Effects of the environment on the project

Context

Being aware of environmental characteristics and phenomena such as winds, waves, currents, ice, precipitation, storms, temperatures, and other factors is key to being able to design and implement drilling activities in a manner that ensures that human health and safety, the environment, the equipment and infrastructures are protected. Severe weather conditions, superstructure icing, extreme waves and ocean currents, sea ice and icebergs, seismicity and geological stability are all events that can have a considerable effect on the project. By looking at how the physical environment of the marine area can affect the process of the project, it provides guidance to avoid or reduce the potential for incidents and accidents that may occur.

Agency Decision

The project is not likely to result in significant adverse environmental effects as a result of the environment on the Project.

(based on commitments by the proponent and implementation of mitigation and follow-up measures)

Predicted Effects

The Agency considered the Proponents analysis, expert advice from federal authorities and comments from Indigenous groups and the public, and identified the following potential effects caused by the environment on the project:

Poor visibility from fog, rain or snow can increase the risk of accidents and malfunction of equipment

Sea ice and icebergs are navigation hazards and can increase risks of collisions resulting in accidental events.

Marine icing on the MODU or vessels from freezing precipitations could result with equipment having higher centers of gravity, slower speeds, manoeuvring difficulties and problems with equipment increasing the risk of accidental events.

A tectonic event could cause an earthquake resulting in seafloor instability thereby causing landslides that could damage the subsea equipment, disrupt project activities and increase the risk of potential accidental events.

Context

Effects

Mitigations

In consultation with the C-NLOPB,ECCC, NRCan and DFO

develop and implement a physical environment monitoring program in accordance with the Newfoundland Offshore Petroleum Drilling and Production Regulations and meet or exceed the requirements of the Offshore Physical Environmental Guidelines

establish and enforce practices and limits for operating in all conditions that may be reasonably expected, including poor weather, severe sea state, sea ice or iceberg conditions

develop an Ice Management Plan including procedures for detection, surveillance, data collection, reporting, forecasting and avoidance or deflection of icebergs

implement measures to ensure that the MODU has the ability to quickly disconnect the riser form the well in event of an emergency or severe weather conditions

Critique

Strengths

The Proponent would obtain a Certificate of Fitness for the MODU as required by the Newfoundland Offshore Certificate of Fitness Regulations to ensure it is fit for purpose and can function as intended.

The development and implementation of an Ice Management Plan is required by the Newfoundland Offshore Petroleum Drilling and Production Regulations as part of the Safety Plan submitted by the Proponent with an application for authorization by the C-NLOPB.

Weaknesses

The proponent did not consider extra-tropically transitioning hurricanes, including “dynamic-fetch waves” climatology which could have severe consequences

Requires a constant data collection that is easy to lose track of.

The proponent provided little geological data which means potential geohazard in the exploration licenses is unknown. A geohazard assessment should be done as of of the Approval to Drill a Well process.

The Proponent committed to complying with Canadian regulations and international standards to mitigate risks but all personal may not previously have conducted drilling in harsh weather environment. This would require specialized training and explicit procedures.

There is insufficient consideration of how climate change can impact the environment effect on the Project. Data on climbing ocean temperatures, increases in ocean acidity and ocean deoxygenation can influence the effects of a discharge, spill, etc. or other impacts via interaction and synergistic effects are important to consider in the analysis of effects of the environment on the projects.

Critique