air The instrument air system provides a supply of compressed, atmospheric dry air to various control and ESD valves. A fraction is used for nitrogen generation for blanketing/ inerting and plant air for operating air-driven power tools. Nitrogen Nitrogen system provides nitrogen for tank blanketing and equipment/ piping purging and inerting during maintenance and start-up. Closed and The closed drains are used to gravity drain any hydrocarbon or hazardous Open Drains drains from equipment during maintenance and is hard piped. The open drains system is provided to collect potentially contaminated run-off and rain/wash water from curbed and paved areas of the site via gravity flow. Open drains are collected in gullies and sent to unit swales. Non-hazardous open drains (oil-free) are sent directly to the evaporation ponds. Hazardous open drains (containing oil) are sent to an Oily Water Treatment Unit for oil removal prior to disposal to the ponds. Chemical System includes corrosion inhibitor which is injected continuously into the Injection System subsea pipeline at the manifold to minimise the rate of corrosion. Methanol Methanol will be pumped down the umbilical and injected subsea at the trees for hydrate inhibition (during start-up only) and remediation (breakup). MEG The Glycol (MEG) system will provide lean glycol for injection Regeneration into the subsea production system for the gas producing wells. The primary purpose for MEG injection is to suppress hydrate and ice formation during low temperature conditions. The MEG tank will be blanketed with nitrogen to prevent air ingress. MEG is returned along with the production gas and regenerated in the gas plant. Produced Water System collects and treats water from the MEG regeneration package to a Treatment quality suitable for its end user. The package will contain a secondary or tertiary treatment process with a settling tank, induced gas flotation unit, and possibly filtration to further reduce the oil content (see Section 3.7.2). Irrigation Treated water will either be disposed of in an irrigation scheme or will be Scheme exported for use in the adjacent power plant. Service Water/ The water is used for plant services and not for human consumption. The Firewater firewater (and foam generators) is used in case of fire. The water will be delivered via road tanker on an intermittent basis to the Service Water Tank. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 56 Power Two gas engine generators with one normally running on LP fuel gas will Generation supply the plant with electrical power. An emergency diesel generator will also be present for black starts and power during shutdowns. Subsea Utilities Various utilities are supplied from the onshore plant to subsea via an (via Umbilical) umbilical containing a number of cores: • Corrosion Inhibitor; • Methanol; Mono ethylene glycol (MEG); Fibre Optic (communications); Electrical Power; High pressure hydraulic fluid; and • Low pressure hydraulic fluid. 3.4.4 Onshore footprint The onshore infrastructures footprint will be 41.1 ha. Ground disturbance will be caused by the installation of the gas plant facilities and the pipeline and umbilical. A summary of the onshore facilities and their expected footprint is provided in Table 3.5. Table 3.8 Estimated Onshore Footprint of the Banda Gas Development • Pipeline • Umbilical 3.4.5 Construction Activities Schedule Construction of the gas plant is expected to begin in Q4 2014 and last for approximately 15 months. Table 3.9 provides a breakdown of anticipated construction activities per month. Table 3.9 Construction Schedule ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 57 Temporary Construction Landtake During construction, temporary land will be needed for worker's accommodation, access roads and site access, laydown areas and temporary infrastructure (eg administration buildings, concrete plant, etc). Once the construction phase is over, all sites will be restored to their original condition. Site Preparation The site preparation phase includes all works necessary to establish the site for the subsequent construction phase including land excavation. During this phase construction infrastructure will be established, such as site access roads, site security fencing and equipment laydown areas. Key works during this phase include site clearance, excavation of the topsoil and surface layers to a depth sufficient to provide firm foundations for construction, installation of drainage works and foundations for the gas plant, developing suitable power and water supplies for the subsequent construction phase, confirming waste management and disposal options and establishing the site perimeter. Gas Plant Construction Construction of the gas plant will be a straightforward operation whereby the plant and associated facilities will be established at the site. Following site ' preparation, foundations will be prepared using concrete from an onsite batching plant. The base case is for the gas plant modules to be fabricated outside of Mauritania and transported to site by road for onsite assembly. Cranes will be used to lift above ground superstructure in place. Excavated material will be used, where possible, for onsite landscaping/ re-profiling. Pipeline and Umbilical The onshore section of pipeline will be trenched along its entire length from the beach tie-in through to the gas plant. Prior to laying the pipeline, the right-of-way will first be graded utilising a combination of hydraulic excavators and dozers (indicative vehicles shown in Figure 3.13). Once grading is complete the pipe joints will be laid out adjacent to the right-of-way using a crawler crane (Figure 3.13). At the same time the pipeline trench will be excavated to depth using hydraulic excavators with the excavated material stored on the opposite side of the right-of-way to the pipe joints. The pipe joints are then welded together to form pipe strings of appropriate length and lowered into the trench using side boomers working in tandem (Figure 3.13). Once complete the pipeline will be inspected, pigged and hydrotested. The onshore umbilical will be laid in the pipeline trench for its entire length and the excavated material will then be used as back-fill to bury both the pipeline and umbilical. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTYLTD 58 3.4.6 Equipment and Utilities A summary of the equipment required for the construction of the onshore gas plant is included in Table 3.10. Photos of indicative pipeline installation vehicles are presented in Figure 3.13. Table 3.10 Construction Equipment Figure 3.13 Indicative Onshore Pipeline Installation Vehicles (b) CAT D8T Dozer (c) CAT TL83 Side Boomer (d) Liebherr HS825HD Crawler Crane ENVIRONMENTAL RESOURCES MANAGEMENT TU LLOW PETROLEUM (MAURITANIA) PTY LTD 59 3.4. 7 Construction Personnel The number of personnel on site during the onshore construction phases is presented in Table 3.9. It is anticipated that a maximum of 90 workers will be onsite at any one time. For the majority of the construction phase the numbers of workers will fluctuate between 20 and 40, with 5-50% local content. 3.5 OPERATIONS 3.5.1 Well Control The subsea system will be controlled from and integrated with the Integrated Control and Safety System (ICSS) of the gas plant. The system will continuously monitored to detect abnormal conditions. The system will be monitored utilising sensors downhole, on the Christmas Trees and in the gas plant. Pressures, temperatures, valve positions and sand production data from the tree will be used to monitor well performance and ensure that production rates from each of the wells are optimised to meet the demand. Sensor outputs will be displayed in the ICSS. Alarms will be triggered should the flow become abnormal. The umbilical will provide electrical power and communications and hydraulic control fluids to the control modules on the subsea trees: it will also supply methanol, MEG and corrosion inhibitors to the wells. , 3.5.2 Gas Plant Process Description Figure 3.14 shows a process diagram for the proposed gas plant. Produced gas will enter the facility and be flashed off in the high pressure (HP) separator, superheated, filtered and exported to the power station. The recovered condensate from the HP separator will be partially stabilised in the medium pressure (MP) separator, heated by an electrical condensate heater and further stabilised in the low pressure (LP) separator. The stabilised product will then be treated in the condensate coalescer to remove any remaining water, cooled and sent to storage. The processed condensate (upto approximately 800 barrels per day [bblj d]) will be exported on a batch basis by road tankers. Any flashed off-gas from the MP and LP separators will be recovered in the flash gas compressor, and fed back to the produced gas stream. Associated water will be recovered in the HP and LP separators and sent for treatment. Injection chemicals (including MEG and methanol) are removed during water treatment, prior to the treated water been sent to a local irrigation scheme. MEG will be recovered from the associated water in a regeneration unit, and recycled for use. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 60 Figure3.14 Typical Process Flow Diagram for the Onshore Gas Plant Gas Gas Gas Export to -..,. Superheater -, fv1etering --p Power Station "' u ., LP Fuel Gas Gas from HP Separator "" to Users Pipeline IJtw f----+ , fvlP Separator Flash Gas +-- Compression 4 .... "'" HC d ... ~ •I MEG/P roduced Water Condensate LP Separator .,... Condensate .. -.. Condensate Storage and Heater Coalescer Export via HCGas Water Rond Tankflr t ! ~ MEG Produced Regeneration ~ -IJtw Water ~~ Irrigation Scheme Treatment ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 61 3.5.3 Personnel Requirements The gas plant is designed to be operated by a limited number of staff. It is envisaged that up to 35 people will work at the plant, this includes rotational positions such as Plant Operators and Control Room Operators. 3.6 DECOMMISSIONING The Banda reservoir is expected to produce for approximately 20 years, through to 2035. The production facilities will have a 25 year design life. The project will be decommissioned at the end of the field life of the Banda reservoir assuming no future development takes place. After cessation of production from Banda (and other future fields producing via the gas plant), it is anticipated that decommissioning will process as follows. • The pipeline will be cleaned and flooded. The tie-in spools will be removed. Pipeline and umbilical sections crossing existing pipelines or cables will be cut and removed. The remaining pipeline and umbilical sections below seabed level will remain in situ. • Well tie-in jumpers will be removed. • Following the recovery of the well completions, the wells will be plugged and abandoned leaving the conductor casings below seabed level. • Fishing protection structures will be removed • The gas manifold and foundation will be removed. • The onshore gas plant will be removed. 3.7 EMISSIONS, DISCHARGES, WASTES AND NOISE 3. 7.1 Emissions to Atmosphere The Banda Gas development will generate varying amounts of air pollutants and greenhouse gas emissions from combustion sources such as generators and thrusters on the MODU, diesel engines on the support and installation vessels and flare emissions from the gas plant. Table 3.11 to Table 3.13 provide estimated emissions for the Project: • Table 3.11 -emissions during offshore activities; • Table 3.12- emissions during onshore construction; and • Table 3.13 - annual emissions during operations. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 62 Table 3.11 Estimated Offshore Emissions During Construction Phase "0 "' ~ § tU bllQJ ·.= ~­ ·~ 0.. ss .... 0 ou ~ 0 ~ ..!:! 3 - .!:> "' ~ .. .QJ "' ;=j [J) Notes: Because the exact vessels to be used for drilling and subsea connects have not yet been contracted, for the sake of this emission inventory, assumed engine sizes have been used based on similar Tullow operations elsewhere. Runtime is based on provisional schedule provided by Tullow. Emissions factors source: Oil&Gas UK. Figures have been rounded to integer. C02e =Carbon dioxide equivalent ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 63 Table 3.12 Estimated Emissions from Gas Plant Construction Phase Table 3.13 Estimated Annual Emissions from Gas Plant Operation PM emission factor: Flare Research Project, Final Report November 1996 All the fuel burned has been assumed as CH4. 3. 7.2 Liquid Wastes Offshore Discharges to water that will arise from the Banda Gas development, along with estimated volumes and treatment systems, are discussed below and summarised in Table 3.14. Offshore discharges will result from the following activities: • Drilling. MODU and support vessel operations during the drilling phase will result in routine discharges to sea (see Box 3.2). In addition; non- routine discharges will include drill cuttings and fluid. WBM will be used for the two top sections and drilling fluid and cuttings will be discharged to the seabed. The lower well sections will be drilled using either WBM or improved SBM. The MODU will use solid control equipment to treat cuttings prior to disposal. For the purposes of this EIA it is assumed that improved SBM will be used. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 64 • Completions. MODU and support vessels operations during well completions will result in routine discharges and non-routine discharges including returned completion fluids. Completion fluids will include completion brine, earth filter aid, surfactant and surfactant boosters. • Installation and Commissioning. Installation vessels will make routine discharges during operations. In addition, commissioning fluid will be discharged when the pipeline is dewatered (ie water is pumped out) and the umbilical is commissioned. • Operations. Offshore operational discharges are likely to be limited to hydraulic fluid associated with subsea valve operation. Box3.2 Expected Routine Discharges from Offshore Operations ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURIT ANI~) PTY LTD 65 Table 3.14 Expected 1,-iquid Discharges during Offshore Drilling and Installation Routine Discharges from Offshore Activities Black water Treat with approved Variable depending on number of people on vessels. • No discolouration of surrounding water MARPOL marine sanitation unit. Estimated 1001 per person per day. • < 1 mg/1 chlorine concentration Annex IV Maceration and Drilling and completions: 11,000 lf d chlorination. Subsea installation: 45,000 lf d Grey water Remove floating solids Variable depending on number of people on vessels. • No visible floating solids or discolouration MARPOL Estimated 220 l per person per day. of surrounding water Annex IV Drilling and completions: 24,000 1/ d Subsea installation: 99,000 1/ d Food waste Macerate Variable depending on number of people on vessels. • Ground to pass through a 25-mm mesh MARPOL Estimated 1 kg per person per day. • Discharge more than 12 nautical miles from 73/78 Drilling and completions: 110 personnel, 110 kg/ d land AnnexV Subsea installation: 450 personnel, 450 kg/ d Bilge water Oil-water separation Bilge water generation variable, depending upon • 15 mg/1 of oil concentration and 20 mg/1 MARPOL facility and vessel characteristics, discharge volume (monthly weighted average) oil water 73/78 variable. threshold Annex I MODU: 32 m3per week Support vessels: 110 bblf d (estimated) Ballast water Oil-water separation Variable depending on vessel and need for storage • No free oil MARPOL displacement. • 15 mg/1 of oil concentration and 20 mg/1 73/78 MODU: Estimated 620 bbl per day (monthly weighted average) oil water Annex I threshold • Ballast exchange at least 200 nm from nearest land in > 200 m water. Deck drainage Oil-water separation Deck drainage water generation variable depending • MARPOL on facility and vessel characteristics and rainfall • 15 mg/1 of oil concentration instantaneous 73/78 amounts; discharge volumes variable. reading oil water threshold Annex I • 20 mg/1 (monthly weighted average) oil water threshold. ~-- ~- - ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 66 Drilling and Completions Drill cuttings WBF: No treatment - ~Well ~ Cuttings Generated Weight Of Mud Volume Of~ Mud • Use of low toxicity (Group III) Tullow and fluid discharge to seafloor. Sectio~ Per Section (MT) Discharged ~(MT) Discharged (P'') ~ ~ · improved SBM Unused fluid will be 36" - - 171/2" 262~7 0.0 0.0 • Less than 5 to 10% oil on improved returned to supplier SBM cuttings. 121/4" 425.7 21.3 15.5 81/2" 8~9 0.4 0.3 • Discharge of improved SBM Improved SBM: cuttings 15 m below water surface Total 697.3 21.7 15.8 Recycle using solid via caisson. Volumes based on BG1.Volumes for BG2 will differ. control equipment. Unused retuned to supplier . • No free oil Hg 1 mg.kg-1 dry wt in stock barite • Cd 3 mg.kg-1 dry wt in stock barite Completion Oil-water separation. Estimated volume per well: • Maximum one day oil and grease IFC (2007) fluids Any acids used will be • Calcium chloride (CaC12) 845 tonnes discharge should not exceed 42 neutralised to pHS-7 • CELITE 545 (Diatomaceous earth filler aid) 5.3 tonnes mg/1; 30 day average should not by addition of soda • Tetraclean-105 (surfactant) 5.9 tonnes exceed 29 mg/1. ash prior to discharge • Tetraclean-106 (surfactant booster) 3.3 tonnes • Any spent acids will be neutralised (to attain a pH of 5-7) before testing and disposal. -·--··- Subsea Installation Riser, umbilical None Commissioning fluid including corrosion inhibitor, oxygen No free oil USEPA, and pipeline scavenger, biocide and dye. 2007 commissioning Operation Hydraulic fluid None 264 litres per year assuming the valves on two Xmas trees. - - 544 litres in the first year. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 67 Onshore Liquid wastes produced during the operation of the project will include produced water from the Banda field (up to approximately 8.7 m3 /d) and waste oils from maintenance activities. Produced water will be removed during the three stage separation and be treated in the produced water treatment system. The produced water treatment system will be designed to remove: • entrained free oil to allow for safe disposal; • soluble hydrocarbons, including volatile aromatics - benzene, toluene, ethyl benzene and xylenes (BTEX); and • MEG and chemicals to reduce biological and chemical oxygen demand prevent biomass accumulation. The system is expected to include either a settling tank or induced gas floatation cell for free oil removal, an activated carbon bed for soluble oil removal, and biological treatment such as Moving Bed Biological Reactor (MBBR) or reed beds. A schematic of the options under consideration is presented in Figure 3.15. The produced water system will be designed to meet the IFC standards on Environmental, Health and Safety Guidelines for Onshore Oil and Gas Development. The required produced water specification for discharge to surface waters is provided in Table 3.15 below. Table 3.15 Produced Water Discharge Specification Following treatment, the treated produced water will be used in one of two ways: • in the power plant as process water to reduce its water demand; or • for gardening irrigation. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 68 Figure 3.15 Schematics of Proposed Produced Water Treatment System r ··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-··-·· :·······························................................................ I ~ ~ ~ I MB'Wption I ~ l ~ I B~otog:v· I I UF Feed I . Flotation ;!,dsorption r---!7 S1ralner 10m3 Pump Vessel Dia.X4m ---! Vessels 2 x 100% 0.5m ---, I I TIT Dia. 15m TIT I I I _y__ Wash Tank 1--- Membr.:me 1-f-- tanks x 2 Fmers 1 Wash Pump J I To re- :Spec, Rec.r>de I I I I ........•....................................................................... To: Irrigation Scheme I I J Reed Bed Option I I I --t· > I I I I I ,----. Reed Bed 1------- I I I "---,7 H- ! ! ~~ Reed Bed f---- . : . ii ················································································" : = ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 69 3.7.3 Solid Wastes Non-Hazardous Wastes The types of non-hazardous and hazardous solid waste that would be expected to be generated as part of the project include the following: • general domestic waste - from the galley and living quarters; • food waste - from meal preparation and left-overs in the galley; • plastic - including drinks bottles; • paper and cardboard; • scrap metal- empty drums and cables; and • wood - pallets and crates. Hazardous Wastes The types of hazardous solid waste that would be expected to be generated as part of the project include the following: • batteries - including large lead-acid type; • chemical residues; • clinical/ medical wastes; • oil filters; • oily rags and absorbents; • used oil - from engine maintenance; and • oily water - slops and contaminated water. The general estimated quantities of non-hazardous and hazardous waste that will be produced by the Banda Gas development are presented in Table 3.16. Table 3.16 Estimated Waste Types and Estimated Generation Rates Hazardous The solid waste generated offshore on board the drilling or support vessels will be shipped back to the Port of Nouakchott where it will be reused or ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 70 recycled where possible or disposed of. Onshore wastes will be collected and disposed of by an appropriate waste contractor. If a suitable contractor cannot be identified in Mauritania, the wastes will be transported to a neighbouring country for appropriate disposal. All waste will be managed to the project's waste management plan. 3.7.4 Noise Offshore The main sources of underwater sound associated with the drilling and completions phase can be categorised as follows. • Drilling noise. Blackwell et al (2004) found broadband (10Hz-10kHz) levels reaching a maximum of 124 dB re 1 pPa at 1 km, mainly at 700 Hz - 1.4 kHz from well drilling operations. Noise from a caisson during drilling in the Beaufort Sea was approximately 150 dB re 1 pPa at 1 m at 30 -40Hz (Richardson et al1995). • Propeller and Thrusters (where fitted). Noise from propellers and thrusters is predominantly caused by cavitation around the blades whilst transiting at speed or operating thrusters under load in order to maintain a vessel's position. Noise produced is typically broadband noise, with some low tonal peaks. • Machinery Noise. Machinery noise is often of low frequency, and often becomes dominant for vessels when stationary or moving at low speeds. The source of this type of noise is from large machinery, such as large power generation units (diesel engines or gas turbines), compressors and fluid pumps. Sound is transmitted through different paths, ie structural (machine to hull to water) and airborne (machine to air to hull to water), or a mixture of both. The nature of sound is dependent on a number of ·variables, eg number and size of machinery operating, coupling between machinery and deck. Machinery noise is typically tonal in nature. • Equipment in Water. Noise is produced from equipment such as drill string and caisson, and during pipeline and umbilical installation. Onshore Onshore noise will be associated with both the construction and operations phases. A short description of sources of noise during these phases is provided below. • Construction Noise. Noise associated with construction of the gas treatment plant will be variable in nature and will depend on the particular activities being undertaken as well as the equipment in operation. Significant noise will be generated during the site preparation phase, including from activities requiring heavy construction vehicles and ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 71 equipment such as land clearance, and also from civil works and plant utilities construction, including installation of concrete foundations and assembly of the plant. • Noise during Operation. Noise will be generated during operation from engine generators, compressors and processing pumps. Noise will also be generated from the flare stack when in it is in operation. Noise generated during operating will be continuous (with exception of flaring) as the plant will operate 24 hours a day, seven days a week. Traffic noise between the gas plant and Nouakchott will also be present during operation. 3.8 REVIEW OF PROJECT ALTERNATIVES CONSIDERED BY TULLOW This section presents an overview of the main alternatives considered by Tullow for the Banda Gas development. The aim of considering alternatives is to establish whether there are reasonable options which could be pursued to develop the Project whilst maintaining an acceptable balance between technical and commercial feasibility and the costs of environmental and social mitigation. The main alternatives that were considered for the Banda Gas development relate to: • routing of the offshore gas pipeline; • the condensate export scheme; • flash-gas recovery versus venting; • methods of umbilical protection; • well design; and • drill cuttings management. The alternatives for each project component are described in the following sections. 3.8.1 Pipeline Routing There are a number of natural features which influenced the pipeline route including a marine ridge occurring approximate 20 km offshore and the presence of a coastal sand dune system. The base case is for the pipeline to be routed around this offshore ridge, directly to the coast and through the coastal dune system. Both decisions have been made on the basis of technical feasibility and constructability. Installing the pipeline over the ridge would be more complicated and carry a greater level of technical risk. 3.8.2 Condensate Export Scheme The project will produce an average plateau production off 800 barrels per day of condensate (approximately 130m3). Four options were evaluated by Tullow based on their technical feasibility/ robustness; health, safety and ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTY LTD 72 environmental (HSE) criteria; cost; reliability, availability and maintainability; and operational and construction simplicity: • la Export via road tankers to Nouakchott Port; • lb Export via pipeline to Nouakchott Port; • 2 Export via road tankers to a refinery in Senegal; • 3 Export via road tankers to a new topping plant; and • 4 Export via road tankers to a new blending plant. The environmental implications of the options were largely similar, with the worst case environmental impact resulting from a spill event. The absolute worst case would occur from the pipeline given the larger volume of hydrocarbons. However, this should have been mitigated by the very low frequency of spills from a pipeline. Ultimately, option la (trucking to the port of Nouakchott) was selected as the base case, largely considering its technical and commercial feasibility. This will entail an average of 5 to 6 trucks per day travelling between the Banda Gas processing facility to the port of Nouakchott. Table 3.17 Ranking of Condensate Export Alternatives Options Criteria ranking Overall Technical HSE Cost Reliability, Simplicity rank feasibility, availability, robustness maintainability la 1 1 2 1 1 1 lb 3 2 4 2 3 3 2 2 3 1 3 2 2 3 4 4 3 4 4 4 4 5 4 3 4 4 5 3.8.3 Flash Gas Venting or Recovery Flash-gas results from the evaporation of natural gas from the condensate in the low-pressure separators. Tullow considered two alternatives for removing flash-gas, namely venting to atmosphere and recovery. Venting would be a simpler option, but resulting in increased greenhouse gas emissions from the plant. However, to maximise gas recovery, Tullow opted for the recovery of flash gas in a flash-gas compressor unit. 3.8.4 Umbilical Protection The umbilical will follow the same route as the gas export pipeline from the Banda field manifold to the gas plant. Tullow considered whether to install the umbilical within the pipeline trench or in a separate trench. The current base case is for installation within the pipeline trench. This is considered the best environmental option as it reduces seabed disturbance and the time the installation fleet operates offshore, which in turn reduces vessel emissions and ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MA URIT ANI A) PTY LTO 73 disturbance to marine fauna from vessel presence and underwater noise. The base case is also the less expensive of the two alternatives. 3.8.5 Well Design Tullow considered various alternatives for the Banda wells including the number of wells, whether slant or vertical, re-using existing wells, casing configuration, tubing diameters and sand screen configurations. The main factor of environmental impacts is the number of production wells to be drilled (in terms of drilling process intensity, installed equipment on the seabed, and duration of offshore operations). In terms of technical and commercial feasibility, design studies indicated that two wells are effectively required to offer greater than 98% recovery of gas from the reservoir. The base case for the development is therefore two wells. The fact that these two wells will be drilled from a single drilling centre will reduce the extent of seabed affected by the drilling operations. It will also allow reducing the duration of offshore operations compared to drilling from two separate locations. 3.8.6 Drill cuttings management. Drill cuttings will be returned to the MODU, separated and cleaned using shale shakers, and then discharged overboard via a caisson below the water surface. Tullow considered the alternative of storing the cuttings on-board and returning them back to shore. However, Mauritania does not possess treatment and disposal facilities for contaminated cuttings, especially for the volumes involved (estimated 1484.6 tons of cuttings). Also, the impact of cuttings discharge offshore was assessed as Minor significance via modelling of total suspended solids (TSS) concentration, and depositional thickness (Section 5.5.1): • The elevated TSS concentrations are expected to be localised, short term and dissipate rapidly as a result of the dispersion capacity of the local marine environment (small magnitude). Additionally, the good existing water quality and low to medium sensitivity of biological receptors leads us to conclude that the impact to the water column is of Minor significance. • A depositional thickness of more than 50 mm (the threshold at which smothering and/ or mortality can be expected) is anticipated for approximately 2.1 km2 of seabed. This represents approximately 3.4% of the Banda field area (small to medium magnitude). Also, the benthic fauna in the Banda field is homogenous and dominated by low value burrowing species which have a high tolerance to burial (low sensitivity). Therefore, the impact to the seabed is assessed as being of Minor significance. Solid control equipment will be used to reduce the oil on cuttings to a target concentration below 10% in weight, depending on the equipment available on board the rig. Tullow considered reducing this target of oil on cuttings but this percentage depends on the technology on board. With mechanical solid ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURJT AN! A) PTY L TO 74 control equipment on the rig, the lowest average achievable weight on cuttings will be 5%. There are existing technologies that can reach smaller oil on cuttings percentages but the environmental benefits are outweighed by the costs. ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 75 4 ENVIRONMENTAL AND SOCIO-ECONOMIC BASELINE 4.1 INTRODUCTION This chapter provides a description of the existing environmental and socio- economic conditions against which the potential impacts of the Banda Gas development are assessed in this ESIA. The baseline description draws on a number of primary and secondary sources, in particular: • Metocean criteria study for Banda field offshore, Mauritania (FugroGeos, 2012). Tullow appointed Fugro Geos Ltd to conduct a study of metocean conditions off the Mauritanian coast in March and August 2012. • Meteorological statistics at Nouakchott, Mauritania (FugroGeos, 2012). Tullow appointed Fugro Geos Ltd to conduct a study of meteorological conditions for the onshore gas processing plant of the Project in September 2012. • Environmental Baseline Survey (Gardline, 2012). This Environmental Baseline Survey commissioned by Tullow aimed to characterize water and sediment quality in the Project area. The offshore (depth greater than 10 metres) part of the survey was completed at the end of August 2012 and the nearshore (water depths less than 10 metres) part during September/October 2012. • Geotechnical Survey (SMSC-LABOSOL, 2012). Tullow appointed SMSC- LABOSOL for a GO Mission (consisting of drilling, testing and geotechnical measurements) as per NF P 94 500 norm. As part of this mission, onsite drilling and pressuremeter tests as well as laboratory analyses were performed at the proposed locations of the gas processing plant and the arrival of the submarine pipeline on the coast. • Marine Mammal and Turtle Observations (RPS, 2011; RPS, 2012). Tullow appointed RPS Ltd to record marine mammal and turtle sightings data during seismic surveys undertaken in June-July 2011, May-June 2012 and September-October 2012 from Block 2, 120 km to the south of the Banda development. Given this proximity, the sightings from Block 2 represent a recent record of the species likely to be present within the vicinity of the Banda development. • Collision Risk Assessment (Anatec, 2012). This study was commissioned to identify shipping routes passing the Banda licence area, calculate collision frequencies and review mitigation measures. • Internationally recognised published sources and databases such as the Food and Agriculture Organisation (FAO), the International Union for the ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 76 Conservation of Nature and its Resources (IUCN), and the online fish database, Fishbase. This data has been completed by field visits of the onshore area of the Project: • Scoping visit, to identify the main issues related to the Project, 9-13 July 2012. • Biodiversity survey, from 9-13 July 2012 and from 6-9 November 2012. • Noise measurements, from 6-9 November 2012. • Consultations with stakeholders, from July 2012 to March 2013, as detailed in Annex A, ESIA Consultation Records. 4.2 BASELINE STUDY AREA The environmental and social baseline has been assessed within the global study area of the Project, whom the determination is based on the Area of Influence of the Project illustrated in Figure 4.1: • Project footprint (d. Chapters 3.3.7 and 3.4.4). • Local Area of Influence corresponding to the direct footprint of the Project. This area includes the wells and a 10 km buffer (to take into account the extent of potential effects during the drilling phase), the offshore and onshore pipeline route with 1 km buffer and the onshore gas facilities site with a 1 km buffer (to take into account the extent of potential effects during the construction phase). A channel between Banda and the Nouakchott port that will serve as a logistics base for the Project is also taken into account for the determination of the local area. • Regional Area of Influence to account for possible indirect effect for the potential environmental and social receptors outside the local study area. This large scale area is defined as the coastline extending from Mamghar to M'Balal (to target fishing communities likely to be concerned) plus a 5 km buffer around the onshore facilities (to include the human activities potentially affected by indirect impacts of the Project). ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 77 Figure 4.1 Determination of the Study Area ! l __\ N 0 Nation boundaries Traffic from/to Nouakchott harbour (logistics support) ~-::::::-------------.-:::---------- Proposed offshore Mauritania pipeline Proposed onshore Fish Market pipeline IDetermination of the study area Proposed gas Regional study area r> processing facility Local study area ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 78 4.3 PHYSICAL ENVIRONMENT 4.3.1 Climate and Meteorology Climate and Seasons Specific climate and weather information for the Banda field was drawn from the meteocean study and from the meteorological analysis commissioned by Tullow (FugroGeos, 2012). This data covers the onshore and offshore parts of the study area. Mauritania is strongly influenced by the trade winds and is characterised by an upwelling system offshore ("upwelling" refers to a phenomenon when cold, nutrient-rich water is forced up from ocean depth, and rises to shallower coastal water or to the surface.). Both of these phenomena are dictated by the influence of the high pressure originating from the Azores, the Azores High, and its seasonal variation. The Azores High is a large semi-permanent anticyclone located over the Atlantic Ocean, centred in the area of the Azores archipelago. The High tends to move north towards the Iberian Peninsula in summer, and south of the Azores at the onset of winter (Figure 4.2). The West African coast is subjected to sudden squalls, an exception to the relatively benign meteorological environment usually experienced. The regional climate is also influenced by the Inter Tropical Convergence Zone (ITCZ). Two air masses, one over the Sahara (tropical continental) and the other over the Atlantic Ocean (maritime) converge at the ITCZ, resulting in an area of low pressure where hot and dry continental air meets moist oceanic air and produces heavy rainfall. The ITCZ migrates northwards up to 20°N to 25°N with the Saharan depression from January to August. The Mauritanian climate can be divided into three seasons (Soule, 2003): • a rainy season from June to October; • a cool dry season from October to March; and • a hot dry season from March to June. Relative humidity is low (down to 30% at times), but can reach up to 70% during the rainy season. The average weather conditions in Nouakchott are illustrated in Figure 4.3, Figure 4.4 and Figure 4.5. ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PE1ROLEUM (MAURITANIA) PTY LTD 79 Figure4.2 Prevailing Winds in the Atlantic Ocean Source: FugroGeos, 2012. Figure4.3 Air Temperature Statistics in Nouakchott, 2007-2012 Air Temperature [ C] 0 50 45 40 Max 35 Mean 30 25 Min 20 15 -----Annual 10 mean 5 0 Source: ERM (interpretation of FugroGeos, 2012) ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 80 Figure4.4 Monthly Precipitation in Nouakchott, 1981-2012 1'v1onthly Precipitation [mm] 140 120 AverJge 100 RafnfJII {1981-2010) 80 60 II MJximum 40 RJinfJII 20 (2009-2012) 0 Source: ERM (interpretation of MeteoFrance, 2012 and FugroGeos, 2012) Figure4.5 Relative Humidity in Nouakchott, 2007-2012 Relative Humidity(%) 100 80 60 -Max 40 20 -Min 0 Source: ERM (interpretation of FugroGeos, 2012) The offshore climate at Banda location is influenced by the sea; temperatures are lower than the onshore ones, as shown in Figure 4.6. ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 81 Figure4.6 Air Temperature Statistics at Banda Air Temperature (C0 ] 40 35 30 Max 25 20 Me.:m 15 Min 10 5 -----Annual 0 mean Source: ERM (interpretation of FugroGeos, 2012) Offshore winds The Azores anticyclone drives the north-eastern Atlantic trade winds which blow over Mauritania year-round. The trade winds band varies seasonally, being located further north (35°N to 20°N) in the summer, shifting south (30°N to l2°N) during the winter in response to the southwards shift of the Azores High (FugroGeos, 2012). The southwards shift of the Azores anticyclone in April and May results in an accentuation of pressure gradients, which may give rise to high intensity winds. In August and September, the anticyclone takes its most northerly position, considerably reducing the pressure gradients and, consequently, reducing the speed of the trade winds. As a result, the climate in winter is characterised by light winds (Ould Taleb Sidi, 2005). The drying effect of the trade winds in winter is enhanced by the Harmattan, a hot and dry wind that arises from the Saharan depression and blows from the north-east or east. In the summer, the Harmattan is undercut by the cooler rain-bearing winds of the south-west monsoon that blow in from the ocean (FugroGeos, 2012). Wind data were acquired (FugroGeos, 2012) for the Banda field location (17.77° N, 16.57° W). Winds in the Project area blow predominantly from the north at average speeds of 6 to 8 m.s-1 (Figure 4. 7), with slight seasonal variations: in December and January, winds blow mainly from the northeast whereas in June through September, they blow from the northwest. ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 82 Figure4.7 Joint Frequency Table of Wind Speed and Direction at Banda field Total 40.78 14.95 2.38 0.18. <0.01 16: <0.01 15:- 0.01 <0.01 <0.01 <0.01 14. 0.04 <0.01 <0.01 f E 13 12. 0.15 0.47 0.03 0.06 <0.01 0.02 <0.01 <0.01 <0.01 <0.01 0.35 0 1.22 <0.01 <0.01 <0.01 2.68 (iJ 3.90 <0.01 <0.01 <0.01 0.04 6.65 -o 10.55 ~:<-..::>~~ ~fQ ~- "'-~0' ~<.~ ~~ ~..::><::-rq II Max Source: ERM (from FugroGeos, 2012) 4.3.2 Hydrography and Oceanography Currents Four main currents influence Mauritanian waters: the Canary Current, the Azores Current the North Equatorial Current and the Equatorial Counter Current. During periods of well-established trade winds, coastal currents flow ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 83 southwards with speeds of 25 cm.s-1 to 50 cm.s-1 at the surface. Tidal currents are usually weak over the whole of northwest Africa, with speeds of about 5 cm.s-1 to 10 cm.s-1. In the Project area, average surface current speed ranges from 15 cm.s-1 in December to 22 cm.s-1 in June and July (Fugro, 2012). From December to May, the Canary Current, the dominant surface current of the region, flows southward along the Mauritanian coast between 30°N and 10°N and is fed by the Azores Current. Counter-currents in the surface layer are a typical feature offshore along the continental slope (between l7°N and 23°N) and flow at speeds of between 5 cm.s-1 and 15 cm.s-1 (FugroGeos, 2012). In summer, the trade wind band moves to its northernmost limit. This, coupled with the intensification of the North Equatorial Counter Current and the presence of the south-west monsoon at low latitudes, brings about a northward compensation flow along the West African coast (Figure 4.9). During the winter, the southwards shift of the trade wind band results in the creation of a southward surface current along the continental shelf as well as the emergence of coastal upwelling (Fugro, 2012). The upwelling is driven by prevailing winds which cause this displacement of warmer shallow coastal water by the nutrient-rich deep water. There is an area of almost permanent upwelling off the Bane d' Arguin with seasonal upwelling further south. One of these areas of seasonal upwelling is near and to the south of Cap Blanc and occurs from December to March. Figure4.9 Circulation of Currents off the Coast of West Africa January to March April to June July to September October to December Source: Mittelstaedt, 1991 ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 84 Currents are also influenced by the depth, and they increase when the depth decrease (cf. Figure 4.10). Tides and Waves Tides offshore Mauritania are relatively weak, semi-diurnal, with an average tidal range of 1.44 m (PANPA, 2012). The wave regime is characterised by relatively low significant wave heights. During the summer, waves measure an average of 1.5 m, with maximum heights of less than 3 m. During the winter, maximum wave height can reach 5 m. Figure 4.11 illustrates significant wave height and direction in the Project area. Long-period swell dominates in the region which originate from North Atlantic storms and the Southern Ocean: low frequency swell waves with low significant wave heights originate in the Southern Ocean, whereas low frequency swell waves with a higher significant height originate from North Atlantic storms (FugroGeos, 2012). Figure4.10 Current profile of maximum current speed 50 100 200 250 3QQL-~--~~--~·~~--L~~~~-J~-···········L----~----~····-·····-~-~-~~~---······'--~~ 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 Current Speed [m/s] Source: FugroGeos, 2012 ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 85 Figure4.11 Total Significant Wave Height and Direction in Banda Area AII·Year "'" 002 1.55 53J2 100.00 5.00. 4.75 om 4.50l 0.03 0.05 I 0.11 0.25 :c Cl) 0.47 <0.01 (jj 0.91 :r: 1.64 w 3.36 > ~ <0.01 <0.01 673 c ro <0.01 <0.01 0.02 12.88 23.77 0 <0.01 <0.01 <0.01 0.06 41.07 ~ <.0.01 <0.01 ()19 62.12 .Ql <0.01 0.01 0.34 (/') 8200 0.01 95.21 0.01 99.65 100.00 0.25' ··s .. 0.00\. 'ilE E sE sw .. w NW Total Exceed % % Source: FugroGeos, 2012 4.3.3 Morphology Marine Bathymetry The Mauritanian continental shelf extends parallel to the coast from 21 oN to 16°N up to 50 km from shore over a surface area of approximately 39,000 kmz. The seabed is relatively flat, with water depths decreasing regularly to the 100m isobaths approximately 40 km off Nouakchott, except for a few submarine troughs reaching depths of up to 600 m. These troughs are thought to encourage the phenomenon of upwelling, channelling the upwelling of deep water along the continental margin. To the north of the Banda field, there is a deeply incised submarine canyon (>20 km north). There is also a large area of landslides southwest of the Banda field that transport sediment downslope to the West, towards the Abyssal Plain (Colman et al, 2005). Lastly, there are several carbonate mud mounds along the 450-550 m depth contour along the coast, to the north and south of the Banda field. These mounds are inhabited by cold-water corals, further discussed in Section.4.4.L The Banda Field is located approximately 50 km from the coast in water depths of between 200 and 325 m. The pipeline route from the manifold to the shore is presented on Figure 4.12. The bathymetric profile of the pipeline route is presented on Figure 4.13. ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURJT ANIA) PTY LTD 86 Figure4.12 Pipeline Route and Bathymetry Proposed gas wells Banda Gas Mauritania Proposed gas pipeline - Proposed onshore pipeline Proposed power plant site Proposed gas processing facility Capital ..\ . N 12 16 20krn ENVIRONMENTAL RESOURCE MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LID 4-87 Figure4.13 Bathymetric Profile of the Pipeline Route Distance from Drilling Center (km) 0 10 20 30 40 50 60 70 80 0 5 <( -50 E ..s::: +J a. -100 Ql c ... Ql +J -150 co 3: -200 Source: ERM (from Gardline, 2012) Morphology of the Onshore Area The geomorphology of the Mauritanian coastline is characterized by narrow beaches and shifting sand dunes that follow seasonal conditions. Further back from the coastline, semi-fixed dunes precede some depression areas of salty clay called "sebkha" (Faye, 2010). Sebkhas can be flooded during the rainy season, between August and September (Figure 4.38). The Great Sebkha of Ndramcha, located about 15 kilometres north of the proposed onshore gas plant location, presents some very low altitude (down to -4 m). The use of Short Wave InfraRed (SWRI) satellite images permits to distinguish the location of the Great Sebkha (in cyan blue on Figure 4.14). On the onshore study area, the floods are not such as important as more on North; however, SWRI imagery shows some temporary flooded areas (in cyan blue on Figure 4.14). The typical geomorphology of the north of Nouakchott coastline (based on the scoping visit conducted from 9th to 13th July 2012) is presented on Figure 4.15. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 88 Figure4.14 Flooded Areas around the Proposed Location of the Project's Onshore Component ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 89 Figure4.15 Schematic Geomorphology of the Mauritanian Coastline (North of Nouakchott) Zone d'imp!antation des installations de traitement de gaz i Dunedvl' di$COOti-0tJe ~~ ........ Dunes flx6es Bt semt-fixees Crhtc dt•ht>rnP Source: ERM Glossary: Rivage: shore- Plage: beach- Dune vive discontinue: discontinuous shifting dune- Dunes semi-fixees: semi-fixed dunes - Dunes fixees et semi-fixees: fixed and semi-fixed dunes - Zone d'implantation des installations de traitement de gaz: Location of the gas treatment facilities 4.3.4 Geology and Sedimentology Sedimentology Particle size distributions of sediments in the marine environment are to a large extent determined by hydrodynamic energy at the sediment water interface. Strong currents tend to scour the seabed thereby suspending fine particles and any material associated with them, whilst the finest sediments predominate in areas with the least hydrodynamic energy. Sediment particle size is also a critical measurement for the categorization of habitat type since this parameter controls to a large extent which organisms are capable of living within sediments. Most benthic infaunal organisms exhibit preferences for sediment with particular grain size characteristics. Many organisms live in tubes or burrows constructed from sediment particles; each organism's ability to do this may be limited by the range of particle size available. The distribution and abundance of free-living mobile organisms, i.e. those that do not construct tubes or burrows, are also affected by particle sizes, which influence their ability to move within the sediment. A specific Environmental Baseline Survey (EBS) was conducted by Gardline (Gardline, 2012) at the proposed Banda Drilling Center and along the Pipeline Route. The main results and conclusions related to sediment characteristics are the following: • At the drilling center, the sediments were homogenous with no indication of a change in sediment type across the sampling stations. Sediments were described as fine silty sand with occasional shell fragments. • The 14 first set of sampling stations along the pipeline route presented sandy seabed with shell fragments but different types of sediments were observed. These are presented on Figure 4.16. • The second set of four near-shore sampling stations from the EBS presented: sand with loosely cemented coral debris and shell fragments ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 90 closest to the shore, then sand with boulders and coral patches, and finally only sand for the last two stations that were the furthest from shore (Gardline, 2012). The sediment types are also presented on Figure 4.16. Figure4.16 Type of Sediments along the Pipeline Route Type of sediments: Sand with cora I debris Hard ca lcifie sand Source: ERM (interpretation from Gardline 2012) The general sedimentology of the area is shown in Figure 4.17. This figure confirms that the offshore pipeline route will cross several different types of seabed, including rocky banks, discontinuous rocky areas and sandy seabed. Sediment Quality The role of sediment in the transport a.nd retention of chemical pollutants is tied to both particle size and to the amount of organic carbon associated with the sediment. The chemically active fraction of sediment is usually cited as the organic component and also as the finest size fractions (smaller than 63pm, silt, clay). The sediment, in particular the organic carbon and finer fractions, acts as a sink for many of the persistent compounds, including metals, hydrocarbons and chlorinated compounds. Many of these persistent substances are also inherently bio accumulative and toxic. The concentrations of many parameters are typically positively correlated with the proportion of fines found in the sediment as a result of fine particles possessing a relatively large surface area. Fine sediment particles are relatively easily suspended by waves and currents, and may be transported, along with the materials sorbed to them, over large distances, finally being deposited in areas of lower hydrodynamic energy. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY L TO 91 Generally speaking, sands and coarser grained materials are often organically deficient. Strong currents have a tendency to suspend fine materials and their associated organic matter. Therefore, in an environment that is not nutrient enriched due to anthropogenic discharges, both total organic matter and total organic carbon will normally be lowest at sites with coarse-grained sediment, where currents are often strongest. During the EBS undertaken by Gardline, the levels of pollutants (hydrocarbon and metals concentrations) were measured at the sampling stations (DC and pipe route). The main results were that: • Hydrocarbon concentrations were lower than the levels that might be considered to cause a toxicological effect, and are consistent with historical and ongoing oil and gas related activity in the area. • Overall the results of the metals analysis indicate that the sediments within the Banda DC were free from any notable contamination: the levels of heavy metals did not exceed any of the apparent effects thresholds (AETs) defined by Buchman (2008), which were obtained by establishing relationships between sediment metal concentrations and benthic community toxicological impacts. Terrestrial Geology The maritime zone in the coastal area belongs to the large sedimentary basin that extends from Mauritania to Guinea-Bissau. The Mauritanian coast belongs to the secondary-tertiary sedimentary Senegalo-Mauritanian basin, with an area of approximately 340,000 km2 (Mohamed Lemine Ould Aboye, 2003). This basin lies at a depth increasing rapidly approaching the coast (5000 m near Nouakchott) on the ancient basement that outcrops in the East with Mauritanides chain. Four stages have been identified for marine Quaternary in Mauritania, corresponding to transgressive levels; Nouakchott and the onshore study area belong to Nouakchottian (7,000 to 4,000 BP). The Quaternary cover is often recent and outcrops over much of the coastal zone. It results from a bustling history characterized by alternative invasions and withdrawals from the ocean. These are represented by local important changes (Ndramcha sebkha, Senegal Delta) of shoreline and varied deposits, added to climatic episodes which are arid or wetter, with their dune systems and the introduction of an extensive cover of wind sands. As part of the environmental baseline, Tullow commissioned a geotechnical survey at the proposed locations of the gas processing plant and the submarine pipeline landfall. The 25m depth core drilling undertaken during the geotechnical survey mandated by Tullow at the proposed location of the gas treatment plant identified the following layers: ENVIRONMENTAL RESOURCFS MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 92 • a layer of sand with a thickness of 4 to 6m; • a transition layer of sand cockle; • a layer of consolidated shells compact 8-9 m to 16-17 m depth; • another transition layer shell silt; and • a final layer of gray silt from 18-19 m depth. The water levels recorded at the location of the proposed gas treatmentplant were 5.1 m and 7 m above the natural ground. However, the existence of movement and j or water infiltration is possible during and after intense or prolonged rainfall events. The following layers were identified by the core holes of 15m depth made at the proposed location of the submarine pipeline landfall : • a layer of sand slightly cockle 12 to 14m thick, and then • a layer of compact consolidated shells. The water levels recorded beneath the proposed gas processing facility were 1 m and 1.5 m above the natural ground. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 93 Figure4.17 Sedimentology along the Offshore Pipeline Route Mauritania 1Sedimentology along the Proposed Offshore 4· 19 Pipeline Route Source: Carte sedimentologique du plateau continental mauritanien. ORSTOM 1985 JA Glossary: Fonds rocheux: rocky bed - Banes rocheux: rocky banks - Sable: sand - £pave: wreck. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURJT ANI A) PTY LTD 94 4.3.5 Water Quality Water Temperature Surface water temperature off the coast of Mauritania is relatively low due to coastal upwelling, but varies seasonally as a result of the mixing of cold masses of water from the north (Canary Current) and warm masses of water from the south (a combination of tropical waters and monsoon rains) (Ould Taleb Sidi, 2005). In the Project area (between 16°N and 18°N), surface sea temperatures vary between 19°C in February and 28°C in September (d. Figure 4.18) (Ould Taleb Sidi, 2005). The near bed conditions for the Banda field are not so influenced by the seasons, and the mean temperatures vary between 11.7°C and 12.1°C (d. Figure 4.19). Finally, temperatures are also influenced by depth (Gardline, 2012): • within the first forty meters, the temperature is quite stable and similar to the surface (around 28 °C); • from forty to ninety meters depth, it decreases about 15 oc; and • from ninety meters to the seabed (215 m), the temperature decrease very slowly until12°C. These variations are presented on the Figure 4.20. Figure4.18 Monthly Mean Surface Water Temperature 29 15+---~---.--~----~--.---~---.--~----r---~--~ Jan Feb March April May Jun€ July Aug Sept Oct Nov Dec Source: ERM (from Ould Taleb Sidi, 2005) ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 95 Figure4.19 Monthly Near-seabed Temperature in the Banda Field Near-Bed Temperature Statistics [ C] 0 15 14 13 12 Mean 11 -Min 10 9 8 Source: ERM (interpretation of FugroGeos, 2012) Turbidity Turbidity profiles collected at the drilling centre indicate that the surface waters can be very turbid (>7 FTU) down to approximately 7m below sea level. Between 10m and 30m the turbidity averages around 6 FTU. The values measured varied by 1 FTU between the sampling days (4 different measures). Still, turbidity increased slightly with depth on all profiles. The spikes on day two to four are most likely caused by objects particles or animal in the water column (See Figure 4.22) (Gardline, 2012). Salinity In the absence of fresh water inflow from rivers, the salinity of surface water off the coast of Mauritania is stable at around 36%o year-round (Ould Taleb Sidi, 2005). In the Project area, some low variations between 35.2 %o and 35.8 %o (from June to September) are anticipated (FugroGeos, 2012). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTO 96 Figure4.20 Water Temperature and Turbidity Profiles in the Banda Field 04---~--L-~--~---- 0 10 10 20 20 30 30 40 40 50 50 60 60 70 70 80 BO 90 90 '§: 100 g 100 ~110 ""' 0. 110 ~ 120 0"' 120 130 130 140 140 150 150 160 if,G 170 17C 180 180 190 190 200 200 210 210 220-t-----.---.,----,-----,----+- 220 10 15 20 25 30 35 5.5 5.75 •3 13.25 6.5 6]5 7 Temperature ('C) Turbidity (FTU) Key Day 1 of Environmental Sampling Day 2 of Environmental Sampflng Day 3 of Environmental Sampling Day 4 of Environmental Sampling Source: Gardline 2012. FTU : Formazin Turbidity Unit Figure4.21 Monthly Near-seabed Salinity in the Banda Field !\'ear-Bed Salinity Statistics [%o] 35,9 35,8 35,7 35,6 35,5 35,4 -Max 35,3 Mean 35,2 35,1 Min 35 34,9 Source: ERM (interpretation ofFugroGeos, 2012) ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 97 4.3.6 Noise Introduction An important part of the noise assessment is the quantification and understanding of the existing acoustic environment including the identification baseline noise levels at potentially affected noise sensitive receptors. The baseline environment can be defined as the conditions that would prevail in the absence of the Project; it is intended to describe the spatial planning and the status of the noise climate in the area surrounding the Project site, setting the scene for the assessment of the potential noise impacts created by the Project. Acoustic Characteristics of the Project Site Based on a desktop analysis, it was anticipated that due to the desert nature of the proposed area, the acoustic environment will have low ambient noise levels which will not vary considerably across the Project area. In fact, specific noise emissions have not been detected during the site inspection. The Project study area consists mainly of a sparsely populated desert environment and the whistling wind is the main source of noise. The Project site is located about 9 km north of the city of Nouakchott. It is characterized by fixed and semi-fixed dunes , alternating with some depression areas of salty clay called "sebkha". The site and its wider environment are used by shepherds for the grazing of herds of camels and goats and crossings to remote places. Along the pipeline and in proximity of the gas plant the nearest identified buildings are: • the new University of Nouakchott located 2.7 km south/ southwest of the proposed gas processing facility, still under construction (see Figure 4.22); • scattered residential buildings 3.8 km west-northwest of the proposed processing facility site, including also some tented camps (Figure 4.23). These receptors have been identified previously by a desktop analysis of the local cartography or satellite images and confirmed by means of site visit to verify the state of the buildings and the presence of inhabitants. In addition to the future noise sources related to the Project, in the study area the only noise emissions derives from Nouakchott-Nouadhibou road traffic, even if no relevant noteworthy infrastructure affects the area. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 98 Figure4.22 Pictures of the University of Nouakchott Construction Site (November 2012) Figure Permanent Residential Buildings Located 3.8 km West of the Site ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 99 Noise Baseline Measurements Ambient (background) noise levels for the Project area were measured by undertaking a series of attended short-term measurements during the day over the period 6-7 November 2012. The noise baseline survey report, including methodology and detailed results is presented in Annex B-3. Figure4.23 Noise Measurement Locations Noise Measurement Locations il Site boundary .~ N Onshore gas terminal Near receptor Onshore pipeline 0 0.4 0.8 1.2 km Table 4.1 summarizes the daytime ambient noise levels at each of the measurement on the site boundary. Table 4.2 summarizes the daytime ambient noise levels at the identified nearest receptors. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 100 Table4.1 Results of Monitoring Measurements. Site Boundary NMLl 396661.01 2010941.59 34.1 29.3 31.3 29.2 58.5 NML2 396804.68 2010942.38 35.0 29.3 34.1 29.2 59.4 NML3 396953.11 2010942.38 "32.0 29.5 32.2 29.4 52.3 NML4 396954.70 2010755.85 31.4 29.4 31.6 29.3 50.4 NML5 396956.29 2010573.29 40.3 29.4 35.3 29.3 66.4 NML6 396815.00 2010574.08 33.7 32.0 36.4 31.1 45.8 NML7 396657.04 2010573.29 38.4 31.3 42.2 30.8 57.2 Note: Coordinate System: WGS 84 UTM 28N (1! Table 4.2 Results of Monitoring Measurements near Identified Noise Sensitive Receptors Settlement near Nouakchott- Nouadhibou NML8 road (3.8km 392757.87 2011623.77 47.0 36.1 52.2 30.6 75.2 northwest of the Project site) University NML9 (2.7km southwest 395021.29 2008307.89 30.8 29.3 32.0 29.2 50.1 of the Project site) Note: Coordinate System: WGS 84 UTM 28N (1! Conclusions From observations made and measurem,ents recorded during the site visit it may be concluded that the areas set within and surrounding the Project site are typical of undeveloped area sufficiently far from city centre and infrastructures, with low background noise levels throughout the day time period, and consequently throughout the night time period. No particular sensitive receptor has been identified in the immediate vicinity of the Project area. The nearest receptors being the new University of Nouakchott located 2.7 km south/ southwest of the proposed gas processing facility and rare permanent residential buildings located 3.8 km west /northwest of the proposed gas processing facility. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PE1ROLEUM (MAURITANIA) PTYLTD 101 4.4 MARINE BIOLOGICAL ENVIRONMENT 4.4.1 Plankton Information on plankton (phytoplankton and zooplankton) was sourced from available publishedsources (eg AtlantNIRO, 2009). Phytoplankton and zooplankton form a fundamental link in the food chain. The composition of plankton communities and their abundance is variable and depends upon water circulation into and around the coast of Mauritania, the time of year, nutrient availability, depth and temperature stratification. Phytoplankton Phytoplankton, grouped as diatoms, dinoflagellates and coccolithophores, are microscopic and range between 30 mm and 60 mm in size. Primary production is linked to the amount of inorganic carbon assimilated by phytoplankton via the process of photosynthesis. Primary production determined for the M.auritanian Exclusive Economic Zone (EEZ) is 2,549 mg cm-3 per day (Seas Around Us Project, 2012). Typically, productivity in the offshore ecosystems (100 to 200m water depth) range from 10 to 100 mg cm-3 per day. Thus, the values obtained within the nearshore areas indicate a system of relatively high productivity. This is not unexpected since the coastal ecosystem of the area undergoes seasonal upwelling, bringing nutrients to the surface which makes phytoplankton especially abundant from March to May and from July to October. Organisms encountered are large diatoms including Chaetoceros (C. tortissimum, C. laciniosum, C. didymum), Rhizosolenia (R. stolterfothii, R. delicatula, R. calcar -opinion, R. setigera), the common coastal diatom Skeletonema castatum and Asterionella japonica, Talassionema nitzschioides, Nitzschia closterium, Thalassiothrix frauenfeldii and Ditylum Brightwell. All of these species can occur in proliferations of up to several hundred thousand cells per litre. During the warmer months of the year, dinoflagellates can grow in abundance (up to 900,000 cells per litre). Occasionally, in the right conditions, particular species can occur in very high densities creating 'red tides'. In Mauritania, several cases have been observed both in inshore waters and several miles offshore, mostly in calm weather. The main species of dinoflagellates that cause red tides mostly belong to the genera Gonyolax, Gyymnodinuim, Amphydinuim, Cochlodinium and Noctiluca. During the EBS conducted by Gardline on behalf of Tullow, concentrations of chlorophyll-a were used as an estimate of phytoplankton biomass within the water column. Concentrations recorded on all environmental sampling days were all below the limit of detection of <10!lg.L-1 both at the Banda Drilling centre and on the pipeline route (Gardline, 2012). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY L TO 102 Zooplankton There is no comprehensive inventory of zooplankton species for Mauritania, however in common with other offshore areas, zooplankton assemblages are likely to be dominated by Copepods, followed by Ostracods, Appendicularians and Chaetognaths. From the studies that have been undertaken copepods include Oncaea spp, Oithona spp and Parvocalus scotti. In the Bay of Greyhound, Sagitta hispida is found whilst in Bane d' Arguin Sagitta friderici is more abundant. Among non-native species are Calanoides carinatus and Galanus helgolandicus. Concentrations of both zooplankton and phytoplankton are found at sites where upwellings occur, bringing nutrient rich cold waters to the surface. 4.4.2 Benthic Communities Benthic fauna form an important part of the marine ecosystem, providing a food source for other invertebrates and fish as well as cycling nutrients and materials between the water column and underlying sediments. Different species of benthic fauna exhibit different tolerances to stress, making them useful indicators of environmental conditions. The Mauritanian marine environment has not been extensively studied for its marine benthic communities, particularly in deeper waters. During the EBS undertaken by Gardline in 2012 on behalf of Tullow, faunal samples were collected from each sampling stations. The study revealed a taxonomically diverse and species rich benthic community. To quantitatively assess the population, the data set was divided into four gross taxonomic groups: Annelida (Polychaeta), Arthropoda (Crustacea), Mollusca and Other taxa, comprising solely of Nemertea (ribbon worms). The gross number of individuals and number of different taxa were evaluated. At the drilling centre, the faunal community was dominated by polychaete annelids, which contributed between 93% and 99% of the total individuals at each sampling station and between 71% and 93% of total taxa. This shows that the benthic fauna is rather homogenous and subject to little spatial variability around the drilling centre. Therefore, the average abundance and average proportional contribution in terms of individuals and taxa is relevant to describe the benthic fauna. These parameters are shown in Table 4.3. This domination of Annelida at the drilling centre is partly due to a relatively high abundance of the polychaete Prionospio ehlersi, the most abundant species in the survey around the drilling centre, with 1,216 individuals accounting for 58% of the total individuals recorded (Gardline, 2012). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 103 Figure4.24 Indicative Primary Productivity (mg Cm-3 per day) Offshore Mauritania in February 19.5° 19.0° 18.5° 18.0° 17.5° 17.0° 16.5° 16.0° 15,50 21.0° 20.5° 20.0° 19S 19.0° 18.5° 18.0° 17.5° 17.0° 16.5° 16.0° 15S Source: Atlantic Research Institute of Marine Fisheries and Oceanography (AtlantNIRO, 2009) On the pipeline route, the benthic fauna community was found to be dominated by polychaete annelids and crustacean arthropods. Polychaetes contributed between 3% and 95% of the total individuals and between 32% and 81% of the total taxa depending on the station. This highlights a variable faunal community along the proposed route. At the stations where polychaetes contributed a higher proportion of the total individuals, it was partly due to a relatively high abundance of the polychaete Prionospio ehlersi, which was the second most abundant species in the survey, with 1,127 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 104 individuals and accounting for 11% of the total number of individuals recorded. Crustaceans contributed between 3% and 94% of the total individuals and between 11% and 49% of the total taxa depending on the station. The crustaceans Ampelisca spp. was the most abundant species in the survey, with 2,052 individuals accounting for 20% of the total number of individuals recorded. Figure 4.25 and Figure 4.26 represent this distribution by showing the abundance of individuals and taxa at each sampling station (near-shore included). Table 4.3 Contribution of the Gross Taxonomic Groups at the Drilling Centre Annelida (Polychaeta) 2001 95.7 55 79.7 Arthropoda (Crustacea) 76 3.6 8 11.6 Molusca 8 0.4 5 7.2 Nemerta 7 0.3 1 1.4 Source: Gardline, 2012 Figure4.25 Individual Abundance at the Sampling Stations on the Pipeline Route OArthropooa (Crustaoeca] 8 lGO'~ OAnn~!ld;a (Polyehaecta} - - - - - - - - - - - - 1 1 ., 1400t--~:=:=:=:=:=:=:=~-----------~·· ~ 1~ot--------------------------~··• !!! i 100\D+.-----------------------------------~-r--~ 11 ®00 +------------:=::---------------+ 0 " ; ,. ., ~ s: .., E s "' ~ ... "" • ~ .... "' ~ i' "' "" "" ... :e :;j: Iii" Iii" ;;; "" ~ ~ "" "' • "" ~ ~ F:: "' "' !::l • " " " " .. " " It It II " "'~ ~Ji s "' s ~ .. s '" s .s "' s ~ s i s $! s " s s ~ " s s s N s ... s "' ~ "' > ~ ffi llJ ~ ~ llJ ~ Ul llJ Ul > m m i w Station "' > 1!i "' i w z ~ "'• "" z ! ."', z ~ z Source: Gardline, 2012 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANJA) PTYLTD 105 The IUCN Red List of Threatened Species identifies 18 species from these four taxonomic groups in Mauritania that are all of Least Concern or Data Deficient. None of these species were observed during the EBS. In 2005, carbonate mud mounds have been recorded approximately 15 km from the drilling centre (Colman et al, 2005), at the approximate depth contours of 450 to 550 m, approximately 60 km from shore (Figure 4.27). In the past these mounds were inhabited by dense communities of cold-water corals including Lophelia pertusa. However, Colman's survey in 2005 found the coverage by live coral was greatly reduced in comparison to previous surveys. He postulated that this decline could be caused by trawling by fishermen in the area or the result of natural decline as a result in a change in oceanographic conditions such as a change in water temperature, currents (affecting food supply and/ or sedimentation rates). This rare habitat was not observed by Gardline in the vicinity of the drilling center , nor on the Pipeline route during the EBS (Gardline, 2012). Figure4.26 Abundance of Taxa at the Sampling Stations on the Pipeline Route " s. iii tl i tl i II i rr fi i tt i if ii M : ~ li ~ i !I i II .« II . "' n ill> .e .e .e s. .e .e " " .e lf .e .e If .e .e " .e s. .e .e s. !" ~ ~ iw ~ ~ ·.~ i i' > ; g :;$; > :ll > i ~ ~ ~ > if! til w w w w w li iii iii iii ai ~ z w, "' z WI "' z :1 z Sbtion Source: Gardline, 2012 The Gardline EBS survey concludes that there was no indication of any· sensitive habitats, nor was there any evidence of threatened and/ or declining species such as those listed under the IUCN Global Red List of Threatened Species and those on the OSP AR (2008) list of threatened and/ or declining species and habitats (Gardline, 2012). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 106 4.4.3 Fish The fish communities present on the offshore Project area are described in Section 4.7. This section also describes the fisheries and the economic activities linked to the fish. Figure4.27 Location of Carbonate Mud Mounds (Colman et al, 2005) 0 10 20 30 Nation boundaries Proposed offshore pipeline Mauritania Proposed onshore pipeline Proposed gas wells Carbonate Mud Mounds I Location of Carbonate Mud Mounds Source : Colman et at (2005) Source: Colman et al, 2005. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 107 4.4.4 Marine Mammals Cetaceans About twenty species of cetaceans have been identified in Mauritania (Perrin, 2007). Most are not threatened with extinction according to the IUCN Red List (UICN, 2011). Only the Atlantic humpback dolphin (Sousa teuszii) is listed as vulnerable (VU). The fin whale (Balaenoptera physalus) and blue whale (Balaenoptera musculus) are listed as endangered (EN). The upwelling of high-productivity cold water explains the presence of species that are normally found in the temperate and cold waters of the North Atlantic (Robineau, 1998). The observations made during the seismic surveys carried out in Block C2, about 120 km south west of the proposed Project area have been used to compile this description of the baseline environment. Observers on board the vessel for the 2D seismic survey carried out by Tullow in June-July 2011 identified 8 specimens of baleen whales in the survey zone and 1,825 specimens of toothed whales (over a total observation time of 332 hours) (RPS, 2011). 65 sightings of marine mammals comprising a total of 5,622 individuals were made by th~ observers on board the vessel for the 3D seismic survey carried out by Tullow during the first phase in May-June 2012 (over a total observation time of 392 hours) (RPS, 2012). A total of 9 marine mammal species were positively identified: blue whale, humpback whale, sperm whale, short-finned pilot whale, bottlenose dolphin, Risso's dolphin, atlantic spotted dolphin, (short-beaked) common dolphin and rough-toothed dolphin. Marine mammals not identified to species level were described as unidentified dolphins, small whales and rorqual whale species (RPS, 2012). 150 sightings of marine mammals comprising a total of 4,825 individuals were made by the observers on board the vessel for the 3D seismic survey carried out by Tullow during the second phase in September-October 2012 (over a total observation time of 280 hours) (RPS, 2012). In addition to species already identified during the previous surveys, sightings of killer whales (Orcinus orca) and pantropical spotted dolphin (Stenella attenuata) were reported during this survey. The sensitivity of cetaceans to noise is addressed in Chapter 5. Baleen Whales The West African coast is located on a whale migration route: in the summer they find their food in the North Atlantic, which they leave in the winter to travel to breeding sites located close to the equator. This phenomenon is particularly marked for the humpback whale (Megaptera novaeangliae), listed as ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 108 of Least Concern on the IUCN Red List. Peak times for the gathering of these animals are observed in February-March at breeding sites in the south and between June and August in the north (Rosenbaum, 2006); migrating individuals are likely to be present in the Project area between those two periods. The fin whale (Balaenoptera physalus) is also likely to be found within the Project area. Classified as endangered by the IUCN Red List, very little information exists regarding the abundance of this species in Mauritanian waters. Whale species likely to live or migrate in the Project area are shown in Table 4.4. Observers on board the seismic vessel for the 2D seismic survey carried out by Tullow in June-July 2011 observed 5 individuals of the genus Balaenoptera (edeni or borealis) and 3 individuals of the Balaenopteridae family. Observations were not sufficiently close to enable identification of the species and particularly to identify whether the five individuals of the Balaenoptera genus were Bryde's whales (Balaenoptera edeni) or Sei whales (Balaenoptera borealis). The latter species (classified as Endangered by the IUCN) is not mentioned in literature as being present in Mauritanian or Senegalese waters. It is therefore more likely that the individuals observed were Bryde's whales (RPS, 2011). During the first phase of the 3D seismic survey carried out in May-June 2012, one single blue whale (Balaenoptera musculus) was visually detected (RPS, 2012). Three humpback whales (Megaptera novaeangliae) were visually detected on one occasion during the first phase of the 3D seismic survey carried out in May-June 2012 (RPS, 2012). Toothed Whales In October 2008, Mauritania signed a Memorandum of Understanding on the conservation of manatees and the small cetaceans (all toothed whales, with the exception of the sperm whale (Physeter macrocephalus)) of Western Africa and Macaronesia, within the framework of the Convention on Migratory Species (CMS) of the UNEP, which includes signing up to action plans for the conservation of these two species. These Action Plans aim to reduce or eliminate any threat to these species and thus ensure their conservation. With the exception of the harbour porpoise (Phocoena phocoena), several species of toothed whales identified in Mauritanian waters are likely to be found in the Project area. The most sensitive of these species is the Atlantic humpback dolphin (Souza teuszii), in view of its endangered population and its restricted and fragmented range of action. It is endemic to the coastal waters of tropical and subtropical West Africa. This species figures amongst the threatened species ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 109 listed in Annex I of the CITES and is classified as vulnerable (VU) on the IUCN Red List. It is found in coastal or estuary waters and rarely more than 1km from the coast or at depths of more than 20m. According to Robineau & Vely (1998), this species is found most commonly within the boundaries of the Bane d' Arguin National Park and occasionally around Nouamghar. This study reported 15 strandings and 15 sightings between Cap Timiris (inside the park) and Grand Plage just south of Nouamghar. Similarly, Maigret (1980) identified two hotspots inside the Park based on 18 sightings. The Bane d' Arguin National Park being located approximately 150 km north of the Banda Field, the probability of finding an Atlantic humpback dolphin within the local Project area is low. No observation of Atlantic humpback dolphins was reported by the observers on board the seismic vessel during the 2D seismic survey carried out in June- July 2011 or during the two phases of the 3D seismic survey carried out in May-June 2012 and September-October 2012. Sperm whale (Physeter macrocephalus) is classified as vulnerable (VU) on the IUCN Red List (IUCN, 2011). It is important to note that the cause of the population reduction in this species (commercial whaling) is reversible, understood, and is not currently in operation. The species has a wide geographic range and a global population size in the 100,000's (IUCN, 2011) and can potentially be encountered in the Project area. Sperm whales were observed on one occasion during the first phase of the 3D seismic survey carried out in May-June 2012. This sighting took place in deep waters of just under 2,000 m and comprised 5 animals remaining in close proximity to each other, blowing and travelling briefly at the surface (RPS, 2012). Sirenians The West African manatee (Trichechus senegalensis) is classified as vulnerable (VU) on the IUCN Red List. It lives in inshore, estuary and riverine areas such as estuary lagoons and mangroves and should therefore not be found in the sea in the local Project area. No sirenians were observed by observers on board the seismic vessel during the 2D seismic study carried out by Tullow in June-July 2011 or the 3D seismic study carried out by Tullow in May-June 2012 in the nearby Block 2. Pinnipeds The northern Mauritanian coasts are home to colonies of monk seals (Monachus monachus) around the rocky coast of Cap Blanc, a species classified as in critical danger of extinction (CR) on the IUCN Red List. This highly sensitive species should not be found in the Banda licence area which is located more than 300 km to the south of identified colonies. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 110 No pinnipeds were observed by observers on board the seismic vessel during the 2D seismic study carried out by Tullow in June-July 2011 or the 3D seismic study carried out by Tullow in May-June 2012 in the nearby Block 2. Summary The marine mammal species identified in Mauritanian waters, their conservation status, the number of sightings during the 2D seismic survey carried out in June-July 2011 and the two phases of the 3D seismic survey carried out in May-June 2012 and September-October 2012, as well as a . qualitative assessment of their probability of presence within the Project area are summarized in Table 4.4. · Several other marine mammals have been mentioned in the literature, but data concerning their abundance is rare and it has not been possible to confirm their presence. The following species could be encountered within the Project area, but their presence is not considered very likely: • dwarf sperm whale (Kogia sima); • long-finned pilot whale (Globicephala melas); and • minke whale (Balaenoptera acutorostrata). Figure4.28 Blue Whale Recorded during the 3D Seismic Study of nearby Block 2 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 111 Table4.4 Marine Mammals Species Identified in the Project Area- Sightings Recorded during Seismic Surveys in Nearby Block C2 Least concern Insufficient data 1 Pilot whales were observed on 22 occasions, including 4 sightings of mixed species. During these events~ positive species identification as short-finned pilot whales was only possible during one sighting. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTY LTD 112 Figure 4.29 Common Dolphin Recorded during 3D Seismic Study of the Nearby Block 2 4.4.5 Marine Turtles The Mauritanian coast and the north of the Senegalese coast are home to marine turtle nesting sites (Fretey, 2001). Amongst them are notably the presence of loggerhead sea turtles (Caretta caretta) and green sea turtles (Chelonia mydas), which are both classified as endangered species (EN) by the IUCN. Hawksbill sea turtles (Eretmochelys imbricata) and leatherback sea turtles (Dermochelys coriacea), are also reported and are classified as critically endangered (CR). The potential presence of olive ridley sea turtles (Lepidochelys olivacea), classified as a vulnerable species (VU), is also noted. The observations made during the seismic surveys carried out in Block C2, about 120 km south west of the proposed Project area have been used to compile this description of the baseline environment. Observers on board the seismic vessel during the 2D seismic study carried out by Tullow in June-July 2011 in the nearby Block 2 identified 17loggerhead turtles and 6 olive ridley turtles (over a total observation time of 332 hours) in the survey area. 41 other observations of turtles were made, the species of which could not be identified (RPS, 2011). A total of 11 turtle sightings (all single individuals) were made by the on board observers during the first phase of the 3D seismic survey carried out by Tullow in May-June 2012 (over a total observation time of 392 hours). Two turtle species were positively identified: the loggerhead turtle and the olive ridley turtle. Turtles not identified to species level were hard-shelled turtles (i.e. notleatherbacks), briefly seen at surface, or seen sub-surface (RPS, 2012). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 113 A total of six turtle sightings (all single individuals) were made by the on board observers during the second phase of the 3D seismic survey carried out by Tullow in September-October 2012 (over a total observation time of 280 hours). One loggerhead turtle was positively identified. Turtles not identified to species level were hard-shelled turtles (i.e. not leatherbacks), briefly seen at surface, or seen sub-surface (RPS, 2012). The five species of marine turtles identified in Mauritanian waters, their conservation status, the number of sightings during the 2D seismic survey carried out in June-July 2011 and the two phases of the 3D seismic survey carried out in May-June 2012 and September-October 2012, as well as a qualitative assessment of the probability of their presence within the Project area are summarized in Table 4.5. In the nesting season, major turtle migrations can be observed. Knowledge of the beaches, and above all of the nesting seasons, is essential in order to take into account the sensitivity of these species. The known nesting locations of species which breed in Mauritania and the distances to the Banda field and the proposed landfall are discussed and assessed in the following species specific sections. Green Turtle Green turtle (Chelonia mydas) is the most abundant turtle species in Mauritania. Its breeding period would appear to be centred on the months of July-August (Maigret, 1977) and, more specifically, during the last two weeks of July and the first two weeks of August for the beaches in the Langue de Barbarie National Park (Maigret 1978). Archives held by this National Park do indicate, however, an egg-laying season of June-July (Fretey, 2001). Further south in Senegal a second egg-laying season has been reported (Maigret 1977), which has caused some authors to refer to a double breeding period from January to March and then from July to October (Dupuy, 1986). In the north of Mauritania, fishermen have reported observations of mating in June-July in the Bane d' Arguin and nesting on the beaches of the Bane d' Arguin and on the Baie du Levrier (Maigret, 1983). Juveniles are omnivorous in their first year of life but sub-adults and adults are herbivorous, feeding mainly in coastal seagrass meadows. In Mauritanian waters the large seagrass beds at Bane d' Arguin provide an important feeding area for individuals from breeding colonies both in Mauritania as well as in other West African countries. The known distribution in West Africa is shown in Figure 4.30. The Bane d' Arguin and the Langue de Barbarie National Parks are located approximately 160 and 170 km away from the Banda Field respectively. Similarly the proposed pipeline landfall is located more than 130 km from the boundaries of the Bane d' Arguin and 250 km from the Langue de Barbarie in Senegal. In consequence, the Project should not have an impact on the major nesting sites of Green Turtles. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 114 Loggerhead Turtle The loggerhead turtle (Caretta caretta) is relatively abundant in Mauritanian waters. Its breeding period corresponds to the rainy season and lasts from July to October (Dupuy, 1986). The same author reports observation of nesting in the Langue de Barbarie National Park in January 1982 (approximately 160 km from the Banda Field). This observation is not confirmed, however, in the National Park archives (Fretey, 1990). Fretey states that laying "appeared to be very rare and took place indifferently in January, March, June, August or September and not from July to October as stated by Dupuy" (Fretey, 1990). Observers on board the seismic vessel during the 2D seismic survey carried out by Tullow in June-July 2011 identified 17loggerhead sea turtles. During the first phase of the 3D seismic survey carried out by Tullow in May- June 2012, loggerhead turtles were seen on 2 occasions, both times in water depths of -1,500 m and both being detected at approximately 25m from the beam of the vessel (RPS, 2012). There are also reports of loggerhead turtle nests in the Bay of Tanit, from observations made in 1994 (Arvy et al, 2000). The bay of Tanit is located approximately 65 km from Nouakchott and 55 km from the proposed pipeline landfall. Loggerhead turtles are carnivorous, with adults largely feeding on benthic species and juveniles and sub-adults feeding on pelagic species. Known distribution in West Africa is shown in Figure 4.30. Major nesting areas of loggerhead turtles are more than 55km from the proposed Project location and proposed pipeline landfall and should not be impacted by the Project activities. Hawksbill sea turtle The Hawksbill sea turtle (Eretmochelys imbricate) is rare on the Mauritanian coast. It is unlikely that this turtle would breed in this location (Fretey, 1987). Leatherback Turtle Dermochelys coriacea is rare in the study area. Numerous observations at sea were reported in the north of Mauritania in the seventies (Maigret, 1983). Very little is known about its nesting habits in the region, but the leatherback turtle has been recorded in Mauritania (Fretey, 1987). Some studies have identified individuals in Mauritanian waters that nest in America (Eckert, 1989). Fishermen have reported that this species lays eggs in August and September (Fretey, 1990). Sporadic egg-laying has been reported in the Langue de Barbarie National Park and north of the Bane d' Arguin in the Baie du Levrier (Fretey, 1991). Adults feed almost exclusively on jellyfish, traveling to cold waters after breeding where prey species are more abundant. Very little is known about ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY L TO 115 the distribution of juveniles, although they are likely to remain in relatively coastal waters until they mature into sub-adults. Figure4.30 Known Presence of Green Turtles and Loggerhead Turtles in West Africa Green Turtle Source: Fretey, '2012 Olive Ridley Turtle There are reports of Olive ridley turtles (Lepidochelys olivacea) being observed in the 1950s in Nouadhibou; however it is probable that Senegal constitutes the northern limit for the breeding range of this species (Maigret, 1983). Records of shells beached in Mauritania confirm that the species is present in Mauritanian waters. Six observations of olive ridley turtles were reported by observers on board the seismic vessel during the 2D seismic study carried out by Tullow in June- July 2011. During the 3D seismic study carried out in May-June 2012 a single olive ridley turtle was recorded. Kemp's Ridley Turtle Kemp's ridley turtle breeds in the Gulf of Mexico and its core range is within the Gulf of Mexico and the south eastern coast of the USA. However vagrant individuals are sometimes found on the shores of the Atlantic Ocean. The presence of this species in Mauritanian waters is confirmed by sporadic findings of shells. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 116 Table 4.5 Marine Turtle Species Identified in the Project Area- Sightings Recorded during Seismic Surveys in Nearby Block C2 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 117 Summary It is important to note that the rainy season, which extends from June to October is the most sensitive time for marine turtles. The months of July and August in particular correspond to peak nesting times Major nesting areas of loggerhead and green turtles are located more than 55 km away from the proposed landfall and should not be impacted by the Project activities. Figure4.31 Green Turtle Recorded within the Licence Area during the 3D Seismic Study of Nearby Block 2 Figure4.32 Olive Ridley Turtle Recorded within the Licence Area During the 3D Seismic Study of Nearby Block 2 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 118 4.5 TERRESTRIAL ECOLOGY 4.5.1 Methodology and Sources of Data Considering the limited data available, the terrestrial ecology baseline is mainly based on data collected during two visits undertaken by ERM: • one initial scoping site visit (including fauna and flora investigations on 9- 13 July 2012); • a biodiversity survey undertaken on 6-9 November 2012. During these two surveys, most of the proposed pipeline route, the gas plant location and the surrounding environment have been covered, allowing to present a representative assessment of the issues related with fauna and flora. In addition, this study includes a compilation of the results of an avifauna inventory, undertaken during the 3D seismic study of the nearby Block 2 in May-June 2012 (RPS, 2012). Even though the Project is not directly located within Block 2, the species inventoried during this survey have been taken into account, as all these pelagic species are considered to be potentially located into Project area because of their migratory status. The assessment of onshore natural habitats was based on a preliminary analysis of satellite imagery; this pre-mapping has been verified during the field visits, in order to obtain a precise land cover map and a good description of the representative vegetation of each habitat. The assessment of flora took place over 30 vegetation plots (Figure 4.33), representative of the various natural habitats encountered within and around the Project footprint. Flora species have been identified on the field or brought back for further identification. The assessment of the fauna has been realized on the same time that habitats and vegetation; every animal encountered during the field visits has been recorded; the identification has been done directly on the field (most of the species) or latter using photographic logs. With regards to seabirds, the beach area has been monitored during the breading season (July field visit) and the migration season (November field visit). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 119 Figure 4.33 Monitoring Tracks and Vegetation Plots 4.5.2 Natural Habitats General Context The terrestrial study area presents different abiotic characteristics influencing the characteristics of natural habitats, in particular: • soil salinity and exposure to sea-spray; and • the mobility of the soil substract. The biodiversity surveys has allowed to identify seven different habitats within the onshore study area. The localisation of these habitats on for the local study area (1 km buffer) and the regional study area (5 km buffer) is presented on the Figure 4.34 and Figure 4.35and. The Table 4.6 below presents the cover surface of each habitat into the 1 km and 5 km study areas. Table4.6 Land Cover Surface ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY L TO 120 Figure4.34 Land Cover in the Local Study Area (1 km) LEGEND Study Area 1 km Proposed gas processing faci!rty Proposed onshor-e pipeline Land Cover Coasla! shifting dunes Temporaril~· flooded area {excepted Sebkha) Bare soil with Zygophyllum Open low shrubs with Euphorbia ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 121 Figure4.35 Land Cover in the Regional Study Area (5 km) Proposed gas processing facility Proposed onshore pipeline Coastal shifting dunes Temporarily flooded area (excepted Sebkha) Bare soil with ZygoptlyUum Open !ow shrubs wtth Euphorbia Other anthropized areas ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 122 Foreshore The beach corresponds to the area delimitated by the highest tides; there is very scarce vegetation, and the main living species using this habitats are seabirds, some molluscs and some small mammals (rodents and small carnivores). Figure4.36 Foreshore from the Landfall Site Coastal Shifting Dunes This habitat directly subject to sea spray is mainly populated by salt-tolerant species, such as Zygophyllum fontanesii and Calotropis procera (Figure 4.37). The substratum is loose and mobile, and exposed to sea spray. Sebkha The sebkha, behind the dunes, becomes seasonally flooded with salty water in August-September (depending on rainfalls), and the substratum presents high salinity and humidity. In these conditions the flora is poorly developed, and is mainly represented by herbaceous plants resisting to high salt- conditions (Figure 4.38). In the study area, the main sebkha is located on the South close to the pipeline route; historically, it communicated with the Great Sebkha of Ndramcha, but the construction of the main sealed road between Nouakchott and Nouadhibou seems to disrupt the flows between these two areas. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 123 Figure4.37 Coastal Dune with Zygophyllum fontanesii and Calotropis procera Calotropis procera Figure4.38 Sebkha Temporarily Flooded Area (except Sebkha) Some areas around the sebkha are only very temporarily flooded seasonally, and present some significant differences with the sebkha, essentially: ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 124 • transitions areas with the dunes and/ or open shrubs habitats around the sebkha; or • temporar flow stream in direction of the Great Sebkha of Ndramcha. The second configuration can be visualized on the Figure 4.35, where the temporarily flooded areas (excepted sebkha) are orientated from South-west to North-east. The vegetation is composed by the same species that the ones encountered on the sebkhas and on the dunes and is mainly represented by salt-tolerant and water-tolerant species, including Zygophyllum fontanesii and species such as Nitraria retusa, mainly found in the slightly higher areas, where soil salinity and humidity levels are more favourable (Figure 4.39). Figure4.39 Temporarily Flooded Area Bare Soil with Zygophyllum This natural habitat is mainly developed on a calcareous substratum with high drainage capacity; the sparse vegetation is mainly composed by Zygophyllum fontanesii; some acacias (Acacia sp.) are also present. In the areas close to the road, this natural habitat is in a poor state of conservation, due to the local gravel mining activities for construction (Figure 4.40). Figure4.40 Bare Soil with Zygophyllum ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 125 Open Low Shrubs with Euphorbia This habitat is mainly composed by fixed back dunes, and is developed on compacted sand associated with shells. The soil of the areas covered by shells is more compact and hosts burrows of small mammals. The flora is mainly represented by Euphorbia balsamifera (cf. Figure 4.41 ), as well as by some shrubs of Acacia sp. and Salvadora persica. Figure4.41 Dune with Euphorbia balsamifera Inland Dunes The back dunes, fixed and farther from the sea, present a loose substrate explaining a low vegetation cover; flora is mainly represented by Calotropis procera and Euphorbia balsamifera (Figure 4.42); a very limited number of herbaceous plants like Cyperus conglomeratus were observed. Figure4.42 Inland Dune ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTY LTD 126 Shrubs Some shrubs are occasionally found into the Project area. The trees of this habitat are used by an important number of birds during breeding season for nesting. This habitat is considered as of moderate sensitivity into the study area. This habitat has not been mapped because of its much reduced size. Reforestation Project Two of these habitats are concerned by a reforestation project; this project is managed by the Mauritanian Authorities and concerns an area of 334.8 ha and of 725 ha into the 1 km and 5 km study areas. This project consists in planting a red of hedges of Euphorbia balsamifera (Figure 4.43) in order to fix the dunes; the planted areas are fenced. The Figure 4.44 shows the location of the concerned areas, and the detail of the surfaces of habitats concerned by the reforestation is presented on Table 4. 7. Table 4.7 Habitats Concerned by the Reforestation Project in the Study Area ENVIRONMENTAL RESOURCES MANAGEMENT. TULLOW PETROLEUM (MAURITANIA) PrY LTD 127 Figure 4.43 Example of Hedges of Euphorbia balsamifera and Satellite View of the Hedges ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 128 Figure4.44 Location of the reforested areas Study Area 1 km Proposed gas processing facility Proposed onshore pipeline Reforestation ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 129 4.5.3 Terrestrial Flora The location of the vegetation is influenced by three main parameters: water, temperature and light. On the desert areas, the high temperatures associated can explain the-low diversity of flora (compared to the other kind of climates and biogeographic regions); in Mauritania, about 360 different species have been inventoried (Ozenda, 1991). In the local study area, 14 species from 10 different families were identified (Table 4.8). Table4.8 Results of the Flora Survey Only on the coastal NA dunes Broad-leaved NA Cud weed NA ae Mainly in dunes and LC e sandy habitats Fabaceae Umbrella Thorn Acacia Grarninac Chloris prieurii NA aea Salvadora Salvadora persica Mustard tree NA ceae Zygophyll aceae NA IUCN status: LC =Least concern; NA =Not assessed by the IUCN Red List None of the flora species are protected by the Mauritanian legislation, and 14 of the species are not assessed by the IUCN; the only assessed specie is considered as "least concerned". (1) Deere! n° 83-159 bis portant protection de certaines especes herbacees. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 130 Figure4.45 Flora Inventoried in the Study Area Heliotrapium ramosissimum Zygophyllum simplex 4.5.4 Terrestrial Fauna Birds (including Seabirds) More than 500 species of birds are present in Mauritania, including about 150 breeding species. The study area is located into the transition zone between the Palearctic and the Afrotropics, and birds from both zones are able to breed around the Project area (Isenmann, 2010). The west coast of Africa forms an important section of the East Atlantic Flyway, an internationally important migration route for a range of bird species, especially shore birds and seabirds (Boere et al, 2006; Flegg, 2004). A number of species that breed in higher northern latitudes winter along the West African coast and many fly along the coast on migration. Seabirds known to follow this migrati<_m route include a number of tern species (Sterna spp), skuas (Stercorarius and Catharacta spp) and petrels (Hydrobatidae). The distance of the migration routes of these species from the shore depends on prey distribution and availability, such as the abundance and distribution of shoals of anchovies or sardines (Flegg, 2004). The highest concentrations of seabirds are experienced during the spring and autumn migrations, around March and April, and September and October. Waders are present during the winter months between October and March. Species of waders known to migrate along the flyway include sanderling (Calidris alba) and knott (Calidris canuta). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 131 The coastal areas of Mauritania, and particularly the Senegal delta, hosts a very large number of seasonally migrating birds. The protected areas An Important Bird Area (IBA), identified by Birdlife International has been identified 11 km south of the proposed gas processing facility (see Section 4.6). Three species of bird, known to live or stay during the course of their migration in the Mauritanian marine environment, are considered as Near Threatened (NT) according to the IUCN Red List. These are the Audouin's gull (Ichthyaetus audouinii), the black-tailed godwit (Limosa limosa) and the lesser flamingo (Phoeniconaias minor). These three species are mainly found on the Mauritanian coast between October and March, but have not been monitored during the November biodiversity survey on the terrestrial part of the study area. In addition to coastal birds, the study area supports a number of migratory pelagic seabirds. A number of bird species were recorded during the 3D seismic study of the nearby Block 2 during May-June 2012 (RPS 2012- Table 4.9). Seabirds have also been monitored on the shore and on the beach during the terrestrial biodiversity surveys. Most of the species have been monitored during the July site visit, and there seem to use the coast as resting area and feeding area; no nesting or feeding youth have been observed while the scoping visit, and we can assume there is no breeding colony of seabirds within the study area. During the November visit, the seabirds inventoried were mostly migratory birds. Desert birds, such as Alaemon alaudipes and Eremopterix nigriceps, have been identified on the dunes and the sandy areas; these species are common within the study area. Other species non-specific of deserts and arid areas have also been identified, mainly on bushes and dense shrubs. These species are for example the Merops persicus, which presence is due to small sand quarries localised around the study area and which present favourable habitats for the specie. These species are presented in Table 4.9. Table4.9 Seabird Species Recorded During the 3D Seismic Survey of the Nearby Block 2 in May-June 2012 alaudipes Calidris alba No LC Calonectris No LC diomedea Caprimulgus Wintering No LC eximius ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 132 Offshore area (pelagic bird) Foreshore and seaside Brown- All No LC necked Raven Black- All, particularly shrubs No nigriceps crowned No area (pelagic No LC No .LC caspia Lanius Great Grey Onshore habitats No excubitor Shrike Lanius Woodchat Onshore habitats No senator Shrike Blue-cheeked All No area (pelagic No area (pelagic Migratory No area (pelagic Migratory No or No Passer luteus No LC Pelacanus area (pelagic Migratory No onocrotalus pelican Puffinus Sooty area (pelagic Migratory No NT grise us shearwater Stercorarius Arcticskua area (pelagic Migratory No parasiticus Pomerine area (pelagic Migratory No skua Stercorarius Great skua area (pelagic Migratory No skua Little tern area (pelagic Migratory No Sterna area (pelagic Migratory No hirundo Sterna Royal tern Offshore area (pelagic No maxima bird) Foreshore and seaside Sterna Arctic tern Offshore area (pelagic No paradisaea bird) Foreshore and seaside Sterna Sandwich Foreshore and seaside No sandvicensis Tern Sterna sp. Tern sp. No ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTY LTD 133 Urocolius Breeding No LC macrourus Xemasabini Migratory No LC IUCN status: LC=Least Concern; NT= Near Theatened; "-"=Not assessed Almost all of the birds recorded were species categorised as Least Concern by IUCN. The only species with a higher conservation status recorded during the study was sooty shearwater, categorised as Near Threatened by IUCN. These species have different status into the study area: • Migratory species: birds (for ex: great white pelican -Figure 4.46) only present during the migratory periods (between March and April, and September and October) on the study area. • Feeding/resting: species (e.g. Caspian tern- Figure 4.46) using the seaside and the beach area to feed and rest, during summer (no reproduction). An overview of the characteristics of the study area did not show any particularity, and we can consider that these species are also present on other parts of the Mauritanian seaside and that the study area does not represent important feeding/ resting area for the conservation of these species. • Wintering species: regarding the period of the biodiversity survey (November), it is sometimes not possible to determine if some species are migratory or wintering (for ex: Golden Nightjar- cf. Figure 4.46). In both cases, the area does not present specific characteristics, and we can consider that these species are also present on other parts of the Mauritanian seaside and that the study area does not represent important wintering area for the conservation of these species. • Breeding and resident species: these species (for ex: Blue-cheeked Bee- eater, Blue-naped Mousebird or Namaqua Dove - cf. Figure 4.46) are mainly onshore bird and there are not specific to the onshore habitats present into the study area; these habitats do not represent important area for the conservation of these species; however, the shrubs are used by an important diversity of birds, and represent an interest for the biodiversity into the study area. There are 24 Important Bird Areas (IBAs) identified by Birdlife International within Mauritania (Birdlife International, 2012). The coastal IBAs are described in Section 4.6. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 134 Figure4.46 Birds Observed during the Biodiversity Survey Pelecanus onocrotalus Hydroprogne caspia Caprimulgus eximius Terns (Chlidonias niger and Sterna sandvicensis) Merops persicus (couple) Nest of Merops persicus Urocolius macrourus Oena capensis Reptiles This class is mainly represented by lizards; signs of snakes have also been identified during the biodiversity surveys without any possibility to define ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 135 what species it was. The reptiles are essentially present within the dunes and the highest points of the sebkha. The list of the species identified into the local study area (1 km) and their protected status and vulnerability (IUCN status) are presented at Table 4.10. Four different species of Acanthodactylus (Figure 4.47) have been surveyed; none of these species have been assessed by the IUCN. A track of Varanus sp. has also been encountered, but it has not been possible to identify the species. The IUCN distribution data also mentions the potential localization of three other species of reptiles; their vulnerability status from IUCN is least concern. Table 4.10 Reptiles Identified in the Study Area Acanthodactylus boskianus asper Present No Acanthodactylus senegalensis Present No Agama Potential Cerastes vipera Potential No LC Chalcides sphenopsiformis Potential No LC No IUCN status: LC=Least Concern;" -"=Not assessed Mammals The mammals typical of desert areas are discreet and most of the species are nocturnal; their observation is difficult, and the best way for identification is to look at the tracks. The biodiversity survey permitted to identify the species of mammals using the Project area as habitat; a list is presented at the Table 4.11. This table also presents the potential threatened mammals based on the distribution data from IUCN, to define the potential species localized into the study area; 24 species have been identified as potentially present, and three of these species have been identified during the biodiversity survey. Only one species is considered as near threatened by IUCN, but the probability of presence in the study area is consider as very low. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 136 Figure4.47 Species of Acanthodactylus Obersved in the Study Area Acanthodactylus aureus Acanthodactylus boskianus asper Acanthodactylus longipes Acanthodactylus senegalensis Table 4.11 Mammals Identified in the Study Area ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 137 Figure4.48 Arabian Hare Domestic species such as camels are also present. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURJTANIA) PTYLTD 138 Figure 4.49 Dromedaries 4.6 PROTECTED AREAS FOR NATURE CONSERVATION No protected areas are present within a 100 km radius around the Project footprint. Further away, the following protected areas have been identified and shown on Figure 4.50: • the Chat'Tboul Nature Reserve (Biosphere Reserve, Ramsar Site, Important Bird Area) located approximately 180 km to the south of the proposed gas processing facility; • theDiawling National Park (Biosphere Reserve, Rarnsar Site, Important Bird Area) located approximately 185 km to the south of the proposed gas processing facility; and • the Bane d' Arguin National Park (World Heritage, Ramsar Site, Important Bird Area) located 130 km to the north of the proposed gas processing facility. An Important Bird Area (IBA) classified by the NGO Birdlife, is located 11 km south of the proposed gas processing facility. This IBA named" Aftout es Saheli" is a narrow coastal lagoon that extends from just south of Nouakchott for 165 km to finish some 60 km north of StLouis in Senegal. This Important Bird Area has no Protected Area status on a national level. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 139 Figure4.50 Protected Areas in the Vicinity of the Project Area Bane d' Arguin National Park itante g a 1 0 20 40km i N Proposed onshore pipeline Mauritania '''';Regional study area Proposed offshore Local study area pipeline Protected Areas Proposed Traffic from/to gas wells Nouakchott harbour Proposed gas (logistics support) processing facility · ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 140 4. 7 FISH AND FISHERIES 4. 7.1 Introduction This section provides a baseline description of fish and fisheries in Mauritania and in the Project area. It describes the species classified as threatened by the IUCN Red List and information on the industrial, artisanal and coastal fishing fleets and supporting infrastructure as well as fish landing data for Mauritania. It has been documented with international and national literature along with the results of the field survey which was conducted from 9 to 19 July 2012 and is further described in Section4.9 4.7.2 Fish 699 species of marine fish are listed for Mauritania by FishBase (Fishbase, 2011); 38 of these species are classified as threatened on the IUCN Red List (IUCN, 2012) and are presented in Table 4.12. Six have a critical status (CR), 10 are endangered (EN) and 22 are vulnerable (VU). 315 species are potentially fished commercially (Fishbase, 2011). 4. 7.3 Overview of Mauritanian Fishing Sector Economic Importance Mauritania has an Exclusive Economic Zone (EEZ) of 234,000 km2 and its coastal waters are among the richest fishing areas in the world. The fishing sector is one of the key economic sectors of Mauritania and represents about 6 to 10% of the Gross Internal Product (GIP) and 16% of the exports. 16 to 21% of the State's revenue is generated by this sector. 40,000 jobs are directly or indirectly related to the fishing industry, which is approximately 36% of employment in the country (BID, 2011). Despite its economic importance in Mauritania, fishing is not fully developed yet due to historical and traditional reasons but also due to logistics reasons: there is only one harbour suitably equipped to accommodate industrial fishing, Nouadhibou, but its economic development has been hampered due to its remoteness from Nouakchott. Nonetheless, the industry has been developing since the 1980s. The fisheries sector is one of the key strategic development areas of the Mauritanian government. Industrial and Artisanal Fishing The Mauritanian fishing fleet is subdivided into two sub-sectors: the industrial fleet and the artisanal and coastal fleet as described in Law 2000-025 of 24th of July 2000 (Article 5) pertaining to the Maritime Fishing Code, modified by Ordinance 2007-022 of 9th of April2007 and its Application Decree 2002-073 of 1st of October 2002. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 141 Table4.12 Fish Species Listed for Mauritania and Listed on the IUCN Red List Coastal and intertidal species which sometimes crosses ocean floors to reach islands I Possible out at sea. White skate Lives in sandy and detritus-filled coastal seabeds at depths of between 40 and 400 Possible m. Scalloped Semi-pelagic coastal species living at depths of up to 275 m. Possible hammerhead shark Undulate ray floors, generally in relatively shallow water in the I Possible of 200m. Rhinobatos rhinobatos I Common guitarfish ·\Lives on sandy and muddy ocean floors, generally in relatively shallow water in the I Possible intertidal zone, down to 100m. African wedgefish Lives on sandy and muddy ocean floors, generally in relatively shallow water in the I Possible intertidal zone, down to 75 m. Thresher shark Pelagic species living at depths down to 366 m, mainly out at sea, 40 to 50 miles Unlikely from the coast. Balistes vetula Queen triggerfish Species living in rocky or coral reefs, down to depths of 275 m, and generally Possible on the rocky between 0 and 30 m. floors on the pipeline route Carclzarhinus Oceanic whitetip Species living on the ocean floor at depths of more than 200m. Possible in the vicinity of longimanus shark the Drilling Centre ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 142 Lowfin gulper shark lusitanicus Centrophorus Leafscale gulper found close to the base of continental margins and in the first I Unlikely squanwsus shark Galeorhinus galeus Tope shark Possible Mustelus mustelus Common Coastal demersal species found on continental shelves and upper margins, Possible smoothhound shark generally at depths of between 5 and 50 m on sandy or muddy ocean floors and down to 350 m. Oxynotus centrina Angular rough shark I Lives on external continental shelves and on margins, at depths of between 60 and I Possible 660m. Rhincodon typus Whale shark Species migrating between oceanic basins and the coast, at depths of between 0 and I Possible 700m. Rhinobatos Whitespotted Coastal species living in relatively shallow water down to depths of up to 35 m. Possible albomaculatus guitarfish ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURIT AN!A) PTY LTD 143 Industrial Fishing Industrial fishing represents about 80% of the production of the country in quantity and value. 95% of the production is exported and only 10% of the exported production is processed (EU, 2010). Small pelagic species make more than 90% of the catches made by the Mauritanian industrial fishing fleet. Pelagic industrial fishing is mainly operated by foreign vessels ruled by EU /Mauritania fishing agreements (Table 4.13). Mauritania has agreements with EU fishing vessels for pelagic trawling (Lithuania, Latvia, Netherlands, Poland, UK) tuna and crusta~ean fishing (mostly Spanish vessels). Demersal fishing agreements are used by Spain, mainly for Senegalese hake (Merluccius senegalensis). Table 4.13 Number of Recorded Industrial Fishing Vessels Operating in the Mauritanian EEZ Mauritania also has established fishing agreements with Japan (tuna and octopus), China (mostly small pelagics), the Russian Federation (pelagics), Ukraine and Senegal (the latter for coastal fishing only). The coastal area is restricted to artisanal and coastal fisheries which generally fish at a maximum depth of 30 m and distance of 6 nautical miles from shore. According to DSPCM (Delegation ala Surveillance des Peches et au Controle Maritime), the Marine Authority in charge of fisheries surveillance and sea control and according to the fishing code, the restrictions for industrial fishing are as follows : • prawn fishing vessels cannot operate within 3 nautical miles of the Mean Low Water level; • cephalopods fishing vessels cannot operate within 6 nautical miles of the Mean Low Water level; and • pelagic fishing vessels cannot operate within 12 nautical miles of the Mean Low Water level. These zones h~lVe been moved away from the coast in order to allow the development of artisanal and coastal fishing. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 144 Fishing techniques used by the industrial fishing industry are varied and adapted to the targeted species: prawn trawls, bottom lines ("palangre"), angling, purse seine, Danish seine, pelagic trawl and bottom trawl. Trawls are forbidden in all zones with a depth of less than 20 min order to protect spawning and nursery grounds. Artisanal and Coastal Fishing Article 13 of the application Decree 2002-073 of 1st of October defines artisanal fishing as "all fishing activities achieved by foot or with an open boat, motorized or not, with an overall length of 14 metres or less. Fishing activities must use manual devices expect for purse seines that are allowed" In addition, the boats must be made out of wood, aluminium or plastic. The artisanal fleet is expanding and estimated to represent about 5,600 boats including 4,300 that are currently active in Mauritania (IMROP, July 2012). Mauritania signed a convention with Senegal for 300 fishing licences for pelagic fishing with an obligation to land 15% of the captures at Nouakchott. Figure4.51 Typical Artisanal Fishing Fleet Artisanal and coastal fishing are authorised to operate within six nautical miles from the coast. Nevertheless during consultation, artisanal fishermen mentioned conflicts with industrial vessels which did not respect the different fishing zones (see Annex A, ESIA Consultation Records for details). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 145 Figure4.52 Targeted Species for Artisanal Fishing Se!achians 15% Cephalopods 7% 38% Sciaenida 14% bster 0% 3% 5% Source: Profil des peches de Ia Mauritanie, FAO, 2004 Fishing Zones The Mauritanian EEZ is divided into 3 sub-zones : • Northern zone: Nouadhibou and Lagouiera with 62% of the landings (in tons). • Central zone: Pare du Bane d' Arguin with 2% of the landings. • Southern zone: M'heijratt to Ndiago with 35% of the landings and which corresponds to the project study area. 80% of the artisanal production lands at Nouadhibou and on the fish market of Nouakchott. There is no other fishing port in the area south of Nouakchott. The area south of Nouakchott consists of mobile and seasonal fishermen camps which are almost exclusively foreign fishermen (Senegalese and · Malians) despite the recent efforts of the government to create development centres between Belawakh and Ndiago. Infrastructure Nouadhibou is the main fishing port of Mauritania and has better commercial fishing infrastructure than Nouakchott. It hosts well-developed fishery activities, and operates a restricted marine area dedicated to artisanal fisheries. In Nouakchott, fishing activities are predominantly artisanal, and fish landings are concentrated at the sea-side fish market. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 146 Figure 4.53 Nouakchott Fish Market There are about 80 sites for fish processing in Mauritania, mostly freezing facilities but also fish meal production (EU, 2010). The EU estimates that only 50 of these facilities are operational and compliant with international sanitary standards. (EU, 2010) At a national level, the daily capacity for freezing fish is 700 tons from which only 30% is used (EU, 2010) There are nine fish meal factories in the country, seven of them being located in Nouadhibou and two near Nouakchott. The total capacity is-35,000 tons in 2010, equivalent to 175,000 tons of fresh fish. Figure 4.54 Fish Meal Factory at PK28, South of Nouakchott ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA} PTY LTD 147 Fishing Resources The fish resource potential of Mauritania is estimated at 1,500,000 tons per year and around 880,000 tons per year were landed on average between 2006 and 2010 artisanal and industrial fishing combined according to the National Office for Statistics (ONS, 2010) and the Institut Mauritanien de Recherche Oceanographiques et des Peches (IMROP, 2012). Industrial fishing represents the largest proportion of the landings compared to artisanal fishing. Figure 4.56 presents the proportion of industrial and artisanal fishing landings between 2006 and 2010. Figure 4.55 Industrial and Artisanal Fish Landings (in Tons) 1200 000 Pikhe Artisanale 600 000 Pee he lndustriel\e 400 000 200 000 0 2006 2007 2008 2009 2010 Source: ONS, 2010 for industrial fishing; IMROP, 2012 for artisanal fishing For industrial fishing, small pelagic fish represent about 90% of the catch landed but only 40% of the economic value of landings is retained in Mauritania. Demersal species make about 20% of the fish landings, cephalopods about 30% and crustacean about 10% (EU, 2010). Figure 4.56 shows the proportion of the species landed by industrial fishing. Fish resources in the coastal zone are relatively abundant and the artisanal fishing sector has developed in the last few years. Since there is limited fishing experience in Mauritania, the sector used foreign experience and work force to develop several profitable fishing fields with high potential for export and added value. The most common species to be found in the fish landings from industrial and artisanal fisheries are presented in the Table 4.14 overleaf. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 148 Figure4.56 Industrial Fish Landings in Tons per Category of Species 1.200.000 1.000.000 800.000 Crustaceans 600.000 Cephalopods Demersal 400.000 Pelagic 200.000 0 2004 2005 2006 2007 2008 2009 2010* Source: ONS, 2010 Fish is not commonly consumed in Mauritania, as a result of cultural habits and despite diminution of livestock production, droughts and rural depopulation toward coastal areas. The average consumption of fish is estimated to be 4.3 kg/ year/ capita (Sustainable Fisheries Livelihoods Programme, FAOjDFID, 2005). Table4.14 Most Common Species in Fish Landings ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 149 4.7.4 Fishing within the Study Area Fishing Traffic The reports from the stakeholder engagement survey were that only artisanal and coastal fisheries are present within the study area. However, the Collision Risk Assessment conducted by Anatec (Annex C) found that 67% of all vessels within the 30 nm around the Banda drilling centre were fishing vessels, and of these 80% were large industrial sized stern trawlers (Figure 4.57). It appears that the majority of the fishing vessels pass through the 30 nm around the Banda drilling centre at a speed of over 4 knots (approximately 91%) and can be assumed to be passing through the area and not actively fishing. The remaining fishing vessels travelling under 4 knots may have been fishing in the area. The path of these vessels is shown in Figure 4.58. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 150 Figure4.57 Fishing Vessel Traffic within the Vicinity of the Banda Field Figure4.58 Fishing Vessels Travelling under 4 Knots There are three main shipping routes, used by approximately 480 fishing vessels a year, within 30 nautical miles of the Banda field. This corresponds to ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 151 an average maritime traffic of one or two vessels a day. These shipping routes are shown in Figure 4.59. Figure4.59 Shipping Routes within 30 Nautical Miles of the Banda Field 0 15 Source: Ana tee, 2011. Organisation of the Artisanal Fisheries Sector in Mauritania The artisanal fisheries sector in Mauritania is organised as follows: • Some fishermen are employees of a chief fisherman who is basically an investor and frequently not a fisher himself. Fishermen are a seasonal labour force recruited from southern Mauritania or often from Senegal or Mali (especially for octopus fishing). The materials (boats, nets and sometimes the onshore camps) belong to the investor who cooperates with a pirogue captain who brings the expertise and is paid by the tonnage landed. Generally the price is fixed by the investor prior to the beginning of the season as well as apportionment of the earnings. The investor generally organises the fish landings and selling. The labour force is mobile along the coastal area depending on season and available fish resources. This kind of investor is often member of the Federation Nationale de Peche (FNP) - artisanal section. • Some fishermen are migratory fishermen who own their own boat and materials. These fishermen mostly originate from southern Mauritania (Ndiago) and are members of Federation Libre de la Peche Artisanale (FLPA). Most are seasonal migratory and work in different settlements depending on the season and available fish resources. Most sell their catch to ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 152 intermediaries (fish traders or "mareyeurs") who organise the transfer to fish market, factories or export. • Others are non-mobile fishermen, which is the case of the Imraguen tribes and some of the fishermen originating from southern Mauritania and settled in camps or in Nouakchott. They partly work for themselves and partly in cooperation with Mauritanian investors who contract them by pre-financing material and sometimes labour force. Figure4.60 Pirogue Captain and his Team Fishing Patterns and Techniques Most artisanal fishermen fish by day, the daily hours depending on the targeted species. Senegalese fishermen are most likely to practice "tide fishing" meaning sailing for several days until the ice they carry on-board is out of stock however this practice is a minor component of the artisanal fishing sector. Imraguen fishermen traditionally used to fish by foot from the shore but due to the decrease in coastal fish resources this technique has been abandoned for more than 20 years. Artisanal fishermen use traps (pot fishing), seine nets (with two boats), simple nets (cast nets) and drifting nets, depending on the prey. Fishing lines (angling) are also used to target tuna and groupers. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 153 Figure4.61 Traps for Cephalopod Fishing Figure4.62 Artisanal Fishermen Landing In all of these cases, artisanal fisheries remain within the limit of approximately six nautical miles from the coast. They do not therefore venture as far off as into the proposed Banda development area. Targetted Fish Species According to the fishermen communities consulted during the survey, the , most common species targeted by the artisanal fishing are: common octopus, white grouper, gilthead seabream, meagre, Senegalese sole, golden grey mullet, thicklip grey mullet, Mauritanian lobster, and common cuttlefish. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 154 Other fished species with minor significance are tuna, sharks, conger eels snails and skates. Figure4.63 Octopuses Caught by Artisanal Fishennen These species are fished during specific periods of time. The fishery is seasonally closed to protect the octopus reproductive seasons (1) from mid- May to mid-June and mid-October until mid-November. The Figure 4.64 below presents a seasonal calendar per species based on the statements of the fishermen gathered during the consultations carried out for this ESIA (see Annex A, ESIA Consultation Records). Figure4.64 Seasonal Calendar of Artisanal Fishing by Species (1) Diop, H. & Kazmierczak, Jr., R.F. 1996. TeclmologJJ and Management in Mauritanian Cephalopod Fisheries. Marine Resource . Economics, 11: 71-84. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURIT AN!A) PrY LTD 155 4.8 NON FISHING MARINE USERS 4.8.1 Non-fishing Maritime Traffic An important consideration of the local socio-economic conditions is the maritime traffic occurring in the Study Area, although no interaction with maritime traffic has been declared as problematic by the local communities. Table 4.15 Maritime traffic at Nouakchott Port de l'Amitie Table 4.16 Maritime traffic at Port Autonome de Nouadhibou A maritime traffic survey has been undertaken by Anatec as part of the Banda Oil Project and is attached in Annex C. The main results of this study are as follows: • there are five shipping routes that pass within 30 nautical miles of the Banda field; • an estimated 588 ships per year or 1-2 ships a day pass within 30 nautical miles of the Banda field; and • half of all ship traffic are cargo vessels; tankers and offshore support vessels make up the majority of the rest of the traffic with a smaller number of industrial sized fishing trawlers. Anatec' s ship density model was used to calculate the density of shipping based on the ship routeing database. A thematic map showing the estimated variation in shipping density around the local study area is presented in Figure 4.4. Higher density routes include one route heading south out of Nouakchott, as well as traffic associated with the petroleum activities supporting the Berge Helene FPSO on the operating Chinguetti field. In general the traffic levels are relatively low in the surrounding area. The risk of collision with vessels is discussed as part of the impact assessment within Chapter 5. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 156 Figure 4.65 Shipping Density Grid in the vicinity of the Banda Oil Drilling Centre 4.8.2 Submarine communication cables One existing submarine communication cable was identified in the Project area. The Africa Coast to Europe (ACE) fibre optic cable links Europe to the West Coast of Africa. It was initiated by France Telecom-Orange and administered by a consortium of 16 operators. It was inaugurated in December 2012. The proposed pipeline and umbilical will cross over the existing ACE fibre optic cable around 18° 6.6"N 16° 10.1"W in 15m of water. In this area the ACE cable is buried in coarse sand at around 0.8 m depth. Another submarine communication cable, the GLO 1 cable owned by the Nigerian operator Globacom Ltd, was identified as having a capability to connect Nouakchott through a branching unit. However at the time of drafting this EIA this branching unit was not installed. 4.9 SOCIO-ECONOMIC BASELINE 4.9.1 Introduction The data used for this report has been compiled from published literature as well as from the results of a field survey carried out from 9 to 19 July 2012 in order to gather more accurate and specific primary data. During the same ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 157 period stakeholder engagement activities were undertaken, and the methodology and outcomes of this consultation study are described in Annex A of this report. The consultation survey area was agreed with the DCE as the communities located along the stretch of coastline between PK 144 (which belongs to the commune of M'Balal) in the south to Nouamghar in the north (Figure 4.66). The purpose of the survey was to gather qualitative rather than quantitative data in order to gain an understanding of the overall area; therefore not all settlements have been surveyed. 4.9.2 Administrative Context Mauritania has a four level administrative structure which consists of: • 13 Wilayas (Governorates) including the District of Nouakchott which encompasses the whole of the consultation survey area. Wilayas are led by Walis (Governor) named by the state. • 53 Moughataas (Districts) which are led by nominated Hakems (Prefet). • 31 Arrondissements which are subdivisions of Districts covering certain parts of the country only. Officially abolished in 1990 but no decree was ever signed to this effect. • 216 Communes (Municipalities) including nine in Nouakchott. They are led by mayors (Maires) elected at municipal level. Settlements have been identified within the consultation study area of coastal communities and are listed in Table 4.17 below as well as the administrative divisions they belong to. Figure 4.66 presents the location of the surveyed settlements. Table4.17 Administrative Framework of Surveyed Settlements Traditional authorities (village chiefs) are not present all over the country. Within the consultation study area, village chiefs exists in Imraguen villages, ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 158 north of Nouakchott, whereas no traditional authorities were found in the settlements visited in the south of Nouakchott. The Imraguen village chief is elected among the elderlies and his duties are to provide advice, solve conflicts and manage daily life issues. 4.9.3 Demographics According to the estimates by the National Office of Statistics, the total population of the three relevant Wilayas for this survey is 1,457,863 people in 2012, largely concentrated along the coastline. The last census is dated from 2000 and population's forecast has been calculated per municipality which gives a total population of the surveyed municipalities of 1,008,000 as shown in Table 4.18. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 159 Figure4.66 Location of Surveyed Settlements .,\ N 0 20 40 60 km Nation boundaries •Ill Capital Commune Village Mauritania Port * Fish Market I Location of surveyed settlements • Camp ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 160 Table 4.18 Population per Municipality in the Study Area No official statistics are available at village level. The data presented in Table 4.19 has been gathered through statements of stakeholders during the field surveys and should be taken as qualitative rather than quantitative. It is important to note that" seasonal" residents work in several of these locations, with figures indicated for seasonal workers being high-level indications given by local village representatives. Table 4.19 Population per Surveyed Settlement (Approximate Estimate) Source: ERM based on interviews carried out in July 2012 4.9.4 Fishermen Settlements - Structure and Local Services Regional Study Area With the exception of the Urban Community of Nouakchott which is an important centre of fishing but also processing, trade and export of fisheries products, the survey area can be separated into two distinct areas, north of Nouakchott (Imraguen villages) and south of Nouakchott. North of Nouakchott- Imraguen Villages The settlements north of Nouakchott up to Nouamghar are Imraguen villages. The Imraguen are an ethnic group originating from a mix of Arabic, Berber and Sub-saharan Africans tribes. They are one of the rare groups of Saharan inhabitants with a livelihood based on sea fishing. They have settled in the coastal villages of this area since the Sixteenth Century, from Belawakh up to Agadir in the current Bane d' Arguin National Park (PNBA) in the North. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURJT ANIA) PTY LTD 161 Although this is the oldest fishermen community in Mauritania, it currently makes up only 9% of the artisanal fishermen. The Imraguen villages are made of concrete buildings and are located directly on the coast, along the former Nouadhibou-Nouakchott trade route. When the Nouadhibou-Nouakchott road was built around 5 km inland some villagers moved to the main paved road in order to seek economic opportunities. For example in M'haijratt only 30 households still live on the shore whereas 240 households migrated toward the main road. Nevertheless the settlements along the road remain connected to the settlements on the coast as families usually live in both settlements and use the proximity of the road to sell some of their catch. The poor quality of groundwater resources is also a motivation for leaving the coastal village. Fresh water has to be brought from Nouakchott by truck and costs between 7 € and 10 € per cubic meter, which is prohibitive for average income earners. A pilot seawater desalting plant was installed in Belawakh but is not operational. Figure4.67 View of the Imraguen Village of M'haijratt Access to electricity is very limited, except on an individual basis for individuals who can afford a power generator. The field surveyor visited the four main settlements in the study area: Belawakh, Lemcid, Tiwilit and M'haijratt. All these villages are administratively managed by the municipality of Nouamghar. Next to the Imraguen villages, there are camps which have been built by Mauritanian investors for housing seasonal migrants coming from south of Mauritania or neighbouring countries (Mali or Senegal) and working as seasonal fishermen. Most of these camps are owned by the investors, but some are owned by individual fishermen from the southern region. These camps have been built next to the village in order to take advantage of existing infrastructures. Past conflicts caused by competition for occupation of land have been reported during consultation. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 162 South of Nouakchott- PKs The coastal settlements located between Nouakchott and Ndiago are dedicated to fishing activities (They are named PK, which stands for "Point Kilometrique", referring to the distance between Nouakchott and the junction at the main road). They are located at an average of 25 km west of the main road, along the coastline to the coast. The temporary camps of PK 28, PK 93 and PK 144 have been built around the facilities of the fishing training centre CASAMPAC (Centre d'Apprentissage et de Soutien Aux Metiers de la Peche Artisanale et Cotiere) built in 2009. These facilities include housing for students and teachers, training facilities as well as a fishermen housing village in PK28. The CASAMPAC centres are vocational training centres for the artisanal and coastal fishing sector. They are used for the theoretical training of students for 6 month sessions before the students are sent to practise traineeships in the field. There is also an initiative by the Mauritanian authorities to create development centres in these villages in order to keep populations in the region and to curb rural depopulation. Some partly nomadic families originating in the region (Tenghda tribes) have settled in the coastal area when the CASAMPAC facilities were built, hoping for employment opportunities. A limited number of jobs have been created (primarily security guards) but to-date no important economic development has yet been triggered by the implementation of the centres. These families also interact with fishermen by supplying them with salt exchanged with fish. This economic activity is nevertheless seasonally and geographically very restricted. The fishermen settlements are temporary (tents, recycled material) or semi temporary with wooden barracks covered with a tent roof; respectively seen to the right and to the left of the photograph shown on Figure 4.68. Figure4.68 View of Fishennen Encampment at PK 28 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 163 As in the area North of Nouakchott, this area also has limited access to fresh water and electricity. An alternative source of water is the artisanal wells but the water is highly saline and only used by local populations for cattle. Project Footprint and Surrounding Area In February 2013, the residential areas nearest to the Project site are located more than 5 km away, to the South. They correspond to the Nouakchott outer neighbourhoods of Tevragh Zeina and Teyarett. Some isolated residential constructions have been identified in the vicinity of the Project footprint (see details in Section 4.8.6.) Figure4.69 Nearest Residential Areas to Project Site Proposed offshore pipeline - Proposed onshore pipeline Sanda Gas Mauritania ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 164 4.9.5 Development Indicators Poverty Rates For the purpose of this study we have used the threshold values defined in 2008 by the International Monetary Fund (IMF, 2011). Poverty was described in Mauritania as an income lower than 129,000 Mauritanian Ouguiya (MRO)(l) per year per capita , whilst 96,000 MRO (2) was the threshold for extreme poverty. The Wilayas of Nouakchott and Nouadhibou, are the main economic centres of the country and have the lowest poverty rate which is below 30% of the population. The poverty rate of the wilaya of Trarza varies from 30% to 50%, according to the Strategic Framework for Poverty Reduction, whereas the national average is 42%. During the survey, about 75% of the communities declared income classifying them below the poverty rate in the southern area (60% in the northern area). Nevertheless it is important to note that interviewees do not consider the value of the livestock (which is used as money savings and can reach an important level), but rather the daily availability of cash. Education According to the Department for Statistics, literacy rates are respectively of 76.2% and 66.4%in the Wilayas of Nouadhibou and Trarza. According to the village authorities met during the field survey, primary school classes are available at all villages visited, including PKs. Nevertheless, a high rate of teacher absenteeism is reported from most primary schools, and there is reluctance among the villagers to send children to school. Religious education is delivered by local imams at all the settlements visited. Health Community health centres are theoretically available in all surveyed locations but no trained staff is available and the stations are therefore not functional. The nearest available health facilities can be found at municipal centres (M'Balal, El Arya, Tiguent and Nouamghar). 4.9.6 Land Tenure in the Study Area General Context Land rights in Mauritania are regulated by Ordinance N°. 83-127 of 23 June 1983 and its implementation decrees, the latter being the Decree N°2000-089 dated 17 July 2000. Chapter IX of this decree establishes the rules regarding urban concessions. OJ 432.5 USD based on October 2012 exchange rate (2 l 322 USD based on October 2012 exchange rate ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 165 A concession is a temporary authorization of use with an engagement of sale if the title holder fulfils conditions such as fencing its land within two years 11nd developing it within five years. With a total of 2,757 concessions north of PK7, this is the most common type of tenure in the Northern part of the city. Informal land tenure is also relatively common in the area with an estimation of 820 land users (locally refered to as gazras) who have no recognizable legal right or claim to the land or assets they occupy or use. Licences delivered by the Ministry of Tourism constitute a third type of land right in the area. These licences do not constitute secure land titles. According to the Ministry of Urbanism, the area north of PK7 has been allotted on both sides of the road. However, only very limited signs of land occupation were observed during the baseline survey conducted in January 2013. Between PK7 and PK20, only small scale houses and sheds constructions have been reported. 30 small houses or sheds were located on the eastern side of the Nouakchott-Nouadhibou road and only seven on the other side. Local study area Small houses and sheds are present in the immediate vicinity of the proposed pipeline route at the Nouackhott-Nouadhibou highway crossing (see Figure 4.70). Only one small shed is included in the proposed exclusion zone (60 m on both sides of the proposed pipeline route), 35m away from the proposed pipeline route. One villa is present 350m south of the proposed pipeline landfall (see Figure 4.71) No other signs of occupation have been recorded on the proposed Project footprint. Tullow has initiated a request with the Ministry of Urbanism to access Nouakchott's land title register in order to confirm land tenure on the Project footprint and identify land owners and users potentially affected by Project- related land acquisition and restrictions on land use. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY L TO 166 Figure4.70 Proposed pipeline route and exclusion zone at the highway crossing - Proposed onshore pipeline Exclusion zone (60 m buffer) Mauritania Constructions IProposed pipeline route and exclusion zone Iat the highway crossing I ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 167 Figure4.71 Proposed pipeline route and exclusion zone at landfall - Proposed onshore pipeline Exclusion zone (60 m buffer) Mauritania Constructions 4 ·71 I Proposed pipeline route and exclusion zone at landfall ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 168 Figure 4.72 presents the other types of land use identified in the Project Area. These are described in the Local Study Area headings of Sections 4.9.7 to 4.9.10. Figure4.72 Land use in the Project Area Proposed onshore pipeline Exclusion zone (60 m buffer) Mauritania Seashell extraction site Ribat El Bahr Reforested area Nouakchott ring road project ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 169 4.9.7 Trade and Livelihoods Regional Study Area Some small scale trade for daily commodities (canned food, sweets, cigarettes, cooking oil, sugar, tea etc) has been observed in the Imraguen villages. The fishermen organise the commerce of the fish by themselves. About two thirds of their catch is sold to intermediaries, the remaining third being sold by their families to intermediaries at the village or along the marn road for the Imraguen villages. In the latter case, community women process the fish (artisanal drying and production of mullet oil) before selling it. Local populations settled around the fishermen camps in the southern area operate small scale and occasional salt trade with fishermen. Local Study Area Seashell extraction Seashell extraction is the main economic activity in the Project area. Seashells are the only aggregate available within a few hundred kilometers from Nouakchott (Theunynck and Widmer, 1988) and are one the basic building materials in the area. There are several sites for seashells extraction North of Nouakchott. The most important are located at PK40 and PK 45. The nearest to the Project area is located 2.7 km north-west of the proposed gas processing facility, 1.2 km north of the proposed onshore pipeline route and covers a surface area of 0.15 km2 • According to the Federation des Transports de Nouakchott, two types of shells extraction occurs North of Nouakchott near the Nouackhott-Nouadhibou highway. The first one, referred to as raw extraction (prelevement brut) is used for residential construction and represents a fleet of 40 trucks. The second one, referred to as refined extraction (prelevement raffine) is used by the local cement industry (Mauritano-Fran<;aise de Ciment -MAFCI, Ciment de Mauritanie) and since recently for the construction of the new airport's runway and represents a fleet of 18 trucks. Each truck collects 7 to 23 tons of shells per rotation and makes 2-3 rotations a day. Other activities The Project area and its wider environment are also used by shepherds for the grazing of herds of camels and goats. However this activity has been restricted on the location of the proposed gas processing facility since the installation of the reforestation project (see Section 4.5.2). The area is also located within a wider area of passage crossed by herders coming from further afield to the city of Nouakchott, to sell milk. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 170 No other economic activities have been identified in the Project area. 4.9.8 Livestock Regional Study Area Livestock is a common way of saving in Mauritania. Some people living in the surveyed location own a small number of animals as savings but few rely on livestock production as main income source, for example people attracted to the coast by the construction of CASAMPAC centres that do not receive an income from fishing. In the south of the Survey Area, there are very limited interactions between the populations earning a living from fishing and the nomadic or semi- nomadic pastoral communities. Local Study Area Before the development of the Nouakchott-Nouadhibou highway, breeding camels was the only economic activity in the area. It remains the first activity in terms of number of people who practice it. Most livestock owners are based in Nouakchott. 4.9.9 Agriculture Although agriculture is a dynamic sector at national level despite an unfavourable environment, no activities related to agriculture have been mentioned nor witnessed in the visited areas. Therefore this economic sector should be considered as negligible within the Study area both at regional and local level. 4.9.10 Tourism and Recreation Regional Study Area International tourism is not very well developed in the Regional Study Area. Only the protected areas of Diawling and Bane d' Arguin attract a small number of foreign tourists. In recent years, the tourism industry in Mauritania has suffered as foreign embassies have issued travel security warnings in relation to radical Islamist activism in the Sahara and the Sahel. There are a few signs of development of a local tourism industry with the presence of hotel facilities ("campements") nearby but not directly located on the beach at PK 28 and at PK 93. According to a note from the National Tourism Authority in 2008, hotel capacity includes 344 beds in the Wilaya of Nouhadibou and 25 beds in the wilaya of Trarza. There is also a recent phenomenon of development of holiday homes along the coast (FIBA, 2007) but this is still a very uncommon phenomenon. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 171 Finally, the beach in immediate proximity of Nouakchott is used for recreational purpose (bathing, recreational fishing, kite surfing) by national and foreign residents of Nouakchott but this remains economically insignificant with only small scale business related to this usage. Local Study Area There are several signs indicating guest-houses along the Nouakchott- Nouadhibou highway. Some of the facilities have disappeared mostly because of a lack of demand. Presently, there are three functional campsites that are developing, one of which is on the road and the other two are located on the beach. • Campsite Badr, located on the road at PK 12 is composed of seven bungalows. • Campsite les Sultanes, founded in 2006, is composed of a restaurant and six tents located on the beach 3.8 km of the proposed pipeline landfall. It . receives about 60 persons per weekend. • Campsite Oceanides, founded in 2009, is located on the beach next to the campsite les Sultanes. It has a dining room, 3 bungalows and 8 tents. It hosts approximately 100-120 persons per weekend. In addition to these small-scale tourism and recreation facilities, a major fully integrated real estate and recreation project is being developed approximately 4 km south west of the proposed gas processing facility. The Ribat Albahr project is being developed by the Mauritanian Investment Group (MMI). Its first phase will include the development of: • a 1 km2 residential district; • a shopping centre; • a beach front hotel; and • a recreational walkway that will stretch from the shopping centre to the beach. Preliminary construction works started in 2010. Grading activities have been performed on the walkway area in order to level the 1,700m-long and lOOm- width land prepare it for hosting several facilities. This included planting palm trees along the walkway and the construction of a car park. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 172 Figure4.73 Ribat Albahr Preliminary Construction Works 4.10 CULTURAL HERITAGE 4.10.1 Introduction A significant amount of information exists about the earliest populations in Mauritania. The earliest confirmed hominid presence dates to the Early Stone Age. It is believed that Homo ergaster first entered Mauritania around 1 million years ago. The most common artifact found at Early Stone Age sites are Acheulean hand-axes; large chipped stone tools used for both crushing and scraping. Sites dating to this period exist within now desolate regions in Mauritania where paleo-lakes existed before the Sahara began turning to desert in the mid fourth millennium BP. Homo ergaster populations probably did not regularly hunt but obtained a significant portion of their diet through scavenging. 4.10.2 Regional Context Aterien microliths found across the northern half of the country suggest presence of Homo sapiens by around 100,000 years ago. These microliths, belonging to the Middle Stone Age, are small, chipped stone projectile points, which indicate an increase in hunting over scavenging activities. Middle Stone Age sites are not known to extend further south than the Adrar Mountains which contain multiple rock art sites depicting hunting and ritual scenes. Late Stone Age sites exist in larger numbers than previous periods. Most known Late Stone Age sites are clustered around the Dhar Cliffs, the Hodh Depression, the Adrar Mountains and the Atlantic costal region. By around 5000 BP, the Late Stone Age populations began domesticating animals and plants. Ceramic vessels also come into use about this time. The earliest known stonewalled settlements in sub-Sahara Africa belong to this period in Mauritania. These settlements sit upon easily defensible topographic features such as cliffs and natural rises. Stone tool technology largely shifts from microliths to ground stone axes. Harpoons fashioned from animal bone are ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 173 also found in high quantities along the shores of now-desiccated lakes that likely hosted large numbers of ancient fishing groups. Beginning around 2 500 BP, much of West Africa, including Mauritania, entered the Iron Age. It is during this prehistoric period that populations abandon many of the older Late Stone Age settlements. Other settlements begin to develop and eventually take on urban characteristics. The highest densities of Iron Age sites are located within the southern one-third of the country, especially within the Hodh Depression and along the Senegal River. Iron tools and weapons replace stone tools and extensive trading networks begin moving gold, slaves, salt and other commodities across much of West Africa and possibly to the Mediterranean coast. The increase in economic activity eventually led to the origins of the Ghana Empire around year 800, which likely controlled an area between southeastern Mauritania and western Mali. While considered sub-Sahara Africa's first empire, the rise of Ghana also ushers in a suit of major social and political changes that placed Mauritania and the rest of West Africa within a more global position. Most notably, and soon after the rise of Ghana, an Islamic and ethnically Berber group known as the Almoravids established a short-lived empire between 1040 and 1147 that covered an area between southern Spain and Mauritania down to Ancient Ghana. The Almoravid expansion is considered the first of multiple jihads that took place in West Africa, which initiated sustained contact and complex cultural connections between white Berber and black sub-Saharan ethnic groups. The Medieval Period in Mauritania, and elsewhere in West Africa, begins with the Mali Empire in 1230 and the military conquest of Sundiata Keita. The Malian kings ruled over an area that covered southern Mauritania, Senegal, Guinea and modern Mali. It is during the Mali Empire that trade with Europe and the Near East became well established. Gold and slaves were traded north through the Sahara via camel caravans in exchange for salt and other goods brought down south from the desert interior and North Africa. Additionally, a number of important trading centers in both Mauritania and Mali established world-renowned libraries and universities that received visitors and students from as far away as the Middle East. Ancient Mali's fall occurred soon before the rise of the Songhai Empire in the late 15th century with the military conquest of Sonni Ali. However, by the time the Songhai Empire established itself as the new political entity in West Africa it had failed to incorporate the important trading centers within Mauritania. The Songhai Empire fell in 1591 with the military conquest of the Saadi Dynasty that sent an army across the Sahara from Morocco. The invasion succeeded in capturing the cities of Timbuktu, Jenne, and Gao. Soon after the Saadi invasion West Africa entered into a period of Balkanization devolving into a number of small and competing political areas. Economic patterns also shifted by the early seventeenth century with the establishment of Portuguese trading colonies along West Africa's Atlantic coast which greatly diminished the importance of the earlier trans-Saharan caravan routes. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANlA) PTY LTD 174 European exploration of Mauritania was slower to start than other areas in West Africa. While Portuguese sailors had mapped the coast by the early sixteenth century, it was difficult to enter into the country's interior due to a lack of navigable rivers and the presence of hostile groups. French colonial cartographers eventually began mapping Mauritania's interior in 1859 and discovered large deposits of copper and iron in the Adrar Mountains. Throughout the Colonial Period Mauritania remained under nominal French rule, although colonial administrators did not directly control most of the area above the Senegal River. Colonial settlements in southern Mauritania remained under regular threat from northern raiders until1934 when France managed to pacify most of Mauritania with the defeat of warring nomadic groups through a campaign of military fort construction at strategic locations. During the Colonial Period, Nouakchott was a small military camp and Saint Louis served as the regional capital city. However, after independence Saint Louis became part of Senegal and it was decided to make Nouakchott Mauritania's new capital city due to its central location in the country. Starting off with approximately 500 habitants in the late 1950's, Nouakchott has become a major center for trade and commerce in West Africa. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) I'TY LTD 175 Figure4.74 Previously Identified Archaeological Sites in Mauritania @ UNESCO World Herirnge Sites 0 UNESCO Tentitave Sites Archaeological Site: Known Location Archaeological S1fe: Approx. Location Historic t3uilding: Known Location Modern Settlement 4.10.3 Local Study Area From a costal perspective, Mauritania has a rich and long tradition in maritime resource extraction. Originating in the Neolithic period, small and temporary fishing villages served as a seasonal subsistence activity where nomadic groups would travel to Mauritania's costal shores and extract shellfish and fish for consumption. Archaeologically, these ancient fishing villages left behind shell middens of varying size with associated stone and bone artefacts. Because the Project is primarily influencing a portion of Mauritania's costal area, it is likely that Neolithic temporary fishing villages are primary archaeological resource of concern. This observation is reflected in the local cultural heritage baseline context presented below. Artefacts were observed within the footprint of the proposed gas treatment plant by ERM consultants during the scoping visit held in July 2012. Preliminary analysis of pictures taken of the sites and of artefacts identified ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 176 suggested the presence of Late Stone Age Sites within the footprint of the proposed gas treatment plant. An independent Mauritanian archaeologist was then contracted to undertake a site reconnaissance study in order to confirm the cultural heritage value of the site and suggest recommendations on measures to be implemented in order to be compliant with Mauritanian regulations in terms of cultural heritage. His report is summarized in this baseline. The site reconnaissance confirmed the presence of Late Stone Age cultural heritage within the proposed footprint. Recorded locations within the Project footprint are reported on Figure 4.75 The artefacts observed include pottery fragments, stone tools, bones and ostrich egg shells. The variety of pottery techniques and patterns suggest the presence of seven or eight different human groups during the Late Stone Age period. No evidence for graves has been identified and the shell middens have been reported to be relatively superficial. However this does not exclude the risk to encounter underground ancient burials during ground disturbing activities. Table 4.20 Analysis of Artefacts Found within Project Footprint These types of shell-middens are typical of several important Late Stone Age cultures in costal Mauritania: 1: La culture de Foum Arguin (-5500- 3500 BC) 2: La culture de Tintan (-4000- 2000 BC 3: La culture de Nouakchott (-3000 BC) 4: La culture de Dhraina (-2000 -1400 BC) 5: La culture de Tin Mahham (- 400 BC- AD 500) Note: It is common to find burials benieth prehistoric shell middens. Stone armlets are common in West Africa during the Late Stone Age and Iron Age. These are likely fishing-net weights, which are common to many ancient West African costal populations from the Late Stone Age on, and provide preliminary evidence for aquatic resource exploitation aside from shellfish. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 177 Late Stone Age Ceramic Sherd Coil built ceramics are common to both the Late Stone Age and Iron Age in Mauritania. However, here the coil lines are left for aesthetic purposes, which suggest it is Late Stone Age in date. These types of ceramics vessels - large, thick with a restricted neck - are common to several prehistoric cultures. However, this one seem to match with the Nouakchott culture fairly well. This is a ground stone axe. Production of ground stone tools abruptly stops across much of West Africa with the introduction of iron smelting around 500 BC. Following this logic, this tool is estimated to be between 2500 and 5000 years old. This is a grinding stone. They are common across all West Africa and are used as far back as 30,000 BC right up to the modern period. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 178 Figure4.75 Locations of Cultural Heritage Recorded within the Project Footprint LEGEND Study Area 1 km Proposed onshore gas terminal Proposed onshore pipeline Small- Sites less than 100 m1 Medium - Sites 100 m~- 200 m? Large - Sltes more than 200 mZ ceramics ceramics ceramiCs ceramics ENVIRONMENTAL RESOURCES MANAGEMENT TULWW PETROLEUM (MAURITANIA) PTY LTD 179 5 IMPACT IDENTIFICATION AND ASSESSMENT 5.1 APPROACH TO THIS ASSESSMENT This assessment of the potential environment impacts associated with the proposed Banda Gas development is developed as follows: • Section 5.2 presents the impact assessment methodology ; • this is followed by an identification of impacts that may potentially arise (Section 5.3), and a preliminary assessment of their significance (Section 5.4); and • impacts found to be significant are then assessed in further detail in Section 5.5 to 5.7. 5.2 IMPACT ASSESSMENT METHODOLOGY The purpose of the impact assessment is to identify and evaluate the significance of potential impacts on identified receptors and resources; to develop and describe mitigation measures that will be taken to avoid or minimise any potential adverse effects and enhance potential benefits; and to report the significance of the residual impacts that remain following mitigation. 5.2.1 Predicting the Magnitude of Impacts The term 'magnitude' covers all the dimensions of the predicted impact to the natural and social environment including: • the nature of the change (what resource or receptor is affected and how); • the spatial extent of the area impacted or proportion of the population or community affected; • its temporal extent (ie duration, frequency, reversibility); and • where relevant, the probability of the impact occurring as a result of accidental or unplanned events. Table 5.1 provides definitions for the impact characteristics used in this assessment. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 180 Table 5.1 Impact Characteristic Terminology Direct - impacts that result from a direct interaction between the project and resource/ receptor. Indirect - impacts that follow on from direct interactions between the project Type and its environment as a result of subsequent interactions. Induced - impacts that result from other activities that happen as a consequence of the project. Local- impacts that are limited to the Banda development area or Nouakchott onshore base and the surrounding area. Regional - impacts that are experienced beyond the local areas to the wider Extent region, eg Dakhlet Nouahibou or Block ClO. International - impacts that are experienced at an international scale ie affecting another country. Temporary- predicted to last less than the project duration. Short-term- predicted to last only for the duration of the drilling or construction operations (ie up to approximately two years). Medium-term - predicted to last from two years to the end of the project life (ie Duration 20 years). Long-term - predicted to continue beyond the project life but will cease in time. Permanent- impacts that cause a permanent change in the affected receptor or resource that endures substantially beyond the project lifetime. Continuous- impacts that occur continuously or frequently. Frequency Intermittent - impacts that are occasional or occur only under specific circumstances Unlikely - the event is unlikely but may occur during the project. Likelihood* Possible - the event is likely to occur at some point during the project. Likely -the event will occur during the project (ie it is inevitable). *For unplanned events only. Magnitude describes the actual change that is predicted to occur in the resource or receptor (eg the area and duration over which disturbance of the seabed will occur; the degree of impact on the livelihoods of a local community; the probability and consequences in terms of accidental events). An assessment of the overall magnitude of an impact is, therefore, provided that takes into account all the dimensions of the impact described above to determine whether an impact is of small, medium or large magnitude. ENVIRONMENTAL RESCURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 181 5.2.2 Sensitivity/Vulnerability/Importance of Resources and Receptors The significance of the impacts resulting from an impact of a given magnitude will depend on the characteristics of resources and receptors to that impact in terms of their sensitivity, vulnerability and importance. The quality or importance of a resource will be judged taking into account, for example, it's national or international designation, its importance to the local or wider community, its ecosystem function or its economic value. The assessment of the sensitivity of human receptors, for example a fishing community or wider social group, will consider their likely response to the change and their ability to adapt to and manage the effects of the impact. Where required, specific criteria for assessing sensitivity are presented under the relevant impact assessment sections. 5.2.3 Assessing and Reporting Impact Significance All human activity imposes some level of change to the natural and social environment, because of physical interactions with natural systems or other human activities. To provide information to decision makers and other stakeholders on the importance of different project impacts, the EIA team makes an evaluation of the significance of each such change. There is no statutory definition of significance. Therefore, in the EIA, the evaluation of significance is inherently subjective. It is based on the professional judgement of the EIA team, informed by legal standards, national and regional government policy, current industry good practice and the views of stakeholders. Where specific standards are either not available or provide insufficient information on their own to allow grading of significance, evaluation of significance will take into account the magnitude of the impact and the quality, importance or sensitivity of the affected resource or receptor. Magnitude and receptor quality/ importance/ sensitivity are assessed in combination to evaluate whether an impact is, or is not, significant and if so its degree of significance (defined in terms of Minor, Moderate or Major). Impacts ranked as Negligible include those that are slight or transitory, and those that are within the range of natural environmental and social change. This principle is illustrated schematically in Table 5.2. 5.2.4 Mitigation Measures One of the key objectives of an EIA is to identify and define socially and environmentally acceptable, technically feasible and cost-effective mitigation measures. Mitigation measures are developed to avoid, reduce, remedy or compensate for the significant negative impacts identified during the EIA process, and to create or enhance positive impacts such as environmental and social benefits. In this context the term mitigation measures includes operational controls as well as management actions. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 182 Where a significant impact is identified, a hierarchy of options for mitigation is explored as shown in Box 5.2. Table 5.2 Significance Matrix Negligible Negligible Low Medium Negligible Minor High Negligible Box 5.1 Context of Impact Significances For impacts that are initially assessed during the EIA process to be of Major significance, a change in design is usually required to avoid, reduce or minimise these, followed by a reassessment of significance. For impacts assessed during the EIA process to be of Moderate significance, where appropriate the discussion explains the mitigation measures that have been considered, the one selected and the reasons (eg in terms of technical feasibility and cost-effectiveness) for that selection. Impacts assessed to be of Minor significance are usually managed through good industry practice, operational plans and procedures. The EIA is intended to help decisions on projects to be made in full knowledge of their likely impacts on the environment and society. As noted below, the ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 183 residual impacts and their significance reported in this report are based on the proposed Banda Gas development as described, ie inclusive of all proposed mitigation. Box5.2 Hierarchy of Options for Mitigation • Apate at Receptor - jf an impact canno.t be a_bated on-site then control measures can be implemented off-site (eg noise barriers to reduce noise impact at a nearby residence or fenCing to prevenf.animals straying onto the site). • Repair or Remedy- s~me impacts involve unavoidable damage to a resource (eg agricultural land and forestry due to creating access, work camps or materials storage areas) and these impacts can be addressed through repair, restoration or reinstatement measures. • Compensate in Kind -where other mitigation approaches are not possible or fully effective, then compensation for loss, damage and disturbance might be appropriate (eg planting to replace damaged vegetation, financial compensation for damaged crops or providing community facilities for loss of fisheries access, recreation and amenity space). 5.2.5 Reporting Residual Impacts Significance The degree of significance attributed to residual impacts indicates the level importance that should be associated with each impact, in the decision- making process on the Project. Box5.3 Weight of Residual Impacts in the Decision-making Process Impacts of Minor significance are brought to the attention of decision-makers but will be identified as warranting little if any weight in their decision; mitigation will be achieved using normal good practice and monitoring may be required to confirm that impacts are as predicted. 5.2.6 Uncertainty Even with a final Project description and an unchanging environment, predictions of impacts and their effects on resources and receptors can be uncertain. Predictions can be made using varying means ranging from ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY L TO 184 qualitative assessment and expert judgement through to quantitative techniques (eg air quality modelling). The accuracy of predictions depends on the methods used and the quality of the input data for the Project and the environment. Where uncertainty affects the assessment of impacts a conservative (ie reasonable worst case) approach to assessing the likely residual impacts is adopted with mitigation measures developed accordingly. To verify predictions and to address areas of uncertainty, monitoring plans are proposed. 5.3 SCREENING/PRELIMINARY IDENTIFICATION OF IMPACTS The initial stage of the assessment process is the screening of potential impacts. This was conducted during the scoping phase based on a preliminary Project description and involved the production of a high level, matrix of potential interactions between the proposed activities and the surrounding environment. The preliminary interaction matrix for the Banda Gas development is included as Table 5.3. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 185 Table 5.3 Impacts Screening Matrix for the Banda Gas Project >, s ~ Q) .£ , ~ ;:::s CJ .... 6i3 co 0 ·.o .£ Q) 0 u 0 co ro vnPrtPrl finds. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 198 I Negligible Destruction of fauna and flora habitats !• The site layout has been optimized to minimize the size of the footprint Small - destruction of natural habitats will be limited due to Low- the natural habitats within the plant layout do not during construction activities (13 ha). the small footprint of the present important biological plant. values; habitats sensitivity is • Areas of required ground disturbance low considering their will be clearly defined and ground homogeneity at a regional disturbance outside these areas will be scale. avoided. No protected or vulnerable Any vegetation cut on the gas species of fauna and flora processing facilities location will be have been recorded. Three offset. partially protected species (Streptopelia senegalensis and two species of hare) has been recorded; their conservation status within the study areas is good, and these species present low sensitivity to the disappearance of a very small part of their habitats. Civil Works and • Waste generation • Operational controls contained in Low to Medium - impact Medium-High- depending I Minor Plant Utilities Construction . Waste Management Plan. Proper storage of hazardous waste . Safe transport using well maintained, could occur at a local level and in the long term but volumes of wastes will be on the sensitivity/ vulnerability of soils and groundwater resources at and suitable vehicles and trained smalL Limited currently disposal sites and the operators. available facilities for waste proximity and access of • Use of Tullow approved waste handling and disposal. communities to the disposal contractors. site. Selection of a suitable disposal facility or facilities. Measures to ensure proper continuous operation and monitoring of the disposal facility. Both plant construction • Release of gaseous emissions (PM 10, SOx, . Routine inspection and maintenance of engines, generators and other Small - emission sources are transient, mobile, and very Low - emissions from the construction works are I Negligible phases NOx, VOC, CO, C02, equipment to minimise air emission. limited in terms of quantities unlikely to have significant CH4)- with potential Use of low-sulphur diesel if locally emitted. The emissions direct impacts given the effects on air quality inventory is detailed in distance to the nearest available. 3. sensitive ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURIT ANJA) PTY LTD 199 • Noise disturbance to fauna I• No mitigation required. Best practice and good operation management will Medium- noise levels are likely to be almost similar Low-. fauna living or passing I Minor by noise or vibrations sources be applied. during the two stages of plant can be frightened, and construction activities. The temporarily leave the plant model prediction shows that area and its surroundings. noise levels should not exceed The area around the disturbed applicable standards. zone represents similar habitats for the fauna However, the size of the area potentially concerned, so this of disturbance could induce temporarily avoidance will an impact of medium not induce modification of the magnitude. conservation status of the species. Noise disturbance to local community j• No mitigation required. Best practice Small- noise levels are likely to be almost similar during Low- the nearest receptor is located 2.7 km from the site I Negligible and good operation management will be applied. the two stages of plant and the predicted noise levels construction activities. The should not exceed applicable model prediction shows that standards. noise levels should not exceed applicable standards. Road traffic I• Impact on traffic safety I• Application of the company's road Small - the construction fleet Medium- the Project related I Minor safety policy to operator and will be relatively small (2 fleet will contribute to traffic contractor vehicles. dump trucks, 4 mini buses on a busy area with relatively and 4 cars) and comply with sensitive spots such as the the company's road safety new university. • { ..;ro11nli I Jl~hn·h;:tnrP I • Areas of required ground disturbance Small - the onshore pipeline Medium- potential sensitive will be clearly defined and ground will length 5.6 km. Long term habitats could be affected by disturbance outside these areas will be but very localised impact to earthworks. avoided. soil. Prior to works, access road to the working sites will be determined. (1) Impacts associated with pipeline landfall are assessed with offshore activities. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURIT ANlA) PTY LTD 200 Release of gaseous emissions (PM 10, SOx, engines, generators and other transient, mobile, and very construction works are NOx, VOC, CO, C02, equipment to minimise air emission. limited in terms of quantities unlikely to have significant CH4)- with potential Use of low-sulphur diesel if locally emitted. The emissions direct impacts given the effects on air ·quality inventory is detailed in distance to the nearest available. I. chapter3. sensitive • Potential impact to The footprint of the Onshore Pipelay Small - ground disturbing Medium - receptor's Minor cultural heritage route should be surveyed by an activities are localized and sensitivity is medium (archaeological sites) archaeologist for any sites that may any impacts can be managed considering that all potentially be impacted by associated through proper archaeological sites are archaeological mitigation unique and irreplaceable but ground disturbing activities. measures. that the type of site found • A surface artefacts collection will be within the Project footprint is organized before the ground relatively common at a disturbing activities under the regional level. supervision of the Mauritanian Institute for Scientific Research (Institut Mauritanien de Recherche Scientifique- !MRS). Basic archaeological training in site detection should be provided to project staff and construction workers. An archaeological chance finds protocol should be developed to manage unexpected finds. • Destruction of fauna and flora habitats I• Avoid sensitive habitats such as shrubs if possible. Small - the pipeline will be trenched, and the final Low- the most sensitive habitats (shrubs) will be Negligible The pipeline route will be reinstated. footprint will be reduced to preserved as far as possible. its minimal. The pipeline route will not create any corridor effect disturbing the movements of fam1a. • Noise disturbance to No specific mitigation required. Medium- noise levels are Low-. fauna living or passing Minor fauna I: Best practice and good operation likely to be almost similar during the two stages of plant by noise or vibrations sources can be frightened, and management will be applied. Beach inspection at the pipeline construction activities. The temporarily leave the pipeline model rediction shows that route and its ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 201 landfall before the ground disturbing noise levels should not exceed The area around the disturbed activities in order to identify any applicable standards. zone represents similar potential turtle nest. However, the size of the area habitats for the fauna of disturbance could induce potentially concerned, so this an impact of medium temporarily avoidance will magnitude. not induce modification of the conservation status of the species. • Noise disturbance to • No mitigation required Small- noise levels are likely Low- the nearest receptor is Negligible local community to be almost similar during located 2.7 km from Site and the two stages of plant the predicted noise levels do construction activities. The not exceed applicable model prediction shows that standards. noise levels should not exceed applicable standards. Highway crossing 1 • Disturbance of road Safety process for highway crossing Small- important impact but Medium- interruption of the Minor traffic will be established in liaison with the very short term and localised. highway on one lane will road traffic authorities. Only one lane affect users. will be closed at a time. Impact on traffic safety • Application of the company's road Small - the construction fleet Medium- the Project related Minor safety policy to operator and will be relatively small (2 fleet will contribute to traffic contractor vehicles. dump trucks, 4 mini buses on a busy area with relatively and 4 cars) and comply with sensitive spots such as the the company's road safety new university. Domestic Waste • Operational controls contained in Small - limited amounts of Low- limited habitat Negligible Waste Management Plan. wastes predicted; no sensitivity and no • Safe transport using well maintained, significant generation of environmental amenity and suitable vehicles and trained hazardous wastes. identified near the proposed operators. plant site. • Use of Tullow approved waste contractors. Selection of a suitable disposal facility or facilities. • Measures to ensure continuous ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 202 operation and monitoring of the disposal facility. • Industrial Waste • Operational controls contained in Small - limited amounts of Low - limited habitat Negligible Waste Management Plan. wastes predicted; no sensitivity and no • Proper storage of hazardous waste. significant generation of environmental amenity • Safe transport using well maintained, hazardous wastes. identified near the proposed and suitable vehicles and trained plant site. operators. Use of Tullow approved waste contractors. • Selection of a suitable disposal facility or facilities. • Measures to ensure proper continuous operation and monitoring of the disposal facility. • Direct employment by • Implement Tullow' s local employment Small - few additional Medium- high level of training I the Project and indirect and skills development policies. employment training expectations and direct employment through • Accordingly, Tullow and its opportunities will be created benefits to the population at a contractors and contractors, will employ and train but could have a positive local level. suppliers will have a nationals where it is practical to do so. direct effect at the local level positive impact on • in the short term. those people employed, their families and their local communities from wages and other benefits. Procurement of • Socio-economic • Implement Tullow' s local content Small - most goods and Medium- high level of goods and opportunities generated policy. services will be sourced expectations and direct services through procurement of • Accordingly, Tullow and its internationally. Some goods benefits to the population at a goods and services contractors will use local products and and services will sourced local level. associated with Project services where it is practical to do so. from Mauritanian companies activities. in order to support national economy and to create ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTYLTD 203 Publicly advertise Tullow' s in-country speculative jobseekers recruitment procedure. in the immediate vicinity of in a peri urban area with low to the Project vicinity, • No "at the gate" recruitment. Nouakchott which is the environmental sensitivity . leading to land take • Discourage potential settlers through largest urban centre in Local communities are over public or private proactive communication by Tullow Mauritania, and speculative essentially composed of Mauritania's stakeholder engagement land, pressure on the jobseekers are likely to live in residential areas of the team. environment and public Nouakchott already. periphery of Nouakchott. infrastructure, potential conflict with resident etc. Accommodation Temporary • Footprint • After use, temporary sites will be Small- installation predicted Low - temporary J Negligible infrastructures cleared of any structure and wastes to last only for the duration of infrastructures will be sited in installation and re-profiled. construction operations such a way as to limit footprint over land used by other stakeholders. Domestic wastewater Physical presence of 100 workers . Black and grey water generation 0 Waste water will be treated via an onsite waste water treatment system. Medium- construction works will last 2 years. Workforce Low - no receptors should be affected. I Minor accommodation will be in existing facilities in Nouakchott, ie there will be no generation of wastewater from worker accommodation Cleaning, checking and . Liquid effluents • Selection and use of chemicals taking into account its concentration, toxicity, Small- the water used for these operations will bE; I Low- no receptors should be affected. f Negligible testing installed bioavailability and bioaccumulation recovered and treated for equipment potential with selection based on least hydrocarbon removal. environmental potential hazard. • Ensure minimal quantity of chemicals is used. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (Jv!AURITANJA) PTYLID 204 Flare testing • Noise disturbance to No mitigation required Small - localised and Negligible fauna temporary effects. Limited noise levels. area. • Noise disturbance to No mitigation required Small- localised and Low- the nearest receptor is Negligible local community temporary effects. Limited located 2.7 km from Site. noise levels generated by construction activities. • Release of gaseous No mitigation required Medium - localised and Low - very limited number of I Minor emissions (PM1o, NOx, temporary. nearby receptors. CO, C02, CH4) Road traffic • Release of gaseous No mitigation required Negligible- approximately Low - very limited number of 1 Negligible emissions (PM1o, SOx, Eight vehicles will be needed nearby receptors. NOx, VOC, CO, C02, Construction Contribution to global Best practice and good operation Negligible- GHG emissions NA Negligible phaseGHG warming management will be applied to in Mauritania represented emissions enhance efficiency and where possible 8.9 Mtfy of C02-equivalent minimize C02 emissions in 2005. The onshore construction phase emissions are estimated to be less than 10 000 to1mes of C02 equivalent. (see Chapter 3 for the Emissions inventory). The Construction phase emissions will represent less than 0.1% of the country's yearly GHG emissions. containment ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 205 quality • Maintenance of vehicles during bunkering) are a sensitive users identified Impacts to fauna and • Management plan of dangerous possibility during the life- within or around the Project flora products time of the Project but these onshore footprint. • Oil Spill Contingency Plan (OSCP) are generally localised and which contains detailed procedures I impacts are of short duration. that will be followed in the event of an oil spill ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 206 Table 5.6 Preliminary Assessment- Operational phase Plant operations I• Noise emissions from No particular mitigation required. Small - the model Low- the nearest receptor is I Negligible flue gas system and Use of best practice and good prediction shows that noise located 2.7 km from the site and cooler I: operation management. levels should not exceed the predicted noise levels are the IFC Guidelines predicted to not exceed the thresholds. international threshold values there. • Release of gaseous . Limited emission sources . Small - the model Low- the nearest receptor is I Negligible emissions (PM1o, NOx • Compliance with Air Emissions and prediction shows that located 2.7 km from the site and CO, COz, CH4) -with potential effects on ambient air quality . Ambient Air Quality IFC Standards. Routine inspection and maintenance of engines, generators and other pollutant concentrations at groundlevel should not exceed the IFC Guidelines the predicted noise levels are predicted to not exceed the international threshold values equipment to minimise air emission. thresholds. (IFC Guidelines) there. • Domestic waste Operational controls contained in Small - limited number of Low- limited habitat sensitivity I Negligible Waste Management Plan. employees on site; no and no environmental amenity • Safe transport using well maintained, accommodation on site. identified near the proposed plant and suitable vehicles and trained site. operators. • Use of Tullow approved waste contractors. Selection of a suitable disposal facility or facilities. • Measures to ensure proper continuous operation and monitoring of the disposal facility. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (lv!AURIT AN! A) PTY LTD 207 Industrial waste • Operational controls contained in Small - limited amounts of Low -limited habitat sensitivity Negligible Waste Management Plan. wastes predicted; no and no environmental amenity • Proper storage of hazardous waste. significant generation of identified near the proposed plant • Safe transport using well maintained, hazardous wastes . site. and suitable vehicles and trained operators. Use of Tullow approved waste contractors. Selection of a suitable disposal facility or facilities. Measures to ensure proper continuous operation and monitoring of the disposal facility. • Produced water from Water will be a product of the three Small- very limited Low - no sensitive habitats and Negligible production the Banda field (8.7 stage separation and will be treated in amounts of wastewater (up very limited sensitive users m3jd) the produced water treatment system to approx. 8 m3j d); on-site identified within or around the • Waste oils to ren1ove: treatment, no untreated Project onshore footprint. • entrained free oil to allow for safe environmental discharge. disposal; • soluble hydrocarbons, including volatile aromatics -benzene, toluene, ethyl benzene and xylenes (BTEX). • MEG and chemicals to reduce biological and chemical oxygen demand prevent biomass accumulation. • Treated produced water will be used in the power plant as process water to reduce its water demand or local irrigation ENVIRONMENTAL RESOURCES MAN ACEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 208 Naturally Disposal of NORM from Containment and disposal as hazardous Negligible- At Banda Low- the material would be Negligible occurring periodic pipeline cleaning material. NORMS are not expected contained and disposed of as radioactive operations (scale removal) because there is a low hazardous material. material (NORM) probability of formation water production and hence low risk of scaling Condensate • Impact on traffic safety Application of the company's road Small - the processed Medium- the Project related fleet Minor export j Road safety policy to operator and condensate (-800 barrels will contribute to traffic on a busy traffic contractor vehicles. per day) will be exported area with relatively sensitive spots on a batch basis by road such as the new university. tankers. This will require 2 to 6 trucks a day and constitute the main impact source on road traffic. Physical presence • Disturbance to fauna No mitigation required. Best practice Small- activities associated Low- no protected or vulnerable Negligible of the gas plant and good operation management will to the presence of the plant species of fauna and flora have and associated be applied. will potentially disturb the been recorded. Three partially operations fauna; however, the protected species (Streptopelia habituation of the species senegalensis and two species of to the gas plant operations hare) has been recorded; their (and the associated conservation status within the decrease of the study areas is good, and these disturbance) will induce an species present low sensitivity to impact of small magnitude. the disturbance due to the physical presence of the plant. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 209 Physical presence • Physical presence of • The pipeline and umbilical will be Small - the physical Low- no sensitive resources that of the onshore the pipeline trenched. presence of the pipeline could be impacted by the physical pipeline • Only pipeline markers will be visible will not prevent movement presence of the pipeline have been above ground. across the Project area. identified along the pipeline route • Periodic monitoring of the onshore Pipeline markers will be part of the pipeline to reduce the the only structure visible likelihood of any intentional damage above ground to it. . Exclusion zone • Restriction on permanent . Coordination with Ministry of Urbanism to take into account the Medium - the exclusion zone of the pipeline will Medium The exclusion zone does I Moderate not affect any significant existing infrastructure within Project in land planning scheme. prevent the construction of construction (only one shed has 60 m on both sides of any permanent been identified within the the pipeline infrastructure during exclusion zone). However it Project operation creates an additional constraint in a suburban area that will have to be taken into account in land • valVes on the subsea • No mitigation required. Negligible- an estimated LowjMedium - good existing subsea control equipment will 264litres of hydraulic fluid water quality, water depth, system I discharge hydraulic control fluid to the will be discharged every year (544 litres in the first distance offshore and hydrography in area provides a marine environment. year). Intermittent high level of dilution and discharges will be small dispersion. Low to high value volume every 3 to 6 species supported. months. The fluid is likely to be a waterbased glycol which is low toxicity, readily biodegradable and non-bioaccumulative. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MA URIT ANl A) PTY L TO 210 Subsea production structures I. Physical presence of subsea production structures. I. Liaison with other users of the sea to make them aware of the subsea production structures Small - relatively small area (0.79 :Y,m2) will be unavailable for fishing Low - the Banda field is not considered tO be an important area for artisanal or industrial fishing. Artisanal and coastal I Negligible • 500 metres fishing exclusion zone fishing activities are expected to around well heads and manifold. remain within the limit of 6 nm off The subsea production structures and the coast. The area is used for exclusion zone will be marked on industrial fishing (pelagic and navigation charts. demersal trawlers) and is used as a transit route by fishing vessels Pipeline, umbilical and • Physical presence of pipeline, umbilical . Liaison with other users of the sea to make them aware of the pipeline and Negligible -The physical presence of the pipeline, alon the coast. Medium - traffic and fishing activities are relatively important Negligible rock dumps and rock dumps. umbilical umbilical and rock dumps on the nearshore section of the is unlikely to impact other pipeline route. • The pipeline and umbilical will be sea users. There will be no trenched along most of its length to exclusion zone along the provide stability and to prevent route and all the structures damage from fishing gear. will be overtrawable. • Where soil conditions obviate trenching, the pipeline and umbilical will be protected by rock dumping or flexible concrete mats. The pipeline and umbilical route will be marked on Implement Tullow' s local employment Small - some limited Low- high level of expectations training I the Project and and skills development policies. additional employment and direct benefits to the indirect employment • Accordingly, Tullow and its opportunities will be population at a local level. through contractors contractors, will employ and train created but could have a and suppliers will nationals where it is practical to do so. positive direct effect at the have a positive impact local level in the short on people employed, term. their families and their local communities from wages and other benefits. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURIT ANJA) PTY LTD 211 Procurement of • Socio-economic • Implement Tullow's local content Small - most goods and Low- high level of expectations Positive goods and opportunities strategy. services will be sourced and direct benefits to the services generated through • Accordingly, Tullow and its internationally. Some population at a local level. procurement of goods contractors will use local products and goods and services will and services services where it is practical to do so .. sourced from Mauritanian associated with Project companies in order to activities. support national economy and to create employment opportunities. In-migration In-migration of Publicly advertise Tullow' sin-country Small- The Project is Low- The project is located in a Negliii.ble speculative jobseekers recruitment procedure. located in the immediate periurban area with low to the Project vicinity, No" at the gate" recruitment vicinity of Nouakchott environmental sensitivity. Local leading to land take Discourage potential settlers through which is the largest urban communities are essentially over public or private proactive communication by Tullow centre in Mauritania, and composed of residential areas of Mauritania's stakeholder engagement land, pressure on the speculative jobseekers are the periphery of Nouakchott. team. environment and likely to live in Nouakchott public infrastructure, already. potential conflict with resident community etc. Spills Loss of Soil contamination • Oil and chemicals spill prevention Small - small oil spills and Low -no sensitive habitats and Negligible containment • Impacts to equipment, measures and procedures leaks (ie diesel spillages very limited sensitive users groundwater quality Install secondary containment around during bunkering) are a identified within or around the Impacts to fauna and tanks to contain accidental releases. possibility during the life- Project onshore footprint flora • Maintenance of vehicles time of the Project but • Management plan of dangerous these are generally products localised and impacts are • Oil Spill Contingency Pian (OSCP) of short duration . which contains detailed procedures that will be followed in the event of an oil spill ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY L TO 212 Fire&Explosion Fire and explosion • Impacts on people's . Active fire protection system Medium - impacts Low - very limited presence of Minor . health and safety Impacts on assets • • Gas leak detection devices Development of a fire and life safety prevention through design and operations, supported stakeholders. There are no dwellings in the vicinity of the • Impacts on workforce health and safety . plan for workforce Coordination with local authorities for by risk assessments. proposed processing plant site, and a 60 m exclusion zone will be . external emergency response. Markers will be provided to prevent accidental excavation damage to the established on both sides of the pipeline, and a 300m exclusion zone around the processing plant boundary. . pipeline and umbilical 300 m exclusion zone with no permanent infrastructure around the processing plant boundary. • 60 m exclusion zone with no permanent infrastructure on both . sides of the pipeline. Periodic monitoring of the onshore part of the pipeline to reduce the likelihood of any intentional damage to it. I '---- --· --- ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAUR!T ANIA) PrY LTD 213 Contribution to global 1 • Greenhouse gas reduction strategy Negligible- GHG Negligible emissions warming with focus on optimisation of overall emissions in Mauritania energy efficiency and reduction in represented 8.9 Mt/y of flaring and venting. C02-equivalent in 2005. Minimization of gas leaks by maintenance programme The operational phase Flash gas recovery system in plant emissions are estimated to • Best practice and good operation be less than 1 400 management will be applied to tonnes/year of C02 enhance efficiency and where possible I equivalent. (see Chapter 3 minimize C02 emissions for the Emissions inventory). The estimated annual emissions from the gas processing facility operation will represent less than 0.02% of the country's yearly GHG emissions. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 214 5.5 KEY IMPACTS IDENTIFIED- OFFSHORE DRILLING AND INSTALLATION PHASE The majority of aspects of the proposed offshore construction phase have been identified to be Negligible or Minor significance (Section 5.4). Of those impacts identified as significant, only hydrocarbon spills are assessed as Moderate significance and warrant a more detailed assessment and a more comprehensive discussion o£ the mitigation measures adopted. In addition, quantitative assessments have been used to confirm the conclusions of the preliminary impact assessment in regards to discharge of drill cuttings and navigation and collision risk. The results of these assessments are summarised in this section. This also includes the conclusions of the navigation and collision risk assessment was originally conducted as part of preliminary assessment work developed on the Banda Oil phase development project. 5.5.1 Drilling Discharges Introduction To quantify the magnitude of potential impacts from the discharge of drill cuttings and associated drilling fluids on the marine environment drill cuttings dispersion modelling was undertaken (see Annex B-1). The study methodology and results are also summarised below. Modelling Approach Drilling discharges were simulated using a numerical model, GEMSS (Generalised Environmental Modelling System for Surfacewaters) and its drill cuttings and fluid discharges module GIFT (Generalised Integrated Fate and Transport). GIFT simulates the transport, dispersion and bottom deposition of dissolved and particulate material discharged into a water body. The modelling approach is based on a single event, deterministic mode of simulation. In this scenario, the start date, current speed and current direction at each time step are selected from a database of properties for the selected period. The model was based upon expected metocean conditions for the period between June and August. These months were selected due to the absence of any strong net directional currents thus having the highest potential for depositional thickness and sedimentary rates. The environmental data used by the model includes spatially varying bathymetric data and time varying wind, current, temperature and salinity data. The bathymetric data was obtained from GEBCO (2012). The depth-varying, six- hour average wind, current, temperature and salinity data for the period between December 1995 and March 2001 were obtained from the National Centres for Environmental Prediction (NCEP), using oceanographic output from their Climate Forecast System Reanalysis (CFSR) program (NCEP 2012). The drilling programme that was modelled consisted of four sections using seawater and sweep pills for the two top sections (the top hole and surface ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 215 section) and either WBM or improved SBM for the two bottom sections. The top (conductor hole) will be jetted in rather than drilled. The drilling fluids used to drill the top sections (prior to installing the riser) will be released to the seabed together with the cuttings and associated pumped seawater. Once the riser is installed, cuttings and either WBM or improved SBM will be returned to the MODU where it will be treated and discharged overboard. Table 5.4 provides volumes of drill cuttings and fluid that were modelled for each well. Table 5.4 Drill Cuttings and Drilling Fluid Volumes (Per Well) Banda Gas 1 36" 81.8* 0 0 Seafloor 26" 262.7 0 0 Seafloor 171/2" 425.7 21.3 15.45 Surface 8 1/2" 8.9 0.4 0.34 Surface 779.1 21.7 15.79 Banda Gas 2 36" 81.8* 0 0 Seafloor 26" 262.7 0 0 Seafloor 171/2" 359.1 18 13.66 Surface 8 1/2" 1.9 0.1 0.07 Surface 705.5 18.1 13.73 *jetted The drilling unit will be fitted to each well using anchors via a single drilling centre. In this study, it was considered that muds and cuttings will be discharged at the surface from the drilling centre. • Northing: 1965000 m, Easting: 334700 m, UTM WGS 1984, Zone 28 N The top hole discharges are located at the well sites located approximately 50 m apart: • Banda Gas 1. Northing: 1965000 m, Easting: 334675 m, UTM WGS 1984, Zone 28 N; and • Banda Gas 2. Northing: 1965000 m, Easting: 334725 m, UTM WGS 1984, Zone 28 N. This surface discharge was considered to be continuous. It will take approximately 10 days to drill each well and therefore a total duration of 20 days has been assumed for drilling the two wells. Other input data considered in the model included drill cuttings and fluid particle size distribution and material densities. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 216 Modelling Results The results of the modelling are illustrated in the following sections as contour plots. The plots presented indicate the location of the drill cuttings release point, taken as the drill centre. The results are presented for the following parameters: • bottom thickness in mm; • total suspended solids measured in parts per million (ppm); and • sedimentation rate. Bottom Deposition The cuttings discharged at the seabed are deposited directly adjacent to each of the well sites, resulting in the thickest layers of deposition. The cuttings discharged at the sea surface disperse over a much larger area with smaller particles travelling distances exceeding 5 km from the discharge location. Figure 5.1 shows the expected thickness of the mud and cuttings layer on the seabed as a result of the drilling activities at the end of the model simulation. The maximum thickness predicted by the model was 209 mm, located in the vicinity surrounding the second well (1). Figure 5.2 shows this peak from a 3D perspective. Approximately 66.2 km2 of seabed is expected to be covered by more than 1 mm of deposition and approximately 5.3 km2 of seabed is expected to be covered by more than 10 mm deposition. (1) Well Head #1 and Well Head #2 refers to Banda Gas 1 and Banda Gas 2, respectively. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 217 Figure 5.1 Bottom Deposition Thickness Figure 5.2 Bottom Deposition Thickness - 3D Perspective ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 218 Total Suspended Solids Concentrations of Total Suspended .Solids (TSS) exceeding background levels are known to decline quickly with increasing distance from the discharge location due to dilution of the plume and rapid settling of larger particles. For this reason, relatively high concentrations are expected in the immediate vicinity of the well site with a sharp reduction at increasing distance from the discharge location. Figure 5.3 shows the maximum TSS exceeding background levels. The modelling results show excess concentrations of TSS between 10 and 60 mgl-1 during surface discharge of cuttings with a maximum of 447 mgl-1. The range is a result of currents mixing the dispersion plume. At the seabed deposition from the top hole is estimated to increase TSS by 270 mgl-1. Typical values at the seabed range between 20 and 90 mgl-1. Although the volume of cuttings at the seabed is much higher, the maximum TSS concentration is estimated to be lower than that at the surface because particles quickly rapidly settle onto the seabed and have less opportunity to recirculate in the water column. Figure 5.4 shows the TSS concentrations during the first top hole release. Figure 5.3 Maximum TSS Concentration Exceeding Background Levels ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) P1Y LTD 219 Figure 5.4 TSS Concentration Exceeding Background Levels from Top Hole Release Sedimentation Rate The maximum modelled sedimentation rate peaks at around 170,000 mg cm-2 per day at the seabed. This rate is experienced during drilling the top well sections (Figure 5.5). The rate decreases by an order of magnitude within a day and decreases spatially by an order of magnitude after 30 m from the discharge location, and again after 60 m. Beyond this region, scatter locations have deposition rates above 10 mg cm-2 per day. The sedimentation rate decreases to approximately 1,800 mg cm-2 per day a month after the initial release. Figure 5.6 shows the maximum sedimentation rate decreasing over time. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 220 Figure 5.5 Maximum Sedimentation Rate at the Seabed Figure 5.6 Maximum Sedimentation Rate over Time :!..80000 :;: .g :!.. 60000 +--~---·--· .. -~---~·-·········-~-···--······· ···~···--·~··~--- ""'"""""~-~~---~---····- i :!..40000 !;~·-······-·-··· u ~ 120000 !. 100000 ·•·-····~--~~-~----~--~--······---~-····· ·-·-····-~----······-···---········ ~ i 80000 = 60000 .............................................................. ···---------·············· ·-·······-·---·----·-- ,; .... ... = ~ 40000 20000 (Iii .E "'C 0 il.l Vi 0 5 15 20 25 Days Since Initial Release Description of Potential Impacts As described in Chapter 3 a total of two wells are required for the development. Discharges of drill cuttings to the environment have the potential to impact the water column and seabed. The extent of the impact will to varying degrees be predominantly dependent on the following. • Point of discharge, eg discharge at the sea surface or release on the seabed, and the volume and rate of discharge. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) P1Y LTD 221 • The physical and chemical properties of the cuttings and base fluids (eg water based or improved synthetic based), which may include particle size distribution and particle cohesion, and its chemical characteristics. • The extent of mixing and dispersion, which can be influenced by the currents present and the water depth in which the cuttings pass; and the presence and sensitivity of pelagic, demersal and benthic communities. The impacts to marine organisms (which assume the stated discharges and releases) will arise from the following two types of cuttings and mode of discharge. • Cuttings generated from the top sections drilled with seawater and sweep pills, which are released at the seabed from the well. • Cuttings generated from the lower well sections will be drilled with either WBM or improved SBM, which are treated reduce oil retention on cuttings and discharged from the MODU at approximately 5 m below the sea surface. As a realistic 'worst case' it is assumed that an improved will be used. Receptor Sensitivity The effects of the disposal of drill cuttings are well documented from previous studies and the impacts from drill cuttings discharges depend largely on the quantity and nature of the discharged material, the area affected and the sensitivity of the receiving environment (eg the habitat/ species potentially affected). The benthic fauna expected is informed by an environmental baseline survey of the Banda field area. The habitat has been assessed as relatively low value given the homogeneous nature of the substrate and types of species it supports (primarily polychaete worms). The environmental baseline survey for the project reported no evidence of sensitive habitats within the Banda field (see Chapter 4). Mitigation Measures The following mitigation measures to minimise the impact of drill cuttings and fluid discharge on the marine environment will be adopted. • Solids control systems will be used, including dryers, to treat oil on cuttings to between 5 and 10% as a weighted average. • Measures will be taken to comply with project effluent guidelines, including use of low toxicity (Group III) improved SBM, no free oil, and limits on mercury and cadmium concentrations. Water based muds may be used instead if feasible. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 222 Impact Assessment Biological Impacts to the Water Column Following the discharge of cuttings at the sea surface, cuttings will pass down through the water column (ie water depths of approximately 250 m) and gradually be dispersed before settling on the seabed. During this time, marine life, such as pelagic fish, may become exposed to suspended solids (eg fine particles that may interfere with respiration) or toxic substances (such as certain metals or organic compounds) associated with the suspended solids or dissolved in the surrounding water. An oxygen demand may also be exerted on the water. However, these impacts on the water quality are unlikely to represent a concern as cuttings do not disperse readily in seawater and tend to settle rapidly through the water column and onto the seabed. In addition, most pelagic species are sufficiently mobile to avoid being exposed periods of time that could potentially be harmful. Model-predicted TSS concentrations in the water column are primarily due to drilling fluid solids, since these particles have lower settling velocities and remain suspended in the water column for longer periods of time. In contrast, discharged cuttings settle to the seabed very quickly. Predicted TSS concentration for the drilling discharges will predominantly occur when the bottom sections of each well are drilled. The elevated TSS concentrations are expected to be localised, short term and dissipate rapid as a result of the dispersion capacity of the local marine environment. The overall impact is considered of small magnitude and given the good existing water quality and low to medium sensitivity of biological receptors, the impact to water column is assessed as Minor significance. The effects of discharges of drill cuttings and associated improved SBM into the marine environment are, therefore, primarily on the seabed sediments and associated fauna since there is little effect on water quality. Biological Impacts to Seabed As cuttings and WBM used to drill the upper sections of each well will be released from the well at the seabed, the large or heavy cutting particles accumulate in the immediate vicinity of the well. The finer particles released at the seabed during drilling of the top two well sections are likely to form a dense plume which may interfere with the respiration of benthic and demersal communities downstream of the release point. However, the plume is expected to occur over a relatively short duration whilst the top sections of the wells are drilled and effects are likely to be local to the well. Thereafter improved SBM cuttings released at the surface will spread over a wider area subject to currents, however, the majority of cuttings will still settle on the seabed within the local vicinity of the well. Sedimentation rates are expected to be around 170,000 mg/ cm2 during day one of drilling, decreasing ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 223 exponentially over time to approximately 1,800 mg/ cm2-day after 20 days. The maximum model-predicted thickness of the deposited material on the seabed is 209 mm. Deposits of more than 1 mm thick are expected to occur within a region approximately 66.2 km2 around the vicinity of the two wells, while depositional areas over 10 mm are estimated to be 5,300 m 2 • Last et al (2012) assessed the tolerance of different benthic species to burial in fine sand against a benchmark of 50 mm burial depth. The study found that tolerance to burial varies considerably between benthic species. In general, burrowing species such as polychaetes had a high tolerance to burial, while encrusting species such as ascidians and bivalves have a lower tolerance. The EBS of the Banda field showed that benthic communities are dominated by burrowing species (primarily polychaetes). Therefore, the communities are assumed to have a lower sensitivity to smothering effects. The modelling results predict that approximately 2.1 km2 of seabed will be exposed to depositional thicknesses greater than 50 mm, therefore smothering impacts and/ or mortality of benthic fauna is likely to occur for a small area around each well (see Figure 5.1). Other effects from improved SBM cuttings could include organic enrichment of sediments through organic carbon loading and toxicity from organic enrichment and the drilling fluids (including bioaccumulation and bio- magnification through the food chain). These effects are related to the degree of accumulation of drill cuttings on the seabed and the toxicity of the drilling fluids. The type of NADF (EDC 99 DW or similar) that will be used for the mid and lower sections of each well does not contain any aromatics and is readily biodegradable in aerobic conditions. Anaerobic conditions slow down the rate of biodegradation and increase toxicity of the sediments. Solid control equipment will be used to reduce the oil on cuttings to a target concentration of between 5 and 10%. The biological impact of drilling discharges on the seabed could occur as a result of smothering effects and biochemical effects. The modelling results predict a maximum depositional thickness on the seabed of 209 mm, and a thickness of over 1 mm for an area of 66.2 km2. Approximately 2.1 km2 of seabed is expected to be exposed to depositional thickness of more than 50 mm, the threshold at which smothering and/ or mortality can be expected; approximately 3.4% of the Banda field area. Therefore, the magnitude of seabed impacts is considered small to medium. Benthic fauna in the Banda field is homogenous and dominated by low value burrowing species which have a high tolerance to burial (low sensitivity). Therefore, the impact to the seabed is assessed as being of Minor significance. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 224 5.5.2 Hydrocarbon Spills Introduction The risk of a fuel oil (diesel) spill into the marine environment is inherent in all offshore activities. The likelihood (probability) of significant spills, ie those that can reach the coastline or other sensitive areas is very low with most spills being very small and having only limited environmental effects. Considering that the Banda Gas development wells are only targeting gas bearing formations, not oil bearing formations, the assessment does not consider modelling for spills resulting from accidental well blowouts. Assessment Methodology An oil spill model was set up and a diesel spill scenario modelled using GEMSS (Generalised Environmental Modelling System for Surfacewaters) and its oil spill module COSIM (Chemical/Oil Spill Impact Module). The modelling results have been attached as Annex B-4. The GEMSS application requires both spatial data and temporal data. Spatial input data includes the shoreline and bathymetry. Temporal data includes time-varying boundary data defining tidal elevation, inflow rate and temperature, inflow constituent concentration, outflow rate and meteorological data. Oil Spill Modelling Introduction Oil spill modelling has been used to predict the consequence of a diesel spill from the MODU. The modelling considers the nature of the diesel spilled, the location and duration of the spill, the behaviour of oil in the marine environment, and the transport from the spill site to other marine and coastal areas. The information used in the model allows the likely fate of the diesel spill to be assessed and illustrated. This aids the assessment of potential environmental impacts of an oil spill on sensitive receptors (eg coastal habitats). Modelling Inputs The diesel spill scenario that was simulated is presented in Table 5.5. It represents a hypothetical loss of diesel containment on the MODU resulting in a discharge of 1,200 m 3 of diesel over a three-hour period at the surface level. The spill location is at the drilling centre. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 225 Table 5.5 Oil Spill Simulation Scenarios The diesel release volume is conservative and is considered to have a low likelihood of occurrence. Data on wind and currents that represent conditions at the Banda field were obtained and used in the modelling study. Winds are represented stochastically and the currents are represented deterministically. The currents in the Banda field region are mostly directed towards the southwest, away from the shoreline. There is no month when currents predominantly travel towards the shore. The months with the lowest frequency of currents directed away from the shoreline were in July and August. Considering also the months of June, July and August have the highest frequency of winds directed towards the shore, these months were selected as the analysis period. These three months represent the time of the year with the greatest risk for shoreline oiling, providing the shortest response time. Oil Behaviour The physical and chemical change that spilled oil undergoes is collectively known as 'weathering' (Figure 5.7). Knowledge of these processes and how they interact to alter the nature and composition of the oil with time is essential in identifying the best oil spill response strategies, choosing appropriate equipment and developing effective contingency plans. A short description of the fate process is provided in Figure 5.8. Figure 5.7 Weathering Processes for Oil at Sea ' . + • ' .. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 226 Figure 5.8 Oil Weathering Process Modelling Results The modelling results present a worst case that could result from a diesel spill, assuming that no oil spill response measures were deployed. The remainder of this section summarises the results of the modelling. Stochastic Modelling Results The COSIM stochastic model was applied to predict the probability of sea surface oiling as a result of the modelled diesel spill. The stochastic simulations indicate the probable behaviour of potential spills under the specific metocean conditions expected to occur in the Banda field. The stochastic model simulations showed the predominant transport of spilled oil is to the south-east under worst case oceanographic conditions. For the modelled scenario, a 200 km stretch of coastline, located 35 km to the north and 165 km to the south of Nouakchott, has a greater than 4% probability of being impacted. A relatively small volume of diesel (on average ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 227 14m3 ) is expected to beach. The model predicts that the spill would not impact the more sensitive habitats to the north of Nouakchqtt, for example Bane d' Arguin, or the wetland areas around the Senegal River Delta. The following figures depict the modelling results. • Figure 5.9 presents the surface probability of oiling; • Figure 5.10 presents the thickness of the diesel slick at the surface; • Figure 5.11 presents probability of shoreline oiling; while Figure 5.12 shows the maximum volume of shoreline oiling; and • Figure 5.13 presents the travel time of the diesel spill to shore. It is noted that these figures represent composite results from a number of simulation runs and present the overall results under varying meteocean conditions rather than the extent of a single spill. Figure 5.9 Probability of Visible Surface Oiling from Diesel Spill N A A minimum threshold thickness value has been chosen at 0.1 f.!m, translated into units of mass per surface area as 0.08 g/ m 2 • Model output is presented for those locations with surface diesel mass per unit area equal to or above this threshold, and presented in terms of the color classifications. Table 5-6 summarizes these descriptors. ENVIRONMENTAL RESOURCES MAN ACEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 228 Table 5-6 Oil thickness descriptors Silver sheen 0.1 0.080 Rainbow 0.3 0.24 Metallic 5 4.0 Transitional dark 50 40.0 Dark / true color 200 160.0 Black oil >200 >160.0 Figure 5.10 Diesel Spill: Maximum Oil Thickness ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 229 Figure 5.11 Probability of Shoreline Oiling from Diesel Spill · Oiesel36-3.mdb Shoreline Oiling % Figure 5.12 Diesel spill: Maximum Shoreline Oiling Volume ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA') PTY LTD 230 Figure 5.13 Travel of Time ofDiesel Slick : Diesel36-3.mdb Travel Time (days) N A Deterministic Modelling Results The deterministic (trajectory j fate) modelling simulations represent the fate of an oil spill release under specific meteorological conditions (ie one particular wind direction and strength). Deterministic model simulations provide a time history of oil weathering over the duration of the simulation, expressed as the percentage of spilled oil on the water surface, on the shore, evaporated, and naturally dispersed in the water column. Figure 5.14 presents the evolution of a diesel spill event by showing snapshots of the spill at different times. The mass balance for the spill is illustrated in Figure 5.15. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 231 Figure5.14 Example of the Evolution of a 1,200 m 3 Diesel Spill during 2 Weeks OlcsclJb~liler.mdb Oic:'I-(:IJ~rllkr.mdb Ulc!!-t.tlb·1~hT.mdb ;\ MMtfUll\lifA 1 day after spill 4 days after spill 6 days after spill Oi~.J30·1iteundb Vfe::o.cl:J6·lih!1,mdb 0ie5of_•tJO·litcun.db A l\ ,,::· 1 t l ' : I \. / 1 ' MIWRl'tMJtt_ ! r iJ!J ,,,,J' ::."~ 8 days after spill 12 days after spill 14 day after spill ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 232 Figure 5.15 Mass Balance Plot: Diesel Spill 100 'E 90 ~ v 80 Q. 70 ~~ 60 ] 50 .s 40 '5 c 30 : 0 10 10 11 12 13 14 Time, days Diesel is expected to weather rapidly, with 50% of the light fractions quickly evaporating at the start of the simulation due to the high proportion of short chain hydrocarbons present in diesel. In the first 14 days approximately 60% of the initial mass has evaporated. The diesel that does not evaporate stays on the surface and a proportion of this diesel dissolves as the winds and waves entrain the diesel into the water column. As a result of this process a significant percentage of the oil (approximately 22%) dissolves in water rapidly. A small fraction of diesel may contact the shoreline approximately 6 days after the release. After two weeks, approximately 1% of the total mass may be on the shorelines (6 tons out of the total960 tons comprising the 1200 m 3 volume released). Description of Potential Impacts In the event of a diesel spill the most sensitive components of the ecosystem in the marine environment are seabirds, marine mammals and turtles, due to their close association with the sea surface. In the event of spilled diesel reaching the coast notable sensitive receptors include coastal habitats such as wetlands, lagoons and turtle nesting beaches, fish and fishing activities and people whose livelihoods depend on coastal resources. This section summarises the potential impacts on the most sensitive receptors. However, it should be noted that this assumes a 'worst case' spill that reaches the coastline and is subject to no response efforts. Mitigation Measures Mitigation of oil spills takes two forms: spill prevention and spill response. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 233 Spill Prevention To minimise the risk of potential spills a range of inherent measures aimed at reducing the risk of oil spill have been included in the project design. Spill prevention is achieved through both operational controls and technology applications. • Adoption of formal and systematic hazard identification and operational procedures • Use of competent crews, trained and certified in well management and well control procedures. • A system of wells and pipeline and umbilical, designed to international process codes and with alarm and shutdown systems to maintain the system within its design criteria at all times. The system will be tested, inspected and maintained to ensure performance standards. • Use of drilling fluids for hydrostatic control in the event of sudden or unexpected changes in well bore pressure. • Installation and regular testing of industry standard safety valves (blowout preventers) on subsea well heads. • Protection of subsea equipment, such as by installation of overtrawlable protection structures, trenching to reduce the risk of damage (and subsequent leaks/ spills) to wellheads, manifolds, pipeline and umbilical from trawling activities. Spill Preparedness and Response Despite the prevention measures and management procedures built into the design of the project there is always a risk that an oil spill can occur. In response to such an event, an Oil Spill Contingency Plan (OSCP) will be developed which will have procedures which set out the strategy and specific actions that will be taken in the event of an oil spill. The actions that will be required for the OSCP in the event of an oil spill vary according to the size and type of the spill. Oil spills are defined according to three 'Tiers'. This classification is in alignment with the International Petroleum Industry Environmental Conservation Association (IPECA) which advocates a response to oil spills such that the planned response engages resources commensurate with the severity of the spill with the higher the Tier the higher the level of response required. The OSCP will be informed by the oil spill modelling study so that the response strategy and location of equipment takes into account the areas most ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 234 at risk and the response times required to mobilise resources and equipment in the event of a spill. The OSCP interfaces closely with the Mauritanian National Oil Spill Contingency Plan. The resources available to provide a suitable response to any oil spill from the project, and the responsibility for leading spill response, are set out in the OSCP as follows for each Tier of spill. • Tier 1: The response to all Tier 1 spills will remain the responsibility of Tullow. Tullow will hold the appropriate level of Tier 1 oil spill response equipment and trained personnel so as to facilitate an immediate response in the event of a Tier 1 spill and to assist with Tier 2 spill events. • Tier 2: In the event of a Tier 2 spill event the initial response would be the responsibility of Tullow. However, if the magnitude of spill warrants a further response it would engage mutual aid resources which may be provided by industry partners within Mauritania and the Oil Spill Response Limited (1 ) (OSRL) West and Central Africa surveillance and spraying aircraft. • Tier 3: In the event of a spill situation which is clearly beyond Tullow' s immediate response capability, both mutual aid resources which may be provided by industry partners within Mauritania and the OSR call-out guarantee from the Oil Spill Response Base in Southampton, UK. It is important to note that, in Tier 2 and 3 spill situations, the response strategy set out in the OSCP is intended to align with the Mauritanian National Oil Spill Contingency Plan and comply with its requirements. The intention is that in any major spill situation there is cooperation between Tullow, other offshore oil and gas operators and the Government of Mauritania in order to ensure a coordinated and effective response to a spill. Impact Assessment Seabirds and Coastal Birds Several protected areas have been identified as being possibly impacted by a spill, including the following: the Chat T'boul Reserve, the Diawling National Park and the Saint-Louis Ramsar site .. Unprotected areas along the coast are also important bird habitats. These include the wetlands and swamps in inter-dunal depressions along the Aftout es Saheli area, a proposed Rarnsar site with up to 50,000 waterbirds recorded and globally threatened and biome-restricted species present, between Nouakchott and StLouis. In addition, two proposed marine IBAs are located (1) Oil Spill Response Limited (OSRL) is a Global Tier 3 Oil Spill Response Organization, owned by its oil industry member shareholders, for the benefit of its members. OSRL provides immediate response to a Tier 3 oil spill from Southampton, UK. Regional Tier 2 response can be provided with access to an aircraft based in Sao T orne which can both spray dispersant and detect and quantify oil at sea using specialist remote sensing cameras. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 235 offshore Mauritania, namely the Aftout es Saheli which includes inshore marine areas between Nouakchott and StLouis and the Atlantic Eastern Central 4 marine IBA located further offshore and covering an area of approximately 68,000 km2. Direct mortality of birds is often the most widely perceived risk of an oil spill, however, birds can also affected by diesel pollution in the following ways. • toxic effects after the ingestion of oil during preening, ingestion of oiled prey, inhalation of oil fumes or absorption of oil through skin or eggs; and • indirect effects resulting from destruction of bird habitats or food resources. Taking into account the international significance of the habitat, including threatened and biome-restricted species; coastal bird species and habitats in Mauritania are considered highly sensitive to potential impacts resulting from an oil spill that reaches the coastline. Marine Mammals Marine mammals are generally less sensitive to oil spills than seabirds as they will tend to detect the area around a surface oil slick and avoid any breaching or feeding behaviours that may bring them into direct contact with oil. However, marine mammals are still sensitive to impacts from oil spills, and in particular from the hydrocarbons and chemicals that evaporate from the oil, particularly in the first few days following a spill event. Although it is likely that certain species of marine mammals occur in the area offshore Mauritania, it is considered that as mobile species they would generally avoid any areas affected by oil spills, minimising the potential for heavy oiling though there is potential for ingestion and eye and skin damage from oil contact. Marine Turtles In Mauritanian waters the large seagrass beds at Bane d' Arguin provide an important feeding area for individuals from green turtle breeding colonies both in Mauritania as well as in other West African countries. Juveniles and sub-adults of other species which are less well understood, such as the Leatherback, are also likely to use this relatively sheltered area for foraging prior to migration as adults. However, based on the modelling study, diesel is not expected to impact this area. Turtles are sensitive to the effects of oil spills at all life stages: eggs, post hatchlings, juveniles and adults. Several aspects of sea turtle biology place them at particular risk. These include a lack of avoidance behaviour, indiscriminate feeding around the sea surface and large pre-dive inhalations at the sea surface. Potential direct impacts to sea turtles include: ENV!RONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 236 • increased egg mortality and developmental defects; • direct mortality due to oiling in hatchlings, juveniles and adults; and • negative impacts to skin, blood, immune systems and salt glands. In addition, sea turtles are sensitive to potential secondary and longer term impacts, which are generally less obvious than the short term impacts immediately following a spill. In the event of a diesel spill reaching the coastline between Nouakchott and Cap Vert sea turtle populations may be highly sensitive to impacts assuming that nesting beaches are present. Coastal Habitats The coasts that are predicted to be most at risk of being oiled are 200 km in length, located 35 km to the north and 165 km to the south of Nouakchott. This stretch of coast is made up entirely of sandy beach habitat which is considered to have a low to moderate sensitivity to oil spills depending on its grain size. The model predicts that the spill would not impact the more sensitive habitats to the north of Nouakchott, for example Bane d' Arguin, or the wetland areas around the Senegal River Delta. The shoreline at risk of oiling ends 7 km North of the Chat'Boul Reserve. Fish Stocks The offshore and coastal waters in Mauritania support significant numbers of fish species many of which are targeted by the artisanal and coastal fishing and industrial fleets. Most commercial species occur in coastal waters from close inshore to the edge of the continental shelf. Fish species that occur in the shallow coastal habitat are also important as these areas act as vital nursery grounds and assist with sustaining fish stocks in coastal waters. Typically, fish are not considered highly sensitive to impacts from oil spills. Adults are mobile and generally able to detect heavily contaminated areas or areas of low water quality. Oil contamination ih open waters below an oil slick is generally low (only a few ppm or below) (IPIECA 2000) and there is no evidence to suggest that fish are significantly affected by oil in open water. Non-lethal negative effects are more usual and fish can be affected in the long term in some circumstances, especially when oil spills into shallow or confined waters. Fish exposed to elevated concentrations of hydrocarbons absorb contaminants though their gills, accumulating it within their internal organs which can lead to long-term, sub-lethal effects. In addition, spilled oil in confined and shallow waters, such as intertidal mudflats and remnant mangroves, poses a threat to fish eggs and larvae which cannot actively avoid or escape a pollution event. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 237 In terms of the vulnerability of fish stocks to impacts from a diesel spill, while fish in open waters are not particularly sensitive, the species found in shallow coastal habitats are highly sensitive. Fisheries There is no other fishing port in the area south of Nouakchott. The area south of Nouakchott consists of mobile and seasonal fishermen camps which are almost exclusively foreign fishermen. Coastal lagoons and estuaries are also important sources of fish and shellfish for both subsistence and commercial purposes. In the event of an oil spill that reaches either coastal waters, or beaches within coastal lagoons, fisheries may be suspended by the regulatory authorities to avoid contamination of fish being lifted through the slick on the surface waters and to prevent gear contamination. Fishing is difficult or impossible in areas directly affected by a spill. Vessels and gear will be smeared in oil and the catch might be spoiled. The fishermen might for a period be forced to stop or temporarily move to other fishing grounds nearby free of oil slicks. These fisheries closures will directly affect fishing communities along the coastline by preventing them from maintaining their livelihood during the period of closure, resulting in a reduction in both food and economic resources. In addition, tainting of fish from contamination with hydrocarbons can impact fisheries affected by oil spills. Tainting of fish will reduce the quality of the fish landed and sold to traders. As a result these fish may fetch a lower price than others unaffected by tainting. Given the importance of the artisanal fishing industry along the coastline and the presence of particularly sensitive fisheries such as lagoons, fisheries are considered highly sensitive to impacts resulting from a diesel spill that reaches coastal waters. Impact Significance The metocean conditions in the area during the summer months, and in particular the strong winds blowing from the North-West tend to move spilled hydrocarbons towards the Mauritanian coast. It should be noted that this assumes that no oil spill response measures are taken. The majority of the shoreline which would most likely to be impacted is sandy beach which is considered to have a low to moderate sensitivity depending on grain size. This coastline and inshore marine zone habitats between · Nouakchott and Senegal are important bird areas and would be sensitive to the effects of an oil spill. Wetland areas are highly sensitive to oil spills as these habitats support significant bird populations and act as fish nursery grounds, turtle nesting sites and artisanal fishing grounds. These receptors would be adversely impacted in the event of an oil spill that reaches the ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 238 coastline. These shorelines at risk of oiling are 7 km from the nearest of the protected areas. A large diesel spill is COn$idered unlikely tooccurCfl, and should ol1~ oc~ur, th~ proposed oil spill response measures .vould likely prevent the majority Of diesel reaching the shoreline giv.en the relatively small volume of diesel, w~ather.ing processe$, distanc~ to s~ore~ an~ the tiine aJf'Ordedto the response effort (3 days m1niml1m al1d4.6 day~ on average), If diesel doesreach the shore receptors· are likely .be ex:e.osed to UJ,edium term adverse impacts of local to regiq~ctl ~~tent, th~refq,re adieselspill~s consid~redof.mediummagnihlde . . 'FAe sttetch ()f,coasfline;,most ~~~ly to h~~~fected is qgpsider~< w 1. E-08 +------'----,-----'-----'-r-----"------1 10 100 1000 10000 Impact Energy (MJ) Figure 5.17 Passing Drifting Impact Energy Exceedence (jrom Anatec, 2012) 1.E-05 >- u c Q;l :::l 1 .E-06 t:T ... Q;l u.. i.E-07 0 u Q;l u i.E-08 c Q;l "C Q;l Q;l 1 .E-09 u )( w 1.E-1 0 0.001 0.01 0.1 10 100 1000 Impact Energy (MJ) ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 242 Figure 5.18 Infield Vessel Impact Energy Exceedence (from Anatec, 2012) 1.E+OO >- 1.E-01 (.) a; 1.E-02 5- (].) 1.E-03 U: 1.E-04 0 1.E-05 (.) (].) 1.E-06 (.) c: 1.E-07 (].) '0 (].) (.) 1.E-08 (.) >< 1.E-09 w 1.E-1 0 0.1 1 10 100 1000 Impact Energy (MJ) Figure 5.19 Passing Fishing Vessel Impact Energy Exceedence (from Anatec, 2012) 1.E-02 ()' c: (].) 1.E-03 ::::1 C" ... (].) u.. 1.E-04 0 () (].) (.) c: 1.E-05 (].) '0 (].) (.) (.) >< 1.E-06 w 10 100 1000 Impact Energy(MJ) Description of Potential Impacts The likely impacts on the navigation and shipping of the Project's activity are centred on collision risks and hazards (ie associated risks to life, pollution to the environment and emergency dumping of cargo) and can be broadly described as follows. • Potential for collision between MODU, support or installation vessels, and other vessels (merchant, commercial fisheries, recreational and passenger) during drilling, completion, installation or commissioning activities. • Displacement of vessels out of the 500 m safety exclusion zone due to presence of MODU or installation vessels. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 243 Mitigation Measures As a minimum, a 500 m safety exclusion zone will be maintained around the MODU by a supply vessel acting as an ERRV equipped with Automatic Radar Plotting Aid (ARPA). Communication and navigation equipment on the project vessels will comply with requirements of the International Convention for the Safety of Life at Sea, 1974 (SOLAS) and vessel operations will be in accordance with the IMO' s International Regulations for Preventing Collisions at Sea 1972 (COLREGS). The following risk mitigation measures will be implemented to further reduce collision risk for Banda Gas development activities. • Early notification will be provided to mariners so that they are well aware of the Banda Gas development facilities and activities when undertaking their passage planning or in advance of arriving at the field. Specific notification measures will include providing advanced notice to mariners in the area of the proposed development, issuing a Notice to Mariners and providing data on new facilities for inclusion of nautical charts. • AIS detection systems will be installed in the field to provide early detection of passing vessels and improved information to aid in the management of this hazard. • Tullow will consider the use of RAdar and beaCON (RACON) or AIS Aids to Navigation (A toN) to provide a positive identification of the MODU to passing vessels. • Industry guidelines (UKOOA 2003) will form the basis of infield vessel management and a full Marine Operations plan will be developed for the field. This should give account to factors including vessel selection and inspection, crewing and competency. • Collision risk management procedures (preventative and emergency response) will be developed giving account to the traffic patterns and evacuation requirements on the MODU and support vessels. Impact Assessment The navigational sensitivity of the area is considered to be medium given that the Banda field is located on a higher density shipping route out of Nouakchott en-route to the Berge Helene FPSO and that a significant number of large industrial fishing trawlers pass the Banda field location. The intensity of a vessel collision may range from small to large depending on the size of the vessel, travelling speed and subsequent collision impact energy. Lower energy impact collisions are more likely than higher energy collision impact. The magnitude of the consequences of a collision will depend on the collision impact and emergency response procedures. In the event of a high ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 244 energy collision with the MODU, the consequences may be of large magnitude and result in loss of life, spills of oils and chemicals, and subsequent environmental damage. However, the collision risk assessment showed that the risk frequencies for passing vessels (powered, drifting and fishing vessels) colliding with Banda field facilities is very low ranging from 2.5x10-7 to 8.6x10-4, corresponding to return periods of 4 million years to 1,150 years. The collision risk frequency for in-field vessels is higher with a return period of approximately 57 years, however, the majority of these collisions will have low impact energy due to the relatively small tonnages of the vessels and lower impact speed. The mitigation measures proposed will provide notice and early warning to shipping that may use the area so that, if required, they can adapt their routes to avoid the area. Further navigational aids such as AIS will be implemented and infield procedures developed which would reduce collision risk further. Given that the Banda Gas operations will comply with standards of international navigation conventions and implement additional navigational aids and infield procedures to further reduce collision risk, this potential impact is assessed to be of Minor significance. 5.6 KEY IDENTIFIED IMPACTS- ONSHORE CONSTRUCTION PHASE No onshore construction impacts have been identified as Moderate or Major in Section 5.4. However, in response to stakeholder concerns regarding noise impacts from the Project on some sensitive receptors identified in the far field, such as the new university of Nouakchott currently being built (please refer to Annex A for detailed consultation records), construction noise impacts have been considered to warrant a more detailed assessment and a more comprehensive discussion and have been included in the following section and in the supporting Annex B-3. 5.6.1 Construction Noise Assessment Approach This section presents an assessment of the impacts expected to result from the noise emissions associated with the onshore construction phase of the Banda Gas Project. A noise modelling has been performed to predict the noise levels for the area surrounding the gas processing plant. The modelling methodology and results are presented in Annex B-3. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 245 Noise Sources Noise associated with the onshore construction phase will be variable in nature and will depend on the particular activities being undertaken as well as the equipment in operation. The construction phase is expected to be approximately 12 months and is anticipated to begin in early2015. The overall noise produced during the construction phase comes from several types of equipment and from specific activities. Therefore, the noise impact related to this phase can be variable and it is difficult to accurately predict construction noise emissions throughout the entire construction period. Hence, to facilitate the noise assessment, two 'worst case' scenarios have been developed: • Site Preparation Scenario: this scenario includes significant noise- producing activities such as vegetation clearance, topsoil removal, earthworks. These activities will require heavy construction vehicles and equipment (excavators, dozers, rollers, dump trucks). • Civil Works and Plant Utilities Construction Scenario: this scenario includes significant noise-producing activities such as installation of concrete and asphalt batch plants, installation of foundation structures and. paved areas within the gas treatment facilities, assembly of plant items. These activities will require equipment such as concrete trucks, cranes, side-booms. Considering that construction activities will extend throughout the Project site, each scenario has been simulated to represent a 'typical' maximum activity with all equipment operating in the area closest to noise sensitive receptors. The predicted noise levels from the model are based on the assumption that all equipment is operating simultaneously and at full load. The equipment simulated and their acoustic performances for each scenario are detailed in Annex B-3. Construction Phase Noise Magnitude Criteria There is no relevant national guidance and construction noise is not addressed directly by the IFC EHS guidelines. It is common practice to classify impact magnitude as negligible if the predicted construction noise levels do not exceed the existing ambient noise levels. In consideration of the construction period, being a period of 12 months, it is considered that the IFC threshold levels of 55 dB(A) for the daytime and 45 dB( A) for the night time would be appropriate for this Project. ENVIRONMENTAL RESOURCES MAN ACEMENT TULLOW PETROLEUM (MAURJT ANIA) PTY LTD 246 Additionally, a LAMax of 85 dBA is a well-accepted action limit for occupational noise management as it is the threshold at which the potential for hearing damage starts to occur. This level has been adopted as the threshold for critical impacts. The magnitude of construction noise is evaluated by establishing a threshold noise level at which significant impacts start to occur and higher levels for medium and large magnitude impacts. Using these standards and guidelines for reference, usually it is appropriate to set significance thresholds for day and night time according to the duration of the noise, on the basis that temporary construction (<1 month) will have lesser impact than short term (1- 6 months) or long term(> 6 months). Table 5.8 presents the magnitude criteria for noise impacts during the construction phase. Given the duration of construction for this Project, a conservative approach has been taken, adopting the most stringent (> 6 months duration) long term criteria. Table 5.8 Noise Impact Magnitude for Residential Receptors. Construction Phase Construction LAeq,lhr ---------.----~~~~ Short exposure < 75 < 1 month Medium term exposure < 70 1 to 6 months Long term <60 Description of Potential Impacts This section assesses the likely noise levels and potential impacts at off-site noise sensitive receptors. Maximum construction noise levels at receptors have been predicted for the scenarios detailed above. The noise values reported refer to the maximum noise level predicted at each receptor where the construction equipment is located at the nearest point of the Project to receptor location and all the equipment work simultaneously. This assumption represents a worst case ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 247 scenario, considering the worst combination in terms of source level and distance. Table 5.9 Predicted Construction Noise Levels Site boundary NSR 1 68.5 68.5 NSR2 66.0 66.0 NSR3 62.0 62.0 NSR4 63.5 63.0 70 70 NSR5 61.0 61.0 NSR6 64.5 64.0 NSR7 66.0 65.5 Nearest Sensitive Receptors ~N~S~R~8------r~2~9~.o------~t~28~.5------~~ 55 NSR 9 I 32.5 . 32.0 I j~ For residential receptors (NSRS and NSR9) a noise limit of 55 dBA for day time and 45 dBA for night time has been assumed. The predicted construction noise levels at both NSRs will comply with the Project's noise construction criteria during both the daytime and night time periods, hence impact magnitude is Small, as per criteria reported in Table 5.8. NSR1 to NSR7 are not residential receptors and they are located along the site boundary. In this case the criteria defined in Table 5.8 cannot be applied, and the noise emissions have been compared to a suitable noise level of 70 dBA, representative of industrial area as per the IFC guidelines. Also for these receptors, the predicted construction noise levels will comply with the Project's noise construction limits during both the daytime and night time periods and the magnitude impact for construction phase, in absence of mitigation, will be Small. Without mitigation, noise impact significance associated with the construction of the Project is expected to be Negligible, mainly due to the distance of receptors and the temporary duration of construction activities. Mitigation Measures The noise contribution of the construction phase predicted through noise modelling has not identified any significant impacts according to international standards. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 248 Hence no specific mitigation measures will be needed; however, during construction, achievement of Project noise.guidelines will be accomplished through good operations management. The management and mitigation measures presented below are considered to be international good practice and are recommended : • enforcement of appropriate speed limits for heavy vehicles to reduce noise; • utilisation of modern, well maintained industrial equipment Impact Assessment Predicted noise levels for construction are expected to comply with the guidelines presented in Chapter 2 for all conditions during the daytime and night time period. Construction noise levels have been predicted for scenarios representing a typical worst-case activity with all equipment operating and the construction noise contribution would be lower than the levels predicted in this study. Conservatively, the residual impacts are considered equal to potential impacts described above and the overall significance of the residual impacts are assessed as Negligible at all the Noise Sensitive Receptors identified. 5.7 KEY IDENTIFIED IMPACTS- OPERATIONAL PHASE Only the presence of exclusion zones with a restriction on permanent infrastructure within 60 m on both sides of the onshore pipeline and within a 300m radius of the gas processing plant was assessed as Moderate significance. No other operational impacts have been identified as Moderate or Major in Section 5.4. However, in response to stakeholder concerns regarding air quality and noise impacts from the Project on some sensitive receptors identified in the far field, such as the new university of Nouakchott (please refer to Annex A for detailed consultation records), noise and local air quality impacts have been considered to warrant a more detailed assessment and a more comprehensive discussion which is presented in the following sections and in the supporting Annexes B-2 and B-3. 5. 7.1 Onshore Pipeline Exclusion Zone Description of Potential Impacts The onshore pipeline and umbilical will be trenched and will not cause any severance. However, a restriction on permanent infrastructure within 60 m on both sides of the pipeline will be enforced for safety reasons. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 249 The presence of this 0,68 km2 exclusion zone creates an additional constraint in a suburban area. Mitigation Measures Tullow will have to coordinate with the Ministry of Urbanism so that the exclusion zone is included in the land planning scheme. Impact Assessment The exclusion zone of the pipeline will prevent the construction of any permanent infrastructure over a 0,68 km2 area. This exclusion zone will last for at least 20 years (duration of the Project). The impact magnitude is therefore considered to be Medium. The exclusion zone does not affect any significant existing construction (only one shed has been identified within the exclusion zone). However, it affects an already constraint suburban area of an expanding city. Therefore the resource sensitivity is considered to be Medium. Therefore, the iJ;npact of the pipeline exclusion zone is considered to be of Moderate significance. 5.7.2 Gas processing plant exclusion zone Description of Potential Impacts To mitigate potential impacts from accidental operation of the gas processing plant, a restriction area will be established for permanent infrastructure over a distance of 300m around the proposed facility. This zone has been defined based on levels of geographical risks identified during a risk assessment and presented in Figure 5.20. This exclusion zone goes beyond the limits of the plot assigned to SOMELEC west and north in an area of 0.31 km 2 and creates an additional constraint in a suburban area. Mitigation Measures Tullow will have to coordinate with the Ministry of Urbanism so that the exclusion zone will be included in the land planning scheme. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 250 Figure 5.20 Geographical Risk Levels used to define the exclusion zone >=1E-004 >=1E·005 >=1E-006 E·007 >=1E·008 Impact Assessment The exclusion zone of the gas processing plant will prevent the construction of any permanent infrastructure over a 0,31 km2 area. This exclusion zone will last for at least 20 years (duration of the Project). The impact magnitude is therefore considered to be Medium. The exclusion zone does not affect any significant existing construction (only one shed has been identified within the exclusion zone). However, it affects a suburban area of an expanding city already subject to constraints. Therefore the resource sensitivity is considered to be Medium. The!~fore, theimpact}lf the ~as prm;essn1gpla!J-fe~~Iusiqn zbne.is considered .tope of Moderqte si&l1ftic.anc~: · ·· · · 5. 7.3 Operational Noise Assessment Approach This section presents an assessment of the impacts expected to result from the noise emissions associated with the operational phase of the Banda Gas Project. A noise modelling has been performed to predict the noise levels for the area surrounding the gas processing plant. The modelling methodology and results are presented in Annex B-3. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MA UR!TANIA) PTY LTD 251 Noise Sources It is anticipated that the operational life of the facility will be 20-25 years and the Plant will run 24 hours a day, 7 days a week and the main noise sources will be located within: • the gas processing plant and utilities areas, characterized by engine generator, flash gas and processing pumps; and • the flare area, due to the necessity during normal plant operations to occasionally and intermittently burn unwanted gas from the flare tower. The flare will be 30 meters above ground level. To predict noise emissions from plant processing operations, a typical worst case activity has been assumed based on the assumption that equipment is operating simultaneously and at full load. The equipment simulated and their acoustic performances are detailed in Annex B-3. Operational Phase Noise Magnitude Criteria The IFC EHS guidelines have been considered to set operational phase noise criteria described in Table 5.10. Table 5.10 Noise Impact Magnitude for Residential Receptors. Operational Phase Impact Magnitude Plant Operation <55 LAeq,lhr Amenity Impact < 10 6.LA90 Note: LAMax = 85 dB A is a well-accepted action limit for occupational noise management as it is the threshold at which the potential for hearing damage starts to occur (critical level) Description of Potential Impacts Maximum operational noise levels at receptors have been predicted for the operational phase scenarios detailed above. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 252 Figure 5.21 Predicted Noise Levels Generated by the Project- Operation Phase Legend -Operation and Flaring Scenario __\ Noise Sensitive Receptors Noise Level dB LAeq, 1h N (t Site boundary 30-35 ® Near receptor 35-40 l..':l Onshore gas site 40-45 Onshore gas terminal 45-50 Proposed gas pipeline 50-55 · Onshore pipeline 55-60 60-65 0 0.4 0.8 >65 . . . .~==~ ..•kn ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 253 Table 5.11 Predicted Operational Noise Levels Site boundary NSR 1 64.5 NSR2 66.0 NSR3 63.5 NSR4 67.0 70 70 NSR5 63.5 NSR6 68.5 NSR7 66.0 Nearest Sensitive Receptors --:-:-:-:------~,-:-:-:~------------------~1 55 I~ The noise levels at receptors are influenced predominantly by the fuel gas system and cooler. The predicted operational noise levels comply with the IFC noise criteria during both daytime and night time periods for all scenarios. Considering the noise assessment criteria reported in Table 5.10, the magnitude impact for operational phase is expected to be Small. Predicted noise contours for operational activities, including flaring, are shown in Figure 5.21. Increase in Background Noise Levels during the Operational Phase The IFC General EHS Guideline states that [.. noise impacts should not result in a maximum increase in background levels of 3 dB at the nearest receptor location off- site]. To assess the noise impact generated by the Project on the environmental noise quality, the increase above background required by IFC guidelines has been evaluated. Noise modelling has allowed calculating LAeq, 1 hour site contributions for direct comparison to the IFC fixed criteria and as such these values must be converted to a background LA90 value (15 hour daytime and 9 hour night time) to assess any potential increase in noise level. ERM has assumed that similar activities will occur for the whole duration of each period and has applied a conservative 1 dB reduction 1 to convert from the LAeq acoustic (1) As reported in Section 3.2.4 ETSU-R-97 Guidelines states that the LA90 level noise is typically 2 dBA less than the equivalent LAeq,t value. A reduction of only 1 dBA considered in this study guarantees a more conservative approach of the noise assessment. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 254 parameter to the LA90 statistical parameter as the noise emissions from the gas processing plant are considered to be very continuous in nature. An increase in the background noise level at a noise sensitive receptor location of more than 3dB would be considered as significant. The predicted change in LA90 noise levels at each NSR during the operational phase has been compared with the background noise levels as reported in Table 5.12, which shows the increase above background noise for the assessment locations. Only residential receptors NSR8 and NSR9 have been considered. Table 5.12 Increase in Background Noise Levels- Operational Phase Increase in Noise Level LA90 [dBA] Background significance Noise Level criteria (<3 ~B) NSR8 36.0 34.0 (35.0) 38.1 2.1 Yes NSR9 29.5 37.0 (38.0) 37.7 8.2 No Note: (a) A reduction of 1 dBA of the equivalent LAeq,t value has been considered to estimate the LA90 plant contribution. Based on the results reported in Table 5.12, the increase above background exceeds the IFC limit of 3 dBA at receptor NSR9. According to the noise criteria reported in Table 5.10, the amenity impact magnitude at receptor NSR8 is Small and at NSR9 is Medium. It is necessary to underline, however, that the impact at NSR9 is mainly due to low background noise, and it is supposed that once the university facilities have been built the noise background will be higher, comparable to levels monitored at receptor NSR8. Hence it is reasonable to consider also for receptor NSR9 a Small amenity impact. However a noise monitoring survey at the beginning of the operations is recommended to verify the compliance with IFC guidelines. Without mitigation, noise impact significance associated with the operational phase of the Project is expected to be Negligible. Mitigation Measures The noise contribution of the operational phase predicted through noise modelling has not identified any significant impacts according to international standards. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 255 A medium amenity impact may occur at receptor NSR9, but it's supposed that once the university facilities have been built the noise background will be higher and no significant impacts will be expected. Hence no specific mitigation measures will be needed; however, during operation, achievement of Project noise guidelines will be accomplished through good operations management. The management and mitigation measures presented below are considered to be international good practice and are recommended : • enforcement of appropriate speed limits for heavy vehicles to reduce noise; • utilisation of modern, well maintained industrial equipment and plant with the appropriate noise mufflers in place; • operational noise monitoring at established permanent monitoring locations (such as NSR9) to ensure compliance with the guidelines; and • performance of noise modelling in case of modification of the plant, or if ongoing monitoring indicates non compliance with the guidelines. Impact Assessment Predicted noise levels for operations are expected to comply with the guidelines presented in Section 2.2 for all conditions during the daytime and night time period. Operations noise levels have been predicted for scenarios representing a typical worst-case activity with all equipment operating and the plant noise contribution would be lower than the levels predicted in this study. Conservatively, the residual impacts are considered equal to potential impacts described above and the overall significance of the residual impacts for normal operations are assessed as Negligible at all the Noise Sensitive Receptors identified. 5. 7.4 Impacts on Local Air Quality Assessment Approach This section presents an assessment of the impacts expected to result from the atmospheric emissions associated with the operational phase of the Banda Gas Project. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 256 An air quality modelling has been performed to quantify the atmospheric ground-level concentrations of macro-pollutants. The modelling methodology and results are presented in Annex B-2. The air dispersion modelling study aims to quantify the atmospheric ground- level concentrations of macro-pollutants produced by the atmospheric emissions associated to the operation of the High Pressure (HP) and Low Pressure (LP) flares of the Banda gas processing plant. The main atmospheric emissions arising from the combustion of sulphur-free flue gases at the HP and LP flares are NOx, CO and PM. According to the Project characteristics, two simulation scenarios were identified, for operational and emergency conditions. The atmospheric emissions occurring during the normal operation of the Project are produced by the combustion of purge gas at the HP ar:-d LP flares with an emission rate of 250 kg/h. A worst-case emergency scenario, in terms of gas flowrate, has been chosen for both flares in discussion with Tullow; moreover it was assumed that the HP and LP flares operate in their worst emergency conditions at the same time and continuously during the simulated year with emission rates of respectively 59 546 kg/hand 14 377 kg/h. The ground concentrations of NOx (conservatively considered as N02), CO and PM (conservatively considered as PM1o) have been modelled for both scenarios over a 30 x 30 km domain, roughly centred on the flares' location. Significance Criteria for Impacts on Local Air Quality The significance of the predicted impacts is considered in terms of: • the Process Contribution (PC) which is the impact on air quality arising from the process emissions only; and • the Predicted Environmental Concentration (PEC) which is the PC added to the existing baseline. No existing baseline data are available for the Project area thus PEC has not been calculated in the present study. Considering the rural nature of the Project area and the absence of existing atmospheric pollution sources in its proximity, it can reasonably be concluded that background concentrations of airborne pollutants are negligible over the Project area. On this basis a significance criteria based on the PC has been defined and used in the present study. The IFC General EHS guidelines (IFC, 2007) recommends that projects with significant sources of air emissions, such as the Project flares, should not ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 257 contribute to the attainment of relevant ambient air quality guidelines or standards for more than 25 % of the applicable air quality standards to allow additional, future sustainable development in the same airshed. An adjacent proposed electrical power station is to be developed, owned and operated by a separate entity, the Societe de Production d'Electricite apartir du Gaz (SPEG). The SPEG power plant is being developed as a separate project from the Banda gas development, and is not covered by the scope of this EIA. However, this associated facility (l) will produce atmospheric emissions and potential impacts on local air quality. The significance criteria for air quality impacts have therefore been defined and used in the present study based on the IFC recommendation to allow additional development in the same airshed. • If the PC <5% of the air quality standard, then impacts are negligible. • If the PC between 5% and 25% of the air quality standard, then impacts are of minor significance. • If the PC between 25% and 50% of the air quality standard, then impacts are of moderate significance. • If the PC >50% of the air quality standard, then impacts are of major significance. Air Quality Receptors The nearest buildings identified in the vicinity of the proposed gas plant site are: • the new University of Nouakchott located 2.7 km south/ southwest of the proposed gas processing facility, still under construction; and • some scattered permanent residential buildings located 3.8 km west /northwest of the proposed gas processing facility, including also few temporary tents. These receptors have been identified by a desktop analysis of the local cartography or satellite images and confirmed by means of site visit to verify the state of the buildings and the presence of inhabitants. (l)The IFC PS1 defines associated facilities as facilities that are not funded as part of the project and that would not have been constructed or expanded if the project did not exist and without which the project would not be viable. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 258 Figure 5.22 Receptors Identified in the Near Field around the Site LEGEND <1!1 FLARES (HP and LP) AQ RECEPTORS 500 1 000 m Description of Potential Impacts Operational Scenario Table 5.13 provides a summary of the results of the performed modelling study for the Operational Scenario_along with the significance of impacts on local air quality assessed with respect to IFC Air Quality Standards. It shows that the ambient air concentration of all pollutants modelled for the operational phase comply with IFC air quality standards. In particular modelled concentrations of CO are four orders of magnitude smaller than their respective AQS. According to the impact significance levels described above, impacts on local air quality due to NOz, CO and PM1o ground level concentrations induced by the combustion of purge gas at the HP and LP flares have been assessed as Negligible. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 259 Table 5.13 Operational Scenario: Modelled Concentrations of Atmospheric Pollutants and Significance of Impacts on Local Air Quality Annual average 0.15 40 Negligible NOz Maximum hourly 1.87 200 Negligible concentration Shmoving co averageC)(~) 7.62 10000(*) (**) Negligible Annual average 0.42 20 Negligible PM10 Maximum Daily 1.41 50 Negligible average (*)WHO Air Qualif1J Guidelines for Europe (**)The maximum daily eight-hour mean concentration will be selected by examining eight-hour nmning averages, calculated from hourly data and updated each hour. Each eight-hour average calculated will be assigned to the day on which it ends, i.e. the first calculation period for any one day will be the period from 17:00 on the previous day to 01:00 on that day; the last calculation period for any one day will be the period from 16:00 to 24:00 on that day. Modelled pollutants concentration were spatially localised by mean of iso- concentration maps, for N02 and PM1o. These contour maps are shown in the following figures: • Figure 5.23 Operational Scenario: Predicted Annual Average Concentration. • Figure 5.24 Operational Scenario: Maximum Predicted Hourly Concentration. • Figure 5.25 Operational Scenario: Predicted Annual Average Concentration. • Figure 5.26 Operational Scenario: Maximum Predicted Daily Concentration. The iso-concentration maps shows that concentration maxima are localised downwind, thus south-east of flares; moreover the areas affected by the concentration maxima are confined in the near proximity of the Project atmospheric emission sources. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 260 Figure5.23 Operational Scenario: Predicted Annual Average Concentration for N02 IFC concetration {Jmlt: uakchott N A -- 0 6 8 Km ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 261 Figure 5.24 Operational Scenario: Maximum Predicted Hourly Concentration for NOz uakchott N A ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 262 Figure 5.25 Operational Scenario: Predicted Annual Average Concentration for PM10 ILEGENO ·OPERATIONAL SCENARIO i li) Flares (HP and LP) I OA2 0.4 0.36 uakchott 0.32 0.28 0.24 0.2 N 0.16 0.12 0.08 0 A 2 4 6 8 0.04 Km ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 263 Figure 5.26 Operational Scenario: Maximum Predicted Daily Concentration for PM1o Maximum concentration value: 1.41 1, g!m 3 IFC concetration limit: 50 p glm;' uakchott N A -- 0 1 4 6 8 Km Emergency Scenario Table 5.14 provides a summary of the results of the performed modelling study along with the significance of short term impacts on local air quality assessed with respect to IFC Air Quality Standards. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 264 Table 5.14 Emergency Scenario: Modelled Concentrations of Atmospheric Pollutants and Significance of Impacts on Local Air Quality Maximum hourly N02 24.05 200 Minor concentration Shmoving co average(.)(-) 43.00 10000(*) (**) Negligible Maximum Daily PMw 7.76 50 Minor average (*) WHO Air Quality Guidelines for Europe (**)The maximum daily eight-hour mean concentration will be selected by examining eight-hour nmning averages, calculated from hourly data and updated each hour. Each eight-hour average calculated will be assigned to the day on which it ends, i.e. the first calculation period for any one day will be the period from 17:00 on the previous day to 01:00 on that day; the last calculation period for any one day will be the period from 16:00 to 24:00 on that day. As clearly apparent from the previous table all pollutants concentrations modelled for the emergency scenario comply with IFC air quality standards. In particular modelled concentrations of CO are three orders of magnitude smaller than their respective AQS. According to the impact significance levels described above, impacts on local air quality due to CO ground level concentrations induced by the combustion of gas at the HP and LP flares in emergency conditions have been classified as Negligible; whereas impacts due to N02, and PM10 ground level concentrations have been classified as Minor. In comparison with the model results obtained for the operational scenario, short term modelled concentrations obtained for the emergency scenario appears to be higher. This trend was expected considering the higher atmospheric emissions produced in the identified emergency case. However, only Minor impacts on local air quality are expected for the emergency scenarios. Similarly to what is shown in the previous section for the operational scenario, pollutants concentration modelled for the emergency scenario were spatially localised by mean of iso-concentration maps, for N02 and PM1o short term concentrations. These contour maps are shown in the following figures: • Figure 5.27 Emergency Scenario: Maximum Predicted Hourly Concentration. • Figure 5.28 Emergency Scenario: Maximum Predicted Daily Concentration. In order to enable a comparison between model results obtained for the operational and the emergency scenarios, the same classes of concentration values have been adopted in the iso- concentration maps related to the future and present scenarios. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOWPETROLEUM (MAURITANIA) PTY LTD 265 Figure 5.27 Emergency Scenario: Maximum Predicted Hourly Concentration for N02 Flares (HP and LP) Maximum Hourly Concentration {}Jglm'] 3 Maximum concentration value: 24 u glm IFC concetratfon fimlt: 200 l' g!m 3 < uakchott N A -- 0 4 6 8 Km ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 266 Figure 5.28 Emergency Scenario: Maximum Predicted Daily Concentration for PM1o Maxhnum conce-ntrat1on value: ~-76ft glm 3 JFC concetrationlimit: 50 ,u g!m'J uakchott N A -- 0 4 6 8 Km The map of concentration isopleths show that the concentration maxima are localised downwind, thus east south-east of the flares and the areas affected by the concentration maxima are confined in the proximity of the project atmospheric emission sources. The maximum value for N02 hourly concentrations and PM1o daily concentrations occurs at a distance of approximately 33 m and 79 m from the flare, respectively. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 267 Time series extracted at the NMLS and NML9 locations for modelled short term concentrations of N02 and PM1o are presented in the following Figures: • Figure 5.29 Time Series ofNo2 Hourly Concentrations at Receptor NML8 (S~ttlement near Nouakchott- Nouadhibou Road). • Figure 5.30 Time Series ofN02 Hourly Concentrations at Receptor NML9 (University). • Figure 5.31 Time Series of PM10 Daily Concentrations at Receptor NML8 (Settlement near Nouakchott- Nouadhibou road). • Figure 5.32 Time Series of PM10 Daily Concentrations at the Receptor NML9 (University). Figure 5.29 Time Series ofNo 2 Hourly Concentrations at Receptor NMLS (Settlement near Nouakchott- N ouadhibou Road) 200 --------------------------,i,.,FC~A""'0-,-5 175 1:10 2S Figure 5.30 Time Series ofNOz Hourly Concentrations at Receptor NML9 (University) ;oo ~-------------------------------~if~C~~~cs~·· 175 i50 25 ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURrf ANIA) PTY LTD 268 Figure 5.31 Time Series of PM1o Daily Concentrations at Receptor NMLS (Settlement near Nouakchott- N ouadhibou road) trC J~CS Figure 5.32 Time Series of PM1o Daily Concentrations at the Receptor NML9 (University) JFC AQ5 As clearly apparent from the previous Figures, short term concentrations of N02 and PM1o modelled for the emergency scenario are significantly below in force AQS Standards set by the IFC guidelines. In particular, maximum modelled concentrations at receptors accounts for less of the 5% of the regulatory limits, thus even in emergency cases, impacts on local air quality at the closest receptors are classified as Negligible. Mitigation Measures No specific measures are needed to mitigate the impacts on local air quality. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 269 Impact Assessment The performed atmospheric dispersion study quantified the atmospheric ground-level concentrations of N02, CO and PM1o produced by the atmospheric emissions associated to the Banda Gas Project under operational and emergency conditions. Modelled ground level concentrations enabled the comparison with in force air quality standards, set by the IFC guideline, and subsequently the assessment of the significance of impacts on local air quality. It has to be noted that modelled pollutants ground level concentration obtained for the emergency scenario have only been compared against short term air quality standards, due to the short term nature of emergency events. The project contribution in terms of induced ground level concentrations of CO, PM and N02 is Negligible for the operational scenario. The project contribution in terms of induced ground level concentrations of CO is Negligible for the emergency scenario. The project contribution in terms of induced ground level concentrations of PM and N02 is Minor for the emergency scenario. 5.8 CUMULATIVE IMPACTS Cumulative impacts are the result of the combined effect of individual impacts, which may be of no significance when taken individually, but which can have a non-negligible cumulative impact. The potential for the Project to have cumulative impacts with other activities and with known or committed developments taking place in the area at the same time have been considered. This Section presents the assessment of the cumulative impact risk associated with the main receptors studied in the previous sections. 5.8.1 Offshore Drilling and Installation Phase Activities Considered in Assessing Offshore Cumulative Impacts Other activities in the vicinity of the offshore component of the Project area have the potential to cause cumulative impacts. These include: • the operations of the Chinguetti oilfield located approximately 20 km to the west of the Banda field; • the oil and gas exploration activities in the vicinity of the Project area; and • the shipping and fishing related traffic in the Project area. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 270 These scattered and intermittent sources are not considered to cause any significant impact. Interference with Shipping and Navigation of Other Sea Users The vessels taking part in the Project activities will increase shipping traffic in the area, which could increase the risk of collision between vessels. However, with only 1-2 ships a day pass within 30 nautical miles of the Banda field the baseline traffic is relatively low and no particular mitigation or management measures are required to address this cumulative impact. Noise Disturbance to Marine Fauna Cumulative impacts linked to submarine engine noise could be large scale if there was a large amount of shipping traffic in the Project area, or if seismic acquisition surveys were taking place in neighbouring blocks over the same period. The noise disturbance to marine fauna caused by the Project will be localised and in view of the distance between the various blocks and the relatively low traffic in the Project area, these cumulative impacts are not considered to be significant. · Atmospheric Emissions Atmospheric emissions result from the combustion of diesel fuel by the various vessels taking part in the Project.. Taken separately, these emissions are small, intermittent and localised and will not constitute any significant deterioration of the air quality in the Project area (see Chapter 3 for the Project's Emissions inventory). Other possible contributors to air emissions are the other vessels crossing the area. However, the cumulative impact of emissions generated by all shipping traffic in the area should not lead to any significant deterioration of the air quality and no particular mitigation or management measures are required to address this cumulative impact. The offshore construction phase emissions will represent 1.1% of the country's yearly GHG emissions (see Chapter 3 for the Project's Emissions inventory). Waste Generation and Effluent Discharge The Project's waste generation (including both liquid and solid waste, whether hazardous or not) will be localised, of small scale, and limited in time. No ~other significant waste generators have been identified in the vicinity of the Project area and the cumulative impacts linked to the generation and management of waste by other sea users is considered to be Negligible. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 271 5.8.2 Onshore Construction Phase Activities Considered in Assessing Cumulative Impacts from Onshore Construction Other activities or proposed developments in the vicinity of the onshore component of the Project area have the potential to cause cumulative impacts during the onshore construction phase. These include: • the construction of the proposed SPEG power plant; • the construction and operation of the new international airport; and • the existing road traffic on the Nouakchott-Nouadhibou. Due to their scale, expected to be larger than the Banda Gas development, the construction of the proposed SPEG power plant and the new international airport have the potential to cause impact of higher significance than the one covered in this EIA. Noise Disturbance to Local Community Few receptors are located in the vicinity of the proposed gas processing plant and the cumulative impact risk on Noise has been assessed as Negligible. No particular mitigation or management measures are required to address this cumulative impact. Traffic Safety The road infrastructure (dual carriage way) in the Project area is considered to have the capacity to accommodate the additional traffic caused by the proposed development without compromising traffic safety. Therefore the cumulative impact risk on traffic safety has been assessed as Negligible and no particular mitigation or management measures are required to address this cumulative impact. Air Quality Few receptors located in the vicinity of the roads used by the different developments in the area have been identified and the cumulative impact risk on Air Quality has been assessed as Minor. No particular mitigation or management measures are required to address this cumulative impact. Clearance of Natural Habitats The natural habitats within the plant layout and the pipeline were not found to be of particular environmental sensitivity at a regional scale. Other proposed development can impact these natural habitats but cumulative impact risk is considered as Minor. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 272 5.8.3 Operational Phase Activities Considered in Assessing Operational Cumulative Impacts Other activities or proposed developments in the vicinity of the onshore component of the Project area have the potential to cause cumulative impacts during the operation phase. These include: • the operation of the proposed SPEC power plant; • the operation of the new international airport; • residential developments (such as the Ribat El Bahr proposed development); and • road traffic on the Nouakchott-Nouadhibou road and the proposed Nouackhott ringroad. Due to its scale and nature, the operation of the proposed SPEC power plant will generate higher volumes of atmospheric emissions and discharges than the proposed Banda Gas development. No offshore activities have been considered as a potential source of cumulative impact as during its operational phase, all the Project infrastructure will be subsea and are not expected to interfere with other activities or proposed developments. Constraint on Land Planning The onshore component of the Project is located on mostly undeveloped land, 5 km north of the edge of the city of Nouakchott, which experiences rapid suburban growth. Other proposed developments (such as Nouakchott's proposed ring road or the Ribat El Bahr residential development) in the vicinity of the Project can constitute additional constraints on land planning during the Project operations. Therefore the cumulative impact on land planning is considered to be Moderate. Tullow will have to coordinate with the Ministry of Urbanism so that the exclusion zone is included in the land planning scheme. Air Quality In consideration of the IFC General EHS guidelines (IFC, 2007) the significance criteria for air quality impacts used in the present study have been defined to) allow additional development in the same airshed. The IFC General EHS guidelines recommends that projects with significant sources of air emissions, such as the Project flares, should not contribute to the attainment of relevant ambient air quality guidelines or standards for more than 25 % of the applicable air quality standards. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM {MAURITANIA) PTY LTD 273 Maximum modelled concentrations (for N02, CO and PM1o) at nearest receptors accounts for less of 5% of the regulatory limits and allow other developments in the same airshed. Therefore the cumulative impact risk on Air Quality has been assessed as Minor. Future developments in the vicinity of the Project area, in particular the SPEG power plant which will generate much more significant atmospheric emissions than the Banda Gas processing facility, should consider the Project's atmospheric emissions in their baseline in order to assess actual cumulative impacts on air quality. Noise Disturbance to Local Community Few receptors are located in the vicinity of the proposed gas processing plant and the cumulative impact risk on Noise has been assessed as Negligible. No particular mitigation or management measures are required to address this cumulative impact. Traffic Safety The road infrastructure (dual carriage way) in the Project area is considered to have the capacity ~o accommodate the additional traffic caused by the proposed development without compromising traffic safety. Therefore the cumulative impact risk on traffic safety has been assessed as Negligible and no particular mitigation or management measures are required. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 274 6 ENVIRONMENTAL MANAGEMENT PLAN 6.1 INTRODUCTION The environmental and social impacts expected from the Project, and the measures proposed to mitigate these impacts to an acceptable level, are discussed in Chapter 5. This chapter describes the Environmental Management Plan (EMP) for the Project. This EMP is intended to be used throughout the Project lifecycle as the basis for the detailed design and implementation of environmental mitigation measures to be established by Tullow in coordination with its Contractors. 6.2 EMP OBJECTIVES The EMP should be viewed as a register of the mitigation measures proposed by Tullow in the EIA, to provide guidance for their implementation, as the Project progresses. It is intended as a "live" document, to be periodically reviewed as part of an ongoing improvement process, and adjusted as new circumstances arise during the course of the Project, such as a change in the Project design, the occurrence of unforeseen environmental conditions or any unplanned event. Its objectives are as follows: • To ensure compliance of the Project with Mauritanian legislation, international law and international standards, as well as with good practice in the oil and gas industry. • To help ensure that all the mitigation measures and all the commitments made by Tullow and identified in the EIA report are taken into account during the survey planning and performance phases. • To establish an environmental surveillance and monitoring programme so that the EMP can be updated and improved as the Project progresses. 6.3 CONSISTENCE WITH TULLOW EHS MANAGEMENT STANDARDS Tullow Oil Pic has adopted an Integrated Management System (IMS), setting out the expectations that operating and support functions are required to meet. One of the IMS elements is Environment, Health and Safety (EHS) which forms the basis for all underpinning EHS processes and systems, setting out the minimum EHS requirements for business delivery across the group. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURIT ANJA) PTY LTD 275 The Tullow EHS Management Standards consist of 14 Standards. Each Standard consists of a principle statement to provide the overall intent and mandatory EHS requirements. Each standard states a number of EHS requirements that all operations and activities within the organization must meet: • Standard 1 Leadership and Accountability. • Standard 2 Regulatory Compliance & Consultation. • Standard 3 Risk Management. • Standard 4 Management of Change. • Standard 5 Design, Construction & Commissioning. • Standard 6 Operations, Maintenance & Integrity. • Standard 7 Contractor Management. • Standard 8 Asset Protection. • Standard 9 Environmental & Social Management. • Standard 10 Health Management. • Standard 11 Incident Reporting & Investigation. • Standard 12 Training, Competency & Behaviours. • Standard 13 Information & Document Management. • Standard 14 Assessment, Assurance & Improvement. The Banda Gas Environmental Management Plan will be implemented through the development and application of a set of Project-specific EHS management procedures, which will be developed in line with the Tullow EHS Standards, and adapted to the EHS sensitivities specific to the Banda Gas project. 6.4 SPECIFIC MANAGEMENT PROCEDURES 6.4.1 Introduction In addition to the Project's EMP, an EHS plan will be prepared prior to the start of the construction activities, which will include at least the following: • a vessel emergency oil spill contingency plan; • an onshore oil and chemical spills prevention and contingency procedure; • a waste management plan; • a maritime and fisheries liaison procedure; and • an archaeological chance finds procedure. The principles of these procedures are detailed in the following sections. 6.4.2 Vessel Emergency Oil Spill Contingency Plan Despite the prevention measures and management procedures built into the design of the Project there is always a risk that an oil spill can occur. In response to such an event, an Oil Spill Contingency Plan (OSCP) will be ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 276 developed which has procedures which set out the strategy and specific actions that will be taken in the event of an oil spill. The actions that will be required for the OSCP in the event of an oil spill vary according to the size of the spill. Oil spills are defined according to three 'Tiers'. This classification is in alignment with the International Petroleum Industry Environmental Conservation Association (IPECA) which advocates a response to oil spills such that the planned response engages resources commensurate with the severity of the spill with the higher the Tier the higher the level of response required. The OSCP has been informed by the oil spill modelling study so that the response strategy and location of equipment takes into account the areas most at risk and the response times required to mobilise resources and equipment in the event of a spill. The OSCP interfaces closely with the Mauritanian National Oil Spill Contingency Plan. The resources available to provide a suitable response to any oil spill from the project, and the responsibility for leading spill response, are set out in the OSCP as follows for each Tier of spill. • Tier 1: The response to all Tier 1 spills will remain the responsibility of Tullow. Tullow will hold the appropriate level of Tier 1 oil spill response equipment and trained personnel so as to facilitate an immediate response in the event of a Tier 1 spill and to assist with Tier 2 spill events. • Tier 2: In the event of a Tier 2 spill event the initial response would be the responsibility of Tullow. However, if the magnitude of spill warrants a further response it would engage mutual aid resources which may be provided by industry partners within Mauritania and the Oil Spill Response Limited (1) (OSRL) West and Central Africa surveillance and spraying aircraft. • Tier 3: In the event of a spill situation which is clearly beyond Tullow' s immediate response capability, both mutual aid resources which may be provided by industry partners within Mauritania and the OSR call-out guarantee from the Oil Spill Response Base in Southampton, UK. It is important to note that, in Tier 2 and 3 spill situations, the response strategy set out in the OSCP is intended to align with the Mauritanian National Oil Spill Contingency Plan and comply with its requirements. The intention is that in any major spill situation there is cooperation between Tullow, other offshore oil and gas operators and the Government of Mauritania in order to ensure a coordinated and effective response to a spill. (1) Oil Spill Response Limited (OSRL) is a Global Tier 3 Oil Spill Response Organization, owned by its oil industry member shareholders, for the benefit of its members. OSRL provides immediate response to a Tier 3 oil spill from Southampton, UK. Regional Tier 2 response can be provided with access to an aircraft based in Accra (Ghana) which can both spray dispersant and detect and quantify oil at sea using specialist remote sensing cameras. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 277 6.4.3 Onshore Oil and Chemical Spills Prevention and Contingency Procedures Management procedures to reduce the risk of oil or chemical spill during construction works and operations will include the following measures: • Vehicles and equipment shall be appropriately maintained to ensure they are free of leaks. • Drip trays must be provided to capture any drips or spills eg during storage and decanting of hazardous substances including refuelling of bowsers and generators. • Fuel bowsers and refuelling areas are to be installed on bunded concrete hardstand (rollover vehicle bunds are permitted). • During refuelling, the fuel dispensing j fill point must be attended at all times to monitor fuel delivery. • Chemical and hydrocarbon storage facilities must be covered to prevent rainfall ingress into bunded areas. • Secondary containment (e.g. bunding) must be capable of holding at least 100 per cent of the volume of the largest package plus 25% of the storage capacity. • Gauges to measure volume must be installed in order to prevent overfilling. • Fuel and storage areas must be regularly inspected. • Oil water separators (such as triple interceptors) must be installed and maintained to treat all oily water draining from bunded hydrocarbon storage facilities. Despite the management procedures built into the design of the Project there is always a risk that an oil or chemical spill can occur during construction works or operations. In response to such an event, onshore oil and chemical spills contingency procedures will be developed to set out the specific actions that will be taken in the event of an onshore oil or chemical spill. These will include at least the following measures: • Material safety data sheet and spill control equipment will be available at all hazardous material storage and handling locations, and on plant where there is a high risk of spills (including mobile refuelling trucks). • Spill kits will be available at all refuelling locations regularly inspected and maintained. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 278 • The spill substance is to be identified and the relevant material safety data sheet located immediately to ensure that appropriate corrective actions can be made, and to assist emergency response teams with their preparation and response. • All hazardous materials spills must be cleaned up as soon as is reasonably practicable to avoid or limit potential environmental impact or health risk. 6.4.4 Waste Management Plan A Banda Gas Development Project detailed Waste Management Plan (WMP) will be developed and implemented for all stages of the Project in accordance with Tullow' s requirements and procedures. This WMP will be aligned with the waste management procedures developed for similar Tullow Oil projects and will follow current good practice within the oil and gas industry (1 ) and IFC requirements. The WMP will include a description of the non-hazardous and hazardous waste streams expected from the various Project activities. The WMP will adopt the principles of the 'waste hierarchy' to ensure that waste generation is reduced and reuse and recycling is maximized. Waste such as scrap metal will be recycled at approved facilities, where possible. Information on the procedures for handling, storage and treatment and disposal of all project wastes will be included in the WMP. As part of the development of the WMP, Tullow will identify suitable local companies and facilities to receive both non-hazardous and hazardous wastes. All companies receiving Banda Gas Development Project wastes will be approved by the authorities and shall be audited by Project staff prior to receiving any wastes to ensure good practices are in place and companies operate to wholly acceptable standards. Where suitable facilities do not exist for the onward management of hazardous wastes in-country Tullow will store the wastes as an interim measure until suitable companies have been identified. Where necessary the export of hazardous wastes will be considered as an option to allow the sound management of specific waste streams. Where this is necessary all international conventions shall be followed (see Chapter 2) Tullow recognises that waste traceability is a key issue and that it has a duty to ensure that any waste generated is handled safely and in accordance with legal requirements and good international practice. The WMP will implement a waste tracking system to ensure the management of wastes produced from all operational activities from 'cradle-to-grave'. Waste Transfer Notes (WTNs) will be used to ensure that wastes are transferred from the producer, through the transportation chain to the final disposal point and will provide a record of due diligence across the system. (1) OGP (2009) Guidelines for Waste Management witlr Special Focus on Arens witlr Limited Infrnstmchtre. Oil & Gas Producers Report No. 413. September 2008 (rev1.1, updated March 2009). ENVlRONMENT AL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANJA) PTY LTD 279 The following sections provide an initial framework and waste procedures for offshore vessels and onshore locations for the management of expected wastes. It is envisaged that more detailed procedures will be developed as part of the comprehensive Environmental Management System (EMS) that will be periodically updated and improved to reflect the full scope in-country operations. 6.4.5 Maritime and Fisheries Liaison Procedure Other ships travelling within the Project area and its immediate surroundings must be informed about the Project and its timetable. The maritime and fisheries liaison procedure will supply the Project contact details to the Mauritanian port authorities and the fishing communities concerned. Procedures will also be implemented to take account of the presence of fishing boats in the Project area during offshore drilling and installation activities. Any incidents that may occur will be logged and all relevant details will be entered (time, date, type of incident, etc.). 6.4.6 Archaeological Chance Finds Procedure An archaeological chance finds procedure should be developed to manage unexpected finds resulting from any ground disturbing activity. The goal of this action is to minimize potential impact to subsurface archaeological sites that were not detected by archaeological field survey. Basic archaeological training should be provided to Project staff and construction workers to help them identify subsurface archaeological resources discovered during ground disturbing activities. This training can be included as part of introduction training and should insist on the fact that unexpected finds must immediately be reported. The goal of this action is to elevate the protection of either known or unknown archaeological resources from potential impacts from ground disturbing activities. An archaeologist will be deployed to monitor active construction fronts and to guide the recognition of and response to archaeological finds. Protocols will be established for responding to chance finds, including cessation of work in the vicinity of potential significant finds and notification of the Mauritanian Institute for Scientific Research (Institut Mauritanien de Recherche Scientifique - IMRS) and relevant authorities. Expedited plans will be used for evaluation and rescue of significant chance finds; and an auditable record of monitoring activities will be maintained, including negative findings as well as discoveries. All and any artefacts found must be handed over to the IMRS. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 280 Where sites of importance are identified through the chance finds procedure they will be avoided where practicable. If a site cannot be avoided it will be evaluated to determine whether it would be considered non-replicable heritage in accordance with IFC PS8. If it is non- replicable then the construction team will work with the IMRS and relevant government authorities to determine an appropriate strategy. Where sites are considered to be replicable they may be moved to a new location for their protection in consultation with the IMRS. If a cultural heritage site is damaged it will be treated as an incident, if any features are lost or damaged a mitigation strategy will be further developed under the direction of the Cultural Heritage Working Group. 6.5 IMPLEMENTING THE EMP Tullow will own primary responsibility for implementing the EMP. The Project's contractors will also need to integrate the requirements of the EMP in their operating procedures, and ensure that : • Roles and responsibilities for EMP implementation and environmental, social, health and safety are clearly defined within the contractor's structure. • Staff are aware of environmental, social, health and safety procedures. • Procedures for communication and corrective action are established, to allow for appropriate reaction in case of an environmental, social, health and/ or safety incident. • Periodic auditing and review of the EMP implementation are undertaken. 6.6 MANAGEMENT OF CHANGE Gaps and uncertainties inevitably remain in terms of information regarding the proposed Project and the EIA process at the time of writing this report. As a result, Tullow will implement a clear and transparent Management of Change Procedure, in order to take gaps and uncertainties into account as and when they arise. Uncertainties remaining about the timetable and logistics for the Project must be addressed in a structured and transparent manner. The procedure that Tullow proposes to implement in order to manage these uncertainties is outlined in Figure 6.1. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 281 Figure 6.1 Process for the management of change relating to the Project 6.7 DETAILS OF THE EMP The EMP presented in Table 6.1 to Table 6.3 sets out all the specific measures that Tullow proposes to adopt to reduce the impacts identified in this EIA. This EMP should be viewed as the outcome of the overall Banda Gas EIA. The EIA describes the environmental and social context for the Project, details the Project description on which the assessment was based, and describes the impacts and associated mitigation measures, as well as any residual impacts. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MA UR!TANIA) PTY LTD 282 In the following pages: • Table 6.1 presents the mitigation measures and commitments register associated with the offshore construction phase of the Project. • Table 6.2 presents the mitigation measures and commitments register associated with the onshore construction phase of the Project. • Table 6.3 presents the mitigation measures and commitments register associated with the operational phase of the Project. Note that most costs associated with environmental mitigation are embedded in the construction activities and Project operations, and can therefore be considered to form part of the Project cost, rather than being considered as dedicated environmental mitigation costs. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 283 Table 6.1 Mitigation Measures and Commitments Register- Offshore Drilling and Construction Phase Al Physical Presence Al.l Interference with • Provide advanced notice to maritime authorities Section Duration of FLO N/A Included in shipping and navigation Liaison with relevant stakeholders before start of offshore 5.5.3 offshore standard from MODU presence construction. Navigational marks and lights on the MODU construction operations • The MODU will maintain radio contact with other users of the sea to mitigate the risk of collisions A1.2 Interference with shipping and navigation due to 500 m exclusion . • Provide advanced notice to maritime authorities Liaison with relevant stakeholders before start of offshore construction Section 5.5.3 During drilling FLO N/A Included in standard operations zone Navigational marks and lights on the MODU " The MODU will maintain radio contact with other sea users to mitigate the risk of collisions. A1.3 Temporary interference $ Essentially during pipelay operations, as artisanal fishermen Section During drilling FLO N/A Cost ofFLOs with artisanal fisheries will not be affected by the drilling exclusion zone which is too 5.5.3 andpipelay for the work due to exclusion zone far out to sea operations : approx. around drilling and ~ Presence of Fishing Liaison Officers (FLOs) on-board selected 20,000 USD. pipelay operations installation vessels to liaise between fishermen and the Project. The installation vessels will maintain radio contact with other users of the sea to mitigate the risk of collisions. Exclusion zone will be monitored for the safety of the facility and other users of the area (eg fishermen) A1.4 Crossing over the Liaison with the cable operator and development of a crossing Section Before pipelay Pipelay manager N/A Cost of existing ACE cable in approx. 15m of water . agreement. Physical separation between the pipeline and the ACE fibre optic cable. 5.5.3 operations During pipelay operations matting: up to approx .. 600,000 USD. • Protection of the section of pipeline lying on the seabed by rock dumping or flexible concrete mats. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 284 A2 Drilling Operations (top hole and bottom sections) A2.1 Discharge of drill Selection and use of drilling fluids taking into account its Section Top hole Drilling Manager 5-10% oil on cuttings Included in cuttings and fluids concentration, toxicity, bioavailability and bioaccumulation 5.5.1 drilling prior to discharge from standard casing physical potential with selection based on least environmental potential MODU operations smothering of seabed; hazard. water and sediment Seawater and sweep pills used to drill top and surface sections contamination from Use of low toxicity improved SBM, if SBMs is required in light chemicals; and impact to of technical / geological constraints marine fauna from Use solid control equipment to minimise oil and cuttings(5% to * exposure to chemicals 10%) from WBM and improved SBM sections e Separate cuttings from oil before discharge Discharge via caisson 5 m below the water surface A3 Well Completion A3.1 Discharge of completion * Selection and use of completion fluids taking into account its Section 5.4; During Drilling Manager Oil in water content: Included in fluids concentration, toxicity, bioavailability and bioaccumulation Table 5.4 completions - 29·mgl-1 (30 day standard potential with selection based on least environmental potential average) operations hazard -42 mgl-1 (maximum) Compliance with IFC requirements with regards to oil in water contents (Maximum one day oil and grease discharge should pH range 5 to 7 (prior not exceed 42 mg/L; 30 day average should not exceed 29 to discharge) mg/L). A3.2 Emissions from flaring completion fluids and . Any spent acids will be neutralised before testing and disposal Minimise volume of completion and flow back fluid to be flared to the extent practical Section 5.4; During Table 5.4 completions Drilling Manager N/A Included in standard hydrocarbons during • Minimise well test durations to the extent practical operations well testing • Use efficient test flare burner head equipped with an appropriate combustion enhancement system to minimise incomplete combustion, black smoke and hydrocarbon fallout to the sea . A4 Subsea Installation and Conunissioning A4.1 Physical impact to Pre-installation survey Section 5.4; During subsea Subsea Recorded baseline Included in seabed and benthic Post-installation survey Table 5.4 installation Installations conditions standard fauna from subsea Provision of data for inclusion of nautical charts. Manager operations infrastructure ENVIRONMENTAL RESOURCES MANAGEMENT TULWW PETROLEUM (MAURITANIA) PTYLTD 285 A4.2 Physical impact to Pre-installation survey Section 5.4; During subsea Pipelay Manager Recorded baseline Included in seabed and benthic Post-installation survey Table 5.4 installation conditions standard fauna from pipeline andG Provision of data for inclusion ofnautical chartsMicro-routing operations umbilicalinstalla tion the pipeline to avoid sensitive habitats A4.3 Physical impact to Pre-installation survey Section 5.4; During subsea Pipelay Manager Recorded baseline Included in nearshore seabed and Post-installation survey Table 5.4 installation conditions standard * benthic fauna, and Beach inspection at the pipeline landfall before ground phase operations * landfall site. disturbing activities in order to identify any potential turtle nest Micro-routing the pipeline to avoid sensitive habitats AS Testing and Pre-Commissioning Operations AS.l Discharge of hydrostat Dewater pipeline offshore so that discharge is offshore Section 5.4; During Testing Operations N/A Included in waters, impact on water ensuring good dilution. Table 5.4 and Pre- Manager standard quality and fauna. Selection and use of completion fluids taking into account its Commissioning operations concentration, toxicity, bioavailability and bioaccumulation potential with selection based on least environmental potential hazard A6 Employment and Procurement A6.1 Employment and 0 Implement Tullow' s local employment and skills development Section 5.4; Throughout of Operations N/A Cost of training opportunities policies. Table 5.4 offshore Manager (with training to Accordingly, Tullow and its contractors, will employ and train construction support from be nationals where it is practical to do so. CLO) determined as part of labour study. A6.2 Opportunities from Implement Tullow' s local content policy. Section 5.4; Throughout of Operations N/A Included in procurement of local Accordingly, Tullow and its contractors will use local products Table 5.4 offshore Manager (with standard goods and services and services where it is practical to do so. construction support from operations CLO) A7 Support Vessels j Helicopter Support: Drilling, Completions, Installation and Commissioning A7.1 Interference with 9 Provide advanced notice to maritime authorities Section Throughout of Operations N/A Included in shipping and navigation ® Navigational marks and lights on vessels 5.53 offshore Manager (with standard due to support vessel $ The support vessels will maintain radio contact with other construction support from operations presence; collision risk users of the sea to mitigate the risk of collisions. Vessel transit CLO) route will be communicated to fishermen through the CLOs ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 286 Prevent excessive speeds and rapid change of direction for presence and noise) to vessels when operating in the field to reduce risks of collisions Table 5.4 offshore standard marine mammals construction operations A7.3 Disturbance to important Helicopters will normally not have to fly over IBAs during Section 5.4; Throughout of Helicopter pilots N/A Included in bird habitats by normal operation. Helicopters flying over IBAs must maintain Table 5.4 offshore standard helicopters a minimum altitude of 2,300 ft (710 m) to minimise disturbance construction operations AS Other Emissions and Discharges : Drilling, Completions, Installation and Commissioning A8.1 Discharge of black and Compliance with MARPOL Annex IV requirements and good Section 5.4; Throughout of Vessel captains Black water: Included in grey water (including industry practice including treatment of black water in an IMO Table 5.4 offshore - no floating solids standard macerated food wastes) compliant sewage treatment facility construction - residual chlorine at operations <1 mgl-1. Grey water: - max particle size <25 mm - no floating solids or A8.2 Discharges from vessels contaminated with trace . Compliance with MARPOL Annex I requirements and good industry practice Section 5.4; Throughout of Table 5.4 offshore Operations Manager (with foam 15 mgl-1 oil and grease Included in as a maximum limit standard hydrocarbons (bilge construction support from operations A8.3 water, deck drainage) Discharge of ballast . Compliance with MARPOL requirements Section 5.4; Throughout of vessel captains) Operations Exchanging ballast Included in water (from MODU and other vessels) . • Ballast water management measures Compliance with International Convention for the Control and Management of Ships Ballast Water & Sediments to minimise Table 5.4 offshore construction Manager (with support from vessel captains) water at least >200 nm standard from shore operations the transfer of organisms A8.4 Impact to air quality Compliance with MARPOL Annex VI, which sets limits on Section 5.4; Throughout of Operations N/A Included in from release of gaseous sulphur dioxide and nitrogen oxide emissions from ship Table 5.4 offshore Manager (with standard emissions from power exhausts and prohibits deliberate emissions of ozone depleting construction support from operations generation and engine substances vessel captains) exhaust Routine inspection and maintenance of engines, generators and other equipment to minimise air emission ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 287 A8.5 Waste generated on the Operational controls contained in Waste Management Plan. Section 5.4; Throughout of Operations Zero loss of Included in MODU and Project Proper storage of hazardous waste Table 5.4 offshore Manager (with containments during standard vessels will be Safe transport using well maintained and suitable vehicles or construction support from storage and transport operations segregated offshore for vessels and trained operators vessel captains) of wastes storage/ disposal Use of Tullow approved waste contractors onshore. Selection of a suitable disposal facility or facilities Maximised recycling of * Measures to ensure proper continuous operation and wastes monitoring of the disposal facility A9 Unplanned / Accidental Events : Drilling, Completions, Installation and Commissioning A9.1 Accidental fuel oil MODU and marine vessels will be designed, operated and Section Throughout of Operations N/A Included in (diesel) spill impacting maintained in accordance with international standards such 5.5.2 offshore Manager standard the marine environment that the risk of accidental spills will be minimised. construction operations Oil spill prevention equipment, measures and procedures Oil Spill Contingency Plan (OSCP) which contains detailed procedures that will be followed in the event of an oil spill ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLID 288 Table 6.2 Mitigation Measures and Commitments Register- Onshore Construction Phase B1.1 Phvsical disolacement • Should the Project configuration change in such a way that Section 5.4; Design phase Tullow's External Minimize physical Included in some physical displacement is required, Tullow will manage Table 5.5 Affairs Manager displacement (only one standard displacement in line with IF C-PS 5. Prior to land small scale operations acquisition construction has been identified on the proposed exclusion B1.2 Economic displacement . The proposed onshore pipeline will be trenched and will not prevent movement across the proposed route or cause any Section 5.4; Design phase Table 5.5 zone) Tullow' s External N/A Affairs Manager Included in standard severance operations B2 Plant Construction Activities B2.1 Ground Disturbance Areas of required ground disturbance will be clearly defined Section 5.4; Duration of Construction N/A Included in and ground disturbance outside these areas will be avoided Table5.5 ground Manager standard Excavated top soils will be stored for future re-use for disturbance operations revegetation activities Excavated material will be used, where possible, for onsite landscaping/ re-pro filing B2.2 Biodiversity * Areas where ground disturbance is required will be clearly Section 5.4; Duration of Construction N/A Included in delineated Table 5.5 ground Manager standard Vegetation clearance will be kept to a minimum disturbance operations Disturbance in sensitive habitats (such as shrubs) will be activities minimised Any vegetation cut on the gas processing facilities location will be offset. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PrY LTD 289 No specific mitigation required. Best practice and good Section Duration of Construction LAeq,lhr <55 dB(A) operation management will be applied such as : 5.6.1 works Manager for the daytime and 45 standard 0 enforcement of'appropriate speed limits for heavy dB(A) for the night operations vehicles to reduce noise time and utilisation of silent, well maintained industrial equipment LAMax < 85 dB A at all (incorporating noise reduction systems such as capping permanent monitoring and mufflers if required) locations. • noise monitoring at established permanent monitoring locations (such as the new university) to ensure compliance with the international standards B2.4 Atmospheric Emissions e Routine inspection and maintenance of engines, generators Section 5.4; Duration of HSE Manager N/A Included in and other equipment to minimise air emission Table5.5 works standard Use of low-sulphur diesel if locally available. operations B2.5 Cultural Heritage @ A surface artefacts collection will be organized before the Section 5.4; Duration of HSE Manager N/A Up to ground disturbing activities under the supervision of the Table 5.5 works approximate Mauritanian Institute for Scientific Research (Institut ly Mauritanien de Recherche Scientifique- IMRS). 25,000USD Basic archaeological training in site detection should be for pre- provided to Project staff and construction workers construction An archaeological chance finds protocol should be developed artefacts to manage unexpected finds collection B2.6 Road traffic $ Application of the company's road safety policy to operator Section 5.4; Duration of HSE Manager Zero traffic accident Included in and contractor vehicles Table5.5 works standard operations B2.7 Liquid Effluent Waste water will be treated on site via an onsite waste water Section 5.4; Duration of HSE Manager N/A Included in treatment system. Table 5.5 works standard operations B2.8 Temporary After use, temporary sites will be cleared of any structure and Section 5.4; Upon Construction Recorded baseline Included in infrastructures wastes and re-profiled Table5.5 completion of Manager conditions standard installation construction operations works ENVIRONMENTAL RESOURCES MANAGEMENT TULLO\V PETROLEUM {MAURIT ANJA) PTY LTD 290 B3.1 Ground disturbance . Areas where ground disturbance is required will be clearly delineated Section 5.4; Duration of Table 5.5 ground Construction Manager N/A Included in standard Vegetation clearance will be kept to a minimum disturbance operations For the trenching phase, the excavated material will then be activities used as back-fill to bury the pipeline The pipeline route will be reinstated. B3.2 Biodiversity Disturbance in sensitive habitats (such as shrubs) will be Section 5.4; Duration of Construction N/A Cost of minimised Table 5.5 ground Manager beach The pipeline route will be reinstated. disturbance inspection Beach inspection at the pipeline landfall before ground activities approx disturbing activities in order to identify any potential turtle 1000 USD. nest B3.3 Noise • No specific mitigation required. Best practice and good Section Duration of HSE Manager N/A Included in operation management will be applied such as: 5.6.1 works standard enforcement of appropriate speed limits for heavy operations vehicles to reduce noise utilisation of silent, well maintained industrial equipment (incorporating noise reduction systems such as capping B3.4 Ah11ospheric Emissions . and mufflers if required) Routine inspection and maintenance of engines, generators and other equipment to minimise air emission Section 5.4; Duration of Table 5.5 works HSE Manager N/A Included in standard Use of low-sulphur diesel where possible operations B3.5 Cultural Heritage • The footprint of the Onshore Pipeline route should be Section 5.4; Duration of HSE Manager N/A Up to surveyed by an archaeologist for any sites that may potentially Table 5.5 works approximate be impacted by associated ground disturbing activities ly Basic archaeological training in site detection should be 25,000 USD provided to Project staff and construction workers for pre- A surface artefacts collection will be organized before the construction ground disturbing activities under the supervision of the artefacts Mauritanian Institute for Scientific Research (Institut collection Mauritanien de ReclU?rche Scientifique - IMRS) • An archaeological chance finds protocol should be developed to manage unexpected finds ENVIRONMENTAL RESOURCES MANAGEMENT TULWW PETROLEUM (MAURITANIA) PT1 LTD 291 B3.6 Highway crossing . Safety process for highway crossing will be established in liaison with the road traffic authorities Only one lane will be Section 5 .4; Duration of Table 5.5 works Construction Manager N/A Internal time closed at a time B3.7 Road traffic $ Application of the company's road safety policy to operator Section 5.4; Duration of HSE Manager Zero traffic accident Included in and contractor vehicles. Table 5.5 works standard operations B4 Plant Commissioning Activities B4.1 Noise No mitigation required. Best practice and good operation Section 5.4; Duration of HSEManager LAeq,lhr <55 dB(A) Included in management will be applied Table5.5 commissioning for the daytime and 45 standard activities dB( A) for the night operations time and LAMax < 85 dB A at all permanent monitoring locations. B4.2 Liquid effluents * Selection and use of chemicals taking into account its Section 5.4; Duration of HSE Manager N/A Included in concentration, toxicity, bioavailability and bioaccumulation Table 5.5 commissioning standard potential with selection based on least environmental potential activities operations hazard. Ensure minimal quantities of chemicals are used. B5 B5.1 Construction Personnel Employment and Training . Implement Tullow' s local employment and skills development Section 5.4; Duration of policies. Table 5.5 works Tullow'sHR Department N/A Cost of training to $ Accordingly, Tullow and its contractors will employ and train be nationals where it is practical to do so. determined as part of labour study. B5.2 Procurement of goods • Implement Tullow' s local content policy. Section 5.4; Duration of Tullow'sHR N/A Included in and services Accordingly, Tullow and its contractors will use local products Table 5.5 works Department standard and services where it is practical to do so. operations ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MA URIT ANI A) PTY LTO 292 Operational controls contained in Waste Management Plan. Section 5 .4; Duration of HSEManager Zero loss of Included in Generation • Safe transport using well maintained and suitable vehicles and Table 5.5 works containments during standard trained operators. storage and transport operations Use of Tullow approved waste contractors. of wastes Selection of a suitable disposal facility or facilities. Measures to ensure proper continuous operation and Minimized volume of monitoring of the disposal facility. wastes B6.2 Industrial Waste Operational controls contained in Waste Management Plan. Section 5.4; Duration of HSEManager Zero loss of Included in Generation Proper storage of hazardous waste. Table 5.5 works containments during standard Safe transport using well maintained and suitable vehicles and storage and transport operations trained operators. of wastes Use of Tullow approved waste contractors. Selection of a suitable disposal facility or facilities. Maximised recycling of Measures to ensure proper continuous operation and wastes monitoring of the disposal facility. B7 B7.1 Unplanned/ Accidental Events Loss of containment . Oil spill prevention equipment, measures and procedures. Maintenance of vehicles. Section 5.4; Duration of Table 5.5 works HSE Manager Zero loss of containment during Included in standard Management plan of hazardous products. storage and transport operations Oil Spill Contingency Plan (OSCP) which contains detailed of hazardous products procedures that will be followed in the event of an oil spill. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 293 Table 6.3 Mitigation Measures and Commitments Register- Operational Phase No specific mitigation required. Best practice and good Section HSEManager LAeq,lhr <55 dB(A) Up to operation management will be applied such as : 5.7.1 for the daytime; approx. enforcement of appropriate speed limits for heavy 45 dB(A) for the night 25,000USD vehicles to reduce noise time and for yearly utilisation of silent, well maintained industrial equipment LAMax < 85 dBA monitoring (incorporating noise reduction systems such as capping f!.. LA90<8dBA and mufflers if required). at all monitoring * periodic (yearly) noise monitoring at established locations. permanent monitoring locations (such as the new university) to ensure compliance with the international standards (note that noise measurements will not only measure the contribution of the Project, but also those of neighbouring projects like the SPEG owned thermal power plant. Noise measures will therefore only provide an indication of possible changes to ambient noise level, but it will not be possible to clearly relate such changes to the Banda gas processing facility) Cl.2 Atmospheric Emissions Routine inspection and maintenance of engines, generators and Section Throughout the HSE Manager Ambient Air Quality Included in other equipment to minimise air emission. 5. 7.2 Project IFC Standards standard Greenhouse gas reduction strategy with focus on optimisation operations of overall energy efficiency and reduction in flaring and Annual average : venting. N02: 40 11g/m3 Air quality monitoring at established permanent monitoring PM 10 : 20 11g/m3 locations (such as the new university) to ensure compliance with the international standards (note that ambient air quality Max lh: measurements will not only measure the contribution of the N02 : 200 11g/ m 3 Project's atmospheric emissions, but also those of neighbouring projects like the SPEG owned thermal power plant, and more Max daily average generally the contributions to atmospheric emissions of the city PMw: 50 >Lg/m3 of Nouakchott. Ambient air quality measures will therefore only provide an indication of possible changes to local air quality, but it will not be possible to clearly relate such changes to the Banda gas processing facility). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 294 C1.3 Road traffic • Application of the company's road safety policy to operator Section 5.4; Throughout the HSEManager Zero traffic accident Included in and contractor vehicles. Table 5.6 Project standard operations C2 Operations Personnel C2.1 Employment and Implement Tullow' s local employment and skills development Section 5.4; Throughout the Tullow's HR N/A Cost of Training policies. Table 5.6 Project Department training to Accordingly, Tullow and its contractors will employ and train be nationals where it is practical to do so. determined through yearly review of workforce training needs C2.2 Procurement of goods Implement Tullow' s local content policy. Section 5.4; Throughout the Tullow'sHR N/A Included in and services • Accordingly, Tullow and its contractors will use local products Table 5.6 Project Department standard and services where it is practical to do so. operations C2.3. In-migration of Publicly advertise Tullow' s in-country recruihnent procedure. Table 5.6 Throughout the Tullow's HR N/A Included in speculative jobseekers No "at the gate" recruitment. Project Department standard Discourage potential settlers through proactive communication operations by Tullow Mauritania's stakeholder engagement team. C3 Liquid Effluents C3.1 Waste Water Generation Water will be a product of the three stage separation and will Section 5.4; Throughout the HSE Manager IFC EHS Guideline for Up to be treated in the produced water treatment system to remove: Table 5.6 Project discharge to land approximate entrained free oil to allow for safe disposal ly soluble hydrocarbons, including volatile aromatics - 1,500,000 us benzene, toluene, ethyl benzene and xylenes (BTEX) D for the MEG and chemicals to reduce biological and chemical produced oxygen demand prevent biomass accumulation water Treated produced water will be reused in the power plant as treatment process water to reduce its water demand or local irrigation package ENVIRONMENTAL RESOURCES MANAGEMENT TULLOIV PETROLEUM (MAURITANIA) PTY LTD 295 C3.2 Naturally occurring radioactive material . At Banda NORMS will be very unlikely because there is a low probability of formation water production and hence low risk Table 5.6 Throughout the HSE Manager Project Zero discharge of NORMS Included in standard (NORM) of scaling. Still, a possible mitigation measure is containment operations and disposal as hazardous material. C4 Waste Management C4.1 Domestic Waste Operational controls contained in Waste Management Plan. Section 5.4; Throughout the HSE Manager Zero loss of Included in Generation • Safe transport using well maintained, and suitable vehicles and Table 5.6 Project containments during standard trained operators. storage and transport operations • Use of Tullow approved waste contractors. of wastes • Selection of a suitable disposal facility or facilities . • Measures to ensure proper continuous operation and Minimized volume of monitoring of the disposal facility. wastes C4.2 Industrial Waste Generation . Operational controls contained in Waste Management Plan. Proper storage of hazardous waste . Safe transport using well maintained, and suitable vehicles and Section 5.4; Throughout the HSE Manager Table 5.6 Project Zero loss of containments during storage and transport Included in standard operations trained operators. of wastes Use of Tullow approved waste contractors. Selection of a suitable disposal facility or facilities. Maximised recycling of Measures to ensure proper continuous operation and wastes monitoring of the disposal facility. cs C5.1 . Physical presence of subsea infrastructures Physical presence of subsea production The subsea production structures and exclusion zone will be marked on navigation charts Section 5.4; Throughout the HSEManager Table 5.6 Project N/A Included in standard structures. Liaison with other users of the sea to make them aware of the operations subsea production structures 500 metres fishing exclusion zone around well heads and manifold ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 296 C5.2 Physical presence of *The pipeline and umbilical will be trenched along most of its Section 5.4; Pipeline and HSE Manager N/A Included in pipeline, umbilical and length to provide stability and to prevent damage from fishing Table 5.6 umbilical standard rock dumps. gear installation operations Where soil conditions obviate trenching, the pipeline and umbilical will be protected by rock dumping or flexible concrete n1ats The pipeline and umbilical route will be marked on navigation Throughout the charts Project Liaison with other users of the sea to make them aware of the pipeline and umbilical C6 Physical presence of the onshore pipeline C6-.1 Physical presence of the The pipeline and umbilical will be trenched. Section 5.4; Throughout the HSEManager N/A Included in onshore pipeline Only pipeline markers will be visible above ground. Table5.6 Project standard Periodic monitoring of the onshore part of the pipeline to operations reduce the likelihood of any intentional damage to it. C6.2 Restriction on Coordination with Ministry of Urbanism to take into account Section 5.4; Design phase Tullow' s External N/A Included in permanent infrastructure the Project in land planning scheme. Table 5.6 Affairs Manager standard within 60 m on both Prior to land operations sides of the pipeline acquisition C7 Physical presence of the gas processing plant C7.1 Restriction on $ Coordination with Ministry of Urbanism to take into account Section 5 .4; Design phase Tullow' s External N/A Included in permanent infrastructure the Project in land planning scheme. Table5.6 Affairs Manager standard within a 300m radius Prior to land operations around the gas acquisition processing plant C8 Non Routine Events ENVIRONMENTAL RESOURCES MANAGEMENT TULLO\V PETROLEUM (MAURITANIA) PTY LTD 297 C8.1 Loss of containment • Oil and chemicals spill prevention equipment, measures and Section 5.4; Throughout the HSE Manager Zero loss of Cost of procedures Table 5.6 Project containments during OSCP Install secondary containment around tanks to contain storage and transport document: accidental releases of hazardous products up to $ Maintenance of vehicles approx Spill prevention / oil and chemicals management procedure 30.000USD. Oil Spill Contingency Plan (OSCP) which contains detailed Other procedures that will be followed in the event of an oil spill mitigation measures are included in standard operations C8.2 Fire and Explosion Active fire protection Section 5.4; Throughout the HSE Manager Zero fire event Cost Gas leak detection devices Table 5.6 Project considered Development of a fire and life safety plan for workforce as part of 0 Coordination with local authorities for external emergency standard response provisions . • 300m exclusion zone without permanent infrastructure (except for this type Project infrastructures) around the gas treatment plant of plant Markers will be provided to prevent accidental excavation damage to the pipeline and umbilical $ 60 m exclusion zone with no permanent infrastructure on both sides of the pipeline. Periodic monitoring of the onshore part of the pipeline to reduce the likelihood of any intentional damage to it. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAUR!T ANl A) PTY LTO 298 7 PUBLIC CONSULTATION 7.1 REGULATORY FRAMEWORK 7.1.1 National requirements regarding public consultations In Mauritania, in accordance with article 17 of Decree no 2007-105 modifying and supplementing certain provisions of decree 2004- 094 of 4th November 2004 relating to the Environmental Impact Assessment, a stage of public consultation and stakeholder engagement must be carried out during the environmental impact assessment process, in collaboration with the authorities within the concerned administrative district. The public consultation process aims to ensure that stakeholders are informed in advance about the Project and its environmental and social management. It also aims at integrating any comments made by stakeholders into the environmental impact assessment. The objective is to guarantee that the EIA is robust and transparent, demonstrating that public concerns about the Project have been taken into account. In accordance with article 17 of the Decree no 2007-105, public consultation involves: • a meeting to present the Project to local authorities, representatives of the population present in, or close to the Project area, the concerned authorities and any non-governmental organization (NGO) and other associations that may be involved; and • the opening of a register accessible to the public in which any assessments, observations and/ or suggestions made regarding the Project will be entered. 7.1.2 International good practices Stakeholder engagement is an important component of international good practices regarding impact assessments. The IFC standards and, in particular, the performance standard 1 contain recommendations on the participation of the community, the provision of information, and public consultation. Based on these recommendations, stakeholder engagement activities were undertaken as part of the EIA of the Banda Gas Project. These are described in the following section. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 299 7.2 PUBLIC CONSULTATION AND STAKEHOLDER ENGAGEMENT FOR THE EIA 7.2.1 Scoping phase The stakeholder engagement activities started during the scoping phase of the Project and continued throughout the EIA phase. The objective was to ensure the identification of appropriate sources of information, regulatory requirements, and concerns and expectations of stakeholders. Interviews were conducted in June 2012 during the scoping phase to collect relevant data from stakeholders, such as the Mauritanian representation of the IUCN, and from the Ministry in charge of the Environment. Consultation reports can be found in Appendix A. 7.2.2 Marine component During the EIA phase, eighteen stakeholder consultations were carried out in Nouakchott and in coastal communities (three camps south of Nouakchott and four villages north of Nouakchott) during July 2012. The stakeholders consulted included representatives of the administration, cooperation programs, fishermen's associations, private investors, village representativ:es, and traditional authorities. The purpose of these consultations was mainly to exchange information on the Project, to collect baseline data and to understand the concerns of key stakeholders. Consultation reports can be found in Appendix A. The key issues raised during these meetings are summarized in this section. The development of the oil and gas sector has a direct impact on fishing activities • "Since the beginning of oil and gas projects in 2005, fish populations have declined" (Artisanal fishers). • "The population of Cephalopods has declined around the drilling sites" (Professional Training Centre- CASAMPAC). • "Oil and gas projects cause pollution that leads to bad tasting fish" (Artisanal fishers). The development of the oil and gas industry leads to a high risk of pollution • "Pollution from chemicals used during the drilling phase concerns us" (Industrial Fisherman). • "There are risks associated with drilling waste and solid waste management" (NGOs). • "There is a high risk of major oil spills" (Industrial Fisherman). • "Are the contingency plans in case of an emergency adapted to the threats to the population, fisheries and biodiversity?" (NGOs). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 300 The oil and gas sector is seen as an opportunity for the development of local communities • "The oil and gas industry provides employment opportunities" (Local authorities). • "What kind of infrastructure (paved roads, water supply) can Tullow provide to communities?" (Professional Training Centre- CASAMPAC). • "What kind of support for artisanal fishing can Tullow provide?" (Artisanal fishers). Spatial competition with industrial fishing • "Will trawling be allowed along the pipeline route?" (Industrial Fishermen). In general, the concerns of stakeholders were more questions and speculations based on hearsay rather than concrete and rational questions. Implementation of outreach activities and communication with stakeholders is necessary to ensure a good understanding of the Project. Artisanal fishermen have always raised concerns about competition with industrial fishing before general concerns about the oil and gas sector. 7.2.3 Land component Between November 2012 and February 2013, eight consultations took place with stakeholders of the land component of the Project. The stakeholders consulted included government officials, representatives of the projects planned in the vicinity of the study area, and residents. The objectives of these consultations were to share information on the Project, collect data, and understand the concerns of key stakeholders for the land component of the Project. Consultation reports can be found in Appendix A. The key issues raised during these consultations are summarized in this section. Location of the gas treatment plant • "The chosen site is too close to the city and sensitive sites such as the new university and the new airport" (Several authorities and residents). • "Studies should assess the risks posed by the gas processing facility on local communities" (Project coordinator of the new university). • "If the impacts (noise, odor) are managed, the location of the gas processing . facility is suitable" (Owners of camping). Opportunities for the development of local communities • "The project can create jobs" (Resident). ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTY LTD 301 • "The project can improve access to electricity" (Resident, owner of camping and administration). 7.3 PUBLIC CONSULTATION MEETING 7.3.1 Organisation On the 20th of March 2013, a public consultation meeting was held at the Sabah hotel in Nouakchott as part of the environmental impact assessment of the Banda Gas Project. About 60 people attended this meeting. The attendance list is attached in Appendix A. Figure 7.1 Public consultation meeting in Nouakchott The public consultation followed this agenda: • opening by the deputy of the Hakem of Tevragh Zeina; • speech by the representative from the Ministry of Oil; • presentation of the Project, its environmental impacts and mitigation measures by ERM and Moustapha Ould Taleb (independent consultant); • questions, debates and discussion; • opening of a register accessible to the public in which assessments, observations and/ or suggestions made with regard to this Project will be entered; and • closure of the meeting. The ERM presentation included the following points: ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURJTAN!A) PTY LTD 302 • a presentation of the speakers; • the location of the Project; • a description of the Project; • the applicable regulations; • the sources of imp.act assessed in the EIA; • the receptors considered in the EIA; • the methodology for impact assessment; • the main sources of information used in the EIA; • the estimated Project schedule, and • the terms for stakeholder engagement in the EIA. During the presentation, translation into Hassanya was provided for a better understanding and participation of all present. 7.3.2 Main concerns raised The questions and concerns raised by the stakeholders during the meeting were related to: • the location of the Project and its land compopent in particular; • the lifetime of the Project; • protection zones induced by the Project and their boundaries; • the expectations of civil society; • the design of the gas processing plant and pipeline specifications; • the effects of the Project on fish resources and biodiversity; • the environmental management plan provided for the Project; • the monitoring plan for the Project and the devices that will be used for this purpose; • feedback from similar Projects around the world, and • the EIA methodology. The representatives of the DCE, DPHB, Tullow and ERM provided answers to the questions, suggestions and comments raised during the debate. The detailed list of comments, questions and answers made during the public consultation meeting is attached (in French) in Appendix A. 7.4 ADDRESSING STAKEHOLDER CONCERNS Appendix A provides more details of responses made by Tullow to the questions and comments raised by stakeholders in the course of the consultation process. In summary, there were 3 kinds of questions and comments, addressed as follows: • Requests for technical clarification were met by providing more information on the Project - this applies to questions on schedule, technology used, pollution prevention and control etc. ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW PETROLEUM (MAURITANIA) PTYLTD 303 • Points raised on environmental and social sensitivities (eg the sensitivity of marine biodiversity, fisheries resources, migratory avifauna etc) were considered in developing the environmental and social baseline study (Chapter 4), the assessment of environmental and social impacts and mitigation (Chapter 5), and the environmental management plan, which details the measures that Tullow will implement to address potential environmental impacts and risks. • Stakeholder expectations in terms of socio-economic benefits from the Project- largely that the Project will foster the employment of local workforce- where duly noted by Tullow and reflected in Tullow' s recruitment and procurement policy in Mauritania (which includes a commitment to recruit and procure locally where possible). 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