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March 2011

Volume 1
Draft Environmental 
Management Plan 
South Western Karoo Basin Gas 
Exploration Application: 
CENTRAL PRECINCT  
Shell Exploration Company B.V.  
PASA Reference No. 12/3/220

For public comment from Monday,


07 March to Tuesday, 05 April 2011
DRAFT REPORT

Golder Report Number. 12800-10364-5


Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

PURPOSE OF THIS DOCUMENT


This document represents a Draft Environmental Management Plan (EMP) for proposed gas exploration in
the South Western Karoo Basin, South Africa, by Shell Exploration Company B.V., a registered company of
Royal Dutch Shell plc. It relates to the exploration right application referred to as the Central Precinct (PASA
Reference No. 12/3/220). The application area intersects the Western Cape, Northern Cape and Eastern
Cape, and falls within the Central Karoo, Pixley ka Seme, Chris Hani and Cacadu district municipalities.
Once finalised, the EMP will be submitted to the Petroleum Agency of South Africa (PASA), the designated
authority in terms of the Mineral and Petroleum Resources Development Act (MPRDA) (Act 28 of 2002), as
part of an application for a gas exploration right.
The draft EMP is presented in two volumes for comment by interested and affected parties:
- Volume 1. Draft Environmental Management Plan (this report);
- Volume 2. Appendices, which include the Technical Reports to support the EMP.
In addition, a Summary of the EMP is available, as well as a Comments and Response Report in which all
stakeholder comments are recorded and responded to.

Appreciation for contributions by stakeholders


Many stakeholders have participated actively during the EMP process to date by attending meetings, and by
taking the time to prepare written submissions. The EMP team wishes to express sincere appreciation for
these contributions.

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Report No. 12800-10364-5 ii
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

INVITATION TO COMMENT ON THE DRAFT EMP


Stakeholders are invited to comment on the Draft EMP in any of the following ways:

ƒ Attending a public meeting;

ƒ Completing and submitting the comment sheets enclosed with the reports; and

ƒ Submitting additional written comments by email, fax or by telephone to the public participation office.

PUBLIC MEETINGS

AREA / VENUE DATE TIME


1. Beaufort-West: Rustdene Hall, 12 De Vries Street,
Wednesday, 16 March 2011 14:00 – 17:00
Rustdene, Beaufort-West
2. Victoria-West: Town Hall, 78 Church Street,
Thursday 17 March 2011 10:00 – 13:00
opposite the Apollo Building, Victoria-West
3. Graaff-Reinet: Town Hall (big hall), Church Square,
Wednesday 23 March 2011 13:00 – 16:00
opposite Angel Park, Graaff-Reinet

DUE DATE FOR COMMENT ON THIS EMP:


Tuesday, 05 April 2011, to the Public Participation Office below
Marisa du Toit / Annerine Prinsloo
Golder Associates Africa
P O Box 6001
HALFWAY HOUSE, 1685
Tel: (011) 254 4944 / (011) 254 4839
Fax: (011) 315 0317
Email: westernkaroo@golder.co.za

PUBLIC PLACES WHERE A FULL VERSION OF THE DRAFT EMP


AND ITS ACCOMPANYING TECHNICAL ASSESSMENT REPORTS ARE AVAILABLE
Copies of the full reports are available at the public places below as well as on the
following website: www.golder.co.za

PUBLIC PLACE LOCALITY CONTACT PERSON TELEPHONE


Mrs Theron
Mrs Pillay
Central Road
Beaconfield Public Library Beaconfield 053 830 6245
Beaconfield
Kimberley
8301

Ms Ashley Mitchel
112 Donkin Street
Beaufort West Municipality Beaufort West 023 414 8020
Beaufort West
6970

March 2011
Report No. 12800-10364-5 iii
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

PUBLIC PLACE LOCALITY CONTACT PERSON TELEPHONE


Ms Alta van Niekerk
15 Church Street
Beaufort West Public Library Beaufort West 023 414 8113
Beaufort West
6970
Municipal Managager: Mr
Langbooi
Camdeboo Local
Nieu Bethesda 1 Muller Street 049 892 2121
Municipality
Nieu Bethesda
6288
F Taljaard
Emthanjeni Local 45 Voortrekker Street
De Aar 053 632 9100
Municipality De Aar
7000
Ms Conny Mazimba
Ms Eunice Mafungo
No 1 Ramatshela Street,
Galeshewe Public Library Galeshewe 053 871 2315
Galeshewe
Kimberley
8301
Ms Alice Jacobs
Ms Georgina Matomela.
Horse Shoe Public Library Graaff Reinet Parsonage Street 049 892 2121
Graaf Reinet
6280
Ms Iris Ketchen
34 Main Street
Ikwezi Local Municipality Greystone 049 836 0021
Jansenville
6265
Mrs Floretta Bhe
Jansenville Community 34 Main Street
Jansenville 049 836 0021
Library Jansenville
6265
Ms Mary Soetwaters
Stockroos Street
Judy Scott Library Florienville Florienville 053 874 1312
Kimberley
8301
Mr Van Dyk
Mrs van der Merwe
Kimberley Public Library Kimberley No 62 Chapel Street 053 830 6241
Kimberley
8307
Mrs Nel
Beaufort Street
Murraysburg Public Library Murraysburg 049 844 0077
Murraysburg
6995
Mrs Yvonne Besset
1 Muller Street
Nieuw Bethesda
Nieu Bethesda Library Nieu Bethesda 049 841 1659
6288

March 2011
Report No. 12800-10364-5 iv
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

PUBLIC PLACE LOCALITY CONTACT PERSON TELEPHONE


Ms Madelene Louw
No 137 2nd Avenue
Richie Library Richie Richie 084 407 8078
Kimberley
8301
Ms Jacobs
Mrs Karin Peters
Starling Street
Sonny Leon Public Library Roodepan 053 873 1161
Roodepan
Kimberley
8309
Mr Steenkamp
N1 National Road
Ultra City Three Sisters Three Sisters 053 622 0088
North of Beaufort West
6970
Ms Sanie Thousand
4 Church Street
Victoria West Public Library Victoria West 053 621 1204
Victoria West
7070

March 2011
Report No. 12800-10364-5 v
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

ACRONYMS AND ABBREVIATIONS

Acronym Explanation
AQA Air Quality Act
AQM Air quality management
ARC Agricultural Research Council
BBBEE Broad Based Black Economic Empowerment
BEE Black Economic Empowerment
BID Background Information Document
BOP Blowout preventer
BTEX Benzene Toluene Ethylbenzene Xylene
BTU British thermal unit – heat energy required to raise temperature of one pound of
water one degree Fahrenheit

CAA Clean Air Act


CBO Community Based Organisation
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CWA Clean Water Act


D Duration
DEA Department of Environmental Affairs

DMA District Management Area


DME Department of Minerals and Energy
DMR Department of Mineral Resources
DWA Department of Water Affairs
EAP Environmental Assessment Practitioner
EC Electrical Conductivity
ECO Environment Control Officer
EHS Environment, Health, and Safety
EIA Environmental Impact Assessment
EMP Environmental Management Programme
EPA Environmental Protection Agency
FRAC Act Fracturing Responsibility and Awareness of Chemicals Act of 2009
GRI Gas Research Institute
H2S Hydrogen sulphide

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Report No. 12800-10364-5 vi
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Acronym Explanation
HCl Hydrochloric acid
HHP Hydraulic horsepower
HSA Hazardous Substances Act, 1973 (Act 15 of 1973)
HSE Health, safety, and environmental
I&APs Interested and Affected Parties
IOGCC Interstate Oil and Gas Compact Commission (a grouping of the 38 US State’s
that produce petroleum products oil and gas regulatory agency)
IRP Integrated Resource Plan
IWULA Integrated Water Use License Application
IWWMP Integrated Water and Waste Management Plan
KOP kick-off point
LDN Lightning Detection Network

LSA Local Study Area


MHSA Mine Health and Safety Act, 1996 (Act 29 of 1996)
MPRDA Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002)

MT Magneto-Telluric
NAAQS National Ambient Air Quality Standards
NEM National Environmental Management
NEMA National Environmental Management Act, 1998 (Act 107 of 1998)
NEMWA National Environmental Management: Waste Act, 2008 (Act 59 of 2008)
NGDB National Groundwater Data Base
NGL Natural gas liquids
NGO Non-governmental Organisation
NHRA National Heritage Resources Act, 1999 (Act 25 of 1999)

NORM Naturally Occurring Radioactive Material


NOx Nitrogen Oxides
NPDES National Pollutant Discharge Elimination System

NRTA National Road Traffic Act, 1996 (Act 93 of 1996)


NWA National Water Act, 1998 (Act 36 of 1998)
OSHA Occupational Safety and Health Administration
P Probability
P&A plugged and abandoned

March 2011
Report No. 12800-10364-5 vii
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Acronym Explanation
PASA Petroleum Agency of South Africa
RCRA Resources Conservation and Recovery Act
SABS South African Bureau of Standards
SAHRA South African Heritage Resources Agency
SALT Southern African Large Telescope
SANS South African National Standards
SAWS South African Weather Services
SOEKOR Southern Oil Exploration Corporation
SP Significance points
USEPA United States Environmental Protection Agency
VAC Visual absorption capacity

VOC Volatile Organic Compounds


VU Vulnerable
WARMS Water Authorization and Registration Management System

WEC World Energy Council


WHO World Health Organization
WQMS Water Quality Management System

WRC Water Research Commission

March 2011
Report No. 12800-10364-5 viii
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

UNITS OF MEASUREMENT

Unit of Measurement Explanation


(Oil barrel) a liquid measurement unit used in the oil and gas industry,equivalent
Bbl to 42 US gallons

Bcf billion cubic feet


Bcf/D billion cubic feet per day
BLPD Barrels of liquid per day
BOE Barrel of oil equivalent
BWPD Barrels of water per day
GLR Gas to liquid ratio
ha Hectares
J Joule

km Kilometre (1 000 metres)


km2 Square kilometres
km3 thousand cubic meters

kPa Kilopascal
l Litres
l/s Litres per second

lbm/bbl pound per barrel – one pound additive in 42 US gallons of mud


l/s Litres per second
m3 Cubic metres
M3 Mega cubic metres
M Magnitude
mamsl Metres above mean sea level
mm Millimetres
ml Megalitres
MAP Mean Annual Precipitation
MCF Thousand Cubic Feet of gas (the traditional measurement of gas in the US)
approximately equivalent to 1 MmBTU (or 1 Million BTU) which is a standardized
energy unit by which gas is now measured. Gas is now measured by a thermal
unit because some natural gas may have differing components, such as methane,
ethane, butane, propane, etc. An MmBTU measures the energy contained in the
gas rather than the volume of the gas.
mg/kg milligrams per kilogram

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Report No. 12800-10364-5 ix
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Unit of Measurement Explanation


mg/L milligrams per litre
MMscf million standard cubic feet
MMsm3 million standard cubic meters
Mscf/d thousand standard cubic feet per day
MWD Measurement while drilling
MWh Megawatt hour
pH Acidity
ppb parts per billion
ppm parts per million
psi pounds per square inch
S Scale
SKA Square Kilometre Array
tpa Tonnes per annum

μg/m³ Micrograms per Cubic Meter

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Report No. 12800-10364-5 x
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

TERMINOLOGY/DEFINITIONS

Acid frac – A process after fracturing where acid is used to etch the formation to increase the formation
conductivity that could increase production.
Alternative energy - energy, such as solar, wind, or nuclear energy, that can replace or supplement
traditional fossil fuel sources, such as coal, oil, and natural gas.
Annulus – Open space between the well bore (hole) and the casing or between two different sizes of
casing.
Barrel of oil equivalent – Unit of energy that is released by burning one barrel of crude oil.
Bitumen - A dark, gooey type of oil that can be refined to make petroleum products.
Blender – A piece of machinery of fluid mixture and addition of the proppant to the fracing fluid.
Blowout – When pressures at depth cause fluids to enter the well bore at uncontrolled rates.
Blowout Preventer – A valve that is used to close the well in the event of loss of pressure control in the well
bore to prevent a blowout.
Bottomhole – Location at the end of the well bore.

Bottomhole assembly – Equipment located at the end of the drill string to supply mud, measurements, and
drill bit.
Casing – Pipe lowered into a well bore to stabilize and provide support to the well down to the target
formation.
Cement/cementing – Material used to seal off formations and used to stabilize casing used in the well bore.
Cement sets up to form connect the casing to the well bore walls.
Ceramic proppant – A proppant [see proppant] that is composed of a ceramic material. Although more
expensive, ceramic proppants may yield to more production compared to sand-based proppants.
Completion – Finishing a well so that gas or oil production can commence.
Completion – “Completing the well” The process of casing, perforating, fracing the well.

Conventional Gas – Gas that is produced from conventional reservoirs using conventional techniques.
Traditional natural gas reserves include gas associated with oil production and gas that reserves that are not
associated with oil production. In general, these reserves are produced from porous or high permeability
sedimentary formations such as sandstones using vertical drilling techniques.
Cuttings – Waste rock material from the process of drilling the well bore.
Downhole – A location in the well bore
Drill bit – A tool used to crush rock to make the well bore.
Drill pipe – Pipe used to connect the rig to the drill bit and bottomhole assembly.
Drilling motor – Used to power and rotate the drill bit.
Emulsifier – A chemical used to stabilize fracing fluid. Surfactants can be used as an emulsifier to break
down surface tension, to help mix different chemicals in fracing fluid.
Fairway – The connection between perforations and the formation through which oil or gas flows to the well
bore

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Report No. 12800-10364-5 xi
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Flowback – Fluids that resurface from a well after being fractured.


Frac fluid – A liquid mixture primarily composed of water that is pressurized to cause formation fracing. A
proppant is also introduced to the frac fluid at the appropriate time to hold fractures open after pressure is
released.
Frac job – Another term used in the industry to refer to the process of fracturing a well.
Frac pump – A high-pressure pump used to pressurize the fluids used when fracing a well. Many frac
pumps can be used at one time depending on the size of the operation.
Frac stage – A location of fracing along a well bore at a target formation; part of multi-stage fracing where
several frac stages can be performed in one well bore.

Fracture – Natural or hydraulically caused cracks or openings in geologic formations.


Fresh water aquifer – Groundwater that is low in salinity and could potentially be used for drinking water.
Gelling agent – A chemical used to increase fluid thickness to decrease fluid loss during the high-pressure
fracing.

Greenhouse gases - Waste gases given off by industrial and power plants, automobiles, and processes that
trap the heat of the sun in Earth’s atmosphere, producing the greenhouse effect. The major greenhouse
gases are water vapour and carbon dioxide. Lesser greenhouse gases include methane, ozone,
chlorofluorocarbons, and nitrogen oxides.
Horizontal drilling – The process of changing the well bore to a horizontal direction at a target formation to
increase amount of production.
Horizontal leg – The part of a directional well bore that is horizontal and usually in the target formation.
Horizontal well – A well that had horizontal drilling done to increase production (see horizontal drilling).
Hydrocarbons - Any class of compounds containing only hydrogen and carbon. Crude oil is primarily a
mixture of hydrocarbon compounds. Fuels made from hydrocarbons, such as natural gas, liquefied
petroleum gas, coal gas, and refinery gas, can be distributed by pipeline.
Kick-off point (KOP) – The point at which the well bore begins to turn from vertical towards horizontal,
usually located 500 feet above the target formation.

Lateral – Another name for the horizontal portion of the well bore.
LAeq,I dB(A) - the A-weighted equivalent sound level using the ‘I’ (Impulse) dynamic response characteristic
as recommended in SANS 10103:2008 (ref. 1).
LAMin dB(A) - the minimum A-weighted sound level recorded during the period of measurement.

Log – Measurements taken in or of the well bore.


Lubricant (Frac) – A material used to reduce friction in the well bore and fractures to increase fracture
dispersion.
Measurement while Drilling or MWD – A device that provides precise measurements of the drill bit’s
location under the earth’s surface located near the drilling motor and drill bit. This allows the operator on the
surface to control the directional or horizontal drilling of the well bore.
Multi-stage fracing – Several frac stages in one well bore to increase well stimulation (see frac stage).
Natural fractures – Fractures that occur without stimulation practices due to existing properties of a
formation.

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Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Naturally Occurring Radioactive Material (NORM) – Radioactive materials that occur naturally and expose
people to radiation occur widely and are known by the acronym 'NORM'. Exposure to NORM is often
increased by human activities, such as burning coal, making and using fertilizers, oil and gas production.
Radon is a commonly known occurrence of NORM. Cement and shales are sources of NORM.
Perf Gun – Electronic downhole tool that detonates small charges creating perfs in the production casing.
Perf or Perforate – Opening the well bore to connect it to the desired formation.
Permeability – The ability, or measurement of a rock's ability, to transmit fluids, typically measured in
darcies or millidarcies. The term was defined by Henry Darcy, who showed that the common mathematics of
heat transfer could be modified to adequately describe fluid flow in porous media.
Petrochemical - A chemical substance produced from petroleum or natural gas, such as gasoline,
kerosene, or petroleum.

Plug – A device placed in the casing to seal off a portion of the well bore (usually cement). This can be
permanent or temporary.
Produced water – Water that is produced from a well during oil and/or gas production. This water comes
from the producing formation.
Production casing – The final string of casing used to access the reservoir for extracting fluids. Production
casing is placed inside the surface casing.

Proppant – Material used (commonly sand) to hold fractures open after pressure is released in the well
bore.
R% - The relative humidity at the time of the measurement.
Renewable energy - Energy resources that Can be easily “renewed” or made. Forms of renewable energy
include solar, wind, biomass, hydroelectricity, and geothermal energy.
Rig - The machine used to drill a wellbore. In onshore operations, the rig includes virtually everything except
living quarters. Major components of the rig include the mud tanks, the mud pumps, the derrick or mast, the
draw works, the rotary table or topdrive, the drillstring, the power generation equipment, and the auxiliary
equipment. Offshore, the rig includes the same components as onshore, but not those of the vessel or
drilling platform itself. The rig is sometimes referred to as the drilling package, particularly when offshore.
Rotary drilling – An efficient way of drilling that uses a quickly rotating bit to cut through rock. Because the
bit rotates continuously, cuttings are constantly swept away, while fluid circulates through the bit and up the
wellbore.
Seismic survey - A method of finding oil and natural gas by measuring the time it takes acoustic shock
waves to travel through layers of Earth, reflect off of oil deposits, and return to the sender. The longer it takes
the waves to travel to the oil reservoir and back, the farther down it must be.
Shoe or Heel – The bottom of the casing. Cement is pumped through the shoe to “set casing” and then the
shoe is usually plugged.
Stimulation – A variety of different methods (e.g. hydraulic fracturing) used to increase well production.
String – A length of pipe or casing.

Surface casing – A shallow string of casing used to protect fresh water sources and to provide structural
support for later stages of drilling.
Surface location – Place where the well bore begins at the surface, from where all drilling is done.

T°C – The temperature at the time of the measurement.

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Report No. 12800-10364-5 xiii
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Tight reservoirs – Formations such as shales and some sandstones that do not have enough natural
permeability to allow hydrocarbons to flow through the rock.
Tool or downhole tool – Term used to identify any device that is placed in the well bore other than drill pipe,
casing, and the drill bit.
Tripping pipe – The process of removing or replacing the drill string.
Unconventional Gas – Gas that is produced using non-standard recovery techniques. While an exact
definition is difficult to provide, unconventional natural gas is gas that is more difficult or less economical to
extract, usually because the technology to reach it has not been developed fully, or is too expensive.
Sources of unconventional gas include coal beds (coal seams), tight sands, and shales. Hydraulic
fracturing, directional and horizontal drilling, and multi-staged frac jobs are all considered unconventional
recovery techniques.
Upstream - Exploration for and extraction of oil and natural gas, and the built and operation of the
infrastructure necessary to deliver these hydrocarbons to the market.
Well bore – A hole in the ground that is drilled to a target formation to access oil and gas reserves.
Well head (Christmas tree) – The above surface portion of the well through which gas flows and the well is
operated once placed into production.
Wireline – Wire that enters the well bore or casing to accomplish tasks such as controlling the perf gun or
taking FMI readings.
W m/s – The maximum wind speed measured during the measurement period.
In the Comments column of the noise tables, C - Car, Minibus or LDV, HGV – Heavy Goods Vehicle or Bus,
A/c – Commercial airliner, La/c – light aircraft, H – Helicopter.

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Report No. 12800-10364-5 xiv
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Table of Contents

1.0  INTRODUCTION ........................................................................................................................................................ 1 

1.1  Landowners’ and Other Stakeholders’ Concerns ......................................................................................... 1 

1.2  Quick project overview.................................................................................................................................. 1 

1.3  Application and environmental assessment process .................................................................................... 3 

1.4  Environmental consultants ............................................................................................................................ 5 

1.5  Interaction with landowners .......................................................................................................................... 6 

1.6  Structure of this report .................................................................................................................................. 6 

2.0  CONTEXT AND HISTORY ........................................................................................................................................ 8 

2.1  The global energy outlook ............................................................................................................................ 8 

2.1.1  Shale gas in the global energy context ................................................................................................. 10 

2.1.2  International Trends in Natural Gas Supply .......................................................................................... 10 

2.1.3  Environmental Benefits of Natural Gas Use .......................................................................................... 10 

2.2  South Africa’s energy outlook ..................................................................................................................... 11 

2.2.1  Natural gas in the South African energy context ................................................................................... 12 

2.3  Overview of shale gas ................................................................................................................................ 13 

2.3.1  The geology of shale gas ...................................................................................................................... 13 

2.4  Shale gas and greenhouse gas emissions ................................................................................................. 14 

2.5  Previous exploration in the Karoo ............................................................................................................... 16 

2.6  How this links to the proposed Karoo shale gas exploration ....................................................................... 16 

3.0  LEGAL CONTEXT ................................................................................................................................................... 17 

3.1  NEMA ......................................................................................................................................................... 18 

3.2  Background ................................................................................................................................................ 18 

3.3  Mineral and Petroleum Resources Development Act ................................................................................. 19 

3.3.1  Definitions – gas and petroleum ............................................................................................................ 19 

3.3.2  Overview of MPRDA ............................................................................................................................. 19 

3.4  Other legislation .......................................................................................................................................... 21 

3.4.1  The National Environmental Management Act (Act 107 of 1998) ......................................................... 21 

3.4.2  National Environmental Management: Biodiversity Act (Act 10 of 2004) .............................................. 27 

3.4.3  National Environmental Management: Waste Act (Act 59 of 2008) ...................................................... 28 

3.4.4  National Water Act (Act 36 of 1998) ...................................................................................................... 28 

3.4.5  Astronomy Geographic Advantage Act (Act 21 of 2007) ....................................................................... 29 

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3.4.6  National Nuclear Regulator Act (Act 47 of 1999) .................................................................................. 30 

3.4.7  Strategic environmental assessment and Environmental Management Frameworks ........................... 30 

4.0  EXISTING ENVIRONMENT – THE KAROO............................................................................................................ 32 

4.1  Geology ...................................................................................................................................................... 32 

4.1.1  High Level Geology: Karoo Basin ......................................................................................................... 32 

4.1.2  Regional Geology: Central Precinct ...................................................................................................... 34 

4.1.2.1  Lithology ............................................................................................................................................ 34 

Regional Structure ................................................................................................................................................... 36 

4.2  Climate ....................................................................................................................................................... 36 

4.2.1  Local Temperature ................................................................................................................................ 36 

4.2.2  Precipitation .......................................................................................................................................... 37 

4.2.3  Wind Speed and Direction .................................................................................................................... 40 

4.2.4  Microclimate .......................................................................................................................................... 40 

4.2.5  Extreme Weather Conditions ................................................................................................................ 41 

4.3  Topography ................................................................................................................................................ 41 

4.3.1  High Level Topography: Karoo Basin.................................................................................................... 41 

4.3.2  Regional Level Topography: Central Precinct ....................................................................................... 42 

4.4  Soil.............................................................................................................................................................. 42 

4.4.1  Lithosols on the Beaufort sediments ..................................................................................................... 44 

4.4.2  Rock outcrops with limited soils ............................................................................................................ 44 

4.4.3  Structured soils with marked clay accumulation .................................................................................... 44 

4.4.4  Soils on alluvial deposits ....................................................................................................................... 44 

4.4.5  Red soils with high base status ............................................................................................................. 44 

4.5  Terrestrial Ecology ...................................................................................................................................... 45 

4.5.1  Vegetation ............................................................................................................................................. 45 

4.5.1.1  High Level Vegetation: Biomes .......................................................................................................... 45 

4.5.1.2  Regional Level Vegetation: Types in the Central Precinct ................................................................. 45 

4.5.2  Animal life ............................................................................................................................................. 50 

4.5.2.1  Reptiles .............................................................................................................................................. 50 

4.6  Surface water ............................................................................................................................................. 51 

4.6.1  Relevant River Systems ........................................................................................................................ 51 

4.6.2  Relevant Drainage Areas ...................................................................................................................... 51 

4.7  Groundwater ............................................................................................................................................... 51 

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Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

4.7.1  High Level Groundwater: Karoo Basin .................................................................................................. 51 

4.7.2  Regional Level Groundwater: Central Precinct ..................................................................................... 52 

4.7.2.1  Groundwater Occurrence and Borehole Yield ................................................................................... 52 

4.7.2.2  Borehole Drilling Depth ...................................................................................................................... 52 

4.7.3  Depth to Water Level ............................................................................................................................ 53 

4.7.4  Water Quality (EC) ................................................................................................................................ 53 

4.7.5  Registered Water Use ........................................................................................................................... 53 

4.7.6  Field Verification ................................................................................................................................... 54 

4.8  Air quality .................................................................................................................................................... 55 

4.9  Visual aspects ............................................................................................................................................ 55 

4.9.1.1  Sense of Place / Genius Loci ............................................................................................................. 55 

4.9.1.2  Aesthetic Appeal ................................................................................................................................ 55 

4.9.1.3  Visual Absorption Capability .............................................................................................................. 56 

4.9.1.4  Visibility.............................................................................................................................................. 56 

4.9.1.5  Light pollution at night ........................................................................................................................ 56 

4.10  Noise .......................................................................................................................................................... 56 

4.11  Archaeology / cultural heritage / palaeontology aspects ............................................................................. 58 

4.11.1  Pre-colonial Archaeology ...................................................................................................................... 58 

4.11.2  Local tourist attractions ......................................................................................................................... 59 

4.11.3  Palaeontology / archaeology ................................................................................................................. 59 

4.11.4  Cultural landscapes and sense of place................................................................................................ 59 

4.12  Sensitive landscapes .................................................................................................................................. 60 

4.12.1  Terrestrial Ecology ................................................................................................................................ 60 

4.12.2  Heritage ................................................................................................................................................ 60 

4.13  Socio-economic environment ..................................................................................................................... 61 

4.13.1  Population ............................................................................................................................................. 61 

4.13.2  Social Services and Infrastructure ........................................................................................................ 64 

4.13.3  Tourism ................................................................................................................................................. 65 

4.13.4  Economy and Employment ................................................................................................................... 65 

4.13.5  Community Health and Safety .............................................................................................................. 67 

5.0  DESCRIPTION OF APPLICANT AND PROPOSED EXPLORATION PROJECT................................................... 70 

5.1  The Applicant: Royal Dutch Shell ............................................................................................................... 70 

5.1.1  Business principles ............................................................................................................................... 71 

March 2011
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5.1.2  Shell’s commitment to sustainable development .................................................................................. 71 

5.1.3  Safety record ......................................................................................................................................... 71 

5.1.4  Environmental commitments and performance ..................................................................................... 72 

5.1.5  Social responsibility record ................................................................................................................... 72 

5.1.6  Involvement in Gas Exploration and Production ................................................................................... 73 

5.1.7  Shell in South Africa .............................................................................................................................. 73 

5.2  Steps in the gas exploration process .......................................................................................................... 73 

5.3  Location of the proposed exploration phase project activities ..................................................................... 74 

5.3.1  Identification of notional areas .............................................................................................................. 76 

5.4  Description of proposed exploration project ................................................................................................ 77 

5.4.1  Desk-top studies of geology (completed) .............................................................................................. 77 

5.4.2  Application for Exploration Right (submitted) ........................................................................................ 77 

5.4.3  Geophysical Data Collection ................................................................................................................. 77 

5.4.3.1  Magneto-Telluric ................................................................................................................................ 77 

5.4.3.2  Seismic Acquisition ............................................................................................................................ 78 

5.4.4  Drilling ................................................................................................................................................... 79 

5.4.4.1  Exploratory Vertical Wells .................................................................................................................. 79 

5.4.4.2  Exploratory Horizontal Wells .............................................................................................................. 80 

5.4.4.3  Drilling site preparation ...................................................................................................................... 80 

5.4.4.4  Drilling rig mobilisation ....................................................................................................................... 81 

5.4.4.5  Drill site management ........................................................................................................................ 82 

5.4.4.6  Drilling & well bore data acquisition ................................................................................................... 83 

5.4.4.7  Noise from operations........................................................................................................................ 85 

5.4.5  Hydraulic Fracturing .............................................................................................................................. 85 

5.4.5.1  The Hydraulic Fracturing Process...................................................................................................... 85 

5.4.5.2  Fracturing Fluid .................................................................................................................................. 87 

5.5  EPA Principles of “Green Chemistry”.......................................................................................................... 88 

5.6  Historical Choices Chemical Additives........................................................................................................ 90 

5.6.1  Water Requirements ............................................................................................................................. 92 

5.6.1.1  Volume of water ................................................................................................................................. 92 

5.6.1.2  Sources of water ................................................................................................................................ 93 

5.6.1.3  Storage of water ................................................................................................................................ 94 

5.6.2  Well testing ........................................................................................................................................... 94 

March 2011
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Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

5.6.3  Other project components ..................................................................................................................... 95 

5.6.3.1  Waste management........................................................................................................................... 95 

5.6.3.2  Waste water treatment and disposal.................................................................................................. 96 

5.6.3.3  Solid waste management .................................................................................................................. 96 

5.6.4  Decommissioning and rehabilitation ..................................................................................................... 96 

5.7  Resourcing and employment ...................................................................................................................... 97 

5.8  What happens if gas is found? ................................................................................................................... 98 

6.0  ENVIRONMENTAL MANAGEMENT PLAN (EMP) PREPARATION PROCESS.................................................... 99 

6.1  Regulatory requirements for the EMP......................................................................................................... 99 

6.2  Approach to assessment to prepare the EMP ............................................................................................ 99 

6.3  Technical assessment .............................................................................................................................. 100 

6.3.1  Process ............................................................................................................................................... 100 

6.3.2  Technical assessments ....................................................................................................................... 101 

6.4  Public consultation .................................................................................................................................... 101 

6.4.1  The consultation process .................................................................................................................... 101 

6.4.2  Next steps in the public consultation process ..................................................................................... 104 

6.5  Comments and issues .............................................................................................................................. 104 

7.0  CONSIDERATION OF PROJECT ALTERNATIVES ............................................................................................. 108 

7.1  Location alternatives ................................................................................................................................. 109 

7.2  Technology alternatives ............................................................................................................................ 110 

7.3  Access roads ............................................................................................................................................ 110 

7.4  Water supply ............................................................................................................................................. 110 

7.5  Water storage alternatives ........................................................................................................................ 110 

7.5.1  Transport routes for water supply ....................................................................................................... 110 

7.6  Waste disposal alternatives ...................................................................................................................... 111 

7.7  Capturing hydrocarbons on surface .......................................................................................................... 111 

7.8  The ‘no go’ alternative .............................................................................................................................. 111 

7.8.1  South African Energy Policy................................................................................................................ 112 

7.8.2  International Trends in Natural Gas Supply ........................................................................................ 112 

7.8.3  Environmental Benefits of Natural Gas Use ........................................................................................ 112 

7.8.4  Global trends in the use of shale gas .................................................................................................. 113 

7.8.5  Conclusions – consequence of a no-go to exploration drilling ............................................................ 115 

8.0  TECHNICAL ASSESSMENT ................................................................................................................................. 116 

March 2011
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Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

8.1  Approach to technical assessment ........................................................................................................... 116 

8.2  Exploration activities that could potentially impact the environment ......................................................... 116 

8.2.1  Geophysical data collection ................................................................................................................ 116 

8.2.2  Well site preparation ........................................................................................................................... 117 

8.2.3  Exploration drilling ............................................................................................................................... 118 

8.2.4  Hydraulic fracturing ............................................................................................................................. 119 

8.2.5  Decommissioning ................................................................................................................................ 119 

8.3  Summary of environmental components considered ................................................................................ 119 

8.4  Assessment methodology......................................................................................................................... 120 

8.5  Technical assessment .............................................................................................................................. 123 

8.5.1  Geophysical data collection ................................................................................................................ 123 

8.5.2  Well site preparation ........................................................................................................................... 124 

8.5.3  Exploration drilling ............................................................................................................................... 136 

8.5.4  Hydraulic fracturing ............................................................................................................................. 145 

8.5.5  Decommissioning ................................................................................................................................ 150 

8.6  Human Health ........................................................................................................................................... 155 

8.7  Cumulative impacts .................................................................................................................................. 156 

8.8  Assumptions and knowledge gaps / limitations ........................................................................................ 156 

9.0  ENVIRONMENTAL MANAGEMENT PLAN .......................................................................................................... 159 

9.1  Objectives ................................................................................................................................................. 159 

9.2  Project description .................................................................................................................................... 159 

9.3  Applicable Laws and Regulations ............................................................................................................. 160 

9.4  Shell Policies and Procedures .................................................................................................................. 160 

9.5  Roles, Responsibilities and Training ......................................................................................................... 161 

9.5.1  Roles and Responsibilities .................................................................................................................. 161 

9.5.2  Training ............................................................................................................................................... 161 

9.5.3  Monitoring and Inspection Systems .................................................................................................... 161 

9.6  Location and Design Methods .................................................................................................................. 161 

9.6.1  Project Design Codes ......................................................................................................................... 161 

9.6.2  Environmental Criteria......................................................................................................................... 162 

9.6.2.1  Qualitative Criteria ........................................................................................................................... 162 

9.6.2.2  Quantitative Design Criteria ............................................................................................................. 162 

9.7  Environmental Management Plans and Mitigation Measures ................................................................... 162 

March 2011
Report No. 12800-10364-5 xx
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

9.7.1  Drilling and Well Installation ................................................................................................................ 163 

9.7.1.1  Casing ............................................................................................................................................. 163 

9.7.1.2  Cementing ....................................................................................................................................... 164 

9.7.2  Hydraulic Fracturing ............................................................................................................................ 164 

9.7.3  Water Management............................................................................................................................. 164 

9.7.3.1  Water Supply ................................................................................................................................... 165 

9.7.3.2  Water and Fluids Disposal ............................................................................................................... 165 

9.7.3.3  Monitoring ........................................................................................................................................ 165 

9.7.4  General Activities – Individual Environmental Management Plans ..................................................... 165 

9.7.4.1  Air Quality Management Plan .......................................................................................................... 165 

9.7.4.2  Noise Management Plan ................................................................................................................. 166 

9.7.4.3  Sediment and Erosion Control Plan ................................................................................................. 167 

9.7.4.4  Fish and Fish Habitat Management Plan ......................................................................................... 168 

9.7.4.5  Soils and Vegetation Management Plan .......................................................................................... 168 

9.7.4.6  Wildlife and Wildlife Habitat Management Plan ............................................................................... 169 

9.7.4.7  Hazardous Materials Management Plan .......................................................................................... 169 

9.7.4.8  Non-Hazardous Solid Waste and Domestic Wastewater Management Plan ................................... 172 

9.7.4.9  Petroleum Management Plan .......................................................................................................... 173 

9.7.4.10  Radioactive Waste Management Plan ............................................................................................. 175 

9.7.4.11  Spill Prevention and Response Plan................................................................................................ 175 

9.7.4.12  Transportation Management Plan.................................................................................................... 177 

9.7.4.13  Archaeological/Cultural Resources Management Plan .................................................................... 179 

9.7.4.14  Occupational Health and Safety Plan .............................................................................................. 180 

9.7.5  Monitoring Plans ................................................................................................................................. 181 

9.7.6  Grievance Mechanism ........................................................................................................................ 182 

10.0  UNDERTAKING AND COMMITMENTS ................................................................................................................ 183 

10.1  Financial Provision under MPRDA (Act 28 of 2002) ................................................................................. 183 

10.1.1  Financial Provision for Decommissioning and Rehabilitation .............................................................. 183 

10.1.2  Obligations for Unplanned Incidents ................................................................................................... 184 

10.2  Commitments by Shell .............................................................................................................................. 184 

10.3  Undertaking by Shell Exploration Company b.v. ....................................................................................... 186 

11.0  CONCLUSIONS AND RECOMMENDATIONS...................................................................................................... 187 

11.1  Conclusions .............................................................................................................................................. 187 

March 2011
Report No. 12800-10364-5 xxi
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

11.2  Recommendations .................................................................................................................................... 188 

11.2.1  Environmental recommendations made in this EMP ........................................................................... 188 

11.2.2  Environmental Impact Assessment (EIA) in terms of NEMA ............................................................... 189 

11.2.3  Key questions to be considered in EIA................................................................................................ 189 

11.2.3.1  Physical environment....................................................................................................................... 189 

11.2.3.2  Biological environment..................................................................................................................... 192 

11.2.3.3  Social environment .......................................................................................................................... 193 

11.3  Declaration of Independence by the EAP ................................................................................................. 195 

12.0  REFERENCES....................................................................................................................................................... 196 

March 2011
Report No. 12800-10364-5 xxii
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

TABLES
Table 1: Comparison of greenhouse gas related energy emission by fossil fuel in combustion (EIA, 1998). .................... 11
Table 2: Possible listed activities from NEMA Listing notice 1 (GN R544) which could be triggered at various
stages in the gas development process .......................................................................................................... 23
Table 3: Possible listed activities from NEMA Listing notice 2 (GN R545) which could be triggered at various
stages in the gas development process (see also Table 2).............................................................................. 24
Table 4: Possible listed activities from NEMA Listing notice 3 (GN R546) which could be triggered at various
stages in the gas development process (see also Tables 2 and 3). ................................................................. 25
Table 5: Long-term annual average temperature and relative humidity statistics (WB40, 1984)....................................... 37
Table 6: Monthly dry bulb temperature statistics for 2010 ................................................................................................. 37
Table 7: MAP, Monthly Average, Maximum and Minimum monthly rainfall depths ........................................................... 38
Table 8: The 2, 5, 10, 20, 50, 100 and 200 year return period 24-hour rainfall depths (mm/month) ................................. 39
Table 9: Summarised drilling depths in the precinct .......................................................................................................... 52
Table 10: Summarised depths to water level in the precinct ............................................................................................. 53
Table 11: Distribution of water quality (EC) in the precinct ................................................................................................ 53
Table 12: Registered agricultural and domestic use in the precinct .................................................................................. 54
Table 13: Precincts in relation to municipal boundaries .................................................................................................... 61
Table 14: Central Precinct Population Distribution ............................................................................................................ 63
Table 15: GVA per Sector 2009 ........................................................................................................................................ 66
Table 16: Central Precinct Crime Statistics, 2009 ............................................................................................................. 67
Table 17: Central Precinct HIV/Aids, 2010 ........................................................................................................................ 68
Table 18: Currently available “Green Chemistry” hydraulic fracturing chemical additives available by Industry
Suppliers .......................................................................................................................................................... 88
Table 19: Industry Third Party Example: list of additives used by Industry, at the Eagle Ford Shale, Texas, USA
producing assets .............................................................................................................................................. 90
Table 20: Industry Third Party Example: Choices available to a Company for the selection of chemical additives to
be used during hydraulic fracturing process ..................................................................................................... 92
Table 21: describes, for different drilling depths and objectives, the typical ranges of water volumes which may be
required during exploratory drilling operations ................................................................................................. 93
Table 22: Preliminary criteria to use in refining possible locations for well sites (Note: these criteria will be further
defined during the EIA)................................................................................................................................... 109
Table 23: Fossil fuel emission levels – pound per billion Btu of energy input .................................................................. 113
Table 24: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas Exploration Application
Project –Well site preparation ........................................................................................................................ 124
Table 25: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas Exploration Application
Project –Exploration Drilling ........................................................................................................................... 136
Table 26: Noise level in dB(A) at certain distances from the drilling site centre (worst case) .......................................... 144
Table 27: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas Exploration Application
Project –Hydraulic Fracturing ......................................................................................................................... 145
Table 28: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas Exploration Application
Project –Decommissioning ............................................................................................................................. 150
Table 29: Safe Handling Procedures for Petroleum Products ......................................................................................... 173

March 2011
Report No. 12800-10364-5 xxiii
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

FIGURES
Figure 1: Proposed shale gas exploration right applications at a glance. ............................................................................ 2

Figure 2: The Central Precinct application area, showing also the notional drilling areas. Up to eight wells may be
drilled in the precinct .......................................................................................................................................... 4

Figure 3: The application process for shale gas exploration rights and environmental processes required ........................ 5

Figure 4: Projected sources of energy for global electricity generation ............................................................................... 8

Figure 5: Projected sources of the world’s energy supply, to 2030. (CCS is carbon capture and storage
technology). Units are terawatts. From IEA, World Energy Projection System Plus (2010) ............................... 9

Figure 6: These well cores were brought to the surface by Soekor in the 1960s. They are from the Whitehill
Formation which is on eof the hydrocarbon-bearing strata in the Ecca Group of the Karoo............................ 14

Figure 7. Comparative rates for coal, natural gas, and synthetic natural gas life-cycle GGE in electricity generation
as well as just the combustion phase for coal and natural gas. From Jaramillo and co-authors, as
posted by Allmendinger . .................................................................................................................................. 15

Figure 8: Well cores from the 1960s drilling for oil exploration are still being kept at the National Core Library at
Donkerhoek outside Pretoria, managed by the Council for Geoscience .......................................................... 16

Figure 9: Cross Section of the Main Karoo Basin (reproduced from Woodford 2002) ....................................................... 33

Figure 10: Schematic Aerial Distributions of Lithostratigraphic Units in the Main Karoo Basin (reproduced from
Woodford 2002)................................................................................................................................................ 33

Figure 11: Regional Geology – Central Precinct. .............................................................................................................. 35

Figure 12: Massive Sandstone .......................................................................................................................................... 36

Figure 13: Characteristic horizontal bedding ..................................................................................................................... 36

Figure 14: Characteristic Expansive Landscape with dolerite capped range of hills ......................................................... 36

Figure 15: Inselberg, dolerite capping and dyke................................................................................................................ 36

Figure 16: Wind roses for Beaufort West .......................................................................................................................... 40

Figure 17: Major topographical features in the Central Precinct........................................................................................ 41

Figure 18: Soil classes of the Central Precinct .................................................................................................................. 43

Figure 19: Biomes in which the exploration area occurs ................................................................................................... 46

Figure 20: Vegetation communities occurring in the Central Precinct ............................................................................... 47

Figure 21: Photograph taken in the Gamka Karoo vegetation type near Nelspoort .......................................................... 48

Figure 22: Photograph taken in the Southern Karoo Riviere vegetation type near Three Sisters ..................................... 48

Figure 23: Photograph taken in the Eastern Upper Karoo vegetation type near Victoria West ......................................... 49

Figure 24: Photograph taken in the Upper Karoo Hardeveld vegetation type near Murraysburg ...................................... 49

Figure 25: Blue Crane, Grus paradiseus. .......................................................................................................................... 50

Figure 26: Homestead Water Supply Boreholes equipped with Submersible Pump and Windpump ................................ 54

Figure 27: Typical vista of a flat Karoo Plain with flat capped dolerite hills. ...................................................................... 55

Figure 28: Wide open plains with little vegetation cover. ................................................................................................... 56

Figure 22: Baseline noise measuring locations. ................................................................................................................ 57

Figure 23: District and Local Municipalities – Central Precinct .......................................................................................... 62

Figure 24: Central Precinct Employment Distribution by Sector, 2009 .............................................................................. 64

March 2011
Report No. 12800-10364-5 xxiv
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

Figure 29: Central Precinct Employment, 2009 ................................................................................................................. 66

Figure 30: Steps in shale gas exploration ......................................................................................................................... 74

Figure 31: Illustration of possible areas within which a suitable well site may be identified for future exploration
drilling activities ................................................................................................................................................ 76

Figure 32: Well cores from the 1960s Soekor exploration for oil in the Karoo ................................................................... 77

Figure 33: MT sensors like these are placed on the ground for a period of a day, gathering data .................................... 77

Figure 34: From a European location ................................................................................................................................ 81

Figure 35: Down hole measuring device ........................................................................................................................... 83

Figure 36: Close-up of down hole measuring device which contains a small radioactive source used to record rock
type inside the bore hole .................................................................................................................................. 83

Figure 37: Directional head off a perforating gun used to punch a hole through the well casing inside the shale
layer ................................................................................................................................................................. 83

Figure 38: Example of a crack induced by hydraulic fracturing ......................................................................................... 86

Figure 39: Dots in these images indicate the locations of micro-seismic events generated as the rock in a well in
Shell’s Unconventional gas field (Pinedale, Wyoming, America) fractured ...................................................... 87

Figure 40: Public Consultation Process towards the development of the EMP for exploration (not production) -
Central Precinct .............................................................................................................................................. 102

Figure 41: Materials that were made available at the open houses for Stakeholders to take home ................................ 103

Figure 42: Posters displayed at the open house in Victoria West ................................................................................... 103

Figure 43: Sreejeeta Datta from Shell explains the environmental authorisation process at the open house in
Beaufort-West. ............................................................................................................................................... 103

Figure 44: Toni Pietersen from Golder helps local farmers to locate their farms in the map books to confirm details..... 103

Figure 45: During the discussion session at the public meeting in Murraysburg farmers wanted to know what the
impacts of hydraulic fracking would be on downstream groundwater resources ............................................ 104

Figure 46: Mr Johan Mans, a farmer and businessman who attended the public meeting in Murraysburg officially
hands over a memorandum of questions and concerns for the environmental specialists to consider
during their studies ......................................................................................................................................... 104

Figure 47: Left and right: Stakeholders in the Graaff-Reinet area attended the public meeting in Graaff-Reinet
where the community asked what kind of guarantees Shell could provide in case of a pollution incident
during the hydraulic fracturing process of gas exploration. ............................................................................ 104

Figure 48: Environmental process to the stage of completion of a NEMA Environmental Impact Assessment prior
to hydraulic fracturing of wells ........................................................................................................................ 108

March 2011
Report No. 12800-10364-5 xxv
Draft EMP for application for gas exploration in the SOUTH WESTERN KAROO
BASIN (CENTRAL PRECINCT) by Shell Exploration Company B.V.

APPENDICES
Appendices are attached in Volume 2 – see index to Volume 2 below.

Appendix Technical Years of


Report Organisation Qualifications
No. Assessor Name Experience
List of affected
1 - - - -
properties
BSc in Science,
Groundwater Golder Associates MSc in Hydrology,
2 Graham Hubert 40 Years
Technical Report Africa (Pty) Ltd Diploma of
Hydrology.
BSc. Civil
Golder Associates
3 Surface Water Trevor Coleman Engineering, MSc. 32 Years
Africa (Pty) Ltd
Eng.
National Diploma –
Resource Utilisation
(Majors: Soil
Science,
Golder Associates Agricultural-
4 Soil Louw Potgieter 20 Years
Africa (Pty) Ltd Economics and
Extension Method),
1st Year
Baccalaureas
Commerci at Unisa.
BSc (Zoology and
Golder Associates Physiology),
5 Terrestrial Ecology Adrian Hudson 19 Years
Africa (Pty) Ltd MSc (Environmental
Science).
PhD (Chemical
Airshed Planning Engineering)
6 Air Quality Dr Lucian Burger Professionals MSc Eng (Chemical 28 Years
(Pty) Ltd Engineering).
BSc Eng (Chemical).
M.Sc. (Applied
Acoustics),
7 Noise John Hassall JH Consulting 43 Years
B.Sc. (Aeronautical
Engineering).
8 Heritage Frans Prins Active Heritage cc MA (Archaeology) 23 Years
BA Admission,
BA Hons.
Anthropology,
Golder Associates MA Anthropology,
9 Socio-economic Frank Snijder 24 Years
Africa (Pty) Ltd MBL, School of
Business
Leadership (UNISA),
Midrand, 2006.
BA (Hons)
Golder Associates
10 Public Consultation Antoinette Pietersen Psychology, 15 Years
Africa (Pty) Ltd
BA Psychology.

March 2011
Report No. 12800-10364-5 xxvi
Draft EMP for Application for Gas Exploration in the Western Karoo (Central
Precinct) by Shell Exploration Company B.V.

1.0 INTRODUCTION
This draft Environmental Management Plan (EMP) is presented to stakeholders (interested and affected
parties) in draft for their comment, and will be presented at a series of meetings in March 2011.
Once finalised, the EMP will be submitted to the Petroleum Agency of South Africa (PASA),the designated
authority1 in terms of the Mineral and Petroleum Resources Development Act (MPRDA) (Act28 of 2002), as
part of an application for a gas exploration right by Shell Exploration Company B.V. (the name Shell is used
in this document to refer to this company). Should the exploration right be granted, it will be valid for three
years, but may be extended three times for a total exploration period of nine years.
This EMP relates to the exploration right application referred to as the South West Karoo Gas Exploration
Application: Central Precinct (PASA Reference No. 12/3/220). The application area intersects Western
Cape, Northern Cape and Eastern Cape, and falls within the Central Karoo, Pixley ka Seme, Chris Hani and
Cacadu district municipalities. Appendix 1 in Volume 2 contains a list of properties in this application area.
Shell has also submitted two other applications for consideration by PASA, with Reference numbers
12/3/219 (Westen Precinct); and 12/3/221 (Eastern Precinct) respectively (see map in Figure 1). Separate
EMPs are available for these applications.

1.1 Landowners’ and Other Stakeholders’ Concerns


There has been concern among landowners and other stakeholders about the proposed exploration project,
in particular about drilling and hydraulic fracturing, but also about a range of other aspects. They also
expressed uncertainties about the environmental legal process and the time available for thorough
environmental assessment of potential impacts. These and other concerns are described and discussed
throughout this document and are listed in the Comment and Response Report that will be available.

1.2 Quick project overview


The purpose of exploration will be to assess whether there is viable shale gas (unconventional gas)
underground within the proposed ± 30 000 km2 exploration area. Proposed exploration activities, should the
application be approved, are:

ƒ Gathering geophysical data. This data acquisition process is largely non-intrusive and does not
involve drilling or significant excavation, together with

ƒ Drilling of up to eight exploration wells of up to 5 000 m deep to identify the shale layer. If the shale
layer cannot be found or no hydrocarbons are detected, fewer wells may be drilled. Well sites will be
approximately 100 m x 100 m. Additional land may be required for access roads, supply base,
accommodation etc. The total footprint is not expected to exceed 20 ha of the 30 000 sq km (3 million
ha) application area. A well will require between 0.3 and 6 Mega litres (million litres) of water,
depending on its depth, nature of the underground rock and whether hydraulic fracturing is required.
Various alternatives for obtaining water will be evaluated in detail once actual drill site locations have
been selected and will be subject to approvals under the National Water Act (Act 36 of 1998).

ƒ Gas stimulation (hydraulic fracturing and testing). If the shale layer cannot be found or no
hydrocarbons are detected, hydraulic fracturing may not be used. Fracturing would only be performed if
hydrocarbons are found following the drilling of vertical exploration wells. Hydraulic fracturing may take
place following drilling of the vertical borehole, if the vertical borehole intersects the shale layer, or
hydraulic fracturing may take place at a later stage once a horizontal borehole has been drilled into the
identified shale layer.

1
In terms of section 103 of the MPRDA, the Minister has delegated her powers in respect of the consideration of and issuing of applications for exploration rights to the Director
General of Mineral Resources. Further, in terms of section 70, the Minister has designated the South African Agency for the Promotion of Petroleum Exploration and Exploitation
(Pty) Ltd, known as the Petroleum Agency South Africa (Proprietary) Limited or “PASA”, to perform the functions as set out in Chapter 6 of the Act. PASA therefore administers this
application for an exploration right. However, the Director General, and not PASA, is the authorising authority.

March 2011
Report No. 12800-10364-5 1
Draft EMP for Application for Gas Exploration in the Western Karoo (Central Precinct) by Shell Exploration Company
B.V.

Eastern Precinct
Central Precinct PASA application reference  no 
PASA application reference  no  12/3/221 
12/3/220 30 000 sq km
30 000 sq km Separate EMP
Separate EMP

Western Precinct
PASA application reference  no 
12/3/219
30 000 sq km
Separate EMP

Figure 1: Proposed shale gas exploration right applications at a glance.

March 2011
Report No. 12800-10364-5 2
Draft EMP for Application for Gas Exploration in the Western Karoo (Central
Precinct) by Shell Exploration Company B.V

A full project description is given in Chapter 5. Figure 2 shows the application area (the Central Precinct)
covered by this EMP and notional areas, which are broad indications based on a combination of regional
geology and information gained from the 1960s exploration data by Soekor, indicating where Shell could
choose to focus their initial exploration effort to better understand geology and demonstrate the existence of
shale layers deep under the ground. It is however not yet certain where drilling will take place, and no drilling
sites have yet been determined. Up to eight drill sites per precinct may be drilled during the exploration
process. Typically not all boreholes will encounter gas bearing zones. Therefore, not all boreholes are likely
to require hydraulic fracturing.

1.3 Application and environmental assessment process


The shale gas exploration right application process, and the environmental processes required, are shown in
Figure 3.
Shell had a Technical Cooperation Agreement with PASA for 12 months (December 2009 to Dec 2010). No
field work or environmental baseline studies were permitted during this period. In December 2010, Shell
made a decision to apply for an exploration right, which was accepted by PASA on 14 December 2010.
PASA instructed Shell, in accordance with MPRDA (article 39 (2)) to develop an Environmental Management
Plan2, and submit this to PASA in 120 days, on or before 14 April 2011. This requirement under the MPRDA
leaves limited time for the applicant to undertake site specific environmental baseline studies to help narrow
down and prioritise precise coordinates for drilling locations.
The consultants met with PASA to verify this instruction, and in particular as a result of the concerns raised
by stakeholder during the initial consultation period in January-February 2011. PASA re-confirmed that, the
EMP should, in the absence of specific drilling sites, as a minimum assess and make recommendations for
mitigation in respect of the types of activities to be conducted somewhere within the regional areas.
The current process to compile the required EMP’s consequently comprises assessment of available
information covering the application areas supported by broad based field verification for certain studies. The
EMP process has also seen widespread consultation with interested and affected parties through a multi-
stage consultation process affording stakeholders opportunity to engage with proponent and consultant
teams early on in the process, and again during the period of stakeholder review of the draft documents.

The approach followed in compiling this draft EMP document has been to identify and assess potential
impacts in a broad, regional context, as well as to assess specific exploration activities generically but not in
a site-specific context. A typical gas exploration well was used to assess potential impacts and to develop
indicative mitigation measures. This content of and recommendations made in this EMP document should, to
a large extent, also be viewed as critical input to a later scoping phase, where the required NEMA EIA will be
performed.

2
MPRDA: From section 17 and section 39(2)8 (as read with, 69(2)(a)9) it is clear that the reference to an “environmental
management programme” is an error and that that section 79(4)(b) must refer to an “environmental management plan”. PASA routinely
accepts environmental management plans in compliance with the content requirements as prescribed in regulation 52(2) and therefore
clearly accepts the fact that section 79(4)(b) incorrectly refers to a “programme” instead of a “plan” (Kenneth Cameron, B Proc,
Cameron Cross, Pers Com, February 2011).

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B.V

Figure 2: The Central Precinct application area, showing also the notional drilling areas. Up to eight wells may be drilled in the precinct

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This plan needs to be submitted within 120 days of the application having been accepted.
However, should an exploration right be granted, the applicant may proceed only with those gas exploration
activities that do not trigger a listed activity under the National Environmental Management Act (NEMA).
Drilling and hydraulic fracturing will trigger listed activities under the NEMA (see Chapter 3, Legal
Context). Thus, an Environmental Impact Assessment under the NEMA will be required before
drilling and hydraulic fracturing can commence, including a rigorous process to determine drill sites
in consultation with land owners. This is discussed further in Chapter 7, Alternatives, and Chapter 11,
Conclusions and Recommendations.

ENVIRONMENTAL PROCESSES FOR SHALE GAS EXPLORATION

APPLICATION  AND  ENVIRONMENTAL 
EXPLORATION PROCESS ASSESSMENT PROCESS

Mineral and  Apply for Technical 
Petroleum Resources  None required
Cooperation Permit
Development Act

Mineral and 
Mineral and  Environmental 
Apply for exploration  Petroleum Resources 
Petroleum Resources  Management Plan,  no 
rights Development Act 
Development Act EIA process s 39 (2)

If application right 
granted: 
Environmental  
National 
Data acquisition 
and drilling  + Hydraulic fracturing 
of some drill sites
Impact Assessment 
process and updated 
EMP
Environmental 
Management Act 
(NEMA). 

Drilling and hydraulic 
fracturing will trigger listed 
activities under the NEMA

Figure 3: The application process for shale gas exploration rights and environmental processes required

1.4 Environmental consultants


Golder Associates Africa (Pty) Ltd (Golder) has been appointed as the independent environmental consultant
compiling the EMPs for the three gas exploration areas.
Stakeholders have expressed the concern that environmental consultants responsible for EIAs must
automatically be biased since they are paid by the developer. This is not correct. The requirement for
environmental consultants to act independently and objectively is a well established principle in South
African law and elsewhere. Whilst this EMP process is not an environmental impact assessment under the
National Environmental Management Act (NEMA), the NEMA is South Africa’s overarching environmental
law and its EIA regulations (GNR 385) state:

“that such EAP (environmental assessment practitioner) (must have) no business, financial, personal
or other interest in the activity, application or appeal in respect of which that EAP is appointed in

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terms of these Regulations other than fair remuneration for work performed in connection with that
activity; or that there are no circumstances that may compromise the objectivity of that EAP in
performing such work.”
Thus, the task of environmental consultants is not to promote a project but to provide credible, objective and
accessible information to government and other stakeholders, so that an informed decision can be made
about whether to proceed or not. The consultants are legally bound to critically consider both the potential
negative and positive impacts of the proposed project.
Golder Associates is a 50-year old wholly employee-owned company with a strong culture of ethics and
values. In a recent global participation process amongst the company’s 7 000 employees, the highest
standard of integrity and ethical behaviour were re-affirmed as the fundamental value of the company.
We hope that the information provided in this EMP, and the balanced manner in which it is presented,
considering both negative and positive impacts, illustrates that the work is unbiased. In making draft
recommendations in the report, Golder has consulted widely with landowners and other stakeholders, and
will continue to do so during the period in which the report is finalized.

1.5 Interaction with landowners


Landowners will continue to be consulted throughout the EMP process, and following that, throughout the
EIA process should the exploration right be granted. The site selection process for drill sites will be based on
a set of criteria on which landowners and other stakeholders will be consulted (see Chapter 7 for a
preliminary list of criteria). There is some flexibility in terms of location of the sites and Shell will work closely
with landowners to identify suitable locations and access roads should the application be approved. Shell
also indicated that the company will engage with landowners to try and come to agreements on land access
and will seek prior permission for access to land

1.6 Structure of this report


This Draft Environmental Management Plan Report is structured as follows:

ƒ Chapter 1 is the introduction and amongst other gives a quick overview of the proposed project,
highlighting key aspects and new information;

ƒ Chapter 2 provides the international and national context for and history to the proposed project,
outlining the role of gas in an energy context, South Africa’s energy situation, the role of hydraulic
fracturing in shale gas production and the concerns associated with the technology in the USA, and
previous exploration in the Karoo by Soekor;

ƒ Chapter 3 sets the legal context for gas exploration in South Africa and lists the key laws and
regulations applicable ;

ƒ Chapter 4 describes the existing environment – the Karoo. It summarises knowledge about the existing
physical, biological, social and cultural environment upon which the proposed project may impact;

ƒ Chapter 5 describes the applicant and proposed exploration project, outlining Shell as a company, and
describing the intended steps in and project requirements for gas exploration;

ƒ Chapter 6 outlines how the assessment for the EMP was conducted, both technical assessment and
public consultation. It summarises stakeholder issues contributed during the process, and outlines the
requirement for an Environmental Impact Assessment under the National Environmental Management
Act (NEMA) prior to drilling and hydraulic fracturing;

ƒ Chapter 7 describes the project alternatives, including selection of drill sites should the application be
approved by PASA, and the ‘no project’ alternative;

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ƒ Chapter 8 describes the potential impacts of the proposed project in terms of a range of environmental
and social aspects;

ƒ Chapter 9 contains the Environmental Management Plan which will become legally binding on the
applicant should the exploration right be granted;

ƒ Chapter 10 contains an undertaking by the applicant, required by the Mineral and Petroleum Resources
Development Act;

ƒ Chapter 11 states the consultants’ conclusion and recommendations pertaining to the proposed project
and includes the environmental consultants’ statement of independence; and

ƒ Chapter 12 lists the references cited in the report and technical assessment studies.

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2.0 CONTEXT AND HISTORY


This Chapter grounds the EMP in the context of the energy economy of the world, and examines the energy
situation in South Africa, specifically with respect to energy and development in the face of the country’s
response to climate change. It then addresses shale-gas development, its potential, its technologies, and its
potential risks. It includes a brief history of prior exploration for hydrocarbons in the Karoo region.

2.1 The global energy outlook


Energy supply is rated by many authorities as the world’s greatest present challenge: meeting the needs of
the developing world, and especially the achievement of the Millennium Development Goals3, requires vastly
increased use of energy, while simultaneously the world must substantially decrease the emissions of
greenhouse gases if it is to avoid dangerous climate change.
The late Nobel Prize-winning chemist and physicist Richard Smalley focused world thinking on the world’s
energy challenge4globally. The world currently uses the equivalent of 14.5 terawatts of energy (2004), but
meeting world needs by 2050 would require at least twice this amount, mainly from new technologies, and
mainly from lower-carbon sources such as, for electricity generation, liquid natural gas, nuclear and
renewables (see Figure 4). In his 2005 paper he confronted the world with what he called the Terawatt
Challenge. He reckoned that to meet the needs of a global population of 10 billion by 2100 the world would
need to generate 60 terawatts, if all are to live at the level of energy prosperity currently enjoyed by the
developed world. Providing for the world’s development needs requires such increases, and at cheap prices,
and with much reduced greenhouse gas emissions. The technologies to provide this are presently mostly
unknown.

40

35

30

25 Liquids
Renewables
20
Natural gas
15
Coal
10 Nuclear
5

0
2007 2015 2020 2025 2030 2035

Figure 4: Projected sources of energy for global electricity generation5


In the IEO 2010 projections (i.e. the International Energy Outlook scenarios of the International Energy
Agency (IEA)), total world consumption of marketed energy increases by 49 percent from 2007 to 2035. The
largest projected increase in energy demand is in non-OECD economies6.

3
The UN Summit on the Millennium Development Goals, 20-22 concluded with the adoption of a global action plan to achieve the eight anti-poverty goals by their 2015 target date. See
http://www.un.org/millenniumgoals/
4
Richard E. Smalley, 2005. Future Global Energy Prosperity: The Terawatt Challenge. MRS Bulletin Vol. 30 June 2005. www.mrs.org/publications/bulletin
5
Derived from EIA, International Energy Statistics database (as of November 2009), web site www.eia.gov/emeu/international. Projections: EIA, World Energy Projection System
Plus (2010)

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ompany B.V

Authoritativee foresights on the devellopment of th he world’s en


nergy industrry to meet thiis challenge differ, but
all anticipate
e a substanttial contributio
on from increeases in eneergy efficienccy, relative de
ecline in the
contributionns of fossil fuels, owing to
o national clim
mate policies
s and the rising price of o oil and coal, an
a increase
in the role of
o renewabless as well as, in most cases, nuclear sources.
s But in spite of th
he increasingg role of
renewabless, fossil fuel sources
s remaain importantt for the nextt several deccades, in thesse scenarios s (see
Figure 5). The
T Worldwid de Fund for Nature,
N in its Energy Rep port7, suggests that fossil fuels could beb
eliminated by
b 2050, but even that sccenario anticipates the ne eed substanttial supplies of hydrocarb bon energy
over the nexxt few decad des.

The IEA pro ovided energ gy outlooks fo or the debatee following th


he Copenhag gen Conferen nce of the Pa arties to the
UN Conven ntion on Climate Change (UNFCC) in 2009 on how w to achieve the world’s climate chan nge
mitigation goals (based on its New Policies
P nario – the 450 Scenario -which assu
Scen umes urgent action to
“bring about a wholesale e shift to low
w-carbon tech hnologies”). In its World Energy Outlo ook (WEO) 20102
Factsheet, the
t IEA anticcipates a sce enario in whicch world primmary energy demand incrreases by 36 6% between
2008 and 20 035. This wo ould be at a rate
r of increa
ase nearly ha t previous 27 years (a future 1.2%
alf of that in the
per year as opposed to 2% in the pa ast), owing too anticipated increases in n energy efficciency, but sttill like that
of the Teraw watt Challeng ge. Up to 2035, the IEA projection
p annticipates thaat 50% of thiss increase in supply will
still be from fossil fuels (though
( with much greate er efficiency,, and accomp panied by caarbon capture e and
storage tech hnologies), and
a the Factssheet continu ues: “Natural gas is set to o play a centtral role in meeting the
world’s energy needs fo or at least the
e next two-an nd-a-half deccades.” The survey
s by thee 2011 Econ nomist
Intelligence Unit corrobo orates this view8.
Figure 5, fro
om the IEA WEO’s
W specia
al early exce
erpt of the World Energy Outlook 2009 for the Ban ngkok
UNFCC me eeting, illustra
ates the anticcipated contrributions to the world’s en
nergy supplyy in 2030 from
m different
sources. Th his projection
n is for the so
o-called scennario 450, wh here urgent action
a leads tto containing
g future
atmosphericc CO2 conce entration to 450 part per million.
m

Figure 5: Proojected source


es of the world
d’s energy sup
pply, to 2030. (CCS is carbo
on capture and
d storage tech
hnology).
Units are tera
awatts. From IEA,
I World Ennergy Projectio
on System Plu us (2010)

6 http://www.eia.doe.gov/oiaff/ieo/pdf/0484(2010).pdf Royal Dutch Shell’s Blueprints Scena


ario offers essentially the same
e outlook; see www-static.shell..com/.../scenarios /shell_energyy_scenarios_2050.pdf The OE
ECD is the Organisation for Ec
conomic Co-operation and

Development, which represents 34 members largely from th


he advanced world.
7
http://assets.wwfzza.panda.org/downloa
ads/101223_energy_
_report_final_print_2.pdf

8
Deep water ahead
d? The outlook for the oil and gas industrry in 2011. The Econo
omist Intelligence Un
nit Limited 2011.

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2.1.1 Shale gas in the global energy context


Though natural gas has been exploited for energy for over a century, its contribution to energy supply has
been small relative to coal and oil. But its role has grown rapidly during the past decade.
In the words of the World Energy Council in its World Energy Insight 2010, the world is in an era of energy
innovation. According to the council, the biggest innovation since the start of the new century has been the
sourcing of natural gas in a new way through the exploitation of shale gas. This innovation has in turn
depended on the innovative technology called hydraulic fracturing.
This development of new natural gas transforms the debate over generating electricity, because of the vastly
increased reserves and supply of natural gas from these sources, gas’s relatively low carbon dioxide
emissions, and the fact that natural gas-fired power plants can be built relatively quickly. In addition,
transport fleets can be converted to run on gas. Natural gas holds a further strategic advantage, since gas-
fired power plants can supplement the intermittent electricity supplies from renewable sources in a regime of
growing electricity consumption. In this way natural gas compliments and facilitats the expansion of the
renewable energy sector.
Shale gas, which has been a North American phenomenon until the last few years, is now being considered
in Europe (Poland, Sweden, Austria, Germany, etc.), China, India, Australia and New Zealand as well as
South Africa. Shale gas is clearly a significant development in North America and especially in the United
States. It has dramatically changed the energy outlook for the continent in terms of tapping into a vast
unconventional gas resource for domestic use and even with the thought of being a gas exporter. For many
years North America was being viewed as needing to develop significant LNG import capabilities to meet
rising demands for gas. This has now changed as a result of shale gas.
With the increase in natural gas extraction in the USA and Europe over the past few years there has been
growing concern that the hydrocarbons and other chemicals used in hydraulic fracturing would contaminate
water supplies. This risk may emerge where and if the water and gas-bearing layers are close to each other.
The risk may also emerge if gas-well casings are poorly installed and monitored (see below). This section
reviews these concerns in section 2.6 below.

2.1.2 International Trends in Natural Gas Supply


The rapid development in the international use of gas has changed the world’s energy landscape. The
natural gas supply revolution rests on two pillars of innovation – firstly, improvements in production
technologies noted earlier, which have made it economical to produce shale gas and tight gas resources that
were previously considered too difficult to tap, and secondly the diversification and globalization of natural
gas markets: worldwide, there is now sufficient technically recoverable natural gas in the ground for 250
years at current production rates9. The development of liquid natural gas (LNG) as an efficient means of
transporting natural gas anywhere in the world and the huge gas reserves provided by shale gas have been
mutually reinforcing, providing the increased resource and the flexibility of supply to guarantee the security of
natural gas supply for the long term, thereby providing governments and investors with greater confidence to
support the growth of the natural gas industry.

2.1.3 Environmental Benefits of Natural Gas Use


Natural gas is the cleanest burning of all the fossil fuels (gas, oil and coal). Composed primarily of methane,
the main products of the combustion of natural gas are carbon dioxide and water vapour, the same
compounds people exhale when they breathe. Coal and oil are composed of much more complex molecules,
with a higher carbon ratio and higher nitrogen and sulphur contents. This means that when combusted, coal
and oil release higher levels of harmful emissions, including a higher ratio of carbon emissions, nitrogen
oxides (NOx), and sulphur dioxide (SO2).

9
Deep water ahead? The outlook for the oil and gas industry in 2011. The Economist Intelligence Unit Limited 2011; IEA Natural Gas Information 2010 at

http://www.iea.org/publications/free_new_Desc.asp?PUBS_ID=2044

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Coal and fuel oil also release ash particles into the environment, substances that do not burn but instead are
carried into the atmosphere and contribute to pollution. The combustion of natural gas releases very small
amounts of sulphur dioxide and nitrogen oxides, virtually no ash or particulate matter, and lower levels of
carbon dioxide, carbon monoxide, and other reactive hydrocarbons.
In a major study by the United States Environmental Protection Agency (USEPA) and the Gas Research
Institute (GRI) in 1997, aimed at determining whether the reduction in carbon dioxide emissions from
increased natural gas use would be offset by a possible increased level of methane emissions, it was
concluded that the reduction in emissions from increased natural gas use strongly outweighed the
detrimental effects of increased methane emissions. Thus, the study supported the increased use of natural
gas in the place of other fossil fuels as a means of reducing emissions of greenhouse gases globally.
The combustion of natural gas does not contribute significantly to smog formation due to low levels of
nitrogen oxide emission and virtually no particulate matter emission. For this reason, where natural gas is
used for power generation, this will help smog alleviation strategies where air quality is poor, since the
principal contributors to acid rain are emissions from coal-fired power plants.
Natural gas contains very low concentrations of sulphur and nitrogen oxides (Table 1). These are the
pollutants primarily responsible for acid rain damages to soils, water and crops, forests and structures. These
benefits to air quality are of special potential value, where the burden on non-communicable disease is 2-3
times higher than in the developed world, and in which pulmonary disease associated at least in part with
poor air quality is highly prevalent, and which disproportionately affect mortality and morbidity among
children under five years of age10.

Although natural gas in the combustion phase is a clean energy option, and this offers an important potential
national benefit to South Africa, its life-cycle emissions are less advantageous, and local emissions during
production may be problematic (see section 2.5 below).

2.2 South Africa’s energy outlook


The National Climate Change Response Green Paper (December 2010, Department of Environmental
Affairs)11, while at this stage a discussion document, indicates how South Africa will address the energy
sector in its response to the dangers of climate change.
The SA Government regards climate change as one of the greatest threats to sustainable development.
Table 1: Comparison of greenhouse gas related energy emission by fossil fuel in combustion (EIA,
1998).

Comparison of Combustion Emission

Pounds Per Billion BTU Energy Input

Air Pollution Combustion Source

Natural Gas Oil Coal

Carbon dioxide (CO2) 117,000 164,000 208,000

Carbon monoxide (CO) 40 33 208

Nitrogen oxides (NOx) 92 448 457

10
Bongani M Mayosi, Alan J Flisher, Umesh G Lalloo, Freddy Sitas, Stephen M Tollman, Debbie Bradshaw, The burden of non-communicable diseases in South Africa. www.thelancet.com
Published online August 25, 2009 DOI:10.1016/S0140-6736(09)61087-4; Debbie Bradshaw, Pam Groenewald, Ria Laubscher, Nadine Nannan,Beatrice Nojilana, Rosana Norman, Desiréé Pieterse
and Michelle Schneide. Initial estimates from the South African National Burden of Disease Study, 2000. MRC Policy Brief No. 1, March 2003. http://www.mrc.ac.za/policybriefs/initialestimates.pdf
11
National Climate Change Response Green Paper 2010 at http://www.polity.org.za/article/national-climate-change-response-green-paper-2010-2010-11-18

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Comparison of Combustion Emission

Sulfur dioxide (SO2) 0.6 1,122 2,591

Particulates (PM) 84 2,744

Formaldehyde 0.750 0.220 0.221

Mercury (Hg) 0.000 0.007 0.016

The Green Paper notes that ‘South Africa is both a contributor to, and a potential victim of, global climate
change given that it has an energy-intensive fossil-fuel powered economy and is also highly vulnerable to the
impacts of climate variability and change.’ Government accepts that although there will be costs with South
Africa’s greenhouse-gas reduction efforts, there will be significant social and economic benefits, and that
these costs will be far less than the costs of delay or inaction.
In the Green Paper, Government commits to taking a balanced approach to both climate change mitigation
and adaptation response. It prioritises mitigation interventions ‘that significantly contribute to a peak, plateau
and decline emissions trajectory where greenhouse gas emissions peak in 2020 to 2025 at 34% to 42% of a
business-as-usual baseline, plateau to 2035, and begin declining in absolute terms from 2036 onwards – the
same commitments the country made at the Copenhagen Conference of the United Nations Framework
Convention on Climate Change (UNFCCC) Parties in December 2009. Mitigation interventions that have the
potential to create jobs, alleviate poverty, and have general economic benefits, are to receive priority.
There is a direct link between energy and the achievement of the Millennium Development Goals (MDG)12.
South Africa is necessarily committed to addressing energy poverty as an essential element of its
development strategy, since this a key part of lifting people out of poverty, and supporting the progress in
health (especially among children) and education needed to achieve this upliftment. Providing access to
safe, clean modern energy for all South Africans means increased electricity generation: 20% of South
African households do not yet have access to electricity13, while 28%14 still use indoor fires or paraffin stoves
for cooking and heating, a significant source of childhood mortality and morbidity (and South Africa’s under-
five-year-old mortality rate was still 104 per thousand in 2007, according to South Africa’s MDG report for
2010).
Since the energy sector is the largest contributor to greenhouse-gas emissions (GGE) in South Africa, the
Green Paper is clear that successful climate change mitigation in South Africa must focus on this sector.
South Africa’s disproportionate (to economic output) GGE profile is also becoming a source of economic
vulnerability, in a world in which barriers to trade based on the carbon intensity of traded goods are
beginning to emerge.

The Green Paper identifies energy efficiency measures, the roll-out of renewable forms of energy, as well as
nuclear energy development, as the principal means to GGE mitigation in energy. In addition, Government
will integrate a climate constraint into its energy planning tools, including the Integrated Energy Plan (IEP)
and the Integrated Resource Plan for Electricity Generation (IRP).

2.2.1 Natural gas in the South African energy context


The IRP, which is part of the IEP, presents the plan for electricity for South Africa over the next 20 years. It
projects the need to supply about 52,000 MW over the next 20 years to meet SA’s future economic growth,
despite a 35% offset through improved energy efficiency. The IRP, in its Balanced Revised Scenario, the

12 These goals arose from the World Summit on Sustainable Development in Johannesburg in 2002.

13
http://www.statssa.gov.za/Publications/CS2007Basic/CS2007Basic.pdf
14
Statistics South Africa, General Household Survey (Statistical release P0318), 2008 http://www.statssa.gov.za

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recommended policy frame, foresees only a small contribution from natural gas (about 2,000 MW). However,
the potential offered by such a supply is clear from the global trends outlined earlier, and this depends on
finding and exploiting natural gas resources.
The value of natural gas lies firstly in it being a cleaner burning fuel, compared with fossil fuels such as coal
and oil, with significant benefits in terms of air quality i.e. low particulates (i.e. small particles of dust)
emissions. Secondly, natural gas also has lower GGE, compared with coal and oil. Projects that could result
in a switch from coal to natural gas would therefore be eligible for carbon credits under the Clean
Development Mechanism of the Kyoto Protocol. Thirdly, the use of gas in power generation is more efficient
compared to coal-fired power (see above), particularly when the gas is used in combined cycle facilities15.
Finally, from a cost perspective, it is not as easy to export gas as it is to export coal and consequently the
domestic cost of energy would become more stable, being less exposed to international market price
fluctuations.
The industrial use of natural gas has particular attractions. With the significant increases in domestic
electricity tariffs over the past years, the economic imperative is emerging to invest in power generation
technologies involving natural gas. Significant energy and cost efficiencies can be derived from co-
generation plants operating in combined cycle systems within industrial activities. A combined cycle co-
generation plant involves the burning of gas to drive a gas turbine, which generates electricity, followed by a
heat recovery steam generator, which generates high-pressure steam from the waste heat produced by the
gas. This steam can then be sent to a steam turbine, where it is expanded to produce additional electricity.
The steam exhausted from the steam turbine can then be used in the industry, or alternatively condensed16.
Co-generation is a very efficient form of electricity generation, which carries a significantly reduced
greenhouse gas emissions impact relative to conventional coal-fired power generation.

2.3 Overview of shale gas


Shale gas has the potential to contribute strongly to a country's energy mix, as seen in the United States
where shale gas production has increased from 1.6% of that country’s gas production in 1996 to 5.9% by
2006 (Kuuskraa, 2007), with production projected to account for over 45% of the nation’s domestic gas
production by 2035.
The proving of large resources of natural gas in South Africa has the potential to supply a vital contribution to
the country’s goal of a low-carbon economy, as envisaged in the Green Paper. Unconventional exploitation
from shale gas resources could realise this potential.

2.3.1 The geology of shale gas


Shales containing natural gas are formations of organic-rich shale, a sedimentary rock formed from deposits
of mud, silt, clay, and organic matter. Such shales are referred to as a source rock for gas. In South Africa,
certain shale layers in the Karoo Supergroup of sedimentary rocks contain substantial concentrations of
organic matter, and have the promise of natural gas. These include the Whitehill Formation (see Figure 6)
and the Collingham Formation of the Ecca Group, rocks that crop out at the surface in many places, but
which are mostly buried up to 5 km below the surface17 in the Karoo. These natural gas sources have their
origin in deposits of plant and microscopic animal remains in the water basins of the Karoo era, dating over
250 million years ago, and their subsequent transformation by the weight of overlying rock and the heat deep

15
Energy Efficiency indicators for Public Electricity: Production from Fossil Fuels. IEA Information Paper OECD/IEA, 2008, at http://www.iea.org/papers/2008/En_Efficiency_Indicators.pdf
16
In situations where industries do not have a steam requirement, the amount of power extracted from the high pressure steam can be increased and the vapor exhausted from the turbine can be
condensed and recycled. In this situation, a slightly higher amount of power is generated per unit of gas entering the power generation system.
17
Johnson MR et al, 2006. Sedimentary rocks of the Karoo Supergroup. In: Johnson, MR, Anhaeusser, CR and Thomas, RJ (eds), 2006. The Geology of South Africa. Geological

Soceity of South Africa, Johannesburg/Council for Geoscience, Pretoria. 691 pp; Thomas Branch, Oliver Ritter, Ute Weckmann, Reinhard F. Sachsenhofer and Frank Schilling, The

Whitehill Formation – a high conductivity marker horizon in the Karoo Basin. South African Journal of Geology, 2007, Vol. 110, pp. 465-476. doi: 10.2113/gssajg.110.2/3.46

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below Earth’s surface. The formations in the Karoo that are believed to contain recoverable gas are located
several thousand metres (1 500 m to 4500 m) below the surface18.

Over millions of years the gas may migrate (i.e.‘float’) up


through overlying permeable rock layers, for example,
sandstone and carbonate reservoirs. If the gas reaches an
impermeable rock layer above it (a ‘seal’), it may then be
trapped in one area. If no impermeable layer is
encountered then any gas generated in the shales will,
over millions of years, have disappeared to the surface
and into the atmosphere.
Exploring for hydrocarbons held in traps is typically
referred to as conventional exploration. This type of
exploration for trapped hydrocarbons was pursued by
Soekor in the 1960s (see Figure 6).
In certain geological environments the gas generated in
the shales (the source rock) cannot migrate up through
overlying rock layers, but is held tightly in less permeable
rock, unable to move even a few millimetres. This is due to
the structure of the rock and also impermeable layers
immediately surrounding the shale rock. Exploring for
Figure 6: These well cores were brought to the shales and gas in this type of geological environmental is
surface by Soekor in the 1960s. They are from called ‘unconventional’ exploration).
the Whitehill Formation which is on eof the
hydrocarbon-bearing strata in the Ecca Group Since the 1940s continual advancement in drilling
of the Karoo. techniques and well stimulation technology have made it
possible to extract gas from these, less permeable, rock
formations.
The rock matrix in the shale has low permeability, so gas movement in the shales is very slow.
Consequently, production of gas in commercial quantities requires that the shale layers be fractured to
stimulate gas flow by improving permeability for gas within the shale layer.

2.4 Shale gas and greenhouse gas emissions


Though power generation from natural gas is more efficient that from coal and yields less GGE during
generation, the comparisons must be based on full life cycle analysis, i.e. along the whole electricity supply
chain from production of the resource to electricity output. Natural gas production involves significant GGE
during production and transport; for example, the Environmental Protection Agency (EPA) estimates that just
over 1% of methane is lost during natural gas production in the United States during production,
transmission, and storage. Since methane is a powerful greenhouse gas, these small leakages to the
atmosphere have very large consequences on global warming19.
Recent work by Jaramillo and co-authors showed a clear advantage to natural gas over coal in terms of
GGE, over the full lifecycles of energy generation in either case. The comparative advantage of natural gas
depends on the supply chain, but Jaramillo and co-authors found that the benefit obtains even liquefying
natural gas to transport it from a distant source (say, the Middle East) to the USA yields less overall
emissions than coal. Figure 7 below illustrates their findings in comparing natural gas and coal over their life
cycle.

18
Johnson MR et al, 2006. Sedimentary rocks of the Karoo Supergroup.
19
e.g. R W Howarth at http://www.technologyreview.com/blog/energy/files/39646/GHG.emissions.from.Marcellus.Shale.April12010%20draft.pdf on 27 February 2011

March 2011
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MP for Applic cation for Ga
as Exploration
n in the Westtern Karoo (C
Central
Precincct) by Shell Exploration
E Co
ompany B.V

Figure 7. Coomparative rattes for coal, naatural gas, and synthetic na


atural gas life-ccycle GGE in electricity gen
neration as
well as just th
he combustion
n phase for co
oal and natural gas. From Ja
aramillo and co-authors,
c mendinger 20.
as posted by Allm

Neverthelesss, the compparative GGEE advantage of natural ga as is still under debate. RRobert Howa
arth of the
Cornell Univversity Depa
artment of Eccology and Evvolutionary Biology,
B provvides a succinct summary
y in a post off
1 April 2010
021, stating as
a follows:
“The most recent
r data I could find fo
or the US (fro
om 2006) sug ggest a leakaage rate fromm the oil and gas
industry of an
a amount of methane eq qual to 1.5%
% of the naturral gas consu umed (based d on leakage data
reported in EPA (2008) Inventory of U.S. Greenh house Gas Emissions
E annd Sinks 1990 – 2006 and d
consumptio on data from the U.S. Dep partment of
Energy:httpp://www.eia.d doe.gov/pub/o oil_gas/natural_gas/data a_publications/natural_ga as_monthly/c current/
pdf/table_02 2.pdf). This leakage rate is roughly eqqual to that estimated
e byy the EPA in 1997
(http://p2pays.net/ref/077/06348.pdf). However, th he actual leakage is not well
w known, a as monitoringg is quite
limited, and ‘governmen nt scientists and
a some ind dustry officials caution that the real fig
gure is actua
ally higher”
“If we assumme a 1.5% le eakage rate, this would have a greenhouse gas warming w pote
ential equal too 14.8 g C
of CO2 per million jouless of energy. This would be b additive too the emissio ons during co ombustion (1 13.7 g C of
CO2 per million joules ofo energy) an nd to the emissions assoc ciated with obtaining and d transporting g the natural
gas (very rooughly estima a 4.5 g C off CO2 per million joules of
ated above as o energy). To otal greenho ouse gas
emissions frrom natural gas
g from hyd draulic fractuuring may, the erefore, be equivalent
e to 33 g C of CO O2 per
million joule
es of energy. For diesel fuuel or gasolinne, the total greenhouse gas emissio ons are equiv valent to
approximate ely 20.3 g C of CO2 per million
m jouless of energy.” But it is important to notee that Howarrth in his
paper says the following g – a) he addds additional GHG contrib bution to the natural gas calculations as a result
of transportation and othher activities associated with
w production (pipelines, water tran nsport, drilling
g of wells)
while admittting that no rigorous
r estimmate is available and ass sumes that this is 33% of the GHG produced
when burnin ng natural gaas (compared d to 8% for diesel/
d gasoline). b) By his own admisssion, it is diffficult to
assess simiilar emissions for mining and transportation of coa al but then goes on to sa ay it is probabbly
comparable e to shale gass. These asssumptions indicate some of the difficu ulties in makiing sound lifee-cycle
assessments.

20 Jaramillo, P., Grriffin, W. M., and Mattthews, H. S., 200720


0, as posted by Allme
endiger at

http://www.geo.corn
nell.edu/geology/facu
ulty/RWA/photos/marrcellus_related_imag
ges/marcellus_blog/lifecycle_coal_versuss_natur.html on 27 Fe
ebruary 2011

21R W Howarth, 20
010, Preliminary Asse
essment of the Greenhouse Gas Emissio
ons from Natural Gas
s obtained by Hydrau
ulic Fracturing at

http://www.technolo
ogyreview.com/blog/e
energy/files/39646/G
GHG.emissions.from.Marcellus.Shale.April12010%20draft.pdf on 27 February 2011

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Thus, Howarth’s assessment again is in contention, since Howarth may have assumed too high a Global
Warming Potential figure for methane22.

For any shale-gas development in the Karoo, the real costs and benefits to be anticipated would need
buttressing through a thorough GGE life-cycle analysis based on appropriate assumptions about the
technologies to be employed, the transportation involved, and plausible factors for methane Global Warming
Potential.

2.5 Previous exploration in the Karoo


The first organised search for
hydrocarbons in South Africa was
undertaken by the Geological Survey of
South Africa in the 1940's. In 1965 Soekor
(Pty) Ltd was formed by the government
and began its search in the onshore areas
of the Karoo, Algoa and Zululand Basins23.

In the 1960s, Soekor undertook


hydrocarbon exploration activities across
the Karoo but was unsuccessful in their
exploration for oil. However, the potential
for gas being held within geological
formations at depths down to nearly five
kilometres was noted in a few exploration
wells that were drilled.
In only one of the ten wells drilled did gas
actually flow, and then only for one day
before gas flow stopped and monitoring
Figure 8: Well cores from the 1960s drilling for oil exploration
ceased. This particular well is located
are still being kept at the National Core Library at Donkerhoek
south of Shells Eastern exploration rights
outside Pretoria, managed by the Council for Geoscience
application area.
As no oil was discovered at that time, and in light of the economic climate, it was not technically-
commercially feasible to continue to explore to try to extract gas. Therefore, exploration activities ceased,
and the Soekor wells were decommissioned. However, well cores from the 1960s drilling for oil exploration
are stored at the National Core Library Donkerhoek, managed by the Council for Geoscience (Figure 8).

2.6 How this links to the proposed Karoo shale gas exploration
Technological improvements in drilling techniques make it possible to stimulate gas to flow from these “‘tight”
rock formations, such as those found in the Karoo. However, there is inadequate information to evaluate
whether the shale formations present within the Karoo hold potential as a viable gas resource.
Consequently, early level exploration is necessary to confirm whether South Africa potentially has viable
unconventional natural gas resources which may be of strategic value in the future as an energy source to
meet the growing demand for electricity within the country.
Shell, a company with considerable experience in exploration, has thus made application for exploration
rights to initiate an early level exploration programme in three broad areas to confirm whether the deep shale
strata in the Karoo contain unconventional natural gas and, if so, to evaluate the potential to extract
unconventional natural gas.

22
Allemendinger at http://www.geo.cornell.edu/geology/faculty/RWA/photos/marcellus_related_images/marcellus_blog/thoughts-on-life-cycle.html on 27 February 2011
23
http://www.petroleumagencysa.com/Promotion/ExplorationHistory.aspx

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3.0 LEGAL CONTEXT


This chapter summarises the environmental legal context for the exploration of gas and petroleum
resources24. Key points, in summary, are:
The Mineral and Petroleum Resources Development Act (MPRDA; Act 28 of 2002) stipulates in Section 39
(2): Any person who applies for a reconnaissance permission, prospecting / exploration right or mining permit
must submit an environmental management plan as prescribed and in Section 79(4) (b) that the applicant
should submit an environmental management plan in terms of section 39 within a period of 120 days from
the date of the notice.”
The contents of an Environmental Management Plan are prescribed in the MPRDA Regulations Section 52.
Considering section 52 (2) (b) and (c) of the Regulations, an assessment of environmental, socio-economic
and cultural impact is required, and not an Environmental Impact Assessment process in terms of s 39 (1) of
the MPRDA.However, there are activities which form part of the proposed exploration rights application
which do require consideration under the National Environmental Management Act (NEMA; Act 107 of 1998),
notably the following:

ƒ Activity 24 of Notice 1, GN 544, requiring a basic assessment: The transformation of land bigger than
1 000 m2 in size, to residential, retail, commercial, industrial or institutional use …. (Drill sites will be
approximately 100 x 100 m, thus 10 000 sq m).

ƒ Activity 4 of Notice 2, GN 545, requiring a full EIA: The construction of facilities or infrastructure for the
refining, extraction or processing of gas, oil or petroleum products with an installed capacity of 50 cubic
meters or more per day… (It is assumed that hydraulic fracturing during exploration drilling could
stimulate gas flow of 50 cubic meters or more per day).

Thus, an Environmental Impact Assessment will also be required under NEMA before drilling and hydraulic
fracturing can commence. This will be a separate process which will follow the EMP submission. This is
further described in Chapter 11, Conclusions and Recommendations.
In addition, the applicant may also need to apply for various other licenses such as an Integrated Water Use
Licence or individual Water Use Licenses in terms of the National Water Act (NWA), and possibly the
National Heritage Resources Act 25 of 1999 depending on location of drilling sites and site specific technical
requirements such as water sources which cannot be determined at this time in the absence of known drilling
site locations.

Overview:
Shell Exploration Company B.V. (Shell) has submitted an exploration rights application for petroleum
products over three application areas as described in Chapter 1. Petroleum products include gas and
condensate, oil, natural gas and petroleum. Shells intent is to pursue exploration for unconventional natural
gas, but other petroleum products may be co-hosted in the targeted geological strata.
As a statutory instrument of environmental management, the Environmental Management Plan (EMP) which
Shell Exploration Company B.V. (Shell)) is required to submit, no later than 14 April 2011, in support of its
exploration rights application. This EMP is governed in the first instance by the Mineral and Petroleum
Resources Development Act 28 of 2002 (MRPDA). Other statutes, summarised in section 3.3, which
influence the EMP include the National Environmental Management Act 107 of 1998 (NEMA), the National
Environmental Management: Biodiversity Act 10 of 2004 (NEMBA), the National Environmental
Management: Waste Act 59 of 2008 (NEMWA), and the National Water Act 36 of 1998 (NWA)
Note that this EMP only supports an Exploration Right application. Approval of the EMP does not permit
Shell to undertake exploration borehole drillings, nor does it allow Shell to make a subsequent application for

24
This chapter is based on Golder’s interpretation of the legal context for this EMP. It is presented here in draft for comment.

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Production Rights. All these activities are subject to an independent regulator processes and approvals. The
outline of the statutory requirements regarding the EMP set out here applies to the Exploration Rights
application. This EMP does not constitute undertaking the Environmental Impact Assessment (EIA)
process/es which will be required, as discussed in Section 5 below.
The MRPDA sets out requirements for environmental provisions regarding an application for a petroleum
exploration application in section 79. This section in turn requires an EMP to be prepared following the
application, according to sections 79(4)(b) and 39(2) of the Act. Sections 39(3) of the MPRDA (as read with
section 69(2)(b) of the Act) as well as the sub regulations under regulation 52(2) of the MRPDA specify the
requirements to be met in the EMP. The NEMA also stipulates principles that must be considered by any
organ of state in any decision “which may have a significant effect on the environment”. Thus, the EMP must
demonstrably satisfy these principles.
In terms of section 103 of the MPRDA, the Minister has delegated her powers in respect of the consideration
of and issuing of applications for exploration rights to the Director General of Mineral Resources. Further, in
terms of section 70, the Minister has designated the South African Agency for the Promotion of Petroleum
Exploration and Exploitation (Pty) Ltd, known as the Petroleum Agency South Africa (Proprietary) Limited or
“PASA”, to perform the functions as set out in Chapter 6 of the Act. PASA therefore, amongst others
“promote, facilitate and regulate exploration and sustainable development of oil and gas” in South Africa. As
such it administers this application for an exploration right. However, the Director General, and not PASA, is
the authorising authority.
The EMP is to be submitted within 120 days of the notice of acceptance of the exploration right application
issued by PASA. This 120-day period elapses on 14 April 2011. The MPRDA does not allow for the
extension of this initial timeframe, but the Director General may call for additional information and may direct
that the EMP be adjusted as the Director General may require. As will be more fully explained below, this
EMP is also not the only vessel for assessment and authorisation of environmental aspects associated with
the proposed exploration activities.

3.1 NEMA
The NEMA also requires that an environmental authorisation be issued before the commencement of various
activities specified in terms of the NEMA regulations (GNR’s 544 and 545 of 18 June 2010). In the case of
Shell’s application, environmental authorisation will be required prior to commencement of any drilling and
hydraulic fracturing activity. There are several activities associated with the proposed gas exploration
activities that would require environmental authorisation prior to commencement of such activities,
irrespective of whether an exploration right has been granted by the Director General. Furthermore, an
environmental authorisation for any given activity may only be issued after Shell has complied with the
procedural requirements as set out in the regulations (GNR 543 of 18 June 2010), which once again requires
public participation. These procedures may involve a basic assessment or Scoping and EIA, depending on
the nature of the activity.

3.2 Background
Shell submitted an application for an Exploration Right in terms of the MPRDA to the Petroleum Agency of
South Africa (PASA) in December 2010. PASA accepted the application on 14 December 2010.
In accordance with Section 79(4) of the MPRDA, PASA notified Shell of the acceptance within the statutory
time limit of 14 days, which then initiated the process that led to the preparation of this EMP. The EMP is to
be submitted within 120 days from the date of notice, i.e. on or before 14 April 2011. The MPRDA does not
allow for an extension of this deadline.
In order to meet the 120-day deadline required by the MPRDA, the final EMP is to be submitted to PASA on
or before 14 April 2011 for consideration alongside the exploration right application for purposes of making

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recommendations to the Director General25 on the EMP and exploration right application. The Director
General in turn may call for additional information in respect of the EMP but has 120 days within which to
approve or reject the EMP. Should the Director General approve the EMP, the Director General may grant
or deny the exploration right depending on further considerations as set out in section 80(1) of the MPRDA.
The Exploration Right, if considered favourably, may be granted for a maximum initial period of three years.
It is assumed that this process of review and decision-making will take place during 2011.
Although the granting of an Exploration Right permits Shell to commence with exploration activities, certain
activities associated with exploration will require Shell to first obtain other regulatory approvals from the
relevant authorities prior to commencing with these activities. Such regulatory approvals include certain
environmental authorisations in terms of the NEMA, an Integrated Water Use Licence or individual Water
Use Licenses in terms of the National Water Act (NWA), the National Heritage Resources Act 25 of 1999 and
possibly authorisations in terms of the National Nuclear Regulator Act 47 of 1999 (NNRA), amongst others.

3.3 Mineral and Petroleum Resources Development Act


This act makes provisions for equitable access to and sustainable development of South Africa’s mineral and
petroleum resources. Petroleum is defined to include natural gas (see below).

3.3.1 Definitions – gas and petroleum


The definition of petroleum in the MPRDA refers to any liquid, solid, hydrocarbon or combustible gas existing
in a natural condition in the earth’s crust and includes any liquid or solid hydrocarbon or combustible gas,
which gas has in any manner been returned to such natural condition together with condensates of such
gas, but does not include coal, bituminous shale or other stratified deposits from which oil can be obtained by
destructive distillation or gas arising from a marsh or other surface deposit.
Gas means (as defined in the SI system of units) any hydrocarbon which at normal temperature and
pressure, is in a gaseous phase existing in a natural condition in the earth’s crust, regardless of the nature of
the host rock, and includes any gas which has in any manner been returned to such natural condition, and
includes condensate of such gas, but does not include hydrocarbon gas obtained.
The list of minerals (List 2) attached to the application forms for exploration rights contain inter alia the
following minerals: gas and condensate, oil, natural gas and petroleum. Since there is overlap in the
commodity definitions, Shell applied for all four minerals included in the type description of ‘petroleum and
gas’.

3.3.2 Overview of MPRDA


Chapter 2 - Fundamental Principles, section 6, Principles of administrative justice, provides that, subject to
the Promotion of Administrative Justice Act, 2000 (Act No. 3 of 2000), any administrative process conducted
or decision taken in terms of this Act must be conducted or taken, as the case may be, within a reasonable
time and in accordance with the principles of lawfulness, reasonableness and procedural fairness.
Sections 37 to 42 of the Act make provision for environmental management in prospecting and mining
operations.
Chapter 6, on Petroleum Exploration and Production, contains section 79, Application for exploration right,
which deals with environmental management requirements in the case of petroleum. Section 79(4) provides
that, once the application has been accepted, the applicant for an exploration right must notify and consult
with any affected party, and must submit an environmental management programme to PASA as the
designated authority, within 120 days from the date of notice. Section 79(4)(b) refers to an environmental
management programme, yet this should read an environmental management plan.,

25
In terms of section 103 of the MPRDA, the Minister has delegated her powers in respect of the consideration of and issuing of applications for exploration rights to the Director
General of Mineral Resources. Further, in terms of section 70, the Minister has designated the South African Agency for the Promotion of Petroleum Exploration and Exploitation
(Pty) Ltd, known as the Petroleum Agency South Africa (Proprietary) Limited or “PASA”, to perform the functions as set out in Chapter 6 of the Act. PASA therefore administers this
application for an exploration right. However, the Director General, and not PASA, is the authorising authority.

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The contents of an Environmental Management Plan (EMP) are prescribed in the MPRDA Regulations
(R527 of 2004) section 52(2) as well as section 39(3) of the Act, as shown below.
Contents of an Environmental Management Plan (EMP) as prescribed in MPRDA Regulations (R527
of 2004)

Regulation 52(2)

ƒ (2) An environmental management plan, must substantially be in the standard format provided by the
Department and must contain-

ƒ (a) a description of the environment likely to be affected by the proposed prospecting or mining
operation;

ƒ (b) an assessment of the potential impacts of the proposed prospecting or mining operation on the
environment, socio-economic conditions and cultural heritage, if any;

ƒ (c) a summary of the assessment of the significance of the potential impacts, and the proposed
mitigation and management measures to minimise adverse impacts and benefits;

ƒ (d) financial provision which must include-

ƒ (i) the determination of the quantum of the financial provision contemplated in regulation 54; and

ƒ (ii) details of the method providing for the financial provision contemplated in regulation 53;

ƒ (e) planned monitoring and performance assessment of the environmental management plan;

ƒ (f) closure and environmental objectives;

ƒ (g) a record of the public participation undertaken and the results thereof; and

ƒ (h) an undertaking by the applicant regarding the execution of the environmental management plan.

Section 39(3)
(3) An applicant who prepares an environmental management programme or an environmental management
plan must -
(a) establish baseline information concerning the affected environment to determine protection, remedial
measures and environmental management objectives;
(b) investigate, assess and evaluate the impact of his or her proposed prospecting or mining operations on -
(i) the environment;
(ii) the socio-economic conditions of any person who might be directly affected by the prospecting or mining
operation; and
(iii) any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of
1999), with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act;
(c) develop an environmental awareness plan describing the manner in which the applicant intends to inform
his or her employees of any environmental risks which may result from their work and the manner in
which the risks must be dealt with in order to avoid pollution or the degradation of the environment; and
(d) describe the manner in which he or she intends to -

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(i) modify, remedy, control or stop any action, activity or process which causes pollution or environmental
degradation;
(ii) contain or remedy the cause of pollution or degradation and migration of pollutants; and
(iii) comply with any prescribed waste standard or management standards or practices.
In Section 6, MRPDA affirms the principles of administrative justice:
6(1): Subject to the Promotion of Administrative Justice Act, 2000 (Act No. 3 of 2000), any
administrative process conducted or decision taken in terms of this Act must be conducted or
taken, as the case may be, within a reasonable time and in accordance with the principles of
lawfulness, reasonableness and procedural fairness.
Section 5 of MRPDA deals with the legal nature of prospecting right, mining right, exploration right or
production right, and rights of holders thereof as follows:
S 5 (3) Subject to this Act, any holder of a prospecting right, a mining right, exploration right or production
right may -
a) enter the land to which such right relates together with his or her employees, and bring onto that land any
plant, machinery or equipment and build, construct or lay down any surface, underground or under sea
infrastructure which may be required for the purpose of prospecting, mining, exploration or production, as
the case may be;
b) prospect, mine, explore or produce, as the case may be, for his or her own account on or under that land
for the mineral or petroleum for which such right has been granted;
c) remove and dispose of any such mineral found during the course of prospecting, mining, exploration or
production, as the case may be;

cA) subject to section 59B of the Diamonds Act, 1986 (Act No. 56 of 1986), (in the case of diamond) remove
and dispose of any diamond found during the course of mining operations;
d) subject to the National Water Act, 1998 (Act No. 36 of 1998), use water from any natural spring, lake,
river or stream, situated on, or flowing through, such land or from any excavation previously made and
used for prospecting, mining, exploration or production purposes, or sink a well or borehole required for
use relating to prospecting, mining, exploration or production on such land; and
e) carry out any other activity incidental to prospecting, mining, exploration or production operations, which
activity does not contravene the provisions of this Act.
In context of this application, Section 96 of the MPRDA as read with regulation 74 of the MPRDA regulations
provides that any person whose rights or legitimate expectations have been materially and adversely
affected by the decision of the Director General in this application may appeal in the prescribed manner to
the Minister of Mineral Resources within 30 days after he or she has become aware of the decision or should
reasonably become aware of the decision.

3.4 Other legislation


This section lists only the key other legislation applicable to environmental processes. There are others,
including international conventions, various provincial ordinances, local government regulations etc.

3.4.1 The National Environmental Management Act (Act 107 of 1998)


The National Environmental Management Act (NEMA), amongst others, provide for co-operative
environmental governance by establishing principles for decision-making on matters affecting the
environment.

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Chapter 1 of the Act stipulates national environmental management principles, which apply throughout the
Republic to the decisions of all organs of state that may significantly affect the environment. From this, it is
clear that the Director General must follow these principles in considering the application from Shell to
explore for gas in the Karoo.
These principles apply of course in total, but in the present context, the following ones are immediately
relevant:

ƒ “(1)(a) apply alongside all other appropriate and relevant considerations, the State’s responsibility to
respect, protect, promote and fulfil the social and economic rights in Chapter 2 of the Constitution;…

ƒ (1)(b) apply as serve as the general framework within which environmental management and
implementation plans must be formulated; and

ƒ (2) Environmental management must place people and their needs at the forefront of its concern, and
serve their physical, psychological, developmental, cultural and social interests equitably;

ƒ (4)(a) Sustainable development requires the consideration of all relevant factors including the following:

ƒ (i) That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they
cannot be altogether avoided, are minimised and remedied;

ƒ (ii) that pollution and degradation of the environment are avoided, or, where they cannot be altogether
avoided, are minimised and remedied;

ƒ (iii) that the disturbance of landscapes and sites that constitute the nation’s cultural heritage is avoided,
or where it cannot be altogether avoided, is minimised and remedied;

ƒ (i) The social, economic and environmental impacts of activities, including disadvantages and benefits,
must be considered, assessed and evaluated, and decisions must be appropriate in the light of such
consideration and assessment.

ƒ (k) Decisions must be taken in an open and transparent manner, and access to information must be
provided in accordance with the law.

ƒ (l) There must be intergovernmental coordination and harmonisation of policies, legislation and actions
relating to the environment.”

The MPRDA requires that that a risk-averse and cautious approach is applied in environmental
management, which takes into account the limits of current knowledge about the consequences of decisions
and actions (section 2(4)(a)(vii) of the NEMA as read with sections 37(1) and 69(2)(b) of the MPRDA). This
means that, assumptions underlying the EMP and uncertainties contained in assessments must be
considered in compiling the EMP.
In addition, the Director General, in considering the EMP and the exploration right application as a whole, is
bound by the legal principles of administrative decision making as set out in the Promotion of Administrative
Justice Act 3 of 2000.
Chapter 5 of NEMA provides for integrated environmental management. The purpose of this Chapter is to
promote the application of appropriate environmental management tools in order to ensure the integrated
environmental management of activities. The general objective of integrated environmental management as
including to:

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ƒ “(a) promote the integration of the principles of environmental management set out in section 2 of the
Act into the making of all decisions which may have a significant effect on the environment;

ƒ (b) identify, predict and evaluate the actual and potential impact on the environment, socio-economic
conditions and cultural heritage, the risks and consequences and alternatives and options for mitigation
of activities, with a view to minimising negative impacts, maximising benefits, and promoting compliance
with the principles of environmental management set out in set out in section 2

ƒ (c) ensure that the effects of activities on the environment receive adequate consideration before
actions are taken in connection with them;

ƒ (d) ensure adequate and appropriate opportunity for public participation in decisions that may affect the
environment.”

The NEMA also requires that an environmental authorisation be issued before the commencement of various
activities specified in terms of the NEMA regulations (GNRs 544 and 545 of 18 June 2010). There are
several activities associated with the proposed gas exploration activities that would require environmental
authorisation prior to commencement of such activities, irrespective of whether an exploration right has been
granted by the Minister of Mineral Resources. Furthermore, an environmental authorisation for any given
activity may only be issued after Shell has complied with the procedural requirements as set out in the
regulations (GNR 543 of 18 June 2010) which once again requires public participation. These procedures
may involve a basic assessment or Scoping and EIA, depending on the nature of the activity.
Table 2 and Table 3 list activities from GNRs 544 and 545 which would probably or possibly require EIAs
before such activities can commence as part of the exploration proposed by Shell, together with a
preliminary assessment of whether they would be applicable to the proposed exploration project. Of these,
item 4 of GNR 545 (Table 3) would be triggered for hydraulic fracturing during exploration. This would require
a scoping and EIA for an environmental authorisation before hydraulic fracturing may proceed.
Table 2: Possible listed activities from NEMA Listing notice 1 (GN R544) which could be triggered at various
stages in the gas development process 26
Applicability to proposed gas
GN R544 (require basic assessment)
exploration project

1. The construction of facilities or infrastructure for the This activity would only potentially
generation of electricity where: be triggered if gas from
exploration wells was used to
(i) the electricity output is more than 10 megawatts but less generate electricity.
than 20 megawatts; or

(ii) the output is 10 megawatts or less but the total extent of the
facility covers an area in excess of 1 hectare.
10.The construction of facilities or infrastructure for the This activity would only be
transmission and distribution of electricity …… triggered if sufficient electricity
was generated on site (see
(i) outside urban areas or industrial complexes with a capacity above), and transmitted and
of more than 33 but less than 275 kilovolts; distributed off site.
The nature and volume of

26
Note: The activities listed in Tables 1-3 that would be triggered by the proposed project will be confirmed subsequent to the site
selection process

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Applicability to proposed gas


GN R544 (require basic assessment)
exploration project

chemicals to be handled and


stored at individual drilling sites
13. The construction of facilities or infrastructure for the storage, will determine to what extent this
or for the storage and handling, of a dangerous good, where activity will be triggered
such storage occurs in containers with a combined capacity
of 80 but not exceeding 500 cubic meters.
22. The construction of a road, outside urban areas,
At this stage Shell plans to utilize
(i) with a reserve wider than 13.5 meters or existing roads and to choose drill
sites close to established roads
(ii) where no reserve exists where the road is wider than unless unavoidable.
8 meters.
24. The transformation of land bigger than 1 000 m2 in size, to
residential, retail, commercial, industrial or institutional use, Each drill site will be about 10,000
where, as the time of the coming into effect of the schedule m2 in size. The existing land use
such land was zoned open space, conservation or had an or zoning will also be a
equivalent zoning. determining factor

47. The widening of a road by more than 6 meters, or the


At this stage Shells plan to utilize
lengthening of a road by more than 1 kilometer -
existing roads and to choose drill
(i) where the existing reserve is wider than 13,5 meters; or sites close to established roads
unless unavoidable
(ii) where no reserve exists, where the existing road is wider
than 8 meters

Table 3: Possible listed activities from NEMA Listing notice 2 (GN R545) which could be triggered at
various stages in the gas development process (see also Table 2).
Applicability to proposed
GN R545 (requires scoping and EIA)
gas exploration project

4. The construction of facilities or infrastructure for the refining, This activity triggers a NEMA
extraction or processing of gas, oil or petroleum products with EIA
an installed capacity of 50 cubic metres or more per day,
excluding facilities for the refining, extraction or processing of
gas from landfill sites
5. The construction of facilities or infrastructure for any process or Water and waste management
activity which requires a permit or licence in terms of national or requirements may trigger this
provincial legislation governing the generation or release of activity.
emissions, pollution or effluent and which is not identified in
Notice No. 544 of 2010 or included in the list of waste
management activities in terms of Section 19 of the NEMWA in
which case that Act will apply.
21. Any activity which requires an exploration right or renewal This activity is not yet gazetted
thereof as contemplated in sections 79 and 81 respectively of but may be in the future.
the Mineral and Petroleum Resources Development Act, 2002
(Act No. 28 of 2002). [Commencement date of Activity 21: To be
published]

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Table 4: Possible listed activities from NEMA Listing notice 3 (GN R546) which could be triggered at
various stages in the gas development process (see also Tables 2 and 3).
Applicability to proposed
GN R546 (require basic assessment)
gas exploration project

2. The construction of reservoirs for bulk water supply with a


capacity of more than 250 cubic meters. In the
a) Eastern Cape, Northern Cape provinces …
(ff) Areas within 10 kilometers from national parks or world
heritage sites or 5 kilometers from any other protected area
identified in terms of NEMPAA or from the core area of a
biosphere reserve;
d) Western Cape
iii) all areas outside urban areas
At this stage Shell plans to
4. The construction of a road wider than 4 m with a reserve less utilize existing roads and to
than 13.5 m in choose drill sites close to
(a) Northern Cape Province established roads unless
unavoidable
(ii) outside an urban area ….
During the selection of
(bb) National Protected Area Expansion Strategy Focus area; …
possible drill sites, it will need
(cc) Sensitive areas as identified in an environmental management to be established whether road
framework as contemplated in chapter 5 of the Act and as construction or upgrade will be
adopted by the competent authority; necessary.

(ee) critical biodiversity areas as identified in systematic biodiversity


plans adopted by the competent authority or in bioregional
plans; …..
(gg) areas within 10 km from national parks or world heritage sites
or 5 km from any other protected area identified in terms of the
National Environmental Management: Protected Areas Act,
2003 or from the core areas of a biosphere reserve; and in the
(d) Western Cape
(ii) all areas outside urban areas.

10. The construction of facilities or infrastructure for the storage, or The nature and volume of
storage and handling of a dangerous good, where such storage chemicals to be handled and
occurs in containers with a combined capacity of 30 but not stored at individual drilling
exceeding 80 m3 in sites will determine to what
(a) Northern Cape Province extent this activity will be
triggered
(ii) outside urban areas, in
(bb) National Protected Area Expansion Strategy Focus area;
(ee) critical biodiversity areas as identified in systematic biodiversity
plans adopted by the competent authority or in bioregional
plans;

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Applicability to proposed
GN R546 (require basic assessment)
gas exploration project

(gg) areas within 10 km from national parks or world heritage sites


or 5 km from any other protected area identified in terms of the
National Environmental Management: Protected Areas Act,
2003 or from the core areas of a biosphere reserve; and in the
(e) Western Cape in
(ii) all areas outside urban areas.
12.The clearance of an area of 300 m2 or more of vegetation where
75% or more of the vegetative cover constitutes indigenous
vegetation within (b) critical biodiversity areas identified in
bioregional plans.
13. The clearance of an area of 1 ha or more of vegetation where
75% or more of vegetative cover constitutes indigenous
vegetation in critical biodiversity areas and ecological support
areas as identified in systematic biodiversity plans adopted by
the competent authority;
a) CBA’s and ecological support areas as identified in systematic
biodiversity plans adopted by the competent authority

b) National Protected Area Expansion Strategy Focus areas; and


c) In the Eastern Cape, Northern Cape and Western Cape
ii) outside urban areas, in

bb) National Protected Area Expansion Strategy Focus area;


cc) Sensitive areas as identified in an environmental management
framework as contemplated in chapter 5 of the Act and as
adopted by the competent authority
ee) core areas in biosphere reserves;
ff) areas within 10 km from national parks or world heritage sites or
5 km from any other protected area identified in terms of the
NEM: Protected Areas Act, 2003 or from the core areas of a
biosphere reserve.
14.The clearance of an area of 5 hectares or more of vegetation
where 75% or more of the vegetative cover constitutes
indigenous vegetation, except where such vegetation is required
for;
i) All areas outside urban areas.

19. The widening of a road by more than 4 metres, or the


lengthening of a road by more than 1 kilometre.
cc) Sensitive areas as identified in an environmental management
framework as contemplated in chapter 5 of the Act and as
adopted by the competent authority;
gg) Areas within 10 kilometres from national parks or world heritage

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Applicability to proposed
GN R546 (require basic assessment)
gas exploration project

sites or 5 kilometres from any other protected area identified in


terms of NEMPAA of from the core area of a biosphere reserve;
c) In Western Cape
ii). All areas outside urban areas.

26. Phased activities for all activities listed in this Schedule and as
it applies to a specific geographical area, which commenced on
or after the effective date of this Schedule, where any phase of
the activity may be below a threshold but where a combination
of the phases, including expansions or extensions, will exceed a
specified threshold.

3.4.2 National Environmental Management: Biodiversity Act (Act 10 of 2004)


The purposes of the National Environmental Management Biodiversity Act, 2004 (NEMBA) (Act 10 of 2004)
include to provide for:

ƒ the management and conservation of South Africa's biodiversity within the framework of the National
Environmental Management Act, 1998;

ƒ the protection of species and ecosystems that warrant national protection; and

ƒ the sustainable use of indigenous biological resources and the fair and equitable sharing of benefits
arising from bioprospecting involving indigenous biological resources.

NEMBA in Chapter 3, on Biodiversity Planning and Monitoring, provides for the preparation and adoption of
the National Biodiversity Framework, the determination of bioregions and the publication of bioregional plans.
NEMBA provides further for adoption, coordination and alignment of biodiversity plans and biodiversity
management agreements, amongst others. Any existing statutory instruments for biodiversity protection and
management which may have been adopted in terms of this chapter must be taken into account during the
implementation of any exploration activities as well as during assessments for authorisations in terms of
additional legislation such as, for instance, environmental authorisations in terms of the NEMA.
Furthermore, should Shell be granted the exploration right, all consequent EIAs would be governed by these
biodiversity instruments, and would be activities in the EIA list where threatened ecosystems are involved.

Further provision is made for protection of threatened or protected ecosystems and species as well as
provisions guarding against the introduction of alien and invasive species. The Act identifies restricted
activities involving listed threatened, protected or alien species. These activities include picking parts of, or
cutting, chopping off, uprooting, damaging or destroying, any specimen of a listed threatened or protected
species. As stipulated in Section 57 of the Act, a person may not carry out a restricted activity involving a
specimen of a listed threatened or protected species without a permit issued in terms of Chapter 7. Lists of
critically endangered, endangered, vulnerable and protected species have been published in GNR 151 of 23
February 2007. Regulations have also been promulgated on Threatened and Protected Species in GNR 152
of 23 February 2007. These lists and associated restricted activities as well as the regulations need to be
taken into account during the implementation of any exploration activities as well as during assessments for
authorisations associated with the exploration activities in terms of other legislation.
Application may be made for a permit to engage in restricted activities, which application may be subject to
various stringent requirements as set out in section 88 of the NEMBA.

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3.4.3 National Environmental Management: Waste Act (Act 59 of 2008)


The National Environmental Management: Waste Act (NEMWA) came into effect on 1 July 2009. Section 19
of the NEMWA provides for listed waste management activities and states in Section 19(1) that the Minister
may publish a list of waste management activities that have, or are likely to have a detrimental effect on the
environment. Such a list was published in GN 718 of 03 July 2009 (GN 718) identifying those waste
management activities that require a Waste Management Licence in terms of the Act.
In terms of section 20(b) of the NEMWA, any person who wishes to commence, undertake or conduct a
waste management activity must first obtain a waste management licence issued in respect of that activity.
The licensing procedures in terms of the NEMWA once again makes use of the procedural provisions as set
out in GNR 543 of 18 June 2010 in terms of the NEMA (i.e. procedural regulations regarding environmental
impact assessments) and either a Basic Assessment or Scoping and EIA procedure, both incorporating
public participation, must be followed before the issuance of a waste management license will be considered
by the relevant authority.
This NEMWA however does not apply to, amongst others:

ƒ (a) radioactive waste that is regulated by the Hazardous Substances Act. 1973 (Act No. 15 of 1973). the
National Nuclear Regulator Act, 1999 (Act No. 47 of 1999), and the Nuclear Energy Act, 1999 (Act No.
46 of 1999); and

ƒ (b) residue deposits and residue stockpiles that are regulated under the Mineral and Petroleum
Resources Development Act, 2002 (Act No. 28 of 2002).

Before any exploration activities commence which may generate waste, an assessment as to the
applicability of the relevant provisions of the NEMWA will need be made and if so required, any requisite
waste management licenses applied for and procured prior to the commencement of any waste management
activity which requires licensing.

3.4.4 National Water Act (Act 36 of 1998)


The National Water Act (NWA) includes provisions requiring that a water use license be issued by the
Department of Water Affairs before Shell engages in any activity defined as a water use in terms of the
NWA. The development of the EMP proceeded in cognisance of the relevant NWA provisions, and the
concerns expressed by I&APs during the process.
Water use in terms of the NWA, section 21, includes:

ƒ a) taking water from a water resource;

ƒ b) storing water;

ƒ c) impeding or diverting the flow of water in a watercourse;

ƒ e) engaging in a controlled activity

ƒ f) discharging waste or water containing waste into a water resource …;

ƒ g) disposing of waste in a manner which may detrimentally impact on a water resource;

ƒ i) altering the bed, banks, course or characteristics of a watercourse;

ƒ j) removing, discharging or disposing of water found underground if it is necessary for the efficient
continuation of an activity or for the safety of people.

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Should Shell proceed with exploration, its several points of water use may each need licensing for water use,
to be secured through applications for individual or Integrated Water Use licences, as may be required by the
Department of Water Affairs.
Public and private interests regarding water use are protected in the NWA through the provisions in section
27, Considerations for issue of general authorisations and licences. This section provides as follows:

ƒ 1) In issuing a general authorisation or licence a responsible authority must take into account all
relevant factors, including--

ƒ a) existing lawful water uses;

ƒ b) the need to redress the results of past racial and gender discrimination;

ƒ c) efficient and beneficial use of water in the public interest;

ƒ d) the socio-economic impact--

ƒ i) of the water use or uses if authorised; or

ƒ ii) of the failure to authorise the water use or uses;

ƒ e) any catchment management strategy applicable to the relevant water resource;

ƒ f) the likely effect of the water use to be authorised on the water resource and on other water users;

ƒ g) the class and the resource quality objectives of the water resource;

ƒ h) investments already made and to be made by the water user in respect of the water use in question;

ƒ i) the strategic importance of the water use to be authorised;

ƒ j) the quality of water in the water resource which may be required for the Reserve and for meeting
international obligations; and

ƒ k) the probable duration of any undertaking for which a water use is to be authorised.

The EMP has proceeded in the knowledge that potential risks to water resources and from wastewater that
may arise from the proposed gas exploration would be mitigated by the provisions of the National Water Act,
while at the same time providing foresight in this respect.

3.4.5 Astronomy Geographic Advantage Act (Act 21 of 2007)


The Astronomy Geographic Advantage Act (AGA) serves to provide for the preservation and protection of
areas within the Republic that are uniquely suited for optical and radio astronomy. The Act provides for the
declaration of several categories of Astronomy Advantage Areas, and the management and control of such
areas. The purposes of the declaration of areas as astronomy advantage areas are to:

ƒ (a) ensure that the geographic areas in the Republic which are suitable for astronomy and related
scientific endeavours due to, among other things, atmospheric transparency, low levels of light
pollution, low population density or minimal radio frequency interference are protected, preserved
and properly maintained;

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ƒ (b) enhance the existing geographic advantage of those areas highly suitable for astronomy and
related scientific endeavours through the restriction of activities that cause or could cause light
pollution or radio frequency interference or interfere in any other way with astronomy and related
scientific endeavours or astronomy advantage in those areas; and

ƒ (c) provide for the management of those areas in the public interest and in accordance with good
national and international practices.

The Act provides for the declaration of core astronomy advantage areas, to, among other things, provide
protection from light pollution, radio frequency interference and other activities which may affect astronomy
and related scientific endeavours or astronomy advantage to an area in which radio or optical astronomy is
conducted or will be conducted. Government Notice No. 82 of 5 February 2009, the Declaration of Areas as
Astronomy Advantage Areas in South Africa, prescribes the areas of all the land within the Northern Cape
Province within 250 km of the centre of the South African Large Telescope (SALT) dome, as well as the
whole of the territory of the Northern Cape Province, excluding the Sol T Plaatje Municipality, for radio
astronomy purposes, to be an Astronomy Advantage Area. This is called the Karoo Central Astronomy
Advantage Area.
Government Notice 1092 of 2010 applies to the core astronomy advantage areas declared in the
Government Gazette NO.33462 under Notice No.723 on 20 August 2010, and declares as follows:

ƒ (1) The core astronomy advantage area containing the Southern African Large Telescope (SALT); and

ƒ (2) The core astronomy advantage area containing the MeerKAT radio telescope and the core of the
planned Square Kilometre Array (SKA) radio telescope.

These prescriptions would govern the conditions of any gas exploration right in the Central Precinct.

3.4.6 National Nuclear Regulator Act (Act 47 of 1999)


It is possible that certain residues generated during exploration activities may contain some levels of
radioactivity which may be subject to the provisions of the National Nuclear Regulator Act (NNRA).
Amongst others, the NNRA provides for safety standards and regulatory practices for protection of persons,
property and the environment against nuclear damage. Specifically, should any material derived from
exploration activities have the potential to cause any injury to or the death or any sickness or disease of a
person or the potential to cause other damage, including any damage to or any loss of use of property or
damage to the environment due to ionizing radiation, Shell will be required to obtain a certificate of
registration in terms of section 22(1) or a certificate of exemption in terms of section 22(3)(b)(ii) of the NNRA,
depending on various circumstances. The authorisation process and conditions will ensure that any such
activity will be safe to the public and the environment.
Where any activity associated with exploration may require any authorisation in terms of the NNRA, an
assessment to that effect will need to be made and the necessary authorisation obtained.

3.4.7 Strategic environmental assessment and Environmental Management


Frameworks
There is no statutory requirement for strategic environmental assessment in South Africa. However, NEMA
provides for the development of procedures for the assessment of the impact of policies, plans and
programmes. In addition, a requirement related to SEA in the context of spatial planning is referred to in the
Municipal Planning and Performance Management Regulations of 2001 (Chapter 2, section 2(4)(f)),
promulgated in terms of the Municipal Systems Act No 32 of 2000), and in The White Paper on Spatial
Planning and Land Use Management, produced by the Ministry of Agriculture and Land Affairs in 2001
(Section 3.2).

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South African principles for SEA are contained in the Guideline Document: Strategic Environmental
Assessment in South Africa.
In effect, the Environmental Management Framework incorporates many of the principles of the SEA. The
Environmental Management Framework Regulation of 2010 in terms of NEMA prescribe requirements in this
respect. in section 2. (1) The purpose of this Part is to provide—

ƒ (a) for the Minister or MEC with concurrence of the Minister to initiate the compilation of information
and maps referred to in section 24(3) of the Act specifying the attributes of the environment in
particular geographical areas;

ƒ (b) for such information to inform environmental management; and

ƒ (c) for such information and maps to be used as environmental management frameworks in the
consideration, as contemplated in section 24(4)(b)(vi) of the Act, of applications for environmental
authorisations in or affecting the geographical areas to which those frameworks apply.

ƒ (3) Environmental management frameworks are aimed at─

ƒ (a) promoting sustainability;

ƒ (b) securing environmental protection; and

ƒ (c) promoting cooperative environmental governance

ƒ 4. A draft environmental management framework must—

ƒ (a) identify by way of a map or otherwise the geographical area to which it applies;

ƒ (b) specify the attributes of the environment in the area, including the sensitivity, extent,
interrelationship and significance of those attributes;

ƒ (c) identify any parts in the area to which those attributes relate;

ƒ (d) state the conservation status of the area and in those parts;

ƒ (e) state the environmental management priorities of the area;

ƒ (f) indicate the kind of developments or land uses that would have a significant impact on those
attributes and those that would not;

ƒ (g) indicate the kind of developments or land uses that would be undesirable in the area or in specific
parts of the area;

ƒ (h) indicate the parts of the area with specific socio-cultural values and the nature of those values;

ƒ (i) identify information gaps;

ƒ (j) indicate a revision schedule for the environmental management framework; and

ƒ (k) include any other matters that may be specified.

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4.0 EXISTING ENVIRONMENT – THE KAROO


This section provides a description of the existing environment associated with the Central Precinct. Most of
the information provided below is based on desktop studies. A thorough baseline will be carried out as part
of the full Environmental Impact Assessment (EIA) in the vicinity of each of the proposed well site locations
to:

ƒ Inform and guide the site selection process;

ƒ Inform and guide site specific design, construction and operations at well sites, access roads and any
other areas of activities;

ƒ Inform and guide the development of restoration plans; and

ƒ Provide a benchmark against which any potential impacts can be assessed and monitored, including
the level of success of restoration.

4.1 Geology
A description of the geology was derived through a thorough desktop study of available published resources
at a: high (Karoo basin) and regional (Precinct) level. Field verification of the precinct was then undertaken to
gain a firsthand overview of the geological setting, to support the desk study information.
For more detailed information regarding the geology, refer to the groundwater report in Volume 2.

4.1.1 High Level Geology: Karoo Basin


The Main Karoo Basin has been controlled and shaped by four major geodynamic events (Woodford 2002):

ƒ Deposition of the Karoo sediments and the uplift of the Cape Fold Belt,

ƒ Intrusion of Karoo basalt and dolerite,

ƒ Intrusion of Kimberlite and localised mantle up-welling,

ƒ Modern geomorphology, deposition of recent sediments, uplift, cessation of regional tectonics.

The present day Main Karoo Basin is in-filled with sedimentary strata which are capped by a 1.4 km thick unit
of basaltic lava. Major lithostratigraphic units of the Karoo Supergroup are shown in Figure 9 and Figure 10.
The horizontal strata provide a capping to the shale gas reservoirs present at depths between 1 500 m and
4 500 m depth and protection to the overlying groundwater aquifers. The various lithologies making up the
stratigraphic units of the Karoo sequence include the: Dwyka Group, Ecca Group, Beaufort Group, Molteno
Formation, Elliot Formation, Clarens Formation and Dolerite Intrusives.
The structural pattern is dominated by an E – W and NNW – SSE trends. Faults and fractures have been
infilled by dolerite dykes some of which continue over 500 km.

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12800-002

S MAIN KAROO BASIN N


George

Lesotho
Johannesburg
Cape Fold Belt
Tarkastad Subgroup
Adelaide Subgroup

Drakensberg Group
Molteno, Elliot, Clarence Fms Karoo
Beaufort Group Super km
Ecca Group Group 5
4
Dwyka Group
3
Witteberg Group
Cape 2
Bokkeveld Group Super 1
Table Mountain Group Group 0
Pre-Cape rocks 0 50 100 km
Not to Scale

Figure 9: Cross Section of the Main Karoo Basin (reproduced from Woodford 2002)

12800-006

Legend:
Basalt
Johannesburg
260S Sandstone and subordinate Mudrock/Rhythmite Vryheid Fm
Mudrock/Rhythmite and subordinate Sandstone Vryheid Fm Dwyka
Mudrock/Rhythmite Gp
Carbonaceous Shale
Diamictite Volksrust
0
Exploration Application Area Fm
28 S
Prince Albert Fm
m
tF
Bloemfontein lio
El Dwyka
Gp
Drakensberg
t
Dwyka Gp or Gp Durban
B Tierberg Fm uf
ea Gp
B
Prince Albert Fm
310S Pietermaritzburg
e
ECCA id p d
Whitehill Fm la u ta p Fm
Gp

Tierberg Fm Gp de gro as u Clarens Fm


A b a rk gro
a

Camarvon Su T ub
Ecc

Fm S Volksrust Fm
Molteno Fm
Koedoesbers Fm Dwyka Gp
Skoorsteenberg Fm Burgersdorp Fm
Kookfontein Fm Balfour Fm
Beaufort West Katberg Ripon Fm
320S
Middleton Fm Katberg, Burgersdorp
Fm
A Balfour Fm
Katberg Fm
Collingham Fm Fort Brown Fm C Koonap Fm Fort Brown Fm
Laingsburg Fm Waterford Fm
D Ripon Fm
Whitewhill Fm
Prince Albert Fm Vischkuil Fm Port Elizabeth Collingham Fm
Cape Town Whitehill Fm ECCA Gp
340S Prince Albert Fm
100 0 100 200 km
Dwyka Gp

190E 210E 230E 250E 270E 290E 310E

Figure 10: Schematic Aerial Distributions of Lithostratigraphic Units in the Main Karoo Basin (reproduced from Woodford
2002)

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4.1.2 Regional Geology: Central Precinct


The regional geology setting of the Central Precinct is discussed with reference to the 6 maps (Maps C1 to
C6) presented in the groundwater report in Volume 2.

4.1.2.1 Lithology
The geology shown in Figure 11 was compiled using the simplified geology of South Africa (DWA) with the
dolerite sills and dykes obtained from the published 1: 250 000 scale geological maps superimposed on the
map. The main Karoo sediments that outcrop in the precinct include the sediments comprised of the
Adelaide and Tarkastad Subgroups of the Beaufort Group. A small part of the north and NW of the precinct
is underlain by sediments of the Ecca Group.

ƒ The Adelaide Subgroup covers the large majority of the Central Precinct and comprises predominantly
mudstone. They are underlain by the Ecca Group. The Teekloof Formation is characterised by a greater
relative abundance of red mudstone compared to the underlying and overlying units, in practise the
boundaries are linked to specific sandstone-rich marker units (members). The arenaceous Poortjie and
Oudeberg Members constitute the base of the Teekloof and Balfour Formations, respectively. In the
western basin the Abrahamskraal and Teekloof Formations attain thicknesses of 2,500 and 1,400 m,
respectively. The Balfour Formation attains a maximum thickness of 2,000 m.

ƒ The Tarkastad Subgroup is present in the far eastern portion of the precinct north and east of Bieu-
Bethesda (Figure 11). This subgroup is characterised by a greater abundance of both sandstone and
mudstone when compared to the Adelaide Subgroup. The subgroup has a maximum thickness of
2,000 m and comprises a lower, sandstone rich Katberg Formation and an upper, mudstone rich
Burgersdorp Formation. An example of typical sandstone is shown in Figure 12.

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B.V

Figure 11: Regional Geology – Central Precinct.

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The precinct is characterised by horizontal to quasi horizontal strata.


The scene of horizontally bedded sandstone and shale depicted in
Figure 13 is typical of the geological setting throughout the precinct.
The horizontal bedding gives rise to the wide expansive landscape
of flat to gently undulating plateaux as shown in Figure 14.
Dolerite sills and dykes occur in abundance in the northern and
central parts of the precinct. The dolerite intrusions represent the
main targets for groundwater exploration. The high ridges and
inselbergs which characterise large parts of the precinct are the
result of erosion resistant dolerite forming cappings to these
features, as illustrated in Figure 15.
Figure 12: Massive Sandstone
The locations of four deep core boreholes are indicated on Figure
11. Two are located within the Central Precinct boundary (AB1 and
KA1) and two (VR1 and CR1) are located outside and to the south-
east of the precinct boundary. These boreholes are all located
along a similar stratigraphic horizon with largely reduced presence
of dolerite intrusion to the south of these boreholes.

Regional Structure
The distribution of intruded dykes in the Main Karoo Basin forms
three major structural domains, namely the Western, Eastern and
Transkei-Lesotho-Northern Karoo Domains, (Woodford 2002). The
Western Karoo Domain extends from Calivinia to Middelburg, and Figure 13: Characteristic horizontal
bedding
covers the entire Central Precinct area. It is characterised by two
distinctive structural features:

ƒ E-W Dyke Intrusions


Some of these dykes are extensive and continue over 500 km. They
were intruded along major lateral E-W dislocation/shear zones and
are accompanied by NW and NE trending sympathetic shears.

ƒ NNW Dyke Intrusions


These are also extensive and are regularly spaced from east to
west across the domain. The trend of these dykes varies along the
trajectory, curving from WNW in the south to NS in the north. Figure 14: Characteristic Expansive
Landscape with dolerite capped range of
Only limited fault zones are indicated on the published 1:250 000 hills
scale geological maps of the precinct. These zones have similar
trends to the dykes and form part of the Western Karoo Domain.

4.2 Climate
Climatic data was taken from the South African Weather Service
(SAWS) summary of 1984 (WB40, 1984).

4.2.1 Local Temperature


The monthly variation of dry bulb temperatures for 2010 is shown in
Table 6. The average temperature daily is 25.2°C, which could be
described as temperate. The temperature also appears to rarely fall
below 0°C, however extreme cold temperatures of -5.6°C have Figure 15: Inselberg, dolerite capping
been recorded. Table 5 is a summary of historical dry bulb and dyke
temperature measurements made at Beaufort West.

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Table 5: Long-term annual average temperature and relative humidity statistics (WB40, 1984)
Dry bulb temperature (°C) Relative Humidity (%)
Site Daily Extreme
08h00 14h00 20h00
Average Minimum Maximum Minimum Maximum
Beaufort 4.7 32.2
25.2 -5.6 42 62 29 39
West (July) (January)

Table 6: Monthly dry bulb temperature statistics for 2010


Beaufort West
Month
Min (°C) Ave (°C) Max (°C)
Jan 11.3 24.2 39.2
Feb 3.4 24.7 39.4
Mar 10 22.6 36.4
Apr 4.8 18.6 35.9
May 1.5 16.3 28.1
Jun 0.7 12 27.9
Jul 0 13.5 27
Aug 0.2 15.8 32.5
Sep 2.7 16.7 35.1
Oct 6.2 17.1 34.2
Nov 9.1 20.9 36.2
Dec 9.7 21 36.8

4.2.2 Precipitation
The daily rainfall data for eight rain gauges in the precinct were extracted (Kunz, R, 2004) and analysed.
These eight rain gauges were chosen due to their long historical record and their proximity to the site area.
The locations of the rain gauges are shown in the surface water report in Volume 2. The data was analysed
to determine the rainfall depths for the different recurrence interval 24 hour storms (Smithers and Schulze,
2003) as well as the MAP, minimum, average and maximum monthly rainfall depths. The results of the
analysis are given in Table 7 and Table 8.
This area falls in the arid region of South Africa where the potential evaporation far exceeds the mean
annual rainfall (MAP). The mean annual Symons pan evaporation ranges from 1 800 mm to 2600 mm and
the MAP from 100 mm to 500 mm (WRC, 1994).
The results given in the tables highlight the following:-

ƒ The MAP in the precinct is low ranging from 205 mm to 284 mm.

ƒ The rainfall is one of extremes. There are years where there is no rainfall as shown by the minimum
average monthly rainfall depths and other years where there is significant rain fall as shown by the
maximum average monthly rainfall depths.

ƒ The area is prone to droughts and hence surface water availability is not reliable;

ƒ The rainfall is seasonal with the majority of the rainfall falling between October and May.

ƒ The area can receive significant 24 hour rainfall depths as shown by the 50 year, 100 year and 200
year 24 hour rainfall depths. The area will be subject to flooding.

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Table 7: MAP, Monthly Average, Maximum and Minimum monthly rainfall depths
MAP (mm) Monthly Minimum, average and maximum rainfall depths (mm/month)
Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep
Sterling (0140616_W) 205.6 Average 13.0 18.6 18.3 21.5 29.5 43.3 20.5 13.5 5.7 5.5 8.0 8.3
Maximum 48.4 137.8 78.9 116.2 177.0 211.6 95.2 97.3 23.8 41.0 79.7 85.4
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Rheboksfontein (0141066_W) 216.9 Average 12.5 21.1 19.0 21.4 34.8 39.8 26.6 11.9 7.0 7.4 8.5 6.7
Maximum 62.5 93.0 96.0 114.8 248.0 164.0 96.5 62.5 46.0 40.6 86.0 47.5
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Nelspoort (0093070_W) 204.7 Average 13.7 18.1 20.2 19.2 29.3 41.6 21.7 11.0 5.3 6.8 9.0 8.8
Maximum 112.3 137.2 82.1 105.4 117.2 142.1 104.1 55.5 33.8 57.4 86.5 98.9
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Kampferskraal (0093074_W) 217.9 Average 16.6 23.3 21.5 19.8 27.9 40.4 21.3 12.2 6.1 7.8 10.7 10.4
Maximum 86.5 119.0 109.5 108.5 156.0 184.0 127.0 72.0 37.5 49.0 92.0 104.1
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Bakensrug (0093314_W) 218.4 Average 16.0 24.6 24.1 19.7 30.4 33.5 20.5 14.4 7.5 8.5 8.7 10.5
Maximum 76.5 137.7 160.5 120.5 200.3 161.7 109.5 79.5 48.0 54.5 106.7 75.2
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Murraysburg (0117447_W) 267.2 Average 16.1 29.5 26.1 26.3 39.1 46.1 26.0 18.2 9.0 10.3 10.1 10.4
Maximum 85.4 124.7 147.7 145.8 210.8 150.1 121.2 101.6 42.0 63.0 104.4 75.3
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Doornbosch (0095123_W) 372.3 Average 28.2 35.1 32.3 35.0 47.0 57.1 33.3 30.6 16.4 17.9 21.2 18.3
Maximum 145.9 175.1 130.0 190.8 150.0 198.1 115.3 136.5 70.0 102.6 193.5 162.0
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Quaggasdrift (0095006_W) 384.4 Average 26.9 35.4 32.8 35.5 52.1 60.7 39.3 31.0 16.7 17.3 19.6 17.2
Maximum 127.0 211.6 139.4 150.5 166.4 174.5 152.1 150.3 82.8 80.5 140.1 96.2
Minimum 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

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Table 8: The 2, 5, 10, 20, 50, 100 and 200 year return period 24-hour rainfall depths (mm/month)
Return Period (years)
Rain Gauge
2 5 10 20 50 100 200
Sterling (0140616_W) 243 29.8 42.1 50.8 59.6 71.7 81.4
Rheboksfontein (0141066_W) 235 38.8 54.8 66.1 77.6 93.3 105.7
Nelspoort (0093070_W) 226 35.1 49.3 59.4 69.6 83.5 94.6
Kampferskraal (0093074_W) 219 34.5 48.5 58.5 68.5 82.2 93.1
Bakensrug (0093314_W) 218 34.5 48.6 58.5 68.5 82.3 93.2
Murraysburg (0117447_W) 257 33.3 47.0 56.5 66.2 79.4 90.0
Doornbosch (0095123_W) 407 45.2 63.7 76.7 89.8 107.8 122.0
Quaggasdrift (0095006_W) 411 48.4 68.1 82.1 96.0 115.3 130.5

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4.2.3 Wind Speed and Direction


Figure 16 shows a summary of the wind conditions at Beaufort West. Wind roses comprise 16 spokes,
which represent the directions from which winds blew during the period. The colours reflect the different
categories of wind speeds; the grey area, for example, representing winds of 1 m/s to 2 m/s. The dotted
circles provide information regarding the frequency of occurrence of wind speed and direction categories.
For the current wind roses, each dotted circle represents a 5 % frequency of occurrence. The value given in
the centre of the circle described the frequency with which calms occurred, i.e. periods during which the wind
speed was below 1 m/s.

Figure 16: Wind roses for Beaufort West

It should be noted that Beaufort West falls just outside the study area towards the southwest. The effect of
the topographical barrier that shelters the study area towards the north would not be shown by this figure.
Instead, it is expected that the southerly wind components may be less pronounced. Nonetheless, it is
believed that the prevailing easterly wind would be similar to the conditions in the study area. Furthermore,
the strong westerly winds are also expected to occur in the study area. Low occurrence of calm wind
conditions are also illustrated with these observations.

4.2.4 Microclimate
Microclimates are dictated by the local topography. As shown in Figure 17, the most significant rise in
topography is towards the southern sector. It is expected that these mountain ranges would determine the
prevailing wind conditions to a great degree. Southerly winds would mostly be sheltered. This would only
apply to the area south of the 32° latitude. North of this latitude, the relatively flat terrain will have no
significant impact.

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Figure 17: Major topographical features in the Central Precinct

4.2.5 Extreme Weather Conditions


The Central Precinct is fairly protected against extreme weather conditions. Potential extreme weather
conditions for the central region are noted below:

ƒ The study area is not located on a hurricane track or adjacent to a warm ocean. Therefore it is not
expected that the site will experience a hurricane, or at least there is a very low probability.

ƒ It is important to note the difference between a hurricane and hurricane force winds. The latter refers to
a wind speed scale called the Beaufort Scale, where hurricane force winds are those with speeds
above 118 km/h. This likelihood of this wind speed being exceeded (excluding the occurrence of
tornadoes) has an estimated likelihood of about 0.1 per annum.

ƒ No evidence of tornadoes could be found for the study area. This risk of tornadoes occurring in the
study area is considered to be 1 x 10-7 per year.

ƒ A new Lightning Detection Network (LDN) recently (2006) set up by the SAWS in South Africa reports
that the study area experiences between 1 (western portion) and 5 (north-eastern portion) lightning
flashes per year per km².

4.3 Topography
4.3.1 High Level Topography: Karoo Basin
The Main Karoo Basin covers the greater part of the central region of South Africa. Surface altitudes range
from 800 to 3 650 mamsl. Altitudes are highest in the east decreasing gradually as the surface slopes to the
west. The generally flat to undulating topography is broken by the up-warped plateau edges and the
escarpment, most prominent in the Drakensberg region.
The topography is heavily influenced by the underlying geology of alternating sequence of horizontally
bedded sandstone, siltstone, shale, rhythmite and mudstone of Karoo age, combined with dolerite sills and
dykes. The sequence is over 5 000 m thick. These lithologies are intruded by dolerite sills and dykes. The
horizontal bedding gives rise to the characteristic Karoo landscape of expansive plains formed on siltstone or

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sills, low ridges following sandstone outcrops and high ridges and inselbergs where dolerite sills form
resistant cappings (see photographs in Figure 13 - Figure 15).

4.3.2 Regional Level Topography: Central Precinct


According to Mucina and Rutherford (2006) the majority of the Central Precinct can be described as flat with
gently sloping plains, interspersed with hills and rocky outcrops. The altitude generally varies between
1 000 mamsl and 1 700 mamsl. The area is further characterised by discrete areas of slopes and ridges
including dolerite dykes and sills, in these areas altitude varies between 1 000 mamsl and 1 900 mamsl. The
Central Precinct is bordered to the south by the steeper slopes of the Great Escarpment.
Dolerite sill and ring-complexes are often prominent features of the Karoo landscape. These structures are
easily recognized on satellite images, where they often display a sub-circular saucer-like shape, the rims of
which are commonly exposed as topographic highs forming ring-like outcrops.
Topography forms an integral part of the environment and affects surface drainage, microclimates, soil
formation and ecology. Each of these elements is discussed in more detail separately.

4.4 Soil
Spatial information from the Golder GIS database was used to create three overlays for the Central Precinct
including the 1:1 000 000 Geology map for South Africa, a general soil pattern map for South Africa and
topographical background based on the digital terrain model (DTM) data.
An overlay of the soil classes over the precinct (Figure 18) displayed the following five soil classes of
significance:

ƒ Soils with minimal development (Lithosols);

ƒ Rock outcrops with limited soils;

ƒ Structured soils with marked clay accumulation;

ƒ Soils on alluvial deposits; and

ƒ Red soils with high base status.


A brief description of these soils is given in the sections that follow. More detailed information can be
obtained in the soil report in Volume 2.

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Figure 18: Soil classes of the Central Precinct

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4.4.1 Lithosols on the Beaufort sediments


The Lithosols cover a large area of the precinct, stretching in an east- west band over the centre of the
project area and covering large parts in the west of the project area. Soils in this class are derived from in-
situ weathering of Beaufort Group sediments and have undergone minimal development. These soils are
light coloured, usually shallow (<300 mm) in profile and interface directly with hard or weathering rock
(including the elliptic zones). Lime is often present in the soil profile.
No information for this specific soil class could be obtained from the National Land Type Survey database,
however, the characteristics will be similar to the Lithosols of the Central Precinct (Golder 2011). These soils
displayed fine-grained loamy sand to sandy loam textures, massive structure and soft to slightly firm
consistency when moist often containing a small amount of angular gravel and low organic content typical of
the semi-arid region. Chemically, these soils have alkaline pH, often resulting from elevated concentrations
of calcium in the form of carbonates. In agricultural terms the soils are consider of poor quality that are at
best useful as grazing lands.

4.4.2 Rock outcrops with limited soils


Rock outcrops with limited soils are in abundance over the precinct. This soil unit can be described as
manifesting in-between rock outcrops and/or overly rock at shallow to moderate depths. These soils are
associated with dolerite or Beaufort sediments. Soil characteristics are similar to the Lithosols when in
association with the Beaufort sediments but tend to be more reddish in colour and of heavier texture when
derived from the dolerite. These areas are perceived to have low agricultural potential due to their shallow
nature and rocky surfaces.

4.4.3 Structured soils with marked clay accumulation


In the Central Precinct, soils with marked clay accumulation occur mainly in association with the Beaufort
sediments but are at times associated with dolerite. When the soils are derived from Beaufort sediments they
are greyish to brownish in colour. When the soils are of dolerite origin the soils can have relatively high
magnesium and iron content which impart a strong red colour.
The texture of these soils may vary between sandy clay loam and sandy clay. Chemical profiles of the soils
(Land Type Survey Staff, 1972-2003) indicate highly basic pH and high base status in the sub layer, while
the topsoil is sandy with significantly lower base status. Chemically, dolerite derived soils are perceived as
being more fertile than the soils from the Beaufort sediments.  
The strong structure encountered in this soil class indicates poor drainage capability, which in turn, may lead
to issues for storage and rehabilitation of these soils. Erosion and compaction will be of importance when
management measures are considered. Soils from this class are associated with low agricultural potential.

4.4.4 Soils on alluvial deposits


This soil class is associated with riverbeds and drainage ways and are mainly present in the flatter
topography or wide valleys. They are present in the south and southwest of the precinct. These alluvial soils
can have varying depths and marked differences in textural characteristics. These soils can be associated
with large water courses and are therefore of importance in the context of the predominately dry surrounding
catchment. Rivulets and rocky streambeds serve to channels water from mountainous areas and usually
comprise rocky banks and shallow soils overlying rock and are associated with steeper landscape.

4.4.5 Red soils with high base status


Red soils with high base status constitute 20% of the most south-western of the precinct. The soil profile is
typically sandy in texture with an imbalance of calcium and magnesium, which may indicate a potential risk
for instability. Base status is not in the same order compared to the Lithosols and clay soil classes, which
can ascribed to the lower contents of calcium pH is basic and organic carbon content is low, as can be
expected for this sparsely vegetated region with low precipitation.
Soil from this soil class is perceived as having high agricultural potential soils as they usually present
favourable depth. Depth ranges are not provided in the available soil information but a typical profile (Land
Type Survey Staff, 2006) located in this class, indicates a depth of 0.5 m for the subsoil. The seemingly
adequate depth may raise expectations of a moderate agricultural potential, but given the semi-arid setting,

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development of the profile at depth is very slow. It is therefore anticipated that depth of this soil class in this
particular region will not be favourable for agricultural utilisation.

4.5 Terrestrial Ecology


A literature survey was conducted in order to determine which, if any, areas within the greater exploration
area are regarded as ecologically sensitive. A list of potential occurring species in each of the potential
drilling areas was obtained through databases and a literature study of relevant publications. The list of
species was then cross referenced with the IUCN database (IUCN, 2010) and the national and provincial
Threatened or Protected Species (TOPS) lists (NEMBA, 2007) in order to determine the probability of Red
Data or protected species occurring within the area.
The fieldwork component of the ecological assessment involved a ground truthing exercise, which served to
determine whether or not the data collected during the literature review is correct, at a broad scale level. This
exercise also served to identify biodiversity sensitivities which will need to be taken into account when
selecting drilling sites in future.
The result of the ecological assessment are summarised below. For details, refer to the ecology report in
Volume 2.

4.5.1 Vegetation
4.5.1.1 High Level Vegetation: Biomes
Biomes can be defined as the major communities of the world, classified according to their predominant
vegetation and characterised by adaptations of organisms to that particular environment. The single most
important factor influencing the biomes in South Africa is the weather and, more specifically, the rainfall.
Important factors to be taken into account with regard to the weather and its influence on the biomes of
South Africa are:
ƒ The western parts of the country are much drier than the east;
ƒ Rainfall occurs in winter in the west, but in summer in most other regions; and
ƒ Temperatures in the mountains and on the Highveld are more extreme than along the coast.
As shown in Figure 19 the Central Precinct is comprised of Nama Karoo and Grassland Biomes, these are
described in more detail in the ecology report in Volume 2.

4.5.1.2 Regional Level Vegetation: Types in the Central Precinct


4.5.1.2.1 Vegetation Types
According to Mucina and Rutherford (2006) the Central Precinct encompasses eight vegetation types
namely:
ƒ Upper Karoo Hardeveld NKu2
ƒ Gamka Karoo NKl1
ƒ Eastern Upper Karoo NKu4
ƒ Southern Karoo Riviere AZi6
ƒ Eastern Lower Karoo NKl2
ƒ Northern Upper Karoo NKu3
ƒ Karoo Escarpment Grassland Gh1
ƒ Besemkaree Koppies Shrubland
The coverage of these vegetation units for the Central Precinct is shown in Figure 20, and discussed in more
detail in the ecology report in Volume 2.

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Figure 19: Biomes in which the exploration area occurs

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Figure 20: Vegetation communities occurring in the Central Precinct

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The vegetation of the Central Precinct grades quickly between Karoo, Grassland and Thicket Biomes. Some
typical photos of the vegetation in the area are shown in Figure 21 to Figure 24.

Figure 21: Photograph taken in the Gamka Karoo vegetation type near Nelspoort

Figure 22: Photograph taken in the Southern Karoo Riviere vegetation type near Three Sisters

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Figure 23: Photograph taken in the Eastern Upper Karoo vegetation type near Victoria West

Figure 24: Photograph taken in the Upper Karoo Hardeveld vegetation type near Murraysburg

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4.5.1.2.2 Plant species diversity


The PRECIS (National Herbarium Pretoria (PRE) Computerised Information System (CIS)) data for these
grid squares returned 753 plant species known to occur in these grid squares. Of these species, 24 are
considered rare or are listed as Red Data species (according to IUCN (IUCN, 2010) and TOPS (NEMBA,
2007) lists); species overlap considerably between vegetation types and vegetation communities. Refer to
the ecology report in Volume 2 for a list of red data species.

4.5.2 Animal life


Well over 400 fauna species are known to occur in the Central Precinct of the study area. Of these species
four are of particular concern due to their Red Data status and limited distribution ranges:

ƒ Blue Crane, Grus paradiseus (see Figure 25);

ƒ Mountain Zebra, Equus zebra;

ƒ White-tailed Mouse, Mastomys albicaudatus;

ƒ Riverine Rabbit Bunolagus monticularis; and

ƒ Karoo Rock Sengi, Elephantulus pilicaudus.

The species with the highest distribution in the Central


Precinct include the Riverine Rabbit and Blue Crane. For
more detailed information, refer to the ecology report in
Volume 2.

4.5.2.1 Reptiles Figure 25: Blue Crane, Grus paradiseus.


According to Branch (1996) less than 50 reptile species are
known to occur within the Central Precinct. Five reptilian species were recorded in the Central Precinct
surveys (see the ecology report in Volume 2 for details). None of the recorded species are classified as Red
Data Species. It is likely that more species could occur in the area but, but due to the shy nature of the taxon
it is usually impossible to record all species in an area during a study of limited time.

4.5.2.1.1 Amphibia
No frog species were recorded during the study in the Central Precinct area, and therefore no Red Data or
protected species were recorded. Amphibian species may occur in seasonal rivers which occur in the area
and may occupy the wetlands in the area, these will however be unsuitable as drilling sites and therefore it is
unlikely that any amphibian species will be affected by the exploration activities. Aquatic species such as
Xenopis sp usually occur in man-made dams in the area and drinking troughs occurring on the farms in the
area.

4.5.2.1.2 Avifuana
Approximately 350 species of birds are known to occur in the area in which the Central Precinct is situated,
some of which are endemic to the area. Thirty species were found to occur within the study area during the
time of the study (see list in the ecology report in Volume 2). Of the bird species known to occur in the study
area, 14 are listed as Red Data species, of the 30 recorded species, only the Kori Bustard, Ardeotis kori (VU)
was listed as a Red Data species. Kori Bustards were common species in the northern part of the Central
Precinct, Victoria West and Rietfontein sites.

4.5.2.1.3 Small mammals


Three hundred and ninety-nine mammal indigenous mammal species occur in Southern Africa, of these
species about 54 species historically occur in the region in which the study area occurs. Of the 54 historically
occurring species in the area, 19 species are locally extinct. Mammal species diversity was assumed to be
moderate to low in the study area, with only seven species being recorded (see list in the ecology report in
Volume 2). The reasons for the low mammalian species diversity may be due to degradation of habitat in

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the study area due to anthropogenic impacts such as grazing, and the fact that some species have been
persecuted historically. None of the species recorded were listed as Red Data species or considered
protected species.

4.6 Surface water


The surface water is described in the following sections on the basis of a desktop study and review of
available information. A more detailed surface water report is attached in Volume 2.

4.6.1 Relevant River Systems


The Central Precinct falls mainly in the Northern Cape Province but also in the Western Cape Province and
the Eastern Cape Province. In the Northern Cape Province, the Central Precinct falls into the Ongers, Brak
and Seekoei River Catchments which form part of the Orange River Catchment which enters the sea on the
border of South Africa and Namibia. Of these rivers, only the Seekoei and the Orange Rivers are perennial.
In the Western Cape Province, the Central Precinct falls into the Sout, Buffels and the Kariega River
Catchments, which form part of the Groot River Catchment and then the Gamtoos River Catchment which
enters the sea in the Eastern Cape Province. Of these rivers, only the Groot and the Gamtoos Rivers are
perennial. In the Eastern Cape Province, the Central Precinct falls into the Gats and Kamdeboo River
Catchments which form part of the Sondags River

4.6.2 Relevant Drainage Areas


The Central Precinct falls in the secondary drainage areas D6 and D3 in the Northern Cape Province,
secondary drainage areas L1 and L2 in the Western Cape Province secondary drainage area N1 in the
Eastern Cape Province (WRC, 1994). This area falls in the arid region of South Africa where the potential
evaporation far exceeds the mean annual rainfall (MAP). The mean annual Symons pan evaporation ranges
from 1800 mm to 2600 mm and the MAP from 100 mm to 500 mm (WRC, 1994).

4.7 Groundwater
This baseline description of the hydrogeology of the Central Precinct is based upon a desk study of available
data, supported by brief field verification. Available reports and data for groundwater boreholes obtained
from the National Groundwater Data Base (NGDB) of the Department of Water Affairs (DWA) have provided
a large volume of information which has been used to prepare this regional overview of the groundwater
situation. The more detailed groundwater report is available in Volume 2.

4.7.1 High Level Groundwater: Karoo Basin


The Karoo lithologies are characterised by very low primary porosity and permeability, <0.1% to <0.02%.
Deep holes (up 5550m) drilled by SOEKOR in the late 60’s confirmed that the permeabilities of the
sandstone/siltstone are very low, and vary from 0.00 – 2 m/d for Beaufort strata and 0.00 – 0.1m/d for Ecca
strata. Overall the deep core logs have confirmed that the vast majority of the deep Karoo sequence is
composed of tight and cemented strata.
Weathering and fracturing within the Karoo rocks provides secondary porosity and permeability. This zone
controls the presence of groundwater and groundwater is widespread in the upper 50m and to a lesser
extent the upper 100m of the geological profile. An analysis of fracture frequency struck in boreholes shows
that the highest number of fractures are present with 10m of the water level, and reduces rapidly once below
50m. This confirms the majority of groundwater is present within 50 – 100m of ground surface.

The study has indicated:

ƒ The depth of groundwater supply boreholes is mostly <150m, with the vast majority of boreholes (92%
of 1756 records) reportedly <100m deep.

ƒ Sustainable borehole yields are between 0.5 and 2 l/s over most of the precinct. An area around
Victoria West has yields of 2 – 5l/s and a small area in the SW of the precinct NE of Beaufort West is
characterised by yields of >5l/s.

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ƒ Groundwater levels are generally shallow with 91% of reported levels <20m (1712 records) confirming
that the groundwater resources are driven by rainfall recharge.

ƒ Groundwater quality is variable but mostly potable. 82% of water is Class 0 or 1 (SANS 241, 2005) and
only 4.4% reported as Class 3 or 4 (2356 records).

ƒ Groundwater is widely used for domestic, livestock watering and occasional irrigation. Registered
annual water use is almost entirely agricultural (15.785Mm3) with a small registered domestic
component of 0.243Mm3.

ƒ Groundwater occurrence is controlled by the presence of secondary permeability associated with


weathering and fracturing.

ƒ The contact zones of dolerite dykes often represent linear aquifers and are an important target for the
drilling of water supply boreholes.

4.7.2 Regional Level Groundwater: Central Precinct


The distribution of intruded dykes in the Main Karoo Basin forms three major structural domains, namely the
Western, Eastern and Transkei-Lesotho-Northern Karoo Domains, (Woodford 2002). The Western Karoo
Domain extends from Calivinia to Middelburg, and covers the entire Central Precinct area. It is characterized
by two distinctive structural features:

ƒ E-W Dyke Intrusions; and

ƒ NNW Dyke Intrusions.

Only limited fault zones are indicated on the published 1:250 000 scale geological maps of the precinct.
These zones have similar trends to the dykes and form part of the Western Karoo Domain.

4.7.2.1 Groundwater Occurrence and Borehole Yield


The hydrogeology shown in MAP C2 (see the groundwater report in Volume 2) was compiled from the
published hydrogeological map series at 1:500 000 scale by DWA, dated 1996 to 2003. MAP C2 indicates
that the Central Precinct is dominated by the fractured aquifer type. The borehole yield prospect for a large
portion of the precinct is between 0.5 to 2.0l/s. This increases to 2 – 5l/s around Victoria West and exceeds
5l/s in the SW corner of the precinct NE of Beaufort West.
An area of intergranular and fractured aquifer types is shown to be present in the north eastern portion of the
precinct. The borehole yield in this area mainly has a range between 0.5 to 2.0 l/s although smaller areas of
intergranular and fractured flow are identified throughout the precinct with yields ranging from 0.1 to 0.5l/s.

4.7.2.2 Borehole Drilling Depth


The borehole distribution and drilling depths presented in MAP C3 (see the groundwater report in Volume 2)
were compiled from the NGDB borehole database of DWA, dated 2008. The boreholes are unevenly spread
throughout the precinct. It is nonetheless expected that groundwater is widely used in the precinct.

Information on the drilling depths of 1756 boreholes is available. The depth ranges have been categorised
into 5 depth intervals summarized in Table 9 below.
Table 9: Summarised drilling depths in the precinct
Depth Range (metres) Total number of records Percentage of Total
0 – 50 1101 62.7
50 – 100 558 31.8
100 – 150 38 2.2
150 – 200 11 0.6
200 – 300 48 2.7

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The drilling depths in the precinct indicate that less than 6 per cent of the boreholes abstract water from
depths in excess of 100 metres. The records also show that no water supply boreholes have been drilled
deeper than 300m. The 48 borehole listed above as having been drilled to depths of between 200 and 300
metres relate to deeper exploration drilling by DWA to investigated dolerite ring structures.

4.7.3 Depth to Water Level


The depth to groundwater levels has been compiled from the NGDB borehole database from DWA, dated
2008, and is depicted in Map C4 (see the groundwater report in Volume 2) and summarised in Table 10.
The depth ranges were categorised in 7 depth intervals.
The distribution of water level depths indicates that shallow water level conditions of <20m are generally
(~91%) present throughout the precinct. This indicates that sustainable groundwater exploitation relies
mainly on recharge from rainfall and the storage potential of the aquifer at shallow depths.
Table 10: Summarised depths to water level in the precinct
Depth Range (metres) Total number of records Percentage of Total
0 – 10 1023 59.8
10 – 20 541 31.6
20 – 30 133 7.8
30 – 82 7 0.4
50 – 75 7 0.4
75 – 100 1 0.1

4.7.4 Water Quality (EC)


The electrical conductivity (EC) data presented in (Map C5 of (see the groundwater report in Volume 2) was
compiled from the Water Quality Management System (WQMS) database from DWA, dated 2008. This
information has been plotted on the published EC zone map of DWA.
Information on the electrical conductivity of water from 2356 boreholes is available. The EC ranges have
been categorized in 5 water quality classes as used by DWA. These intervals are depicted in Map C5 and
summarized in Table 11 below.
Table 11: Distribution of water quality (EC) in the precinct
EC Range (mS/m) Total number of records Percentage of Total
0 – 70 Class 0 810 34.4
70 – 150 Class 1 1126 47.8
150 – 370 Class 2 317 13.5
370 – 520 Class 3 37 1.6
>520 Class 4 66 2.8

The distribution of the EC indicates that potable water suitable for domestic use (Class 0 and Class 1) is
largely (82.2 %) available throughout the precinct. Approximately 14% of the water is brackish (Class 2) and
4.4% can be classified as saline (Class 3 and 4) and unsuitable for human consumption.

4.7.5 Registered Water Use


The water use sector is listed for all registered water use on the Water Authorization and Registration
Management System (WARMS) maintained by DWA. Two water use sectors, agriculture (stock watering and
irrigation) and domestic comprise the main water users in the Central Precinct. The annual water use

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registration for these sectors has been categorized in 5 volume intervals and the use distribution is
presented in MAP C6 (see the groundwater report in Volume 2). The annual registered groundwater use for
the precinct is summarised Table 12 below:
Table 12: Registered agricultural and domestic use in the precinct
Water Use Sector Number of Users Annual Use (million m3)
Domestic 63 0.243
Agriculture (Stock and Irrigation) 465 15.785

The total annual agricultural use is 15.785 million m3. The domestic use by municipalities is possibly not all
registered and outdated.

4.7.6 Field Verification


Groundwater use is almost entirely for agriculture, mostly stock watering and for homestead supply. The use
of wind pumps may indicate limited abstraction capacity since the average yield of the wind pumps is usually
0.3l/s and therefore a maximum daily volume of around 26m³ can be achieved.
Farm homesteads are often supplied by 3 - 5 windpumps. These are commonly located on the margins of
dolerite dykes and/or sills. Some homestead supply boreholes are equipped with electrical submersible
pumps, as shown in Figure 26.

Figure 26: Homestead Water Supply Boreholes equipped with Submersible Pump and Windpump

The site visit provided the opportunity to verify the regional geological setting, particularly in respect to the
occurrence of groundwater.

ƒ As noted above, the area is characterised by quasi- horizontal strata. This is important to the gas
exploration programme since the horizontal strata provides a capping and protection to the shale gas
reservoirs present at depths between 1 500m and 4 500m depth.

ƒ Dolerite sills often form capping to hills, due to their increased resistance to weathering and erosion

ƒ The wide expansive plains are controlled by the horizontal bedding and are formed on dolerite sills or
siltstone horizons

ƒ Groundwater occurrence is mostly controlled by the presence of dolerite dykes, where the fractured
contact zones with the country rock offer enhanced permeability, with the upper contact zones of
dolerite sills where these are relatively shallow, fracture zones and weathering and fracturing of
sandstone, siltstone and shale where these strata form topographic lows, along drainage lines for
example.

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Specific verification of groundwater usage, groundwater levels and groundwater quality will be undertaken
during the EIA in the area of the proposed gas exploration drilling sites, once potential site(s) for the drilling
of the gas exploration well(s) are selected. An EIA for each site(s) is required prior to commencing any
drilling. This is further discussed in Section 8.

4.8 Air quality


According to the current understanding of the air quality in South Africa (DEA 2009a), the air concentrations
of nitrogen dioxide in rural regions, such as the study area, are likely to be in the range 0.5 parts per billion
(ppb) to 4.5 ppb. Similarly, the expected sulphur dioxide air concentrations would be between 0.5 ppb and
2.5 ppb (DEA 2009a). The DEA (DEA 2009a) recommends a background inhalable particulate
concentration of 16.39 µg/m³, based on observations made north of Port Elizabeth in the Eastern Cape.
Due to the agricultural activities, daily average inhalable particulate concentrations are therefore expected to
be about 20 µg/m³ or less. Air concentrations of volatile organic compounds, such as benzene are expected
to be very low (less than 2 ppb for benzene and less than 10 µg/m³ for combined volatile organic
compounds) (DEA 2009a).
The study area has a low level of industrial activity. The only identified sources of significant air pollution are
the current farming activities. These emissions are mainly airborne particulates. Commercial activities,
albeit relatively small, vehicular exhausts and domestic use of wood and coal in Victoria West, Murraysburg
and Beaufort West may result in elevated combustion pollutants such as carbon monoxide, sulphur dioxide,
oxides of nitrogen and particulates. The use of solvents and fuel (mainly petrol) evaporation would also
result in some volatile organic compounds (VOC) emissions.

4.9 Visual aspects


4.9.1.1 Sense of Place / Genius Loci
According to Lynch (1992), sense of place is "the extent to which a person can recognise or recall a place as
being distinct from other places, as having a vivid or unique, or at least particular character of its own". Thus,
sense of place means that a site has a unique character that distinguishes it from other places. The primary
informant of these qualities is the spatial form and character of the natural landscape together with the
cultural transformation associated with historic use and habitation.

4.9.1.2 Aesthetic Appeal


On the basis of contemporary research by
Crawford (Crawford, 1994), landscape
quality increases when:

ƒ Topographic ruggedness and


relative relief increase.

ƒ Where water forms are present.

ƒ Where natural landscapes increase


and human-made landscapes
decrease. Figure 27: Typical vista of a flat Karoo Plain with flat capped dolerite
hills.

ƒ Where land use compatibility


increases and land use edge diversity decreases.
The area within which the central district occurs is characterised by vast landscapes, distinct topography
(see Figure 27), geological features and mostly scarce or hardy vegetation communities (as shown in Figure
21 to Figure 24). The latter is distinctly typical of the Karroo and in many parts, responsible for much of the
visual character, especially during blooming time in spring and early summer. The majority of the area is arid
and water is scarce, resulting in a landscape that can be harsh and challenging. Yet watercourses have
been fundamental in shaping the landscape and streams and water bodies do occur; and where they do, are

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prominent or important features. For the aforementioned reasons, the application area can be considered to
have a strongly defined sense of place and is generally characterised by high levels of aesthetic appeal, a
fact which will be taken into consideration when specific sites for prospecting are selected.

4.9.1.3 Visual Absorption Capability


Visual absorption capacity (VAC) describes the capacity of the landscape to absorb development without
creating a significant change in visual character or producing a reduction in scenic quality (Oberholzer,
2005). The ability of a landscape to absorb development
or additional human intervention is primarily determined
by the vegetation cover (see Figure 28), topographical
landforms and existing human structures. A further
major factor is the degree of visual contrast between the
proposed new project and the existing elements in the
landscape.
The Central Precinct is mostly characterised by sparse
or very low vegetation cover due to the arid climate. The
topography is distinct and often appealing, and
numerous prominent if highly eroded landforms occur
almost throughout. The landscape is an intricate network
Figure 28: Wide open plains with little vegetation
of erosion lines and watercourses that snake through cover.
between these landforms, which means that the depth of
views varies considerably. The Karoo and southern
interior of the country is also famous for its expansive landscapes, where human intervention is in little
evidence. The result of the aforementioned factors is that the VAC of the landscape varies somewhat,
especially as a result of the varying topographical conditions. Nevertheless the VAC is generally still low
throughout, meaning that extensive development will be highly noticeable.

4.9.1.4 Visibility
Visibility describes the degree to which elements present in the landscape are actually seen by people in the
area. This aspect is again a function of the topography, land cover and level of development of the location
in which the development will occur. As has been established, the Central Precinct is situated on a highly
eroded plateau, punctuated by distinct landforms. The result is that the depth of views are often somewhat
limited where these visual obstructions occur, preventing long-range views. Nevertheless significant large
low-lying areas with gently sloping topography also occur and many of the higher-lying locations allow views
over vast distances. T

4.9.1.5 Light pollution at night


Light pollution at night is one of the most noticeable impacts of development on rural areas. “Light-spill” is
caused when non-directional lighting methods are indiscriminately applied and can be particularly intrusive,
especially in an area renowned for its star-gazing and spectacular night skies.

4.10 Noise
The baseline description of the noise climate is based on a desktop review that has been verified by
fieldwork in a number of potential drilling site locations. As the exact location of drilling sites is not known, a
number of sites that represent typical drilling locations were sampled to determine the baseline noise
climates. A more detailed noise report is attached Volume 2.

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Figure 22: Baseline noise measuring locations.

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The desktop study found that the noise climate at all potential sites is typical of remote rural areas as defined
by the relevant National Standard, SANS 10183, and are likely to be below the recommended levels of
45 dB(A) during the day (06:00 to 22:00) and 35 dB(A) at night (22:00 to 06:00). This was confirmed by
fieldwork, with the noise climate at the majority of sites being dominated by natural sounds of birds, insects
and the rustling of vegetation in the wind. Only the site located ~100m from the N12 road outside Victoria
West was the noise climate dominated by the sounds of a main road in a rural area.
Once the drilling sites have been selected, baseline noise levels will be measured comprehensively at the
property boundary of the ultimately selected drilling sites, with measurement points chosen to represent the
wider noise climate and, where appropriate, at the position around the property boundary at which the noise
emission is expected to be greatest, or which is nearest to a sensitive receptor.

4.11 Archaeology / cultural heritage / palaeontology aspects


A preliminary desktop exercise to identify potential heritage resources within the Central Precinct was
undertaken. As part of the exercise, a survey of the literature pertinent to the region, including
archaeological, anthropological and historical sources, was conducted. The report is attached in Volume 2.
A brief description of the archaeology and history of the area is given in the sections below to describe the
context of the archaeological and historical environment in which the proposed exploration activities will be
undertaken. This information has been extracted from the heritage report attached in Volume 2 which can
be consulted for more detailed information.

4.11.1 Pre-colonial Archaeology


The results of the desktop survey indicated that the following cultural heritage resources occur in the Central
Precinct:

ƒ Isolated scatters of stone tools on the plains, some rock painting sites in the mountains of the
Camdeboo, and freshwater shell middens containing bone, stone tools, and food remains along river
banks, pans and flood plains.

ƒ More than 16 000 Stone Age sites were recorded during a 30 year period by Professor Garth Sampson
and his students in the Upper, Middle and Lower Seacow River area.

ƒ The SARADA data base of rock art indicates that rock paintings and engravings occur at various
localities within the Central Precinct. Perhaps the best known site is the rock engravings at Nelspoort
near Beaufort–West. This site has recently been developed for tourism purposes. Rock art has been
recorded on four other farms near Beaufort-West, at sixteen different localities in the greater Richmond
area, at two farms near Murraysburg, at two farms near Nieu Bethesda, and at one locality near Victoria
West (Van Riet-Lowe 1941).

ƒ Archaeology of pastoralist occupation of vast areas in the Karoo are indicated by various stone kraal
complexes of which several hundred have been recorded in the Zeekoe River Valley.

ƒ A number of old graveyards and possibly historic buildings belonging to the early Trekboer period on
various farms in the area.

ƒ Another notable feature of the area is the corbelled houses that developed as a vernacular architecture
of the northern Karoo and “Bushmanland” districts during the nineteenth century. The majority of these
occur near Williston and Carnavron in the Western Precinct. However, some do occur near Beaufort-
West in the Central Precinct and one has been declared provincial heritage site.

ƒ Other declared Provincial Heritage Sites include:


ƒ Twelve historical buildings in Beaufort-West
ƒ The old powder magazine at Murraysburg
ƒ Two declared provincial heritage sites at Noupoort. These include a blockhouse from the Anglo-
Boer War and a church building.
ƒ One historical building declared as a provincial heritage site at Victoria-West. Ninety other
histiorical sites, mostly homesteads, are listed on the SAHRA register as occurring in this town.

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ƒ Two historical buildings declared as provincial heritage sites at Richmond. Sixty three other
historical sites, mostly homesteads, are listed on the SAHRA register as occurring in this town.
4.11.2 Local tourist attractions
The first would-be settlers arrived in this region during the mid-1700s. But these pioneers posed a great
threat to the Bushmen’s way of life and they retaliated by making life so difficult for the newcomers that most
left within a short time. Towards the end of the 18th century, an effort was once again made to begin farming
in this area, but it took until the mid-1800s before men were able to settle here. The settlement history of the
area, which is punctuated with conflict during the Anglo-Boer War, manifests itself in the settlements in the
area, some of which have their origins as fortified outposts or settlements.
Natural attractions abound in the area, many of which occur in nature reserves and parks. The Three Sisters
Mountains, near the town of Murraysburg, are one such feature. The region also abounds in evidence left by
its original inhabitants, the peoples collectively known as “Bushmen”. Engravings near Nelspoort are one
such example, the "bushman piano's" - stone gongs whose exact purpose has been lost in the annals of time
– another. Near Leeufontein the exposed the skeleton of a tiny man buried in a sitting position, is another
tantalising relic left by these people. Investigations by archaeologists revealed that he was an early hunter-
gatherer who probably once lived with a group at a nearby natural fountain.
The Northern Cape Province is the largest, but also least and most sparsely populated Province in the
country. Due to the arid conditions, the largest part of the region is dominated by expansive livestock (mostly
goat and sheep) farming and localised irrigated agricultural activity only occurs in areas where viable water
sources are available. However in spite, or perhaps because of its largely agrarian and under-developed
character, the region has developed a burgeoning tourism trade, with a multitude of attractions being
present. Apart from the rich cultural-historic heritage, the area is popular as a backpacking and scenic detour
road trip destination, with a variety of hiking, cycling, camping and adventure sports attractions. Guesthouses
abound in the region and star-gazing is a popular attraction in the region, owing to the clear night skies and
lack of light pollution.
In essence a substantial part of the regional economy is therefore dependent on the tranquil, timeless
character and development must be done circumspectly to ensure that that this way of life is not impacted
upon.
4.11.3 Palaeontology / archaeology
The Central Precinct occurs within the central western extent of the Karoo Basin, one of the few basins
worldwide in which the terrestrial fossil record for the 45-million-year interval spanning the Permian/Triassic
(P/Tr) Boundary is preserved and exposed. The Karoo Basin provides an ideal site for scientists to collect
fossils illuminating the Permian/Triassic Boundary that was marked by the greatest mass extinction during
the last 600 million years of Earth history (Smithsonian Museum of Natural History, 2011). The application
area occurs within an area characterised by rocks dating from the Permian and Triassic Eras and the Karoo
has over the years yielded a number of significant fossil finds that are on display in numerous museums
throughout the region. It is therefore possible that fossils may be encountered during exploration drilling
activities. If and when this occurs, qualified specialists will be consulted to ensure that this precious aspect of
our natural heritage is protected.
4.11.4 Cultural landscapes and sense of place
As no field surveys have been undertaken at this stage it is difficult to establish whether specific areas could
be described as cultural landscapes. Nevertheless, the landscape of the Central Precinct can be described
as a remote arid landscape and its visual qualities linked to the undulating topography and undisturbed
nature of the landscape. The only intrusions are existing transmission lines, scattered homesteads, wind
pumps, and access roads. These contribute to the rural landscape. “There is a perceived sense of absence
of human intervention or intrusion” (Patrick et al. 2009), the vast empty expanses exemplifying the qualities
of the Karoo.
The historic town of Graaff-Reinett situated to the immediate south of the Central Precinct would be an ideal
candidate for nomination as a cultural landscape. This scenic town harbours almost 200 provincial heritage
sites – more than any other town in South Africa (Oberholster 1972). These are mostly historic buildings
belonging to the 19th century period, however, the town is also situated in the mountain shadows of the
Camdeboo National Park – an area that contains various San hunter-gatherer and Khoekhoen pastoralist

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archaeological sites as well as rock art. The scenic natural heritage site of the “Valley of Desolation” is also
situated within this Provincial Park. Various memorials and monuments relating to the Khoisan genocide,
Voortrekker leaders, Anglo-Boer War, and the more recent struggle history of South Africa are located in and
around this town. Although not strictly situated within the borders of the Central Precinct it does indicate the
potential that may exist for similar cultural landscapes in areas less well surveyed and documented within the
study area.
A possible extension of the cultural landscape of Graaf-Reinett would be the Sneeuberge (Snow Mountains)
the mountainous area immediately to the north of the town and well situated within the Central Precinct of
the study area. Not only is the Sneeuberge a prominent physical marker on the landscape of the Eastern
Karoo but it is an important icon in the sad history of the now extinct Karoo San. For many decades this
area functioned as the last stronghold of the San. At one point San resistance here was so effective against
colonial expansion that it effectively halted Trekboer movement for almost 30 years (Penn 2003; Adhikari
2010). The Sneeuberg and adjacent areas contain numerous Later Stone Age sites associated with San
settlement of the central interior. The Seacow River area alone contains around 16 000 sites (Sampson
1985). This is more than any other area of comparable size in southern Africa. Here, as well as elsewhere in
the larger Sneeuberg area are numerous San rock painting and engraving sites. Some spectacular
examples occur on the farm Ganora not far from the little town of Nieu Bethesda, itself an interesting village
filled with historical buildings and ambiance. Although not inhabited ny Khoekhoen pastoralists in historical
times there is archaeological evidence for their occupation of the area during wetter climatic epochs such as
during the so-called Little Ice Age around 1400 AD. Old buildings and graves relating to early Trekboer
history occur on various farms in the area (Van Schalkwyk & Wahl 2007). In addition, the area contains
numerous palaeontological sites. However, there is a need to compile a thorough inventory of heritage sites
in this area and that can only happen once ground surveys have been initiated.

4.12 Sensitive landscapes


4.12.1 Terrestrial Ecology
The Central Precinct infringes on the Karoo National Park to the west and the Sakrivier and Kromrivier
Riverine Rabbit conservancies to the north-west. It is recommended that these areas are avoided during the
exploration.
Rehabilitation in this area will be very difficult due to climatic and vegetation conditions, rainfall is low and
erratic, therefore any vegetation planted during rehabilitation will need to be watered in order for it to survive.
The difficulty in rehabilitation further stresses the importance of site selection for the exploration project.
Removing and keeping vegetation from the site in a nursery, for transplanting back on the site during
decommissioning is an option that can also be investigated. It must be noted that the further eastwards the
development progresses, the more readily areas will be rehabilitated, but in staying with the Precautionary
Principle it is advised that the entire Central Precinct be characterised as an area where rehabilitation will be
problematic.
4.12.2 Heritage
Based on the available heritage data it is possible to indicate broad patterns that may assist the gas
exploration team in avoiding heritage sites and the potential damage thereof:

ƒ Rock shelters in the river valleys bisecting the mountain ranges will contain rock paintings and
archaeological deposit
ƒ Dolerite outcrops and boulders may contain rock engravings. Karoo koppies consisting of dolerite
boulders are promising candidates in this regard.
ƒ It is also likely that ground surveys may uncover scatters of Early, Middle and Later Stone age artefacts
near fountains and water courses.
ƒ Stone walling, including stone walled enclosures, related the Khoekhoen pastoralist activities may also
be found in various localities were grazing would have been available in the past.
ƒ Old farmsteads, older than 60 years and hence of heritage significance, will occur on most farms in the
area. We may anticipate that these may consist of farmhouses, sheds, outbuildings, kraals and other
structures. Of particular significance are the vernacular corbelled huts/houses that has been erected in
the 18th and 19th centuries in the vicinity of Beaufort-West.

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ƒ Various historical buildings occur in the small towns in the area. Victoria-West and Richmond are
especially well represented in this regard.
ƒ Graves belonging to both the indigenous San as well as colonial graveyards will occur on various farms
and small towns in the area.
ƒ Pans and watercourses were a foci of human activity in the past and prehistoric and colonial-era
heritage sites may be found near its environs.

4.13 Socio-economic environment


The Central Precinct is the local study area (LSA) and intersects the Western Cape, Northern Cape and
Eastern Cape, and falls within the Central Karoo, Pixley ka Seme, Chris Hani and Cacadu district
municipalities (DM) as shown in Table 9.
Table 13: Precincts in relation to municipal boundaries
Precinct District Municipality Local Municipality
Central Karoo, Pixley ka Seme, Cacad Beaufort West, Ubuntu, WCDMA05, Camdeboo,
Central
and, Chris Hani and Inxuba Yethemba

The LSA falls mostly within Beaufort West LM in the Western Cape, Ubuntu LM in the Northern Cape and
Camdeboo LM in the Eastern Cape as well as the Western Cape District Management Area (WCDMA05)
(Figure 23).
District Management Areas (DMAs) are often sparsely populated and characterised by abundant natural
resources. These areas fall outside the boundaries of local municipalities and municipal services are
generally not provided to these areas (e.g. national parks and world heritage sites). District municipalities
then assume direct responsibility for the governance, administration and management of these areas by
providing a limited number of local government functions27.
The DMA of the Central Karoo DM is a unique arid zone with a legacy left by the indigenous Khoi-San
people. The DAM incorporates the town of Murraysburg, a small town primarily supported by tourists drawn
by the surrounding Sneeuberg Mountains, plains and rock art sites. The fossil-rich terrain has some of the
most important archaeological sites in the world – particularly near Beaufort West and Nelspoort where
stone-age sites and Bushmen engravings have been found – and boasts over 9,000 plant species.
Murraysburg caters to this market with a number of local crafts being produced. Beyond Murraysburg, the
area is sparsely populated with a few large farms.
Beaufort West (just outside the Central Precinct boundary), the largest urban area in Beaufort West LM, is a
typical South African "platteland" or country town adjacent to the Karoo National Park. Beaufort West was
originally established as a service centre for rail- and road transport and to a lesser degree for rural
agriculture. It lies in a sheltered spot, between two normally dry rivers, at the foot of the Nuweveld
Mountains. During the 1970s and 1980s, 90% of the town’s economically active people were employed by
the SA Railways. The National Road from Cape Town to Johannesburg (N1) bisects the town, and is still
responsible for generating a significant portion of the town’s revenue.
Victoria West is the main town (of three urban settlements) in Ubuntu LM.
4.13.1 Population
Beaufort West LM has a population of just over 37,500 (64% of the total population in the DM) and is
characterized by large areas of agricultural land with Beaufort West as the main urban centre. The
population density is 2 per km². The majority of the population (77%) is Coloured and approximately 90%
speak Afrikaans as their first language.

27
National Study of Service Delivery in District Management Areas (DMAs), Human Sciences Research Society, Final Draft, April 2005

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Figure 23: District and Local Municipalities – Central Precinct

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Table 14: Central Precinct Population Distribution28


Population Designation
Province / Municipality Total Per km2 Black Coloured Asian White
Western Cape 5,357,000 41 30% 50% 1% 18%
Central Karoo DM 59,000 2 10% 80% 0% 10%
Beaufort West LM 37, 600 2 14% 77% 0% 9%
Northern Cape 1,147,600 3 40% 50% 0% 10%
Pixley ka Seme DM 179,500 2 23% 67% 0% 10%
Ubuntu LM 17,600 1 13% 80% 0% 6%
Eastern Cape 6,743,823 40 88% 8% 0% 4%
Cacadu DM 369,700 6 46% 40% 0.2% 13%
Camdeboo LM 43,005 6 23% 68% 0% 10%
Chris Hani DM 812,900 22 95% 3% 0.1% 2%
Inxuba Yethemba LM 49,200 4 48% 36% 0.2% 16%

Ubuntu LM includes the towns of Victoria West (main town), Loxton (outside the Central Precinct boundary)
and Richmond as well as two former Spoornet villages: Hutchinson and Merriman. While the population is
significantly smaller in Ubuntu LM, the population profile is very similar to the rest of the Central Precinct
(notably the Beaufort West LM). More than 80% of the local population in both municipalities is Afrikaans-
speaking and designated Coloured29.

The Camdeboo LM is one of nine LMs in the Cacadu district and represents approximately 12% of the total
population in the district. Main urban centres in the LM include Graaff-Reinet (which falls outside the Central
Precinct boundary) and Nieu-Bethesda which are surrounded predominantly by livestock and game farms.
With reference to the socio-economic landscape, the changing social character of the region was
summarised as follows30:

“During the last fifty years, extensive livestock farms have grown even larger, and shed a
great deal of labour. Many of these unemployed farm workers have drifted to the small towns,
to join the ranks of the urban unemployed. The recent advent of game farming has
contributed to this trend, although opportunities in agri-tourism and eco-tourism are beginning
to create scope for new and more sophisticated types of employment in the tourism sector.”
In a Quality of Life survey conducted in 2008, one of the main reasons for people leaving the Camdeboo LM
was to find employment and approximately 26% of the population between 18 and 65 years was
‘unemployment and looking for work’. Pensions and social grants constituted the main sources of income for
the majority of respondents.

28
Community Survey 2007, Statistics South Africa 2007, sourced at www.statssa.gov.za on 11.02.2011
29
In South African context, the term Coloured (also known as Bruinmense, Kleurlinge or Bruin Afrikaners in Afrikaans) refers or referred to an ethnic group of mixed-race people
who possess some sub-Saharan African ancestry, but not enough to be considered Black under the former law of South Africa. They are mixed race and often possess substantial
ancestry from Europe, Indonesia, Madagascar, Malaya, Mozambique, Mauritius, Saint Helena and Southern Africa. The extensive combining of these diverse heritages in the
Western Cape developed into a distinctive 'Cape Coloured' and affiliated Cape Malay culture.
30
D.Atkinson. 2008. Towards “Soft Boundaries” Pro-poor Tourism and Cross-border Collaboration in the Arid Areas of Southern Africa.

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19%
21%
22%
General government 13% 16%
18%
13% 15%
17%
15% 18%
Community, social, personal services 15%
15%
20%
18%
14%
13%
10%
9%
Finance, insurance, real estate business services 7%
8% 12%
12%
18%
1%
2%
3%
Transport, storage, communication 3%
2%
5%
4%
4%
11% 14%
16%
Wholesale, retail, catering, accommodation 29%
15%
24%
22%
22%
4% 10%
5%
6%
Construction 6%
7%
8%
7%
0%
1%
1%
Electricity, gas, water 0%
0%
0%
4%
3%
4% 5%
Manufacturing 6% 8%
8%
14%
0%
1%
8%
Mining and quarrying 0%
0%
0%
26%
25%
17%
Agriculture, forestry, fishing 18% 34%
6%
12%
7%
0% 5% 10% 15% 20% 25% 30% 35%

Ubuntu LM Pixley ka Seme DM Northern Cape Camdeboo LM


Cacadu DM Beaufort West LM Central Karoo DM Western Cape

Figure 24: Central Precinct Employment Distribution by Sector, 2009

The Capacity Assessment report (2008) (an annual assessment by Government of municipal capacity to
perform the municipal powers and functions for which it is authorised) compiled annually by the Municipal
Demarcation Board (MDB)31 indicated a negative population growth rate of 13%, 1.4% and 6.7% in Beaufort
West LM, Ubuntu LM and Camdeboo LM respectively between 2001 and 2007. The declining population in
Beaufort West LM and Camdeboo LM is significant and could be linked to the declining contribution of the
agricultural sector to the Gross Value Added (GVA) indicator from 8% in 2004 to 5% in 2009 in Beaufort
West LM and from 6% to 3% in Camdeboo LM. The natural arid climate compounded by the pressing
drought in the region will have contributed to the out-migration.

4.13.2 Social Services and Infrastructure


There are 18 schools, 3 hospital and 10 clinics/health centres in the Beaufort West LM, 12 schools, 2
hospitals and 3 clinics in Ubuntu LM and 13 schools, 2 hospitals and 6 clinics in the Camdeboo LM. The
Water Services Development Plan (WSDP) (a municipal planning document compiled annually for municipal

31
Namakwa District Municipality (DC6), Northern Cape, Assessment of Capacity for the 2008/9 Period, Municipal Demarcation Board, November 2008

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water and sanitation services) for Beaufort West LM 14 urban settlements where municipal services are
delivered which includes 291 businesses. The WSDP for Ubuntu LM states that the municipality has three
urban settlements with 85 businesses and 123 homesteads ‘scattered’ in the rural region of the municipality,
while the Camdeboo LM has 3 urban settlements where services are delivered including 207 businesses.
Water services in Beaufort West LM are supplied from 32 groundwater and 2 surface water sources while
Ubuntu LM supplies water through reticulated systems from 17 groundwater sources. The Camdeboo LM
supplies water services from 5 groundwater sources and 1 surface water source. The population is thus
solely dependent on local water sources.

4.13.3 Tourism
Tourism has been considered a developmental opportunity for the Karoo region evidenced by the tourism
conference held at the end of 2009 with the theme “creative tourism in the Karoo – implications for 2010 and
beyond”32. Several presentations were made about the tourism potential that is seemingly locked up in the
history, natural resources and heritage of the region. These experiential features are also referred to as the
‘sense of place’ of the area and relate to what has been referred to by stakeholders as the aesthetic value.
Aesthetic value of an area is the emotional response derived from the experience of the environment with its
particular natural and cultural attributes and includes atmosphere, landscape character and sense of place
(Schapper, 1993).

The local economic situation is typically characterized by small towns with small local economies and a
migration towards the east and coastal regions which are also the focus of tourism development. Tourism is
described in various planning documents as having the potential to generate income and reduce poverty:
The Western Cape highlights the eco-tourism, historical culture, agri-tourism, hiking,
stargazing, bird watching etc. (Western Cape Government 2002). The Cacadu Tourism
Spatial Development Plan refers to the attractions of the open plains; mountains and valleys;
rivers; nature reserves and wilderness areas; private game lodges; hunting and birding; hiking;
biking; and horse riding. In the Northern Cape, the 2005 White Paper on Tourism refers to the
parks, game reserves and conservancies, offering abundant wildlife and floral diversity. There
are also many cultural and heritage resources, including museums, historical sites, and
monuments. There are archaeological and rock art sites, arts and cultural festivals, prominent
historical figures. There are also unique and endangered cultures, such as the San
communities, the Griquas, and the Namas. Another potential area for tourism development is
the game farming industry which has expanded massively in southern Africa.33
The Karoo tourism initiative highlights the economic potential inherent in the ecological and historical
heritage of the region.

4.13.4 Economy and Employment


The Central Karoo district is a designated development node as part of the Integrated Sustainable Rural
Development Strategy and Beaufort West has been linked to the opportunities resulting from its position
along national transportation routes (notably the N1). The IDP highlights that Beaufort West is strategically
situated approximately 450 kilometres northwest from Cape Town along the N1 route, which connects Cape
Town with cities like Bloemfontein and Johannesburg and is also situated on the stretch of the N1 where the
N12 converges with the route, adding to the town transport potentials. Agri-business development initiatives
that have been pursued over the past five years include the manufacturing of essential oils and a hydroponic
project.

32
Karoo Tourism Conference: Creative Tourism in the Karoo – Implications for 2010 and Beyond
33
D.Atkinson. 2008. Towards “Soft Boundaries” Pro-poor Tourism and Cross-border Collaboration in the Arid Areas of Southern Africa.

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50% 45% 47% 46%


45% 45% 44%
43%
45% 40%
40% 37%
35% 34% 34% 34%
33%
35% 32% 31%
30%
25% 20%
17% 18%
20% 16% 15%
14% 13% 13%
15% 10%
10%
10% 6%
5% 5% 4% 4% 4%
5%
0%
Western Central Beaufort Cacadu DM Camdeboo Northern Pixley ka Ubuntu LM
Cape Karoo DM West LM LM Cape Seme DM

Employed - Formal Employed - Informal Unemployed Not Economically Active

Figure 29: Central Precinct Employment, 2009

Formal employment levels are approximately 34% in the Central Karoo DM, over 10% lower than
employment figures for the Western Cape Province (Figure 29). The wholesale and retail industry sector
(including catering and accommodation) is the largest employer in the local municipality, accounting for 24%
of employment, and contributing 14% of the local municipality GVA. The largest contributor to GVA is the
financial, insurance, business and real estate sector at 29%. Agriculture accounts for only 6% of
employment and 5% of GVA sector contribution. However, the Beaufort West LM identifies the sector as
one of importance and with opportunities for growth and employment creation despite the harsh climate and
poor carrying capacity of the veld. Agri-processing, particularly related to mohair and deciduous fruit, is
seemingly offering new prospects for the future. Game farming is also developing as an economically viable
option.
According to a “Broad Socio-Economic Profile” report for the Cacadu DM34 the district experienced a higher
growth rate (1.1%) than the larger province. Camdeboo LM contributed 13% to the district’s GVA in 2007,
preceded by Kouga (22%) and Makana (24%). Agriculture is the greatest employer in the district (34%)
while Camdeboo LM experienced the greatest contribution to employment in the wholesale and retail sector.
The rate of employment (formal and informal) in the district is approximately 53% and approximately 47% in
Camdeboo LM.
In the Ubuntu LM, agriculture and government services are the largest contributors to the economy and
employ the largest number of people.
Table 15: GVA per Sector 2009
Cacadu DM

Camdeboo
Karoo DM

Ubuntu LM
West LM
Beaufort
Western

Central

Seme DM
Pixley ka
Northern
Cape

LM

Sector
Cape

Agriculture, forestry and fishing 4% 9% 5% 6% 3% 7% 15% 21%


Mining and quarrying 0% 0% 0% 0% 0% 27% 5% 0%
Manufacturing 17% 11% 10% 13% 9% 4% 3% 4%
Electricity, gas and water 2% 1% 1% 2% 1% 2% 3% 2%
Construction 5% 6% 5% 4% 3% 1% 2% 7%
Wholesale and retail trade, 14% 14% 14% 12% 19% 12% 14% 11%

34
Cacadu District Municipality, 2008. Broad Socio-Economic Profile.

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Cacadu DM

Camdeboo
Karoo DM

Ubuntu LM
West LM
Beaufort
Western

Central

Seme DM
Pixley ka
Northern
Cape

LM
Sector

Cape
catering and accommodation
Transport, storage and
10% 12% 14% 5% 7%
communication 10% 10% 5%
Finance, insurance, real estate
33% 27% 29% 23% 19%
and business services 14% 18% 17%
Community, social and personal
5% 7% 8% 13% 10%
services 10% 12% 12%
General government 10% 13% 14% 23% 28% 14% 18% 21%

It is evident from this brief description that the local economy in the Central Precinct is driven by the services
sector with limited contributions from the construction and manufacturing sectors and no contribution from
the mining sector.

4.13.5 Community Health and Safety


Community safety is measured by the number of incidents reported at local police stations. Crimes are
typically categorised into violent and non-violent crimes, under the following headings: contact crimes
(including murder and grievous bodily harm (GBH)); contact related crime (arson); property related (theft and
burglary); firearms and drug related crime; other serious crime and other unspecified crime (Table 16).
The total number of crimes reported between April 2008 and March 2009 for the affected towns in the
Central Precinct is 7,525. Several areas recorded an overall decrease in incidents. The increase in
incidents in Beaufort West LM has been attributed to liquor abuse amplified by illegal shebeens, domestic
violence and money lenders.

Table 16: Central Precinct Crime Statistics, 2009


Property related
(burglary, theft)
Contact related
Contact crimes
against person

Firearms, drug
(murder, GBH)

Other serious
crime (arson)

related crime
Total crimes

Other
crime

Town

Total crimes 394 117 17 103 95 32 28

Murraysburg
Change since 2005 2% -31% -39% 312%
Beaufort West LM
Crime distribution 30% 4% 26% 24% 8% 7%

Total crimes 4105 1285 305 753 599 934 225


Beaufort West Change since 2005 21% 12% 17% 44% 37% 14% 4%
Beaufort West LM
Crime distribution 31% 7% 18% 15% 23% 5%

Total crimes 283 111 23 97 20 22 9


Richmond
Ubuntu LM Change since 2005 -12% -12% 21% -13% 25% -46% 50%

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Property related
(burglary, theft)
Contact related
Contact crimes
against person

Firearms, drug
(murder, GBH)

Other serious
crime (arson)

related crime
Total crimes

Other
crime
Town

Crime distribution 39% 8% 34% 7% 8% 3%

Total crimes 507 191 32 153 44 81 6


Victoria West Change since 2005 28% 35% 14% 76% -41% 53% -50%
Ubuntu LM
Crime distribution 38% 6% 30% 9% 16% 1%

Total crimes 2236 673 154 572 168 594 69


Graaff Reinet Change since 2005 -18% -33% -9% -12% 29% -5% -50%
Camdeboo LM
Crime distribution 30% 7% 26% 8% 27% 3%

A scoping health impact assessment was compiled in a separate technical report. Table 17 refers
specifically to the HIV/Aids status of the local populations in the LSA. It is evident that the percentage Aids-
related deaths are significant against an infection rate of between 3-10% of the population in the range 15
and 49 years. In light of the current negative population growth rate, an increase in Aids-related deaths
would further diminish the local population and reduce the ability of the local communities to reproduce their
productive capacity.
Table 17: Central Precinct HIV/Aids, 2010
Population Percentage of Deaths
AIDS Deaths Other Deaths
HIV Positive related to AIDS
Central Karoo DM 3% 0.1% 0.9% 13%
Beaufort West LM 3% 0.1% 0.9% 14%
Pixley ka Seme DM 6% 0.3% 0.9% 26%
Ubuntu LM 6% 0.2% 0.9% 22%
Cacadu DM 10% 0.6% 1.1% 36%
Camdeboo LM 8% 0.4% 1.2% 24%
Chris Hani DM 11% 0.7% 1.1% 40%
Inxuba Yethemba LM 10% 0.6% 1.1% 35%

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According to the IDP of Beaufort West LM, health indicators revealed that the proportion of children under
the age of 1 year with first measles immunization was 93 per cent (above the national target of 90%), TB
prevalence stood at 950 for every 100 000 people, with a cure rate of 74 per cent. The national target for TB
cure rate of 85 per cent had not been met because of social grants, which have become a source of living for
people; it implies that being cured will remove the grant. The patient nurse ratio was 31:1, better than the
national target of 34:1.
During an AIDS strategy planning session in 2002, Ubuntu LM conceded that “There are only 3 clinics and 2
hospitals in the Ubuntu municipal area to deal with people who are living with AIDS. According to estimates
by the District Council about 10 % of a total population of 20 000 are likely to be HIV positive and these
hospitals and clinics are understaffed and under resourced and cannot provide an effective service”. It
appears that the general health systems are inadequate to deal with the present health conditions.

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5.0 DESCRIPTION OF APPLICANT AND PROPOSED EXPLORATION


PROJECT
This chapter introduces the applicant, described the steps involved in exploration for shale gas and typical
activities that may be undertaken for shale gas exploration.

5.1 The Applicant: Royal Dutch Shell


Shell Exploration Company B.V. is a registered company of Royal Dutch Shell plc, a public limited company
registered in England and Wales and headquartered in The Hague, the Netherlands (see www.shell.com).
The application for the exploration right has been submitted by Shell Exploration Company B.V. which is
registered in The Netherlands.
Shell is one of the world’s largest independent oil and gas companies in terms of market capitalisation,
operating cash flow and oil and gas production. The company is active in more than 90 countries, with over
101,000 employees worldwide.
Shell’s upstream businesses explore for and extract crude oil and natural gas, often in joint ventures with
international and national oil companies. These businesses also liquefy natural gas by cooling and
transporting it to customers across the world, and convert natural gas to liquids (GTL) to provide cleaner
burning fuels. They also market and trade natural gas and power.
Shell’s downstream business manufactures, supplies and markets oil products and chemicals worldwide.
Manufacturing and supply includes refineries, chemical plants and the supply and distribution of feed stocks
and products. Marketing sells a range of products including fuels, lubricants, bitumen and liquefied petroleum
gas for home, transport and industrial use. Downstream also trades crude oil, oil products and
petrochemicals. The downstream business also includes activities in biofuels, and it co-ordinates Shell’s CO2
management activities across the company.
In addition, to meet the growing demand for cleaner, lower-CO2 transport fuel, Shell is applying a range of
approaches, including vehicles powered by biofuels, electricity, compressed natural gas and hydrogen fuel
cells.

ƒ Biofuels: Shell has been involved in distributing biofuels for over 30 years and continue to build their
capacity in biofuels Shell distributed 9 billion litres of biofuels in 2009.

ƒ Hydrogen: In partnership with carmakers Shell has opened demonstration hydrogen filling stations, in
the USA, Europe and Asia to learn more about consumer behaviour, safety, cost, and the dispensing
and storage of hydrogen at these stations. Shell has several partnerships that explore the development
of a hydrogen market and help reduce costs.
Shell develops wind power to generate electricity, Shell has an interest in wind projects with an overall
capacity of around 1,100 MW. In the USA, their share of the operating capacity is 450 MW, enough to power
150,000 US homes. Shell has a further 98 MW share of wind generated power in European projects. Shell’s
wind-energy output avoids around 1.5 million tonnes of CO2 a year, if compared to a coal-fired power station.
Shell is looking at potential new North American wind projects.

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5.1.1 Business principles


The company has set business principles, first published in 197635, and standards for health, safety, security,
environment and social performance. Every employee is expected to abide by the business principles (see
http://www.shell.com/home/content/aboutshell/who_we_are/our_values/sgbp/), which cover, among others the
principles of:

ƒ Contribution to sustainable development by balancing short and long-term interests and integrating
economic, environmental and social considerations into decision-making;

ƒ Applying a systematic approach to health, safety, security and environmental management in order to
achieve continuous performance improvement. To this end, Shell companies manage these matters as
critical business activities, set standards and targets for improvement, and measure, appraise and
report performance externally, continually looking for ways to reduce the environmental impact of
Shell’s operations, products and services and involving stakeholders in dialogue about issues of
concern to them;

ƒ Being a good neighbour by continuously improving the ways, in which Shell contributes directly or
indirectly to the general wellbeing of the communities within which they work and committing. Shell
companies aim to manage the social impacts of their business activities carefully and work with others
to enhance the benefits to people in the local communities, and to mitigate any negative impacts from
their activities. Shell has an active Social Investment programme in countries where it operates and at a
global level, with a focus on local enterprise development, road safety and access to clean burning
cooking stoves for local community members; and

ƒ Other business principles include a responsibility to not only shareholders, customers and employees,
but to society as well as contractors, suppliers and business partners.

5.1.2 Shell’s commitment to sustainable development


Shell began reporting voluntarily on their environmental and social performance with the first Shell Report
that covered 1997. The reporting focuses on the environmental and social challenges that most affect
business performance and matter most to their key stakeholders. Internal controls such as audit trails and
statistical checks help assure the accuracy of the Shell Sustainability Report. An External Review Committee
of independent experts helps make sure the reporting is balanced, relevant and responsive to stakeholders’
interests. More information on Shell’s sustainability reporting can be found at
http://www.shell.com/home/content/environment_society/reporting/.

Shell was included in the FTSE4Good Index in 2010, like every year since it started in 2001. Companies
must meet the index’s criteria on the environment, relationship with interested parties, supply chain labour,
bribery, and human rights to be included. There is no ranking within the index. More information can be
found at: http://www.ftse.com/Indices/FTSE4Good_Index_Series/index.jsp
Shell remains second in the Goldman Sachs GS SUSTAIN ESG (environmental, social and governance),
which focuses on sustainable investing in the energy sector. Companies are rated according to 25 indicators
across the categories of corporate governance, leadership, labour, communities and investment and
environment. For more details, refer to http://www2.goldmansachs.com/ideas/environment-and-
energy/goldman-sachs/gs-sustain/index.html

5.1.3 Safety record


Safety is high priority for Shell. In 2009, a number of Shell’s major construction projects achieved a high
number of working hours without time lost through injury. The oil sands expansion project in Canada
recorded 43 million working hours, while the Shell Eastern Petrochemicals Complex in Singapore achieved
38 million working hours without an injury leading to time off work. Gbaran-Ubie, Shell’s integrated oil and

35
Updated in 2005

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gas project in Nigeria, achieved 40 million man-hours without any lost time incidents (LTI) in 2010.The
company has won several safety awards. Recent examples include:

ƒ In Qatar, the company’s Pearl Gas to Liquids team (with 77 million safe working hours) was awarded
the HSE Project of the Year at the Abu Dhabi International Petroleum Exhibition and Conference
(ADIPEC) Excellence in Energy Awards 2010. (http://www.adipec.com/page.cfm/link=35); and

ƒ Shell Todd Oil Services (STOS) which operates the Maui and Kapuni fields in Taranaki, New Zealand,
won the Excellence in Health and Safety Award in 2010 at the inaugural New Zealand Energy Awards.
(http://www.energyawards.co.nz/award/excellence-in-health-and-safety-award).

5.1.4 Environmental commitments and performance


Shell is committed to carry out impact assessments for all its major projects or large expansions across its
existing operations.
Shell is committed to consider biodiversity early in new projects, develop action plans and collaborate with
experts to help protect areas with rich and delicate eco-systems. Shell made the following four commitments:
1. They will not explore for, or develop, oil and gas resources in natural World Heritage Sites.

2. They will further improve the way they operate in IUCN Category I-IV protected areas, and areas of
high biodiversity value. Shell is committed to preparing Biodiversity Action Plans (BAPs) in Areas of
high Biodiversity Value (AHBV) (which include IUCN I - IV, Ramsar, Important Bird Areas, Natura
2000, and man and Biosphere Reserves).
3. They will publicly report on their activities in IUCN Categories I-IV protected areas.
4. They will work with IUCN and others to help safeguard protected areas.

Shell works with conservationists to lessen impact on biodiversity in areas where they operate. As an
example, the Smithsonian Institution Monitoring and Assessment of Biodiversity Programme (SI/MAB) and
Shell have been working together to increase understanding of biodiversity and energy resource
development in the Gamba Complex in Gabon. This partnership, which began in 2000, is funded by the Shell
Foundation, Shell Gabon and the Smithsonian Institution. Through this partnership, SI/MAB has been
carrying out long-term independent biodiversity studies in the area. More details on this partnership are
available at
<http://nationalzoo.si.edu/SCBI/MAB/conservation/centralafrica/gabon/MABinGabon/partnership.cfm>.
In terms of greenhouse gas reduction (GHG), Shell had set a voluntary target of 5% lower GHG emissions in
2010 than their comparable 1990 level. In 2009, the direct greenhouse gas (GHG) emissions from facilities
they operate were 67 million tonnes on a CO 2-equivalent basis, 11% lower than in 2008 and around 35%
below the 1990 level which puts them on track to meet their voluntary target.

5.1.5 Social responsibility record


In their projects and operations around the world, Shell brings benefits to local people by providing jobs, tax
revenue, contracting and business opportunities and social investment programmes.
Shell also support local communities in setting up businesses to provide goods and services. In Nigeria in
2009, 85% of the total number of contracts awarded by Shell companies in Nigeria (worth nearly $892
million) went to Nigerian companies.
Another example is Brunei Shell Petroleum (BSP – Shell interest 50%), which is helping the government to
grow small and medium-sized businesses. BSP prefers local companies in bids, and provides training and
skills development. BSP has increased its spending with Bruneian companies from almost $500 million in
2004 to over $1 billion in 2009. The joint venture’s latest oil platform was built in Brunei, largely by local
companies. Some of these companies have since won international contracts.

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Shell also makes voluntary contributions to support local communities and the areas where they operate. In
2009, Shell spent around $132 million on social investment mostly on community development projects.

5.1.6 Involvement in Gas Exploration and Production


Currently, Shell has some 25,000 wells producing oil and gas in many different countries around the world.
The company drills about 1 000 exploration and production wells each year.
As global energy demand increased over the past five years, the company has found more than 1.5 billion
barrels boe (barrels of oil equivalent) of new hydrocarbon
resources each year. In 2009, Shell explored for and Terminology
discovered 2.4 billion boe of hydrocarbons, and produced 2% of
the world’s oil and 3% of the world’s gas. • Hydrocarbons – any class of
compounds containing only hydrogen
Shell has considerable experience in drilling and fracturing and carbon, such as gas.
unconventional gas wells. For example, over the period 2009- • Boe – barrels of oil equivalent
2010 Shell drilled about 500 wells onshore in North America to
stimulate gas production. Many of these wells were • Conventional gas - gas trapped in a
single gas reservoir underground
hydraulically fractured.
• Unconventional gas – gas trapped in
5.1.7 Shell in South Africa rock underground
The Shell Transport and Trading Company was formed in 1887, • Onshore – on land
exporting oil from the Far East. Not long afterwards, in 1902,
• Offshore – in the sea
Shell started business in South Africa with a focus back then on
distributing paraffin and kerosene.
Shell employs nearly 1 400 people in South Africa and operates a nationwide retail network of 750 service
stations. Its commercial businesses include sale of aviation, marine and commercial fuels and bitumen. They
provide fuel and lubricants to the transport, construction, manufacturing, mining, marine and agriculture
markets in South Africa. Shell jointly owns with BP the SAPREF refinery in Durban, one of the largest
refineries in Africa.
Shell South Africa is a signatory to the Petroleum and Liquid Fuels Industry Black Economic Empowerment
(BEE) Charter of 2000. The charter seeks to increase the participation of previously disadvantaged people in
the petroleum industry. As of 2010, Shell South Africa is the first international oil company to achieve BBBEE
(Broad Based Black Economic Empowerment) accreditation. Shell entered into various empowerment
transactions with a local BEE partner as early as 1998.
The general principle of BEE as a key component of the South African economic environment is established
in several pieces of legislation such as the Broad-based Black Empowerment Act, the White Paper on the
Energy Policy of the Republic of South Africa, the MPRD Act, the Preferential Procurement Framework Act
and the Employment Equity Act. Relevant BEE requirements for Shell’s potential upstream operations are
set out in the MPRD Regulations (Chapter II, Part II), which require Shell to submit a “Social and Labour
Plan” with the application for a production right in order to demonstrate how we will achieve defined BEE.
Even if there is no specific BEE requirements during the exploration phase, Shell is committed to build a
solid BEE compliance programme, which will require early development in exploration phase of a BEE
strategy and some upfront specific actions.

5.2 Steps in the gas exploration process


The following flow diagram shows the indicative steps to be followed in a typical shale gas exploration
programme.

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Steps in shale gas exploration
Desk‐top studies of geology Shell is here :
If not promising, discontinue If promising, Select areas for future 
wells based on geology, complete EMP

Depth to target  shale  accurately known?
Yes, old seismic, offset wells No

Obtain geophysical data 
(Magneto‐telluric)
Target shale too deep or too 
Target shale at right  shallow, select other location
depth range
Obtain land access and perform Environmental 
Impact Assessment for drilling location

Mobilise Rig + Drill exploration vertical well 

If no gas flow observed, rehabilitate,  If promising  
consider continue exploration  (gas encountered in mud logs, logs or canisters)
programme (or exit after n‐wells)
Demobilise Rig, 

Undertake Hydraulic Fracture 
Drill new well first
within existing vertical well

At original well surface location Drill new well at new location nearby

Design frac, mobilise frac crew. Frac & test  Select & prepare new location for vertical 


small vertical section well with horizontal section

If no gas flow observed, rehabilitate,  Mobilise Rig + Drill vertical well 
consider continue exploration  Gas flow tested  with horizontal section
programme (or exit after n‐wells) successfully  If no gas flow observed, 
( “puff” of gas)
rehabilitate, consider continue 
If promising
(gas encountered in mud 
exploration programme(or exit 
logs, wireline logs) after n‐wells)

Demobilise Rig, design frac, mobilise frac crew. 
Frac & test horizontal section
If no gas flow observed, 
rehabilitate, consider continue 
exploration programme(or exit 
after n‐wells)
Repeat process unless successive no‐gas observed or flows

Figure 30: Steps in shale gas exploration

5.3 Location of the proposed exploration phase project activities


The application covers a total area of ±30,000 km2 in the magisterial districts of: Aberdeen, Beaufort-West,
Carnarvon, Graaff-Reinet, Middelburg, Murraysburg, Noupoort, Richmond and Victoria-West.
In terms of physical footprint, a number of sites will be established to execute drilling operations, distributed
across the total license application area. However, in terms of cumulative footprint, only a few square
kilometers of surface land is expected to be required, and the area will be distributed across a number of
different locations throughout the application area. Subject to appropriate regulatory approvals and
landowner consent, Shell’s activities may include:

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ƒ Geophysical Data Acquisition: The non-intrusive geophysical technique called magneto-telluric (MT)
involves placing a number of sensors on the ground for about a day, which are then moved to a new
point, typically 3 - 10 kilometers away. Over time, by collecting individual data points, the acquired data
may represent approximately 1000 kilometers of points that can be joined to form lines on a map.
Section 5 of this report describes the process in a more detail.

ƒ Exploration Drilling: Having analysed Soekor well data from the 1960’s Shell’s prognosis is that
hydrocarbon bearing shale layers may exist in the license area, but at different depths, varying between
1000 to 5000 meters. Shell may drill up to eight wells in the license area to identify the shale layer
(which may or may not contain hydrocarbons). If the shale layer cannot be found or no hydrocarbons
are detected deep underground then fewer wells may be drilled

ƒ A well site typically can be 100 meter by 100 meter (1ha) in area in order to place a temporary
drilling rig, and other drilling related equipment, materials and some onsite storage (e.g. tubulars,
containers and water pits). In some instances additional storage area for equipment or vehicle
parking may be required, which will require additional land in the vicinity. Dependent upon where a
well site is located, an access road may be required. If temporary accommodation is required
nearby in the form of a temporary camp (rather than utilizing available rental accommodation), this
would require additional temporary land. Once drilling locations have been identified, decisions on
access road, accommodation, etc. will be made on a case-by-case basis, taking into account,
individual well site considerations and will involve land owner and community consultations;

ƒ Water wells: Dependent upon regulatory requirements and landowner approval, water wells may be
drilled for baseline data collection, monitoring of aquifers, or possibly to supply water for general
drilling operations. These ‘water’ wells would typically be drilled to shallow depth to intercept either
the shallow aquifer for monitoring purposes, or slightly deeper (>100 m) if a deeper groundwater
supply well was contemplated. No decisions have been taken on this yet, but further analysis will be
required during the planning for well site specific environmental impact assessments; and

ƒ Supply base: a supply/ logistics base will be required for drilling operations to store material, preparation
and possibly testing of equipment before being despatched to sites. Typically a supply base is
established in a central location – such as a major town. The location(s) of the supply base has not
yet been selected as this depends on the location of the drilling sites. Considerations for locating a
supply base would include existing (brown-field) storage facilities, availability of local skills, labour
and other materials.
The precise locations where exploration drilling activities may take place have not yet been identified.
Information on surface conditions and landowner and community opinions are being gathered to assist in the
selection of suitable sites.
The illustration (Figure 31) provides an overview of possible areas within which suitable well sites may be
identified for future exploration drilling activities.

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Figure 31: Illustration of possible areas within which a suitable well site may be identified for future
exploration drilling activities

5.3.1 Identification of notional areas


The precise drilling locations have not yet been identified. During 2009, as part of the Technical Cooperation
Permit (TCP), desktop studies were undertaken to better understand the subsurface, geological
characteristics and surface considerations. In addition environmental mapping data was reviewed to narrow
down potential areas that may fit a number of high level operational criteria. The following criteria were used:

ƒ Topography: slope < 10%, elevation < 2000m.

ƒ Logistics / Accessibility: close to existing, national (tar) road network.

ƒ Population density / urbanisation: outside towns/ urban areas.

ƒ National Electricity Grid Infrastructure: Within 20 km of existing network or substation (where known);

ƒ Consideration of national conservation or protection areas.


As part of the engagement process with I&APs during January and February 2011, Shell has started to
gather the opinions of people in the Karoo to help improve the local understanding against these initial
criteria. In addition, I&APs are also providing suggestions for criteria that Shell may wish to consider in order
to minimise potential impacts on, for example, particular species of plant or native wildlife.
Going forward, detailed site selection criteria will be developed along with the provision of alternative
locations, which will only be possible with further local dialogue and consultation with land owners and

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regional experts. This process of scoping will also form part of any Environmental Impact Assessment(s)
studies.

5.4 Description of proposed exploration project


5.4.1 Desk-top studies of geology (completed)
During the 12-month period of Shell’s Technical Co-
operation Permit, issued by PASA in December 2009, Shell
carried out desktop evaluations of the geology underlying the
Karoo.
These evaluations were based mainly on information
obtained by Soekor in the 1960s, when approximately 10
deep wells were drilled to depths of up to 5 km to search for
hydrocarbons (oil). Cores from these wells are still kept by
the Council of Geosciences (see photo in Figure 32).
Information recorded during drilling operations at the time
indicated that shale may be present underground and in one
well gas was observed.
Analysis by Shell of the 1960’s Soekor well cores and logs
has provided an indication that shales containing gas may Figure 32: Well cores from the 1960s Soekor
be present but the results are not conclusive. exploration for oil in the Karoo

The quality of data acquired in the 1960s had deteriorated


over the past 50 years, and left many technical geological
uncertainties which makes it difficult to assess the presence, volume, quality, and possible rate of flow of gas
in any one particular area.

5.4.2 Application for Exploration


Right (submitted)
In December 2010, Shell made an application to
PASA for an Exploration Right with the objective
to, over a 3-year license period, collect modern
geophysical and well data to help quantify the
possible existence of gas, and if present, start to
assess whether it may flow (or not) within a
particular area.
As part of the application process, legislation
requires Shell to submit an Environmental
Management Plan within 120 days of PASA
accepting the application documents.

The various activities described in the following


sections may form part of Shell’s exploration Figure 33: MT sensors like these are placed on the
programme (should they be granted an Exploration ground for a period of a day, gathering data
Right and after obtaining necessary permits and
approvals).

5.4.3 Geophysical Data Collection


5.4.3.1 Magneto-Telluric
In order to better understand the geological characteristics of the Karoo, Shell proposes to use a non-
intrusive geophysical technique (measuring only natural phenomena) named “Magneto-Tellurics” (MT) which

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is commonly used in modern petroleum, mining and geothermal resource exploration. MT has already been
used successfully by academics36 to study the geological history of the Karoo area.
Naturally varying magnetic fields caused by sunspots and even distant thunderstorms, result in electrical
fields in the earth. The MT technique measures these very small magnetic fields. Information is then
recovered and interpreted to map the subsurface geology, down to depths of 10 km in some instances.
Figure 33 shows how sensors are placed on the ground to measure the magnetic fields. The MT equipment
easily fits into a small suitcase and can be carried by one person. A number of small receiving sensors are
positioned on the ground, orientated in different directions to allow measurement of the magnetic field. The
equipment is set-up during the day, records data overnight and then is moved to a new location the following
day. The distance between measuring locations is typically 3 – 10 km.
Shell will engage with land owners to seek permission to access their land to allow MT measurements to be taken.

5.4.3.2 Seismic Acquisition


During the initial 3-year Exploration Right, a selection of other geophysical data acquisition methods may be
used near a well site or within the well bore itself. These may include shallow seismic and micro-seismic
techniques:

ƒ Shallow seismic is a technique used to assess the (shallow) rock composition in and around a proposed
well site to characterise the geological components. A shallow seismic programme could have an
additional footprint, although if the seismic lines are acquired along existing roads this would be
minimal. A surface seismic programme consists of series of "shots" (i.e. a source of acoustic energy
such as vibroseis trucks (vehicle-mounted vibrator plates), weight drop, or detonation of a small charge
in shallow holes), which are used to create an acoustic signal. For each shot, a string of sensors
(geophones or accelerometers) is used to record the acoustic reflections (echoes) from the subsurface
geologic formations. A typical seismic survey that is designed to image shallow targets (500 to 1 000 m
in depth) would have shots spaced roughly every 40 m and sensors spaced every 10 m along lines that
would be 10 to 30 km in length. The length and number of lines that would be required depend on the
geologic features that need to be delineated.
Seismic sensors are connected by electrical cables back to the recording truck with 100 to 200 sensors
placed for every shot. The sensors are small; a single sensor would fit in a persons hand. Small spikes
on each sensor are pushed into the ground to couple the sensor firmly to the soil. Vibroseis trucks are
often used for lines along roads or in smooth and firm ground conditions. Small charges are used in
more rugged terrain or where ground conditions are not suited for vibroseis trucks. Shot holes are
drilled by small hand held augers or by units mounted on the backs of all terrain vehicles, with hole
depths around 3m and charge sizes of 1/8 to 1/4 kg.

ƒ Micro-seismic is a technique used once a well has been drilled to understand the characteristics around
the well bore. It can also be used if hydraulic fracturing has taken place to map the extent of the
induced microscopic fractures around the well bore (refer to Figure 33) for an example of mapping of
fractures). When deploying micro seismic equipment, the purpose is to listen to the very small noises
that are created, deep underground, as fractures are created during the hydraulic fracturing process.
Sensors (called geophones) are used, which can be placed on the surface, in a grid pattern, to listen to
the very small noises made as the rocks are fractured. There is also the option to use a neighbouring
(drilling) well as the ‘observation’ well, within which one could place the ‘listening geophones’.
A recording truck sits on the well pad to record the signals generated during hydraulic fracturing. No
additional footprint or land disturbance occurs as a result of recording the micro-seismic data.

36
http://www.agu.org/journals/ABS/2007/2005JB003975.shtml: New Magnetotelluric Measurements across the Magnetic Beattie
Anomaly and the Southern Cape Conductive Belt in South Africa, Weckmann, U.; Ritter, O.; de Wit, M.; Jung, A.; Hübert, J.; Branch, T.;
Stankiewicz, J.; Mabidi, T. American Geophysical Union, 2004

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At this point Shell is not planning to acquire other seismic data (e.g. 2D seismic) until after drilling a number
of exploration wells, and therefore most likely not during the 3-year Exploration Right. If Shell successfully
identifies hydrocarbon-bearing rock, 2D seismic technique may be used in some areas at a later exploration
stage.

5.4.4 Drilling
Shell may drill up to eight exploration wells in a license area. Drilling is not expected to start until late 2012.
Furthermore, drilling will not start until an Environmental Impact Assessment has been performed, as
outlined in Chapter 3, Regulatory Requirements, for any gas well site that will be proposed.
Shell has not yet identified where exploration drilling may take place. Since there is some flexibility from a
subsurface point of view in where a well site could be located, Shell will determine the sites in consultation
with landowners.
The section below describes a typical exploration well site and activities that may occur in the Karoo and is
based on typical drilling activities on land, anywhere in the world. For the Karoo, once a number of
alternative well sites have been identified more site specific details, per location, will be included in the
Environmental Impact Assessment (EIA) scoping and evaluation.

5.4.4.1 Exploratory Vertical Wells


To assess whether there is gas trapped in the rock formations, Shell will drill vertical wells possibly down to
depths of 5000 m. Each well would consist of several well bore sections, with each subsequent section
having a smaller diameter, starting at the surface with a hole diameter of approximately 20-30” (inches), and
reducing to about 4 to 8.5” at the deepest point.
Each well bore section would be lined with a steel casing, cemented in place. This process provides a barrier
between the formations (that may include water bearing zones) and the well bore. During the drilling
process, rock core and technical data measurements (including logging) will be recorded.
Each well section would be lined with a steel casing, which in turn would be cemented in place.  
The casing and its accessories will be of such specifications that they can withhold down hole pressures and
are resistant to the composition of the wellbore and formation fluids that they are exposed to. The casing
integrity is tested through a casing integrity test, typically upon completion of the cementation or at any other
moment when there is no open connection with the formation at the bottom of the well. During the test, the
maximum expected pressure during drilling or production is applied to the casing and held for generally at
least 15minutes. The test would confirm that the casing can actually withstand the expected pressures and
hence proves there are no leaks in the casing. In case a leak is detected during the integrity test, pressure is
bled off immediately, and a casing repair will be undertaken before drilling or production can continue. 
The cement around the casing holds the casing in place, but also is aimed to prevent communication (of
pressure or fluids) around the outside of the casing between deeper and shallower formations, or even
surface. The quality of the cement can be accessed through for example a Cement Bond Log. This log will
indicate whether there are possible communication paths through the cement. In case a so-called leak path
would be detected, secondary operations may be undertaken in order to seal off the detected communication
path. Examples of such operations are top-filling the annulus37 with cement (pump additional cement with
specialised equipment into the annulus on top of the existing cement column) or installing packers (sealing
device) above the existing cement column. Once a casing is cemented in place and the necessary integrity
tests and checks have been passed successfully, operations or production may continue.  

During operations all annuli will be monitored to confirm no leaks develop over time. Also during production
when the rig is no longer on site, it is common practice that the annuli are monitored at a regular basis. In
case pressure or fluid levels are observed to increase, a full investigation will be carried out and if required
production is halted or operations stopped (close in well). Once the investigation confirms the cause of the
increased pressure or fluid levels, appropriate action will be taken to restore the required integrity. 

37
The annulus is the gap between the casing and the bore hole.

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Whilst drilling the vertical exploratory wells, geological samples of the rock cuttings from the bore hole as well
as core samples will be collected and analysed to determine the presence of a potential (shale) reservoir and
whether gas is still present in these rock formations deep under the ground.
The drilling equipment necessary to drill the well is transported on trucks to the location. During operations,
the drilling rig itself may be 30-50m in height, dependent upon the equipment selected. Subject to regulatory
approvals, operations may take place 24 hours a day. Once drilling operations are completed, the well is
suspended and the drilling rig equipment is demobilised.

5.4.4.2 Exploratory Horizontal Wells


Should a vertical exploration well confirm indications of hydrocarbon gas, Shell may drill one or more
additional wells, from either the same surface location, or from another location (possibly up to 10 - 25 km
away) to evaluate the possible volume, productivity and distribution of the gas-bearing formations in the
vicinity. In this situation, the next well would likely be drilled with a horizontal section that would be placed
horizontally within the target reservoir rock formation.
A horizontal section exploratory well would be very similar to the vertical exploratory well, with an initial
vertical section drilled to confirm the depth and location of the target rock formation(s), then sidetracked to
drill a horizontal section at approximately 90 degrees (‘horizontal’) into the targeted formations. The
horizontal section may be up to 2000 m in length. Data acquisition whilst drilling would be similar to drilling
vertical wells and may include coring and logging.

5.4.4.3 Drilling site preparation


5.4.4.3.1 National Road Network and Well Site Access
During January-February 2011, as part of developing the Environmental Management Plan, some limited on-
the-ground data collection has taken place in order to begin verifying existing national data sets. Some
stakeholders also shared their local knowledge on the quality of roads. Establishing a good understanding of
the national (tarmac) roads will be essential, including the tonnage (load) weight restrictions. It is assumed
that smaller (access) roads may need to be upgraded (or built) from an existing (minor) road to provide
access to a well site.
Well sites have not been identified yet, therefore it is not possible to say where or how access roads may
require upgrading. In general terms, an access road that is 6 to 10 meters wide would typically be required to
allow vehicles to bring on/off-site temporary equipment. The total length of the road will vary for each
proposed well site, dependent upon the distance of the well site from the nearest existing road. However,
where feasible, existing access routes will be used and upgraded if required. Dependent upon the length and
type of road, Shell expects that activities such as upgrading an existing road may require appropriate
Environmental Impact Assessment and environmental approvals.
As part of the well site selection study, Shell will engage with landowners to help identify what may be an
acceptable well location and route for access. Once a site for drilling has been selected, environmental
impact assessment or other regulatory approvals are in place, and all necessary permissions have been
obtained, then construction can commence. It will be required to identify a contracting and procurement
approach for this engineering phase, including the supply of suitable raw materials, equipment and labour for
any particular proposed well site.

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5.4.4.3.2 Well Site


A typical well site, such as the one shown
above from a European location, may be
approximately be 100 x 100 meters (1ha) in
size, however, dimensions can vary
dependent upon the actual rig used, the
overall operational requirements and other
requirements relating to what is stored on or
off-site. In certain instances additional area is
required for storage of materials or placement
of additional equipment. Typically during
exploration drilling, equipment on site would
include a small site office and store, waste
storage and the drilling rig and associated
equipment and materials.
A well site is constructed using normal Figure 34: From a European location
earthmoving equipment and techniques.
Heavy equipment such as bulldozers, graders,
earth movers and a number of lorries will be used to remove waste as required. In addition, the construction
workers will require temporary accommodation somewhere in the vicinity.
In general, whilst the detailed site-specific designs have not been made yet, typically on a site, preparation
would include:

ƒ Remove topsoil, which is then stockpiled nearby for site rehabilitation purposes later.

ƒ Grade, level and if necessary backfilled with crushed stone the area where the drilling and well pad will
be located.

ƒ Compact the site to ensure for stability during movement of heavy equipment and support the weight of
the rig.

ƒ Create erosion and sediment control structures around the site, where appropriate.

ƒ Create on-site storage for drilling fluids or water, which may require construction of geotextile lined pits
or as an alternative the use of storage tanks.

ƒ Construction of a well cellar may be required on certain sites to contain the wellhead. The dimensions
will vary depending on the size of the wellhead.
As described earlier the crew(s) involved with the drilling operations will require temporary accommodation.
This could be located close to the site in a purpose-built temporary camp, or utilise available
accommodation, or a combination of both. The most appropriate option can only be selected once well
locations have been selected. Shell will draw upon local expertise, landowner preferences and other
guidance to support its final decisions. If camp accommodation was the preferred option for operations
relating to a well site then this would typically require about 0.5 ha of land, for accommodation, a restaurant
(mess), offices, stores, and parking (assuming crews for one well site).

5.4.4.4 Drilling rig mobilisation


The precise specification of the drilling rig to be used will depend on the contractor selection. The contracting
process has not yet commenced since Shell currently does not have an Exploration Right. The choice will be
dependent upon the total drilling depth for a particular well, which in turn will determine the minimum
capacity requirements. However, a 1500-2000hp land rig should in general be capable of drilling the full
range of depths across the license application. Therefore this rig capacity has been used to describe a
typical operational environment.

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The drilling rig will be transported by standard prime mover and 40 ft trailer trucks, and will be assembled on
site. The construction of the temporary drilling rig typically takes between 3 and 4 weeks. Additional trailer(s)
will be required to bring other portable equipment, a site office etc. for temporary use on site. Typical traffic
associated with "rig up" operations requires approximately 50 to 70 truck loads, which includes portable
accommodation units and rig site offices.
The frequency with which additional vehicle traffic visits a site will depend upon the phase of drilling
operations. For example:

ƒ On average a standard re-supply to a rig will require 2 to 4 trucks loads per day, although when pipe
casing strings and mud supplies are required this may require up to 10 truck loads per day for a short
period of time.

ƒ Dependent upon the distance to available infrastructure, for example a supply base or airport, may
require additional traffic once per week, plus ad-hoc travel of employees to/from the site on a daily
basis.

5.4.4.5 Drill site management


This section describes, at a high level, the types of equipment and chemicals required during drilling
operations:

ƒ Fuel: Power for the well site and rig is usually provided through diesel fuelled generators. Dependent
upon drilling activity, fuel use can vary between 2 to 4 m3 per day. Therefore, normally there will be an
on-site fuel store to support ongoing operations. In line with regulatory requirements and international
best practices, fuel will typically be stored in storage tanks, bunded by a retention wall, with fire
prevention equipment in place.

ƒ Drilling Mud (Chemicals): Storage for mud (drilling fluid) is kept in a designated area on the well site.
Typically only the chemicals necessary for the stage (depth, geological characteristic) of drilling are kept
on site - the rest is stored at the supply base. Contingency stocks of heavy mud additives (i.e. barite)
are also kept at the supply base to use if needed to maintain well control. The majority of chemicals
kept on the rig site comprise barite and hole conditioning chemicals. Barite is an inert (naturally
occurring) substance with clay-like properties, which is typically stored in a silo. Well hole conditioning
chemicals are typically stored in 50 kilo sacks or drums inside containers, separated in accordance with
manufacturers handling guidelines. The conditioning chemicals may include KCL (salt), gels and
naturally occurring fibres.

ƒ Steel Pipe: Hydrocarbon wells will be lined with tubular steel pipe. Generally, the storage of individual
sections of the casing (typically 10 meters long) on the well site is kept to a minimum. All casing and
related equipment and materials that are not imminently required for the operations are kept at the
supply base for distribution. Each pipe can weigh hundreds of kilograms, therefore safety and careful
management of the equipment is essential. At the supply base and the well site casing storage is
regulated in accordance with Shell standards and handled by trained personnel.

ƒ Low-Level Radio-active Measuring Device: During drilling operations, at certain points when geological
strata are reached, data measurements may be undertaken. This would typically require ‘logging’, using
a specialised down hole measuring device which is lowered into the well bore . This device may contain
a low level radio-active source for measurement purposes. The handling and execution of these
devices can only be done by specialised licensed companies. The movement, storage and use of these
logging devices are regulated under South African legislation. Temporary storage would likely be used
at the well site, again in compliance with applicable local regulations.

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Figure 35: Down hole measuring device Figure 36: Close-up of down hole
measuring device which contains a small
radioactive source used to record rock type
inside the bore hole

ƒ Minor Explosives: Minor explosives may be required to create


small (typically ~1 to 2 cm) holes, so-called perforations, in the
steel pipe casing, at specified points inside the well bore (across
potential hydrocarbon bearing formations). These perforations
are likely to also penetrate the surrounding rock around the
wellbore to <20cm. The objective of these perforations is to make
a series of holes that would then allow any gas to flow from the
surrounding shale rock into the well bore in a controlled manner.
In the event that hydraulic fracturing is required to stimulate the
gas to flow into the wellbore, slightly larger perforating guns
would be used, that may create a ~2cm hole, penetrating slightly
Figure 37: Directional head off a
deeper (<1 meter) into the rock formation. Any explosives perforating gun used to punch a hole
required would be handled by specialised licensed companies, through the well casing inside the
with the movement, storage and use of explosives regulated by shale layer
the South African legislation, which Shell will comply with. Again,
dependent upon the regulations, storage bunkers would likely be used on the well sites for safe storage.

5.4.4.6 Drilling & well bore data acquisition


A well is "drilled" using a mechanical drill bit. The diameter of the bore hole progressively gets narrower as
the well is drilled deeper. At the surface, when drilling starts the hole would typically vary between 20 and 26
inches in diameter.
After drilling with a certain sized drill bit, for example 22” at the surface, a smaller sized (e.g.18.5/8“) steel
pipe string (casing) is inserted into the 22” bore hole. Next, special cement is then pumped down the steel
pipe casing and forced up the gap between the casing and the bore hole (annulus). The objective is to
cement in place the casing string, providing both structural integrity to the newly drilled wellbore and
importantly to isolate (seal off) off the rock layers that have been drilled through so that there is not linkage
between such layers. This process also isolates any water bearing formations from the well bore or other
formations. Once the casing and cementing process is completed for a specific stage of the well, a new
section can be drilled deeper, this time with a smaller drilling bit lowered through the casing. Subsequently
as deeper sections are drilled and cased off, smaller diameter casing is being used.
The drilling process is a mechanical process, whereby the drill bit, aided by rotary torque and the
compressive weight of the drill string above it, grinds the rock formation. The term drill string, refers to a
gradually lengthened pipe onto which the drill bit is attached; sections of approximately 10m drill pipe are
gradually added at surface, to allow drilling to go deeper. Usually joints are made up into stands of three for
a 30m continual drilling section. Whether this is actually done in practice is dependent on the type of rig

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used. During drilling operations certain mechanical properties are continually recorded, such as the actual
weight on the drill bit used to grind through the rock, the rate of penetration, and torque required. All these
parameters help to characterise the mechanical properties of the different rock layers.
During the drilling process drilling fluid, referred to as drilling mud, is pumped down the inside of the drill
string, exits at the bottom through the drill bit and returns through the space between the borehole and drill
string back to surface.
The drilling mud keeps the drill bit cool and transports rock cuttings from the drill bit deep underground to the
surface for analysis. The mud is directed over a device known as a shale shaker to separate the cuttings
over mesh screens, allowing the mud to return back into the mud tanks for reconditioning and then re-use.
The cuttings are analysed for their rock properties and for possible traces of hydrocarbons, this process is
called MudLogging. After analysis the rock cuttings are recycled in accordance with the regulated waste
management programme.
Typically, vertical exploration wells will likely use a water based mud, comprising water, weighing agents,
such as barite and other additives such as viscosifiers. If exploration wells are drilled with a horizontal
section, dependent upon the subsurface conditions, it may be necessary to use a non-toxic synthetic oil
based fluids. In this case, the base component of such a fluid typically is base oil.
The primary objective to undertake the initial vertical exploration drilling is to gain a better understanding of
the subsurface, identify the existence of shale reservoirs and assess whether gas is still held in the rocks,
deep underground. In addition to analyzing the rock cuttings and the drilling parameters, at certain points
(depths) during drilling solid rock cores may be taken and specialist data acquisition (logging) devices used
inside the well bore, which may include, but not be limited to:

ƒ Measurements while drilling (MWD): specialized tools, for example gamma ray and resistivity tools, are
installed just behind the rotating drill bit. These measurements are transmitted to surface allowing near
real-time observation of the characteristics of different geological rock formations.

ƒ Electric wire-line logging: Upon completion of a drilled section, specialized tools can be lowered down
the well bore on a wire-line to measure characteristics of the rocks. Tools that might used could include
borehole imagers, caliper devices, density-, azimuthal sonic-, and resistivity tools.

ƒ Cores: as part of plans to drill exploratory vertical explorations wells, formation samples (cores) will
likely be taken if targeted geological rock formations are encountered. Specialised coring tools will be
used to retrieve the core for analysis at the surface. Subsequently the core sections will be sent to a
specialist lab for detailed analysis.

ƒ Formation sampling: In addition previously mentioned data acquisition techniques, localized side wall
coring and potentially formation fluid sampling may be undertaken at certain intervals whilst drilling. This
may be to target specific shales or if encountered, to quantify the characteristics of certain water-
bearing zones.

ƒ Mudlogging: drilling fluid returns are analysed at surface on composition. Drilling parameters, such as
Rate of Penetration (ROP), weight on bit (WOB) and torque, as well as cuttings retrieved at surface are
also examined as they may indicate what types of formation are being drilled. This data is compiled into
a so-called mud-log.
Upon completion of the exploratory operations the well is suspended and all drilling related equipment
demobilized and moved off-site.
Drilling related operations (excluding site preparation and rig-up) may take 2-4 months, dependent upon how
deep the well is required to be drilled. Drilling is expected to take place 24 hours per day, using two crews,
each working a 12 hour shift.
Dependent upon the phase of the drilling, a typical crew may contain up to 30 personnel, but may increase
for short periods, to ~50 personnel, during periods of specialist operations, such as data acquisition or

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completion activities. The personnel would include drillers, roughnecks, mud specialists, mechanics,
electricians, drivers, equipment operators, catering and specialist services (e.g. logging, coring, casing
running) and supervisory personnel.
Shell will endeavour to employ only competent staff and contractors to carry out operations. Where staff or
contractors do not meet the appropriate competence or awareness of standards and regulations that is
required, Shell will provide adequate and suitable training to meet the requirements.

5.4.4.7 Noise from operations


The mechanical process of drilling a well, generators and moving equipment create noise. The levels of
noise will vary dependent upon the type of rig, ancillary equipment and phase of operation. For example,
there are differences between drilling itself, and adding new drill pipe into the well bore. Each activity will
generate a different noise profile, with varying contributions of different pieces of equipment. The top drive
and mud pumps have a typical noise range of 96 to 102 dB(A) near the source.
It is common practice that rig-specific operational noise assessments are carried out when a rig is being
considered for use. Sound measurements are typically taken at various sound levels during operations, both
at the source and at distance intervals of 100m away from the well bore. An example of such assessment
was carried out on the KCA-Deutag’s T-208 drilling rig. Shell would consider using the former type of rig
(which does not mean specifically this rig or supplier) for exploration activities in the licence area. The T-208
assessment demonstrated that noise generated around the wellbore during drilling operations quickly
dissipated over distance from 104.7 dB)(A) (measured at 1.5m above ground) to 58 dB(A) at 100m and
39dB(A) at 600m lateral distance. In case noise reduction measures would be implemented these noise
levels may have been reduced further to 53dB(A) at 100m and 35 dB(A) at 600m.
During early baseline data capture for the Environmental Management Plan background noise levels have
been recorded at a number of areas. Later, once well locations are selected an Environmental Impact
Assessment will commence at a specified well site location. At that time noise measurements, impacts and
mitigations will form part of the basic scoping requirement. As part of the site selection process, stakeholders
will be consulted to seek thier input for locating the well site. This will take into consideration proximity to
people, wildlife and livestock and measures needed to achieve acceptable noise levels.
Dependent upon the equipment used and the location where drilling may take place, different options can be
developed to limit the amount of noise created and how quickly the noise dissipates with distance away from
a well site. For example, in Sweden Shell used hay bales on the perimeter of the well site to reduce the
noise impacts. In operations around the world it is often a legislated requirement to monitor and control noise
levels within legal limits, at specified distances from a well site. It is therefore likely that Shell will monitor
noise levels at various distances from the well site, if granted land access to install monitoring equipment.

5.4.5 Hydraulic Fracturing


Fracturing would only be undertaken in the case where hydrocarbons are found during the first vertical
drilling operations, and if the intervals of hydrocarbon-bearing shale rock were found. Dependent upon the
properties of the rock formation, the fracturing operations typically can take 2 - 4 weeks per well. A
specialised crew, normally of 15 to 20 people, operate the pumps and ancillary equipment.

5.4.5.1 The Hydraulic Fracturing Process


Hydraulic fracturing is a process that makes it possible to recover natural gas from low permeability
formations where the rock is unusually densely packed.
Hydraulic fracturing was first used more than 100 years ago in 1903 in the United States. The first
commercial fracturing treatment by Industry was performed in 1949. In Europe, during the 1950’s. Shell
undertook some of its first hydraulic fracturing operations on ventures in the Netherlands and Germany into
hydrocarbon bearing rock layers where gas was discovered but would not flow because it was held very
tightly in the rock.

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Since the 1940’s it has become an industry recognized technique used to try to stimulate the flow of
hydrocarbons held tightly in rock formations and is a key technical process to allow the development of
natural gas resources around the world. In the US, per year, approximately 35,000 wells are now drilled and
then fractured by Industry, annually (source: www.energyindepth.org).
Shell has considerable experience in drilling and fracturing
unconventional gas wells. For example, over the period
2009-2010 Shell drilled ~500 wells onshore in North
America to stimulate the production of gas. Many of these
were hydraulically fractured.
Hydraulic fracturing is the process of creating fissures, or
fractures, in underground formations to enable natural gas
to flow. These fractures start at predetermined points
(perforations) in the wellbore through which fracturing fluid
is pumped under pressure into the formation. The extent of
these fractures depends on the combination of formation
characteristics, the fracturing fluid composition and the
pressure applied during injection of the fluid. Figure 38
shows a typical crack induced through hydraulic fracturing.
Shell is able to measure the distance, direction and
effectiveness with which the fracturing process worked. Figure 38: Example of a crack induced by
hydraulic fracturing
Typically a fracturing fluid consists predominantly of water
and proppant, the latter generally being sand, ceramic or bauxite. A small amount of special-purpose
additives are required to facilitate the hydraulic fracturing process. The proppant holds the fractures open,
allowing hydrocarbons to flow into the wellbore and so to surface after injected fluids (flowback water) are
recovered. Flowback water can be re-used and recycled for other operations. For example, in North America,
Shell collects the water produced, then re-uses it for other drilling related activities, reducing the water use
by up to 50% in some unconventional ventures.
Shell will study a range of variable factors such as the nature of the rock formation and the thickness of the
targeted area before finalising the hydraulic fracturing design (fluid composition, pressure required etc.) to
ensure fractures are contained within the targeted geological formation(s).
The process to optimise the hydraulic fracturing design, including chemical additives to be used, can only
take place once the well has been drilled. Therefore, hydraulic fracturing operations will not occur
immediately after completion of drilling and logging operations. In the case of operations in the Karoo, the
plan will be to move the rig away. Next the rock properties, any core and data acquired from logging will be
analysed before committing to the final fracturing design.
The pressure required to generate microscopic fractures in the shale can vary enormously, which is why rock
cuttings, cores and other data acquired during drilling must be carefully analysed before completing the
fracture design. Typically the range of fracture pressures can be 5,000psi (345 bar) to 10,000psi (690 bar).
The pressure applied during fracturing should never be higher than the tested maximum allowable casing
pressure. The maximum allowable pressure would be confirmed during earlier phases of the well operations
through a casing integrity test.
Only once all data has been analysed can the fracture design be completed and specialist hydraulic
fracturing equipment and ancillary equipment be mobilised to a well site. With careful design of the fracturing
process this allows the fracture network, location, length and effectiveness to create a permanent fracture
system in a specified rock formation to be tightly controlled. Figure 39 shows how the results of a fracture
can be mapped. The pictures depict points, deep underground, where fractures were created as a result of
the hydraulic fracturing process. Each point represents the location (in X, Y and depth) for a microscopic
fracture (typically <1mm in size) which was artificially created in the rock. As the hydraulic fracturing liquid is
pumped along the well casing, through perforation holes and into the rock formation, small fractures are
created in the rock. This process creates very small sound waves that can be picked up by geophones,

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as Exploration
n in the Westtern Karoo (C
Central
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E Co
ompany B.V.

which are very sensitive


e sensors. Th
his example is from one of
o Shell’s pro
oducing unco
onventional gas
g fields in
the United States
S dale, Wyoming, America))
(Pined

Figure 39: Do
ots in these im
mages indicate
e the locationss of micro-seis
smic events ge
enerated as th
he rock in a we
ell in Shell’s
Unconventionnal gas field (P
Pinedale, Wyo
oming, Americca) fractured

5.4.5.2 Fracturi
ring Fluid
The fracturing fluid is a critical
c compponent of the hydraulic fra
acturing proccess in orderr to try to create and
then keep frractures (typpically <1mm is size) open deep in the e targeted ro
ock formationn. In the Karo oo the
targeted shaale layer, if present,
p could be located
d as deep as 5000 meterss under the g ground.
The selectio
on of the fraccturing fluids composition
n used for anny well, at any site, must be tailored to
o be
compatible with the targgeted rock formation in orrder to try an
nd create and d maintain th
he fractures.

Within the Karoo


K area, the
t only inforrmation availlable to Shell, at this time
e, regarding tthe rock com
mposition
deep under the ground, comes from m the Soekor wells drilled in the 1960ss. Within She ell’s license application
a
areas, only ~3 deep wellls provide geeological insights. The ge
eological corre data obtained by Soek kor has, overr
the last 50 years
y deterio
orated, and th ery some generic guidance.
herefore onlyy provides ve
From Shell’s analysis in the Karoo, and
a more ge enerally globaally for unconnventional opperations, the targeted
shale gas (rreservoirs) to
o be stimulatted will vary markedly
m in terms
t of burial depth, tem
mperature, peermeability,
rock compoosition, and pore
p pressuree.
Shell believves that the most
m likely hyydraulic fractturing fluid co
omposition to will be based upon a so-
o be used, w
called slick--water fracturing. This ap pproach woulld typically re equire around
d 99% waterr and proppa ant, plus
some chem mical additivess that comprrises the rem maining 1%.

ƒ For so-called slick--water hydraulic fracturing, the proppant likely to be


b used will be one of sa
and, ceramic
or bauxite.

ƒ nal choice of chemical ad


The fin dditives to bee used will de
epend on inssights from ne
ew informatio
on obtained
after drilling a well.. For example, this will he
elp make app propriate cho
oices with reg
gard to so-ca
alled “Green
Chemiistry” (refer to o section 5.5
5 below)

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Note : Shell will commit to undertake toxicity screening, the results of which will be publically shared, prior to
developing the final hydraulic fracture design for an Exploration well. In addition, more generally Shell
supports disclosure by Contractors and Suppliers of chemicals that may be used during the hydraulic
fracturing process.
The following sub-sections briefly talk about the current drive, across Industry, to utilize more widely so-
called Green-Chemicals, and this is contrasted against a selection of chemicals that have in the past been
used by Industry for hydraulic fracturing.

5.5 EPA Principles of “Green Chemistry”


Note : It is important to emphasize that the additives described in this section are examples from publically
available sources, used for unconventional gas operation. They have not been specifically selected to be
used in the Karoo. The choice of additives will be used in the Karoo will depend on a number of location
specific factors.
There is a growing choice of fluid compositions available by Industry suppliers, which cater to the wide range
of geological conditions and particular drivers of an individual company.
Since 2004, industry has experienced a technical evolution that currently reflected in the availability and use
of so-called Eco-friendly Green Chemistry stimulation fluids (In the United States, these are in compliance
with the USC Water Act).

The term and objectives for ‘Green Chemistry’, are depicted (for example) by the adherence to the EPA’s
Principles of “Green” Chemistry, where by chemicals selected must achieve the following objectives:

ƒ Prevent Waste

ƒ Design safer chemicals and products. Achieve balance between toxicity, fluid effectiveness and loading
requirements

ƒ Design less hazardous chemical syntheses.

ƒ Use renewable feed-stocks and bio-degradable products. Green chemistry and Eco-friendly and
biologically derived versus synthetic or oil-based additives

ƒ Avoid chemical derivatives: No carcinogenics, nor endocrine disruptors, nor heavy metals

ƒ Use safer solvents and reaction conditions to reduce large volumes of solvents and auxiliary chemicals

ƒ Green fracture fluids use of bio-degradable products (into benign byproducts) to degrade after use,
preventing bio-magnification and ecological toxicity

ƒ The change of chemistry and green products to help prevent pollution in real-time. Eco-friendly
alternative fracture fluids allow for easy cleaning of spills
For this reason, there are a growing number of different products available by Industry which cater to these
objectives (Table 18).
Table 18: Currently available “Green Chemistry” hydraulic fracturing chemical additives available by
Industry Suppliers
Company Products Details
Halliburton CleanSuite™ CleanStim™ Hydraulic Fracturing Fluid System. With components are
Technologies - sourced from the food industry and can provide an extremely clean
Ultra Clean fracturing fluid with excellent proppant transport and cleanup. Provides
Fracturing Fluid Breakthrough Environmental Benefits and Excellent Retained Conductivity
Technology CleanStream® Service - Enhances Environmental Performance by
CleanStream® for Reducing the Volume of Conventional Biocides Required

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Company Products Details


Fracturing Fluid, Ultra Clean Liquid Gel Concentrates (LGC™). All LGC’s are now ultra
Ultraviolet Light clean and meet requirements of the Energy Act of 2005 and the
Bacteria Control. CleanWater Act. Under this family, the Water-Based Gelled Fluid Systems
Ultra Clean Liquid include:
Gel Concentrates ƒ SilverStim® LT service for a wide variety of applications including
(LGC™)
SilverStim® LT
ƒ CBM stimulation,

service ƒ pHaserFractureSM – compatibility with CO2,

ƒ SiroccoSM service for high temperatures

ƒ DeepQuest® service that enables fracturing ultra deep reservoirs


Source:
http://www.halliburton.com/public/projects/pubsdata/Hydraulic_Fracturing/
CleanSuite_Technologies.html
FractureTech Eco Green Family Powdered “Greener” Environmental Scorecard suggests a large
Slickwater “Green” improvement as compared to traditional fracture fluids
ƒ Powdered “Greener” components
ƒ Friction Reducer
ƒ Biocide
ƒ Oxygen Scavenger
ƒ Clay Control
ƒ Scale Inhibitor

ƒ Adherence to the EPA’s 12 Principles of “GREEN” Chemistry


ƒ Superior/equal performance vs. current chemistry
ƒ Location footprint reduction
ƒ Simplified logistics
Source: ECO-Green, Green Stimulation Solutions
http://www.fractech.net/eco-green/#slickwater-green
Schlumberger OpenFRACTURE OpenFRACTURE range of hydraulic fracturing fluids are resulting from
Fluid Additive extensive development and testing programme. Operators receive full
Systems disclosure of additive components, a disclosure level similar to that used
in the food industry.

ƒ OpenFRACTURE SW—used for slickwater fracturing, where drag


reduction and less-complex fluid systems are desired

ƒ OpenFRACTURE WF—used for linear gel fracturing, offering


improved proppant transport characteristics.

ƒ OpenFRACTURE XL—used for crosslinking, maintaining all the


advantages of the first two fluids while also creating wider fractures
to enable high proppant concentrations and generate high fracture
conductivity
Source: OpenFRAC Fluid Additive Systems
http://www.slb.com/services/stimulation/unconventional_gas_stimulation/o
penfrac_hydraulic_fracturing_fluids.aspx

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5.6 Historical Choices Chemical Additives


Note : It is important to emphasise that the additives described in this following section are examples taken
from publically available sources, used by Industry for unconventional gas operation, they are not specific to
the Karoo. The choice of additives that may be used in the Karoo will depend on a number of location
specific factors.
As one example, additives used by Industry in the United States on an existing, producing shale gas asset
(Eagle Ford Shale, Texas, USA) is shown in Table 19 below. This information is publically available at the
following website: http://www.halliburton.com/public/projects/pubsdata/Hydraulic_Fracturing/fluids_disclosure.html.
The types of chemicals used in hydraulic fracturing fluids, and common products which may also contain
such chemicals is provided as a point of reference for benefit of the reader (Table 20).
Table 19: Industry Third Party Example: list of additives used by Industry, at the Eagle Ford Shale,
Texas, USA producing assets
Product Name Additive Purpose Concentration

15% Hydrochloric Removes scale and cleans wellbore prior 4000-6000 gal run ahead of
Acid/Solvent
Acid (HCl) to fracturing treatment fracturing stages
Acid used to adjust the pH of the base
BA-20™ Organic Acid 0.1 - 0.5 gal/1000 gal
fluid.
Prevents or limits growth of bacteria that
can cause formation of hydrogen sulfide
BE-9™ Biocide 0.25 - 0.5 gal/1000 gal
and can physically plug flow of oil and gas
into the well
CL-28M™ Crosslink Agent A delayed crosslinker for the gelling agent. 0.3 -1.1 gal/1000 gal
Crosslink A non-delayed crosslinker for the gelling
CL-31™ 0.25 - 0.75 gal/1000 gal
Enhancer agent.
Clay-stabilization additive which helps
Clayfix™ 3 Clay Stabilizer prevent clay particles from migrating in 2.5 gals/1000 gal
water-sensitive formations.
Prevents some treating fluid leak off and
Common White Sand Proppant/Fluid
holds open fracture to allow oil and gas to 0.2 - 1 lbs/1000 gal
100 mesh Loss
flow to well.
Allows fracture fluid to move down the
FR-66™ Friction Reducer wellbore with the least amount of 0.2 - 1 gal/1000 gal
resistance
Corrosion Prevents acid from causing damage to the
HAI-404M™ 5- 25 gals/1000 gal
Inhibitor wellbore and pumping equipment
Losurf-300D™ Surfactant Aids in recovery of water used during frac 0.5 - 3 gal/1000 gal
Prevents build up of certain materials (i.e.
LP-65™ Scale Inhibitor scale) on sides of the well casing and the 0.25 - 10 gal/1000 gal
surface equipment
MO-67™ Buffer Used to adjust the pH of the base fluid. 1 - 10 gal/1000 gal
Optikleen-WF™ Breaker Agent used to degrade viscosity 0.25 - 1 lbs/1000 gal
Premium White Sand Holds open fracture to allow oil and gas to
Proppant 0.5 - 5.5 lbs/gal
30/50 mesh flow to well
Premium White Sand Holds open fracture to allow oil and gas to
Proppant 0.2 - 1.5 lbs/gal
40/70 mesh flow to well

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Product Name Additive Purpose Concentration

SP Breaker Breaker Agent used to degrade viscosity 1 - 2 lbs/1000 gal


Vicon NF™ Breaker Agent used to degrade viscosity 1 - 10 gal/1000 gal
Base fluid creates fractures and carries
Water Base Fluid proppant, also can be present in some N/A
additives
Guar Gelling
WG-36™ Gelling agent for developing viscosity 20 - 50 lbs/1000 gal
Agent
Note : Shell will commit to undertake toxicity screening, the results of which will be publically shared, prior to developing the final
hydraulic fracture design for an Exploration well. More generally Shell supports disclosure by Contractors and Suppliers of chemicals
that may be used during the hydraulic fracturing process.

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Table 20: Industry Third Party Example: Choices available to a Company for the selection of chemical
additives to be used during hydraulic fracturing process

Source http://www.energyindepth.org/frac-fluid.pdf
Note : Shell will commit to undertake toxicity screening, the results of which will be publically shared, prior to developing the final
hydraulic fracture design for an Exploration well. More generally Shell supports disclosure by Contractors and Suppliers of chemicals
that may be used during the hydraulic fracturing process.

5.6.1 Water Requirements


5.6.1.1 Volume of water
Water is required to perform exploratory drilling operations and, if required, hydraulic fracturing at a later
stage.

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Water for drilling vertical wells: As outlined in previous sections, the first objective during the initial
Exploration Right period is to drill a number of vertical exploration wells to understand the geological
properties of the rock, hopefully identify the presence of the shale layer and observe that gas is still held
tightly in the rock. Water is the main constituent of the drilling fluid normally referred to as ‘mud’ which is
required to cool the drill bit during drilling operations, transport rock cuttings to the surface and for bore hole
conditioning during drilling. The mud also acts as a primary control for down-hole pressures that may be
encountered whilst drilling. For drilling, water typical water volumes required will be 0.3 – 0.9 million litres per
well.
Water for hydraulic fracturing: Having drilled a vertical well, if gas is observed in the shale layer at a
certain well site, then Shell may decide to hydraulically fracture a small section of the vertical well, or it may
decide to drill a new exploratory horizontal well section in an attempt to locate the well within the narrow
shale layer deep under the ground. If successful and gas is observed to be still present in the shale rock then
hydraulic fracturing technique may be attempted (this could be in vertical and horizontal wells). Water is
needed also for such hydraulic fracturing operations. In this case, the volume of water required to perform
that operation could be up to 6 million liters. Of course if no gas is observed during drilling then no hydraulic
fracturing will take place, in which case the water consumption would only be that used to cool the drill and
carry rock cuttings to the surface.
Table 21: describes, for different drilling depths and objectives, the typical ranges of water volumes
which may be required during exploratory drilling operations
Indication of anticipated water usage* for drilling and suspension of vertical exploration wells, for
the expected depth range (As part of 3-year Exploration Right)

Well Depth 1000m deep well 2500m deep well 5000m deep well

Drilling Fluids  ~300m3 (300,000L)  ~700m3 (700,000L)  ~900m3 (900,000L) 

* Anticipated water usage assumes theoretical hole volumes plus empirical excess volume assumptions. In practice,
water usage may be higher or lower. The drilling of the exploration wells will provide more insight into the characteristics
of the rock formations and therefore the specific fluid requirement which in turn could mean higher or lower volumes of
water.

Hydraulic - Optional Stage 1 Vertical exploration well: up to 2.2 million litres


Fracturing
- Optional Stage 2 Horizontal section exploration well: up to 6 million
(if performed) litres
# Excludes efficiency gains by re-use or re-cycling of water.

Shell is committed to responsible water management and wherever possible will recycle and re-use water
and drilling fluids. This builds on Shell’s experience elsewhere in similar projects where water from drilling
operations has been cleaned, then re-used for other drilling activities, reducing overall the water use
requirements by ~50% on some North American unconventional business ventures.

5.6.1.2 Sources of water


Shell recognizes that the quality and supply of shallow drinking water aquifers in the licence application
areas needs to be protected and is therefore investigating a number of potential water sources to support the
requirements of the proposed exploration in the Karoo. Shell is looking at suitable options and will respect
the fragile water balance of fresh/potable water in the Karoo – these options may include the use of brackish
or seawater for certain operations.

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Preliminary water assessments, as part an early feasibility scoping will be focused upon a number of
alternative water sources, such as, beneath the ground (typically at depths >100 m), sea water, surface
water, water imported by truck or recycled grey water.
The identification and use of water is likely to be subject to regulatory approvals under the National Water
Act. In the next phase, local experts will be consulted to identify suitable water supply options and
appropriate studies undertaken as required to meet the legal requirements. Detailed evaluations will be
carried out during the Environmental Impact Assessment phase which will focus on specific drilling locations.
The intention is to identify the most suitable water source on a per-well site basis. Stakeholders e.g. the
relevant water authorities, local stakeholders, environmental advisors will be consulted during the water
source selection process.

5.6.1.3 Storage of water


Water required for drilling operations will need to be stored, either on-site or nearby. There are various
options to store water, such as using metal tanks, pillow tanks or geotextile lined bunded-wall. Local experts
will be consulted to help identify where or how best to store the water required for operations.
Water and additives are normally blended into a base fluid off site and then maintained on site with the use
of possibly a truck mounted blending unit, with hoses to transfer liquid additives from storage containers to
the blending unit or well directly from blending truck. Dry additives are poured into a feeder system on the
blending unit. The blended solution is immediately fed into the wellbore as required.

5.6.2 Well testing


During drilling operations which have the potential to drill into hydrocarbon bearing zones, there may be a
requirement to have an operational flare at the well site, which can be used in emergency situations to
evacuate gas or other hydrocarbons in a controlled manner.
If an exploration well identifies a (shale) reservoir containing hydrocarbons and a hydraulic fracturing
procedure successfully stimulates the hydrocarbons to flow up the well bore, then the next stage is to
evaluate the rate of gas flow and fluid composition. The key products of a typical well test may include, but
not be limited to:

ƒ Hydrocarbons and other gases (gas and / or liquid forms)

ƒ Water (From the fracture fluid or produced reservoir water)

ƒ Solids (Sand/rock/mud – from the drilling, hydraulic fracturing process or from the reservoir rock)
These product streams could be handled by routing the hydrocarbons through a low emissions flare at the
well site. Any water flowing up the well bore would be captured for recycling or cleanup and disposal. Any
solids encountered would be caught in a tank and in a test separator, then emptied for recycling or disposal
as part of the waste management programme.
Based upon experience elsewhere in the world, the duration of these gas flow tests may vary greatly from
one well to another, dependent upon the particular properties and thickness of shale encountered.
Based upon analysis a scenario Shell has developed is that gas may flow from a vertical well at about
0.15 MMscf/day on average. This assumes gas is present at a location and can then be made to flow. When
Soekor drilled approximately 10 deep wells, during the 1960s, there was only one successful shale gas well
test (which today is located outside Shell’s licence applications). At that one location, Soekor was able to test
for gas flow to the surface, however after 1 day the gas flow rate had significantly reduced to such a level
that they stopped the test.”
Well test durations are also dependent on the type of information that is sought and regulations. Therefore
the duration for a well test can vary between a few hours to weeks during the initial Exploration Period. If
permitted under South African legislation, and if longer term gas flow tests are to be performed, Shell is

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investigating alternative methods to evaluate gas flow which might convert hydrocarbons in more efficient
ways. These methods may include:

ƒ Combustion of the hydrocarbons in power generation units (turbines or gas engines) installed on-site.

ƒ Liquefaction of gas using surface facilities that will allow compression and cooling the gas to allow for its
transportation by truck to an existing nearby processing facility.

ƒ Capture and settling of any liquid hydrocarbons in a settling tank in preparation for export by truck to an
existing nearby processing facility.

5.6.3 Other project components


The proposed exploratory drilling activities will require additional infrastructure, which may include some or
all of the following:

ƒ Electricity usage: Throughout the exploration phase electricity for the exploration drilling and possible
fracturing activities will be provided through diesel generators on-site. If gas is discovered there may be
opportunities to utilize some of the gas for power generation. However, the rate or duration of flow
cannot predicted; therefore, diesel generation will be the assumed mode.

ƒ Accommodation: Drilling operations will require a number of crews (teams) that will work in rotating
shifts. These employees are expected to be a mix of technical professionals and semi-skilled who,
when not working at the well site will require temporary accommodation within an acceptable distance
of the well site. At this time no well sites have been identified, therefore options have not been
developed whether to, for example, establish a temporary camp or use locally available
accommodation. As plans start to be developed these types of options will be considered on a location-
by-location basis, following dialogue with the local community, landowners and considering the potential
impacts upon road transportation and employee safety.

ƒ Logistics/supply base: Not all materials and equipment required for drilling operations are stored at any
one time on a well site. Typically a supply base is established in a central location, such as a major
town, which allows for storage, preparation and possibly testing of equipment before being dispatched
for use to a well site. The location(s) for a supply base have not yet been selected because the
locations of well sites have not yet been selected. Additional considerations for a supply base could
include the existence of possible (brown-field) storage facilities, local skills, labour and other materials.

ƒ Roads and Traffic: The national network of roads, ports and railways will be used where ever possible
for the transportation of equipment and personnel. If specialist equipment has to be imported the South
African ports facilities will be utilised as much as possible. It is not envisioned that land transport will
involve unusually wide or heavy loads during the initial Exploration phase. Standard heavy goods
vehicle (HGV) transport will be used for the movement of the drilling rig and supplies. When well site
locations are finalised then it may be necessary to create or upgrade existing access roads from
national roads. This process would be subject to individual consultation with land owners and obtaining
necessary regulatory permits. A typical access road, to a well site, would be 6 to 10 metres in width,
allowing for standard HGV transportation of equipment.

5.6.3.1 Waste management


Shell indicates that the company will capture and recycle well construction materials as far as practicable. As
an example, cuttings will be separated from the mud returns at surface, allowing the mud to be treated and
re-used in the well and the cuttings to be transported from the well site to an appropriate waste disposal or
treatment facility registered for such purposes under South African legislation. Shell will develop a waste
management plan prior to commencing any drilling operations, and the plan will be applicable to the possible
range of materials to be used and collected at each well site location. All plans will comply with appropriate
legislation.

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5.6.3.2 Waste water treatment and disposal


Shell is committed to responsible water management and wherever possible will recycle and re-use water
and drilling fluids. This builds on Shells experience elsewhere in similar projects where water from drilling
operations has been cleaned, then re-used for other drilling activities, reducing overall the water use
requirements by ~50% on some North American unconventional business ventures.
During drilling operations fluids (drilling mud) return to surface where they are captured, recycled and re-
used wherever possible. The fluids returning to surface will contain chemicals and subsurface contaminants
mobilised during the drilling process. These elements will be removed from the fluids prior to reuse. Having
passed through separators the fluids are then flowed to secure storage tanks prior to cleanup and/or reuse.
If wells are hydraulically fractured, fluids used in this process return to the surface once the well is back
produced. These fluids are, referred to as ‘flow back’, can then be recycled, and mostly re-used for other
drilling activities. The percentage of fluids that can be re-used for other drilling operations will vary from one
well location to another as a result of even small variations in the geological properties of the shale
formations deep underground. Similarly, the quality of flow back water which may or may not require
additional treatment, prior to re-use, will likely vary.

Any water that is no longer required for the operation will be treated and cleaned up – using mobile water
processing equipment - in line with Shell’s own technical standards and relevant South African regulations.
The most suitable location for recycling will be sought in consultation with Regulators and environmental
consultants on a location by location basis.

5.6.3.3 Solid waste management


Throughout the operations, a number of solid waste elements will be produced. All products must form part
of a regulated waste management plan that Shell must produced as part of later regulatory permitting to then
be allowed to drill.
Some typical well site will include but not be limited to:-

ƒ Standard domestic waste;

ƒ Metal/plastic tubular thread protectors,

ƒ Used engine oil and filters,

ƒ Wood (Pallets, packing crates etc)

ƒ Unused Chemicals – (which will then typically be returned to the supplier)

ƒ Scrap Metal
It is Shell’s intention to contract a reputable local environmental disposal contractor who will dispose of the
waste in accordance with South African Legislation. The Contractor will be fully permitted to perform the work
on behalf of Shell.
As part of the Environmental Management Plan consultation and data gathering process, Shell has started to
investigate the capability of the waste treatment /disposal facilities across South Africa. There are
between~25 sites located in and around the licence areas that could be suitable locations to process the
waste products.

5.6.4 Decommissioning and rehabilitation


Following exploration activities, if the shale layer is not encountered and/or no gas is found present in the
shale, then a decision may be taken for that well site to be decommissioned. If a well is decommissioned
cement plugs are introduced at various stages inside the well bore depending on the geological formations
that have been drilled through, in accordance with Shell’s own technical standards, relevant South African
regulations and recognised Industry practice. This additional plugging is needed for the long term protection

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of groundwater, surface water bodies and soil. Well plugging involves removal of certain down hole
equipment.
Once plugged, the surface casing will be cut at a certain depth below surface (in line with South Africa
regulations and permits) and the wellhead removed. All remaining surface equipment will be removed from
the site. Shell will implement a site-specific land rehabilitation programme appropriate to the local habitat in
line with industry practices and regulations. Shell will consult with local experts and communities to design
and implement the most appropriate way to do this. This will be further assessed as part of the impact
assessment and studies may be then commissioned drawing upon local expertise if Shell is granted an
Exploration Right.

5.7 Resourcing and employment


During the initial exploratory drilling it is likely that certain technologies and equipment will need to be
imported, and highly specialised expertise or personnel be required. Efforts will be taken to source ancillary
services locally, or through companies with an established South-African presence. Whilst a number of these
roles will require specialized expertise, it is likely that over time, if gas is discovered and confidence grows
that there is sufficient volumes to develop, there will be further opportunities for local employment, training
and services generation.
At this stage there are large uncertainties whether gas will be found in the license area and if it is found,
exactly where that might be. Therefore, during the exploration process, Shell will align the development of
the B-BBEE strategy with increasing certainty if there is a viable long-term project and will work with
stakeholders in the process.
Exploration is typically a period for considerable investment, without generating revenues. However Shell will
seek to make meaningful contributions to broad based black economic empowerment (B-BBEE) aligned
projects, enterprises and organisations from the start of its operations in South Africa. Which may include :

ƒ Socio-economic development: contributing to specific, local socio-economic development and


enterprise development activities, for example, linked to specific, local capabilities development. The
dialogue with stakeholders to create the Environmental Management Plan (EMP) and subsequent
Environmental Impact Assessments (EIA), consultation with communities, local governmental and non-
governmental organisations will help Shell develop appropriate project concepts. It is envisaged that
these will initially be focussed on local capability development, but will change if exploration activities
are successful. Once decisions are taken to apply for Exploration Right renewals (over a 9-year period),
then with increasing confidence and understand that gas is present in the licence area, the emphasis
will increase towards local enterprise development, prior to making an application for a Production
Right.

ƒ Procurement: From a procurement perspective, Shell’s foremost priorities in all of its operations are
quality and Health, Safety and Environment (“HSE”) requirements. When assessing potential suppliers
of goods and services to use, Shell, employs a thorough and in-depth process of contractor and sub-
contractor assessment to ensure quality and HSE standards are maintained. Shell will identify various
categories of products and services will be required during the exploration phase, and undertake a
review which are available from South African suppliers of goods and services, for each of the
categories. Shell will endeavour to source products and services, for example, security, catering,
cleaning, transport/ logistics, etc. from local (B-BBEE) compliant parties during the exploration phase.
Shell will work with local companies to raise their capacity in terms of HSE if and where necessary to
enable them to become competitors for local contracts

ƒ Skills development: Shell is committed to attract, development and retain talented South Africans. For
any new project, such as the Shell Karoo Shale Gas Venture, Shell will establish a new team that
combine the best skilled local talent available, provide suitable training and where required utilise
specialist international staff, where skill transfer is required. Due to the uncertainty related to the phase
of the project (exploration phase), Shell does also not wish to create unrealistic expectations regarding
future employment opportunities at this stage of the project.

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5.8 What happens if gas is found?


If the presence of gas is indicated during the initial three year exploration period, Shell can make a formal
application to PASA to renew its exploration rights and to undertake additional exploration activities. This
request for a licence renewal can be made three times, which if granted each time, could allow Shell to
explore for up to nine years.
During later stages of exploration, if Shell successfully discovers gas which can be stimulated to flow to the
surface, the next step would typically be to drill additional wells, to establish whether similar geological
characteristics exist.
Once an area had been established that did have produce-able, sizeable volumes of gas, then the likely
engineering concept would be to drill several wells from a single, existing site, to touch the greatest area of
rock from a single point on the surface.
The guiding principles for the conceptual development are reduced surface footprint modularity and scale-
ability At this stage, due to large uncertainties (E.g.: where gas may be located, how much, how much each
well might flow etc) the concept is based upon using a modular, on (or near) well site mobile gas plants to
process the gas and generate electricity to then be distributed into the existing national electricity grid. In this
scenario additional infrastructure would be required to ”connect” the sites so that the gas can be distributed
or used to generate energy locally, feeding into existing infrastructure.
Shell is also considering other engineering concepts that could take gas that is discovered and generate
energy for the people of South Africa, as described earlier in this document.

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6.0 ENVIRONMENTAL MANAGEMENT PLAN (EMP) PREPARATION


PROCESS
This chapter briefly describes the regulatory situation, then
describes the technical assessment and public participation Box 1: EIA in terms of the National
process, both of which are required in the preparation of an Environmental Management Act
EMP report.

6.1 Regulatory requirements for the Drilling and hydraulic fracturing will trigger
listed activities under the National
EMP Environmental Management Act (NEMA)
Chapter 3, Legal Context, sets out the legal context for this (Act 107 of 1998), notably the following:
EMP, referring to various acts and regulations that need to
be taken into consideration. Below, regulatory requirements ƒ Activity 24 of Notice 1, GN 544,
in terms of the Mineral and Petroleum Resources requiring a basic assessment: The
Development Act, 2002 (Act 28 of 2002) (MPRDA) are transformation of land bigger than 1 000
described as background to the process followed to develop m2 in size, to residential, retail,
the EMP. commercial, industrial or institutional
use …. (Drill sites will be 100 x 100 m,
Note, however, the requirements of the National thus 10 000 sq m).
Environmental Management Act shown in Box 6.1 and
discussed in Chapter 1, Conclusions and ƒ Activity 4 of Notice 2, GN 545, requiring
Recommendations. a full EIA: The construction of facilities
or infrastructure for the refining,
In terms of this EMP process, the MPRDA stipulates that extraction or processing of gas, oil or
Any person who applies for a reconnaissance permission, petroleum products with an installed
prospecting / exploration right or mining permit must submit capacity of 50 cubic meters or more per
an environmental management plan as prescribed within a day… (It is assumed that hydraulic
period of 120 days from the date of acceptance of the fracturing during exploration drilling
application. could stimulate 50 cubic meters or more
The contents of an Environmental Management Plan are of gas per day).
prescribed in the MPRDA Regulations Section 52, shown in Thus, an Environmental Impact
Box 6.2. Considering section 52 (2) (b) and (c) of the Assessment for drilling and hydraulic
Regulations, an assessment of environmental, socio- fracturing will be required in terms of the
economic and cultural impact is required, and not an NEMA. This is further described in
Environmental Impact Assessment process in terms of s 39 Chapter 11, Conclusions and
(1) of the MPRDA. Recommendations.
6.2 Approach to assessment to
prepare the EMP
Shell had a Technical Cooperation Agreement with PASA for 12 months (December 2009 to Dec 2010). No
field work or environmental baseline studies were permitted during this period. In December 2010, Shell had
to decide whether to apply for an exploration right or not, and whether within 120 days of PASA accepting
the application to submit an EMP or not. The company chose to apply for the right and submit the EMP
within 120 days (four months). But effectively, this requirement in the MPRDA leaves little time for
environmental baseline studies or for identifying potential drill sites.
The consultants met with PASA in this regard, and in particular because of the extensive stakeholder
concerns around both the proposed exploration project and the time available to prepare the EMP. In
PASA’s view, indicated in a meeting with the consultants in February 2011, the assessment and EMP
should, in the absence of specific drilling sites, at least assess and make recommendations for mitigation in
respect of the types of activities to be conducted somewhere within the regional areas.
Given the above, the approach followed in the assessment was to identify and assess potential impacts in a
broad, regional context, as well as to assess specific exploration activities generically but not in a site-

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specific context. A typical gas exploration well was used to assess potential impacts and to develop
indicative mitigation measures, but these need to be confirmed during the NEMA EIA, and this EMP will then
need to be updated.

Box 2: Contents of an Environmental Management Plan as prescribed in the MPRDA


Regulations Section 52

Environmental Management Plan

52. (1) An applicant who’s application for a prospecting right or mining permit was accepted in terms of the
Act, must submit an environmental management plan at the office of the Regional Manager in
whose region the application was lodged within 60 days from the date of notification by the Regional
Manager.
(2) An environmental management plan, must substantially be in the standard format provided
by the Department and must contain:
(a) a description of the environment likely to be affected by the proposed prospecting or mining
operation;
(b) an assessment of the potential impacts of the proposed prospecting or mining operation on the
environment, socio-economic conditions and cultural heritage, if any;
(c) a summary of the assessment of the significance of the potential impacts, and the proposed
mitigation and management measures to minimize adverse impacts and benefits;
(d) financial provision which must include-
(i) the determination of the quantum of the financial provision contemplated in regulation 54;
and
(ii) details of the method providing for the financial provision contemplated in regulation 53;
(e) planned monitoring and performance assessment of the environmental management plan;
(f) closure and environmental objectives;
(g) a record of the public participation undertaken and the results thereof; and
(h) an undertaking by the applicant regarding the execution of the environmental management
plan.

6.3 Technical assessment


6.3.1 Process
The technical assessment process consisted of the following:

ƒ Gather broad, regional environmental, social and health baseline data for the application area, using
publicly available data bases and other data sources such as the National Groundwater Database, the
South African Biodiversity Institute database (the SANBI's Biodiversity Advisor38),and others (Chapter 4,
The Existing Environment – the Karoo);

ƒ Gather field data to verify the accuracy of publicly available data in respect of terrestrial ecology, noise
and groundwater. Field studies were done in some of the notional (provisional) drilling areas, each more
than 30 sq km in size, as shown on the map in Figure 1, Chapter 1, Introduction. Field data is reflected
in Chapter 4, The Existing Environment – the Karoo;

ƒ Gather data from international sources on the potential impacts of drilling and hydraulic fracturing since
this type of exploration is new to South Africa, and because of stakeholder concerns about the
exploration methodology in other countries (Chapter 2, Context and History);

38
http://biodiversityadvisor.sanbi.org/

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ƒ Considering comments, local knowledge and information from landowners and other stakeholders
received via the public consultation process described in the next section;

ƒ Assess the potential impacts, both negative and positive, of exploration activities, regardless of where in
the application area they would be conducted (Chapter 8, Environmental Assessment);

ƒ Recommend measures for mitigation of impacts to avoid or reduce negative impacts, and to enhance
positive impacts (see Assessment Reports in Volume 2);

ƒ Capture mitigation measures for each exploration activity in an EMP (see Chapter 9, Environmental
Management Plan);

ƒ Define provisional criteria for the selection of drilling sites to be done during a NEMA EIA process
should this application be approved by PASA (see Chapter 7, Alternatives Consideration); and

ƒ Set closure and environmental objectives (see Chapter 9)


Financial provision required in terms of section 52 of the MPRDA Regulations Section 52 is presented in
Chapter 10 (Understanding and Commitments by the Applicant).

6.3.2 Technical assessments


The baseline information collected and the assessment of potential impacts are captured in a series of
technical assessment reports contained in Volume 2:

ƒ Soils; Terrestrial ecology; Surface water; Groundwater; Noise; Air quality; Heritage and Social.
6.4 Public consultation
This section summarises the requirements for consultation, and the consultation process. The full Public
Consultation Report is included in Volume 2. A Comment and Response Report, in which all stakeholder
comments are captured with responses, is also available.
The MPRDA is brief on public consultation during the development of an EMP. Section 79 (4) of the Act
states: If the designated agency accepts the application, the designated agency must …notify the applicant
in writing (a) To notify and consult with any affected party.
However, good practice principles reflected in the NEMA guide consultation, and these were applied.

6.4.1 The consultation process


The process is shown in Figure 40 and summarised below.

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Identifying landowners and other


PUBLIC CONSULTATION PROCESS TOWARDS THE  stakeholders
DEVELOPMENT OF THE EMP FOR EXPLORATION 
A total of 2,213 stakeholders have
(NOT PRODUCTION) registered as stakeholders across all
Public Consultation Process three of Shell’s exploration application
processes of which 1,337 stakeholders,
IDENTIFICATION OF IAPS including 308 landowners, are currently
registered for the Central Precinct EMP
process.
PROJECT ANNOUNCEMENT They represent various sectors of
Notification  Information  Comment  Paid  Public  Web‐ society: national, provincial and local
letter to 
landowners
letter to 
public
Sheet adverts Places site government, landowners, agriculture,
conservation, cultural heritage,
education, research, NGOs, research
CONSULTATION organisations, and many others.
OPEN HOUSES AND PUBLIC MEETINGS Landowners were identified through the
Victoria‐West Beaufort‐West Murraysburg Graaff‐Reinet Surveyor General’s title deeds database.
Other stakeholders were identified
through networking and referral and in
response to media advertisements.
When stakeholders were registered by a
COMMENTS AND RESPONSE REPORT spokesperson, their permission for
registration was obtained telephonically.
Information on potential land claimants is
being awaited from the Northern and
Western Cape Departments of Rural
ANNOUNCE DRAFT EMP Development and Land Reform.
Announcing the opportunity to
DRAFT ENVIROMENTAL MANAGEMENT PLAN AND  comment and providing information
SUMMARY We  (January 2011 – February 2011)
are 
Distribution 
Public Meetings Minutes as CRR
here The first document for comment, a
of documents Background Information Document
(BID), was distributed in the week of 03
January 2011. The comment period on
SUBMISSION OF FINAL EMP TO PASA the BID ran up to 18 February 2011. The
process was announced as follows:

PROGRESS FEEDBACK
ƒ Telephone calls to organisations
and other bodies alerting them to
documents being mailed;
End of EMP process
ƒ Paid advertisements, in English and
Afrikaans, in two national, one regional
LETTER TO ANNOUNCE DECISION and six local newspapers;

Letter Adverts ƒ Announcements on two national


radio stations;

Figure 40: Public Consultation Process towards the development ƒ Distributing a BID accompanied by
of the EMP for exploration (not production) - Central Precinct a letter notifying Stakeholders of the
proposed project, EMP and consultation
process, in English, Afrikaans and Xhosa; more than 2,800 hard copies and 350 electronic copies
distributed;

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Providing information on the proposed project and EMP process took place as follows:

ƒ Distributing the BID mentioned above, and making available lists of affected properties on Golder’s
website (www.golder.com), at nine public places, at open houses and public meetings and sending
copies to stakeholders upon request;

ƒ Telephone calls to key stakeholders, e.g., farmer’s unions, local communities, NGOs, CBOs to confirm
their attendance at the open houses and public meetings; and

ƒ Convening open houses in Victoria-West, Beaufort-West, Murraysburg and Graaff-Reinet (Figures


Figure 41 – Figure 47) where the project and process were visually displayed and/or presented. At the
request of stakeholders some open houses were run as public meetings in which the proposed
exploration project was presented and there was collective discussion.

Obtaining comments
Comments were obtained in various ways, as follows:

ƒ During the open houses/public meetings mentioned above, where stakeholders commented directly to
members of the EMP team;

ƒ Meetings with three national and three provincial authorities; and

ƒ Comment sheets were returned by stakeholders after having read the BID or having attended meetings,
written submissions were received by email or mail and telephonic comments were recorded.

Figure 41: Materials that were made available at the open Figure 42: Posters displayed at the open house in
houses for Stakeholders to take home Victoria West

Figure 43: Sreejeeta Datta from Shell explains the Figure 44: Toni Pietersen from Golder helps local
environmental authorisation process at the open house in farmers to locate their farms in the map books to
Beaufort-West. confirm details

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MP for Applic cation for Ga
as Exploration
n in the Westtern Karoo (C
Central
Precincct) by Shell Exploration
E Co
ompany B.V.

Figure 45: Duuring the discuussion session


n at the publicc Figurre 46: Mr Joha
an Mans, a farrmer and busiinessman
meeting in Murraysburg
M farmers wantedd to know what the who attended the public
p meeting g in Murraysbuurg officially
impacts of hyydraulic frackin
ng would be on
o downstream m handds over a memmorandum of q questions and concerns for
groundwater resources the environmental
e specialists to consider durin
ng their
studiies

Figure 47: Leeft and right: Stakeholders


S i the Graaff-R
in Reinet area attended the pu
ublic meeting in Graaff-Rein
net where the
e
community asked
a what kind
k of guaranntees Shell could
c provide in case of a pollution inccident during the hydraulicc
fracturing pro
ocess of gas exploration.
e

6.4.2 Next step


ps in the public
p con
nsultation process
The next ste
eps in the prrocess are:

ƒ Annou uncing the avvailability of the Draft EMP


P for commeent. This will be done by w
way of letters
s addressed
to stakkeholders personally, advvertisements in the printe
ed media, emmail, and annnouncements s on the
Golderr website;

ƒ Conve
ene public an
nd other mee
etings with sta
akeholders and
a organisa
ations in Marcch/April 2011
1;

ƒ Collating commentts on the Dra


aft EMP into a Comments
s and Response Report o
on the Draft EMP;
E and

ƒ Once the
t PASA de
ecision is ava
ailable later this
t year, nottify stakehold
ders.

6.5 C
Commen nts and is ssues
A total of 2,796 issues and
a commen nts were raise
ed across all three precin
ncts of which
h stakeholderrs registered
with the Cen ntral Precincct process co
ontributed a total
t of 2,074
4 comments and
a issues b broadly summmarised
below. Each h issue raiseed, or comme ent made hass been respo onded to with
hin the Commment and Reesponse
Report.

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ƒ Aesthetics

ƒ Many stakeholders said the Karoo is a special and treasured environment due to its landscape
quality, quietness, heritage, and sense of place. They were concerned about a range of possible
impacts that would bring industrialised activity.

ƒ Biodiversity and rehabilitation

ƒ Given the low ecological resilience of Karoo ecosystems, and the presence of Red Data Book
species, landowners, conservation bodies and other stakeholders were concerned about potential
impacts to biodiversity. Farmers said there is little research on the rehabilitation of disturbed veld
and that it could take up to 30 to 40 years for a disturbed habitat to recover, if at all;

ƒ Conservation NGOs indicated that some trial research projects on rehabilitation in the Karoo have
been completed recently and offered specialists access to the data; and

ƒ National parks indicated that information on Red Data species that occur in the Central Precinct is
available to environmental specialists.

ƒ EMP process and EMP Report Appreciation for contribution


ƒ NGOs, representatives from research institutions and by stakeholders
landowners were concerned about the limited time Many stakeholders have participated in
available to develop the EMP, and that the authority the process to develop the EMP by
decision will be based on a report lacking critical attending meetings and by taking the time
information on the potential impacts of gas to prepare written submissions.
exploration. They asked that the process of
developing the EMP comply with regulations, Some landowners hosted members of the
compare valid alternatives, and receive a proper EMP team in their homes or offices, or
independent review; and showed them around their properties.

ƒ People asked whether the assessment would include The EMP team wishes to express sincere
a thorough assessment of environmental risks arising appreciation for these contributions.
from the exploration, and what risk management
measures will accompany this. They wanted to know how the assessment can be sufficiently
thorough when the project description is not yet firm.

ƒ Financial provision

ƒ There was concern that the statutes and regulations governing the proposed development are not
adequate to protect the public interest, and/or that the regulations and conditions of approval will not
be properly enforced. Fearing an event like the one which happened recently in the Gulf of Mexico,
stakeholders asked that Shell prove that exploration in the Karoo will be safe, and asked for
examples of similar work the company has undertaken. They wanted Shell to provide a financial
guarantee in the event of environmental harm.

ƒ Human health

ƒ Concerns were expressed about impacts on community and human health, including cancer risk,
arising from air pollution, water pollution and potentially from radio-activity. Stakeholders wanted to
know if the assessment will identify and evaluate the potential sources and impacts of radio-activity,
including uranium.

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ƒ Landowner and property rights and values

ƒ Many farmers and landowners wanted to know whether they had the right to refuse Shell and
environmental specialists access to their land and what process will be followed to gain access to
land once the drill sites have been identified; and

ƒ Landowners were concerned about their property rights, and that adverse public perception will
have an impact on the market value of their properties. They wanted to know if property owners will
receive compensation in case of loss or liability arising from the proposed exploration and its
impacts.

ƒ Local and regional development

ƒ Stakeholders said the EMP must address the potential knock-on effects of the proposed project on
local and regional development planning, including land use planning

ƒ Transport

ƒ Landowners said that provincial, regional and local roads are in poor condition and will deteriorate
with additional traffic as a result of the transport of heavy equipment and materials, and that traffic
hazards will increase due to additional vehicles on the roads.

ƒ Waste management

ƒ Stakeholders asked that the nature and consequences of waste generation, including acid mine
drainage, during exploration, should be quantified and compared with the limited waste disposal
capacity in the Karoo region;

ƒ Stakeholders stated that the Karoo is known for flash floods. They wanted to know how Shell will
deal with flash floods if water is contained in ponds as part of the waste management process. They
are concerned about the potential negative impacts on the environment; if pollution occurs who will
be responsible for management of, and/or clean up the pollution?

ƒ Farmers wanted to know what the risks are of toxic waste being generated during the hydraulic
fracturing process and who will pay for the transport of toxic waste. Facilities for waste disposal in
the Karoo are small with no facilities for hazardous waste. Where would the hazardous waste that
would be generated be disposed of?

ƒ Safety and security

ƒ Landowners were concerned that the exploration project will increase traffic and access to their
properties by unknown persons, thus compromising security.

ƒ Sustainable development

ƒ Stakeholders said the perspective of sustainable development and cumulative impacts should be
assessed. A comparative life-cycle assessment of natural gas development as opposed to
alternative energy source development should be provided through proper cost benefit analysis.
The question was asked about whether this type of development should be allowed in a water-
stressed environment.

ƒ Socio-economic issues

ƒ The impacts on local and regional socio-economic factors, including impacts on employment,
migration and urbanization, on tourism, export products, food security, on road access, and the
sharing of benefits from the project, were raised as issues.

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ƒ Water resources and waste water management

ƒ Stakeholders asked what volumes of water will be required for drilling and hydraulic fracturing,
where the water will be obtained from and if obtained from a farmer, how the farmer will be
compensated;

ƒ Questions were asked about the management of excess and waste water from hydraulic fracturing
and how monitoring will be conducted to measure potential impacts to groundwater and the
environment; and

ƒ Concerns were expressed about horizontal drilling below wetlands and surface water courses.
ƒ Groundwater: NGOs, the business sector and landowners wanted to know whether specialist
studies will be conducted to study the interaction of the various underground systems, e.g., shallow
water aquifers, deep water aquifers, ancient water aquifers and artesian wells within the exploration
area;

ƒ Since hydraulic fracturing is a new technology in South Africa, there is little information available on
its potential impacts locally. Stakeholders were concerned about the potential impacts of hydraulic
fracturing when the hazards of deep and shallow drilling are unknown, and in the knowledge that
the US EPA has placed a two-year moratorium on this type of exploration. They also question why
Shell and the consultants did not disclose which chemicals would be used in hydraulic fracturing;

ƒ Stakeholders asked that the potential impacts on groundwater resources, including disturbance of
the aquifers, pollution of groundwater by chemicals used in fracturing, and increased abstraction, be
properly assessed. They feared that if one aquifer were to be contaminated, all others will be
affected too because the aquifers are likely to be connected; and

ƒ Conservation organisations, NGOs and academia asked that the precautionary principle be applied
and that the exploration rights application be rejected until the consequences of hydraulic fracturing
are better understood and until there is demonstrated proof that hydraulic fracturing is not harmful to
human health and the environment.

ƒ Socio-economic impacts on the Karoo communities

ƒ Stakeholders indicated that the proposed project could help address poverty and other social
problems experienced in local communities. They asked whether this project will bring education
and build capacity in local communities; and

ƒ Some stakeholders expressed concern that the proposed project will impact negatively on tourism
in the area. They suggested that a thorough analysis be done on the impacts of the proposed
project on tourism.

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7.0 CONSIDERATION OF PROJECT ALTERNATIVES


In the event that Shell is granted a gas exploration license by PASA, the company will undertake further
planning for gas exploration in a number of steps. These are described in greater detail in Chapter 5, Project
Description, but are briefly summarized here for the purposes of a discussion about alternatives.
Also as background to this discussion, Figure 48 shows the environmental process to the stage of
completion of a NEMA Environmental Impact Assessment prior to drilling and hydraulic fracturing of wells, as
discussed in earlier chapters.

Figure 48: Environmental process to the stage of completion of a NEMA Environmental Impact Assessment prior to
hydraulic fracturing of wells

Based on previous Soekor data from the 1960s and desktop work, Shell has defined notational drilling areas
as described in Chapter 5, Project Description. These notional areas were based on a desktop study and
high level considerations such as topography, road access, etc. The precise locations where exploration
drilling activities may take place have not yet been identified. This will be done with inputs from
environmental specialists and in consultation with stakeholders, including land owners through the following
steps:

ƒ Step 1: Refine the areas within which drilling could be considered

ƒ Step 2: Determine the specific location of proposed drilling sites in the licence area, on the basis of
integrated technical and environmental analysis and in consultation with the landowners. Prepare a
preliminary Site Selection Report. This step will be undertaken jointly by Shell and independent
environmental consultants.

ƒ Step 3: Prepare an Environmental Impact Assessment (EIA) in accordance with the requirements of the
National Environmental Management Act (NEMA). The preliminary Site Selection Report will be subject

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to public review and will only be finalized during the Scoping Phase of the EIA. The EIA will be
prepared, as required by the NEMA, by independent environmental consultants.
The alternatives that will be considered will consist of various options that could avoid or minimise the
potential impacts as described in Chapter 8 or enhance the benefits of the proposed exploration activities.
This EMP and future EIA studies will not include a comparison of shale gas with alternative energy forms,
which is beyond the terms of reference of this and future EIA investigations. Given the general nature of this
PASA application, it is not possible to consider specific alternatives in detail in this report.
The remainder of this chapter presents an outline of the method that will be used to select sites for drilling as
well as other alternatives that are also likely to be open for consideration in the EIA, if the exploration project
is approved by PASA.
Criteria used to identify drilling sites will be further defined during the subsequent EIA process in terms of
regulations and with input from the subject matter specialists.

7.1 Location alternatives


The selection of drilling sites within the application area will be determined by integrated technical and
environmental analysis. Table 22 presents a preliminary listing of criteria which will help to refine the
locations for drilling sites. It is emphasised that these criteria are preliminary, and are meant simply to
illustrate the structured process that will be followed in order to finalize drill site locations. It will start
BEFORE the EIA as part of the preliminary site selection report Consultation with stakeholders may result in
changes or additions to the criteria.
Table 22: Preliminary criteria to use in refining possible locations for well sites (Note: these criteria
will be further defined during the EIA)

ASPECT DESCRIPTION OF PRELIMINARY ISSUE ADDRESSED


CRITERION
Agriculture SITE NOT to be situated on high potential Economic loss
arable land
Infrastructure (airfield) SITE NOT to be closer than 500m to any Use conflict
airfield
Slope SITE NOT to exceed an average slope of Erosion hazard
10%
Infrastructure (boreholes) SITE NOT to be within 100 m of any Groundwater pollution
borehole
Geology SITE NOT to be closer than 500m to the Groundwater pollution
nearest major dyke present at surface
Dams and Rivers SITE NOT to be closer than 500 m from Surface water pollution /
the nearest dam or perennial river biodiversity
Wetlands SITE NOT to be closer than 100 m from Surface water pollution /
areas of hygromorphic soils biodiversity
Protected Areas SITE NOT to be closer than 500 m from Biodiversity
the boundary of any proclaimed
conservation area
Threatened habitat SITE NOT to be within any area Biodiversity
untransformed area of endangered habitat

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ASPECT DESCRIPTION OF PRELIMINARY ISSUE ADDRESSED


CRITERION
Landowner agreements SITE PREFERABLY to be where Good relations
landowner/s have consented and entered
into an agreement for land access
Homesteads SITE NOT located in close proximity to Nuisance, risk
homesteads – distance to be confirmed
by noise specialist studies, etc

The above preliminary criteria are intended as a means of further narrowing the possible sites using a simple
methodology which is suited to screening of large areas, using computer generated overlay mapping. Final
identification of specific sites within the areas defined as suitable can then follow, using a more layered
approach which compares the details of individual sites.

7.2 Technology alternatives


Various technology and infrastructure alternatives exist which will be considered during the course of the EIA
for each of the wells. The alternatives will vary depending on the location of the well site and the
circumstances specific to each well. Once the location of the well has been identified, realistic options
concerning each of the alternatives described below will be defined and evaluated.

7.3 Access roads


A route selection process will be undertaken to determine the alignment of the access roads to the well sites.
Where possible, existing access roads will be upgraded in preference to constructing new roads.

7.4 Water supply


Between 1 and 6 million litres (Mega litres) of water is typically required per well for the purposes of drilling
and well fracturing in the exploration phase. The following water supply options will be investigated and
assessed during the EIA, depending on the location of the well:

ƒ Deep groundwater aquifers (including wells sufficiently deep to access brackish-to-saline water
supplies);

ƒ Raw (untreated) water from a local municipality;

ƒ Treated wastewater from a local municipality, mine or any other facility generating wastewater;

ƒ Surface water from large perennial rivers or dams and potentially seawater
Water conservation measures are also feasible and have been used by Shell and other companies in other
locations. Measures that may be considered in individual cases include re-use of flow back, which can
reduce water consumption. In other operations, Shell has achieved up to 50% reuse but this will vary from
location to location. Shell has indicated that it will not compete with landowners for fresh water.

7.5 Water storage alternatives


Water required for drilling operations will be stored, either on-site or nearby. There are various options to
store water, such as using metal tanks, pillow tanks or geotextile lined bunded-wall containment. The type of
storage provided may depend, in part, on the quality of the water supplied.

7.5.1 Transport routes for water supply


Water supplied from remote sources may be initially by train in the case of sea water, and then by truck.
Water supplied from freshwater or groundwater sources is likely to be transported to individual drilling sites

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by truck. Specific transport routes will be assessed as part of the subsequent EIA process once drill site
locations are known.

7.6 Waste disposal alternatives


Fluid used for drilling and fracturing will be recovered. This fluid will be treated; the wastes emanating from
the treatment process will be temporarily stored in containers on site. The disposal method will depend on
the location of the site and the quality of the return flow water.
Shell will develop a waste management plan prior to commencing any drilling operations. The plan will be
applicable to the possible range of materials to be used and collected at each well site. It will cover the
disposal of fracturing fluid. It will also take into consideration the location of the drilling site and available
waste disposal options relative to individual drill sites.

7.7 Capturing hydrocarbons on surface


Hydrocarbons surfacing from the well will either be flared or captured for use. Flaring would involve the
installation of short gas flow lines from the well bore to a flare. Capturing and use of the hydrocarbons could
involve:

ƒ Combustion in power generation units (turbines or gas engines) installed on site.

ƒ Liquefaction of gas by means of surface facilities that will allow compression and cooling for
transportation by truck to the nearest refinery.
Both of the above cases could involve the pre-settling of any liquid hydrocarbons in a settling tank in
preparation for export by truck to the nearest refinery, prior to the use of the gas.

7.8 The ‘no go’ alternative


The intention of the ‘No go’ alternative as an option in environmental analysis is to provide the decision
maker with a view of what will be foregone in the event that the proposal does not go ahead. This may then
be compared with the possible impacts resulting from the implementation of the proposal, so as to provide a
balanced view of the costs and the benefits of a particular course of action. The analysis is often complicated
by the fact that some of the major benefits that could be foregone are national, regional, and strategic,
relating to issues such as energy security. These are difficult to compare with the specific, direct local effects
(both positive and negative) of developing the resource.
In the case of the current project, it must be borne in mind that the application is for an exploration right, and
not for the development of shale gas fields – the application for which would have much wider implications.
The Shell exploration right would involve the installation and testing of perhaps up to 8 wells in a 30 000 sq
km area . This is an important distinction since there is a tendency to judge the desirability of the exploration
phase of oil and gas development on the basis of the anticipated, but as yet unevaluated, impacts of a future
production well field. The legal (and reasonable) present compliance requirement is to consider only the
impacts of the exploration phase. The desirability of developing a production well field and the positive and
negative issues associated with this must be undertaken at the appropriate time, if and when such
authorization is sought.
Even in relation to the restricted extent of Shell’s exploration right application, assessed in this report, there
are limitations affecting the extent to which the ‘no go’ alternative can be meaningfully compared with direct
project related impacts. This is because the well sites have not been determined yet, which precludes a
meaningful assessment of local impact caused by each well site. While there is still much debate
surrounding shale gas extraction around the world, with many protagonists and detractors, it is clear from the
evidence emerging from the burgeoning shale gas industry that there can be both successful, low impact
well installations and questionable, high impact installations. The impacts depend on the local circumstances
and the technology selected to manage the impacts and safety standards associated with the well. It is not
possible to make meaningful generic statements about shale gas exploration without consideration of the
specific circumstances surrounding each well.

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With this said, the intention of this subsection is to provide some insight into the benefits that could be
foregone in the event that the proposed shale gas exploration does not go ahead. The benefits as
summarised below are stated in more detail in Chapter 2, Context and History.

7.8.1 South African Energy Policy


In the South African Government’s 2009 Energy Policy, the then DME reflects that one of five key policy
objectives is to secure energy supply through diversity. South Africa has never become fully energy self
sufficient in either petroleum or nuclear fuels. The heavy investment in the apartheid era in synthetic fuels
and nuclear development was costly and left the country with a legacy of undiversified supply. The current
policy is to encourage diversity of supply both locally, wherever there are promising opportunities, and
through international energy trade.
Pertaining to this, the Government commits through the Energy Policy to promote the development of South
Africa’s oil and gas resources by ensuring a range of undertakings are met, including appropriate tax and
contractual arrangements to encourage private investors, promoting research and technology development
and technology transfer to stimulate the development of the country’s oil and gas resources and ensuring
that there is appropriate environmental management and stewardship of any oil and gas development. The
Energy Policy further states (Section 7.5.12) that the approach that has been followed in some countries to
limit the use of gas to particular applications (due to perceived limitations in gas reserves) will not be
followed. The South African Government perceives this as having limited the growth of gas markets and
hence the rate of gas exploration. Even in 1998, when the Policy was published, the Government recognised
that gas reserves are far larger than had been expected (Section 7.5.12).

The Government also acknowledges the benefit of gas as a ‘cleaner fuel’. In the White Paper on Renewable
Energy, published in 2003, it notes that the current euphoria about gas has primarily environmental roots, but
it cautions that a potential shift to natural gas as a significant contributor to energy supply is unlikely since
South Africa has very limited known reserves of natural gas, estimated to be only 0,5% of coal reserves,
even when Mozambique and Namibia are included. These reserves are therefore not expected to materially
change South Africa’s dependence on coal and the Government is looking to increase the potential
opportunities for the growth of the renewable energy industry over time; a strategy which is complimentary to
development of natural gas resources as gas provides a useful foil to the limitations of renewable in terms of
reliability of supply

7.8.2 International Trends in Natural Gas Supply


The rapid development in the international use of gas has changed the world’s energy landscape. The
natural gas supply revolution rests on two pillars of innovation – firstly, improvements in production
technologies that have made it economical to produce shale gas and tight gas resources that were
previously considered too difficult to tap, and secondly the diversification and globalization of natural gas
markets. Worldwide, there is now sufficient technically recoverable natural gas in the ground for 250 years at
current production rates. The development of liquid natural gas (LNG) as an efficient means of transporting
natural gas anywhere in the world and the huge gas reserves provided by shale gas have been mutually
reinforcing, providing the increased resource and the flexibility of supply to guarantee the security of natural
gas supply for the long term, thereby providing governments and investors with greater confidence to
support the growth of the natural gas industry.

7.8.3 Environmental Benefits of Natural Gas Use


Natural gas is the cleanest burning of all the fossil fuels (gas, oil and coal). Composed primarily of methane,
the main products of the combustion of natural gas are carbon dioxide and water vapor, the same
compounds people exhale when they breathe. Coal and oil are composed of much more complex molecules,
with a higher carbon ratio and higher nitrogen and sulphur contents. This means that when combusted, coal
and oil release higher levels of harmful emissions, including a higher ratio of carbon emissions, nitrogen
oxides (NOx), and sulphur dioxide (SO2).
Coal and fuel oil also release ash particles into the environment, substances that do not burn but instead are
carried into the atmosphere and contribute to pollution. The combustion of natural gas releases very small

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amounts of sulphur dioxide and nitrogen oxides, virtually no ash or particulate matter, and lower levels of
carbon dioxide, carbon monoxide, and other reactive hydrocarbons.
In a major study by the United States Environmental Protection Agency (USEPA) and the Gas Research
Institute (GRI) in 1997, aimed at determining whether the reduction in carbon dioxide emissions from
increased natural gas use would be offset by a possible increased level of methane emissions, it was
concluded that the reduction in emissions from increased natural gas use strongly outweighed the
detrimental effects of increased methane emissions. Thus, the study supported the increased use of natural
gas in the place of other fossil fuels as a means of reducing emissions of greenhouse gases globally.
The use of natural gas does not contribute significantly to smog formation due to low levels of nitrogen oxide
emission and virtually no particulate matter emission. For this reason it can be used to help smog alleviation
strategies where air quality is poor (e.g. Sasolburg). Increased natural gas use in electricity generation would
have a major positive impact on smog formation.
As said, natural gas contains very low concentrations of sulphur and nitrogen oxides (Table 23). These are
the pollutants primarily responsible for acid rain damages to crops, forests and wildlife populations, and
cause respiratory and other illnesses in humans. Principal causes of acid rain are emissions from coal-fired
power plants.
Table 23: Fossil fuel emission levels – pound per billion Btu of energy input
Pollutant Natural gas Oil Coal

Carbon dioxide 117 000 164 000 208 000

Carbon monoxide 40 33 208

Nitrogen oxides 92 448 457

Sulphur dioxide 1 1 122 2 591

Particulates 7 84 2.744

Mercury 0.000 0.007 0.016

7.8.4 Global trends in the use of shale gas


In the continuing search for sustainable and secure energy, world attention has turned to ‘new’ and
promising technologies for supplying energy resources. These ‘unconventional methods’, and in particular
shale gas extraction technologies, have been making headlines over the past few years. The ability to
extract gas from shales at economical prices means that very large recoverable deposits of shale gas can
now realistically be developed. Much of this gas lies in non-OPEC39 countries, and its development could
widen the base of energy supply and improve global energy security.
There are more than 688 shale formations wordwide in 142 basins. At present, only a few dozen of these
shales have known production potential, most of which are in North America, where shale gas extraction is
most advanced. Developing shale gas infrastructure may be costly, depending on the location, requiring
significant capital investment to process, store and distribute the gas. This means that that the viability of
each resource will need to be assessed on its own merit, taking into consideration the local infrastructure
and market conditions (World Energy Council, 2010).
The potential volumes of shale gas worldwide are thought to be enormous. Nevertheless, the resource has
not yet been quantified on a national level by most countries. The most credible studies put the global
resource at around 456 trillion cubic meters (tcm) compared with 187 tcm for conventional natural gas. It is
estimated that about 40% of this could be recoverable using currently available technology. The World

39
OPEC – Organisation for Petroleum Exporting Countries

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Energy Council (2010) emphasises that these estimates are likely to be revised (generally upward) as proper
assessments are performed in countries where the resource has not yet been estimated (an example of the
USA is provided in which the estimate of available shale gas was revised upward from 21,7 tcf to 32,8 tcf in
a single year).
Worldwide, the World Energy Council (2010) sees the increased security of supply of natural gas as a result
of shale gas impacting on many aspects of energy policy and practice. Natural gas power plants are likely to
become more common, given the significantly better performance of gas compared with other fossil fuels in
relation to global warming. The World Energy Council also sees natural gas being used in tandem with
renewables, to supply the energy needed at night (solar power generation) and when the wind doesn’t blow
(wind power generation). Because of the widespread occurrence of shale gas, energy supply may become
more localized.

The World Energy Council (2010) views the emergence of shale gas as an energy resource to be a
potentially major factor in strategic geopolitics across the globe. The advantages of expanding the use of
shale gas include:

ƒ Adding significant quantities of natural gas to the global resource base

ƒ Shorter time to first production compared with conventional gas

ƒ Using a cleaner energy resource

ƒ Broader use of new drilling technologies around the world, and

ƒ Improved security of supply for gas importing countries


On the negative side, the drawbacks at a global level are:

ƒ Uncertainty over costs and affordability

ƒ Doubts about the environmental acceptability of the production technology

ƒ Unclear rates of decline which may materially impact reserve estimates, and

ƒ Local opposition to shale gas development.


In its annual World Energy Insight (2010), the WEC concludes that the greatest concern is the fear in some
quarters that hydrocarbons or chemicals used in hydraulic fracturing might flow into aquifers that supply
drinking water. However, the WEC expresses the view that in most instances the gas bearing and water
bearing layers are widely separated by thousands of vertical feet, as well as by rock, with the gas being
much deeper and that hydraulic fracturing is therefore unlikely to be a risk to groundwater in such cases. The
risks of contamination from surface handling of wastes, common to many similar industrial processes,
require continual care but are not un-manageable.
As indicated by the World Energy Council, there are contrary views. Concerns about the human health and
pollution risks of hydraulic fracturing are not limited to the general public. Examples of such concerns may be
seen in the Final Impact Assessment Report on Natural Gas Production in the New York City Water Supply
Watershed (Hazen & Sawyer, 2009). In examining proposals for hydraulic fracturing in the West-of-Hudson
watershed, where the quality of water supply makes possible the use of unfiltered water supply systems to
very large numbers of people in the State, this study observes:

‘Natural gas development in the West-of Hudson watershed at the rates and densities observed in
comparable formations (full well field development of 3000 - 6000 wells), will be accompanied by a level of
industrial activity and heightened risk of water quality contamination that is inconsistent with the expectations
for unfiltered water supply systems. Intensive natural gas well development in the watershed (will) bring an
increased level of risk to the water supply: risk of degrading source water quality, risk to long-term watershed
health and the city’s ability to rely on natural processes for what is accomplished elsewhere by physical and

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chemical treatment processes, risk of damaging critical infrastructure, and the risk of exposing watershed
residents and potentially NYC residents to chronic low levels of toxic chemicals.’
Concerns about hydraulic fracturing (especially potential risks to drinking water resources) culminated in a
directive from the US U.S. Congress’ Appropriation Conference Committee to the United States
Environmental Protection Agency (EPA) to conduct research to examine the relationship between hydraulic
fracturing and drinking water resources40.

In another investigation, Wood et al, 201141 concluded that while shale gas extraction, at a global level, does
not involve the high energy and water inputs at the scale of other unconventional fuels (such as tar sands), it
does pose a significant potential risk to human health and the environment. The report cites the potential for
hazardous chemicals to enter groundwater via the extraction process as a significant risk, particularly as it
difficult to verify, categorically, the pathways of contamination of groundwater by chemicals used in the
extraction process. The authors reference the fact that the only operating shale gas production fields are
currently in the USA. Until such time as the knowledge base concerning the impacts of shale gas is
improved, Wood et al (2011) argue that no development of shale gas should be permitted in Europe and the
United Kingdom.

7.8.5 Conclusions – consequence of a no-go to exploration drilling


The volume of recoverable gas stored in Karoo shales is unknown at present. Soekor’s exploration in the
1960s did not make provision for hydraulic fracturing of the wells, which is the critical technological
development that has facilitated gas recovery from ‘tight formations’. In the absence of a license granted for
exploration, the potential of these shales to supply economically recoverable supplies of gas will remain
unknown.
In our opinion, such a strategy would be unnecessarily conservative. It would prevent (or delay) the
determination of the resource potential of the Karoo shale gas formations and the benefits that South Africa
could derive from this - in the absence of any material evidence that a small number of exploration wells
could result in an unacceptable level of environmental impact.
While such a determination can only be finalized once the exploration wells have been sited, it is unlikely, in
our view, that the construction of a small number of wells could, in itself, result in environmental damage that
is unacceptable, as long as the siting and management of these wells is controlled through a rigorous,
scientific, EIA process.
It is acknowledged that there are concerns about the risks associated with hydraulic fracturing in shale gas
production well fields, which typically involve large numbers of wells over a considerable area and at a high
density. The current review of well-field risks and impacts by the USEPA bears testimony to this. While we
would support the current application for an exploration right submitted by Shell, we believe it would be wise
for the Regulator to await and review the findings of the current USEPA investigation of the impacts of
hydraulic fracturing on human health and the environment42, before any licensing of a production well field
is considered.

40
The USEPA’s announcement in March 2010 that they would prepare a detailed, peer reviewed, investigation of the impacts of hydraulic fracturing on
human health and the environment. It is expected that this study will take two years to complete (Reuters, March 18, 2010)

41
Prepared as a research investigation under the auspices of the Tyndall Research Centre for Climate Change Research, Manchester, United Kingdom
42
Draft Plan to Study the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources, Office of Research and Development US Environmental
Protection Agency, Washington DC, February 7, 2011

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8.0 TECHNICAL ASSESSMENT


8.1 Approach to technical assessment
The location of drilling sites is not yet available. Consequently, assessment of environmental issues,
mitigation and management for a typical exploration site has been adopted for the technical assessment.
Environmental issues were identified for the geophysical data acquisition activities (i.e. Magneto-Telluric and
Seismic Survey techniques) (Section 8.5.1), for well site preparation for drilling activities (Section 8.5.2), and
for vertical drilling (Section 8.5.3). In addition, after drilling a vertical exploration well, if gas bearing shale’s
are encountered, following further data analysis there may be a requirement to perform hydraulic fracturing
of the vertical well to determine whether the gas can be stimulated to flow. This could be done in the shale
intersect in the vertical well, or by drilling a horizontal borehole in the shale layer. The horizontal well section
would then be hydraulic fractured (Section 8.5.4). Once drilling operations are completed at a well site and it
is no longer required, then decommissioning and rehabilitation would be undertaken (Section 8.5.5).
A standard impact ranking system (DEAT, 1998) has been applied to assess the significance of the identified
possible impacts (Section 8.4). It is, however, important to note that impact significance ratings provided
below are estimates of likely significance of these activities, as the impact is dependent upon the site and the
characteristics of that site. No site clearing for drilling or subsequent hydraulic fracturing may commence
before an environmental impact assessment (EIA) has been completed under the requirements of the
NEMA., and authorisation to proceed with these activities has been received from the regulator (in this case
Department of Environmental Affairs (DEA), not PASA) as described in Chapter 3.

Key mitigation measures are proposed for the identified issues and taken up in the project EMP (Chapter 9).

8.2 Exploration activities that could potentially impact the


environment
8.2.1 Geophysical data collection
Magneto-Tellurics
The typical activities associated with Magneto-Telluric Surveys at any one site include:

ƒ Accessing the relevant property via vehicle, using existing roads, and then by foot to access remote
sites;

ƒ Vegetation and soil clearing of five small areas comprising four small trenches of approximately 0.2 m2
(40 cm deep, 20 cm wide, 100 cm long) spaced no more than 5 meters apart and a central vertical hole
of about 20 cm diameter and 100 cm deep;

ƒ Positioning of small receiving sensors in the cleared areas; and

ƒ The equipment will typically be set up during the day; record data overnight, and then will be moved to a
new location (3 to 10 km away) the following day.

Seismic acquisition
During the initial 3-year Exploration Right, a selection of other geophysical data acquisition methods may be
used near a well site or within the well bore itself. These may include shallow seismic and micro-seismic
techniques (refer to Section 5.4.3.2. The typical activities associated with seismic acquisition may include:

ƒ Shallow seismic:

ƒ Creating an acoustic signal by producing a series of "shots" (i.e. a source of acoustic energy such
as vibroseis trucks (vehicle-mounted vibrator plates), weight drop, or detonation of a small charge in
shallow holes);

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ƒ Shots will be spaced roughly every 40 m and sensors spaced every 10 m along lines that would be
10 to 30 km in length. The length and number of lines that would be required depends on the
geologic features that need to be delineated;

ƒ Shot holes produced by charges are drilled by small hand held augers or by units mounted on the
backs of all terrain vehicles, with hole depths around 3m and charge sizes of 1/8 to 1/4 kg; and

ƒ For each shot, a string of small sensors (geophones or accelerometers) are used to record the
acoustic reflections (echoes) from the subsurface geologic formations. These sensors are
connected by electrical cables back to the recording truck with 100 to 200 sensors placed for every
shot. Small spikes on each sensor are pushed into the ground to couple the sensor firmly to the soil.

ƒ Micro-seismic:

ƒ Placing of sensors (called geophones) on the surface, in a grid pattern, or down a neighbouring
(drilling) well; and

ƒ A recording truck sits on the well pad to record the signals generated during hydraulic fracturing.
8.2.2 Well site preparation
The well site will entail establishment of a level, compact and secure (fenced off) area of about one hectare
at each gas exploration drilling site. Should groundwater monitoring wells need to be drilled for monitoring
purposes in proximity to the gas well site, the groundwater wells would be drilled using conventional
groundwater drill rigs commonly used in agricultural applications. The typical activities associated with gas
well site preparation43 at any one site include:

ƒ Remove topsoil, which is then stockpiled nearby for site rehabilitation purposes later;

ƒ Grade, level and if necessary backfill with crushed stone the area where the drilling and well site will be
located;

ƒ Compact the site to ensure for stability during movement of heavy equipment and support the weight of
the rig;

ƒ Create erosion and sediment control structures around the site, where appropriate;

ƒ Create on-site storage for drilling fluids or water, which may require construction of geotextile lined pits
or storage tanks;

ƒ On-site fuel (diesel) storage to support well site preparation (e.g. generators);

ƒ Create on-site storage for cement;

ƒ Construction of a well cellar may be required on certain sites to contain the wellhead;

ƒ Construction of access road to the site;, if required

ƒ Erection of portable offices, stores, storage areas, pumps, offices and parking;

ƒ Construction of open and closed drainage systems;

ƒ Construction of a temporary purpose built accommodation camp which typically requires less than
0.5 ha of land for, for accommodation, a restaurant (mess), offices, stores, and parking. Depending on
the location of the site and local landowner preferences, the drilling crew could also utilise existing
accommodation in the area, in which this activity will not be necessary; and

43
Note: not all materials and equipment required for drilling exploration are stored at any one time on a well site. Typically, a supply base is established in a central location, such as
a major town, which allows for storage, preparation and testing of equipment before being dispatched for use to a well site.

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ƒ Disposal of domestic waste, used engine oil and filters, wood (pallets, packing crates, etc), scrap
metals, etc. (disposal method to be confirmed during refinement of the site specific waste management
plans; plan is to be in accordance with relevant legislation).

8.2.3 Exploration drilling


The typical activities that could potentially impact the environment as a result of drilling vertical wells include:

ƒ Drilling:

ƒ Erection of the drilling rig;


ƒ Drilling a vertical well using a mechanical, rotating drill bit;
ƒ Inserting the pressure rated steel casing string (well casing) into the well;
ƒ Cement grouting of the casing in place. This entails forcing cement up the gap between the casing
and the outer rock surface of the bore hole. Deep gas boreholes of this nature are typically 50 to
80 cm diameter holes at surface. As the depth of the boreholes increases and new casing is
inserted the casing diameter is reduced to fit within the upper cased section of the boreholes.
Consequently, the upper section of the boreholes typically contains multiple layers of steel casing
and cement grouting;

ƒ During the drilling process, drilling fluid, referred to as drilling mud is pumped down the inside of the
drill string, exits at the bottom where the drill bit is rotating and returns to surface through space
between the outer surface of the borehole (upper boreholes sections) or cased sections of the
borehole (lower boreholes sections) and the drill string where it is captured, reconditioned and re-
used;

ƒ Analysing and subsequent disposal/recycling of rock cuttings; and


ƒ Cores may be taken and specialist data acquisition (logging) devices used inside the well bore to
extract core for testing from the shale layer.

ƒ Site management / services:

ƒ On-site fuel (diesel) storage to support exploration equipment (e.g. generators);


ƒ On-site storage and handling of mud (drilling fluid). These will be lined containers or sumps;
ƒ On-site lay down areas for the storage of individual sections of steel pipe (typically 10 meters long);
ƒ Temporary on-site storage and handling of logging devices which may contain a low level radio-
active source;

ƒ On-site storage of explosives;


ƒ Source of water:
− Supply seawater, recycled (treated) or surface water by truck. The source of water will vary from
one drilling site to another depending on available options; or alternatively,

− Borehole drilling where appropriate: Dedicated water wells could be used to access water
supplies at depths greater than 100 m, which may yield brackish or saline quality water;

ƒ Storage of water (using metal tanks, pillow tanks or geotextile lined bunded-wall) on site or nearby;
ƒ Disposal of domestic waste, metal/plastic tubular thread protectors, used engine oil and filters,
wood (pallets, packing crates, etc), scrap metals, etc;

ƒ On-site temporary storage of flowback water in lined storage vessels;

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ƒ Re-cycling, cleaning/treatment and then re-use of flowback water from the well; and
ƒ Disposal of wastes generated from the cleaning/treatment of flowback water from the well (disposal
method to be confirmed during the development of the waste management plan for each specific
site; plan is to be in accordance with relevant legislation).

8.2.4 Hydraulic fracturing


The typical activities that could potentially impact the environment as a result of hydraulic fracturing include:

ƒ Potential hydraulic fracturing at the sites.

ƒ Mobilisation of specialist hydraulic fracturing equipment and ancillary equipment to a well site (e.g.,
pumps, a crane, etc);

ƒ Water and additives will be blended into a base fluid off site and then maintained on site with the
use of possibly a truck mounted blending unit, with hoses to transfer liquid additives from storage
containers to the blending unit or well directly from blending truck. Dry additives will be poured into
a feeder system on the blending unit. The blended solution will be immediately fed into the wellbore
as required; and

ƒ Pumping of hydraulic fracturing fluids under pressure into the shale formation.

ƒ Site management / services:

ƒ Temporary storage of flowback water;


ƒ Re-cycling, cleaning/treatment and then re-use of flowback water from the well; and
ƒ Disposal of wastes generated from the cleaning/treatment of flowback water from the well.

ƒ Hydrocarbons surfacing from the well will either be:

ƒ Flared; or
− Possible installation of gas flow lines from well bore to flare.

ƒ Transformed (possibly by one of the following):


− Combustion of the hydrocarbons in power generation units (turbines or gas engines) installed on
site to generate electricity.

− Liquefaction of gas using surface facilities that will allow compression and cooling the gas to
allow for its transportation by truck to an existing processing facility.

− Capture and settling of any liquid hydrocarbons in a settling tank in preparation for export by
truck to an existing processing facility.

8.2.5 Decommissioning
Wells will only be decommissioned if no gas is found or deemed technically / commercially not viable. If the
well is decommissioned, then the well will be sealed off below the level of the upper aquifer and capped.

8.3 Summary of environmental components considered


ƒ Climate

ƒ Geology

ƒ Topography

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ƒ Soil

ƒ Terrestrial ecology

ƒ Vegetation
ƒ Animal life

ƒ Surface water

ƒ Groundwater

ƒ Air quality

ƒ Visual aspects

ƒ Noise

ƒ Cultural heritage aspects

ƒ Sensitive landscapes

ƒ Socio-economic environment

ƒ Human health
8.4 Assessment methodology
The significance of the identified impacts has been determined using the approach outlined below. This
incorporates two aspects for assessing the potential significance of impacts (terminology from the
Department of Environmental Affairs and Tourism Guideline document on EIA Regulations, April 1998),
namely occurrence and severity, which are further sub-divided as follows:

Occurrence Severity

Probability of occurrence Duration of occurrence Magnitude (severity) of Scale / extent of impact


impact

To assess each impact, the following four ranking scales are used:

PROBABILITY DURATION
5 - Definite/don’t know 5 - Permanent
4 - Highly probable 4 - Long-term
3 - Medium probability 3 - Medium-term (8-15 years)
2 - Low probability 2 - Short-term (0-7 years) (impact ceases after the
operational life of the activity)
1 - Improbable 1 – Immediate
0 - None
SCALE MAGNITUDE
5 - International 10 - Very high/don’t know
4 - National 8 - High

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PROBABILITY DURATION
3 - Regional 6 - Moderate
2 - Local 4 - Low
1 - Site only 2 - Minor
0 - None

Magnitude
According to DEAT (2002), impact magnitude should as far as possible be determined by reference to legal
requirements, accepted scientific standards or social acceptability. If no legislation or scientific standards are
available, the EIA practitioner can evaluate impact magnitude based on clearly defined criteria. The following
section describes the criteria used to assess the magnitude of the potential impacts of the proposed
exploration activities on the environmental components most relevant to this project:

Impact criteria
Geology
There are no specific impact criteria for geology. Impacts on geology are assessed indirectly based on their
effects on other environmental media such as soil, surface water and groundwater.

Topography
There are no specific impact criteria for topography. Topographic impacts are assessed indirectly based on
their effects on other environmental media as well as on an aesthetic basis, based on the change in the
landscape character that may result from the topographic change.

Soil, land use and land capability


Impacts on soil, land use and land capability are assessed qualitatively based on the area of soil
disturbance.

Flora
Impacts on flora are assessed qualitatively based on the anticipated change in species numbers and type,
and the density of cover. This is directly related to the area of surface disturbance. Potential impacts on Red
Data species are also considered during the technical assessment.

Fauna
Impacts on fauna are assessed qualitatively based on the anticipated change in species numbers and type,
and animal populations. This is directly related to the area of surface disturbance. Potential impacts on Red
Data species are also considered during the technical assessment.

Surface water
Surface water impacts are assessed based on the potential of an activity to change the quality or quantity of
surface water affected by the proposed exploration activities. This is directly related to the area of surface
disturbance, as well as the volumes of water to be managed on site.

Groundwater
Impacts on groundwater in the project area are assessed based on the potential of an activity to change the
quality and quantity of the groundwater in the project area, especially those resources used by surrounding
landowners.
Groundwater quality is assessed in relation to relevant National Standards. The following standard is
considered applicable in the context of the proposed development:

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South African Water Quality Guidelines SAWQG (1996) Domestic and/or Agricultural Use which applies to
any water source intended for domestic and /or agricultural use

Noise
Noise and vibration impacts are assessed using the following national standard:

ƒ SANS 10103:2008 – The measurement and rating of environmental noise with respect to land use,
health, annoyance and to speech communication.

Archaeology / cultural heritage


Impacts on cultural heritage are assessed based on the potential of an activity to damage heritage
resources, as outlined in the National Heritage Resources Act, 1999 (Act 25 of 1999). This is directly related
to the area of surface disturbance.

Sensitive landscapes
A ‘sensitive landscape’ usually falls within one of the following categories:

ƒ Nature conservation areas and important natural resources;


ƒ Sites of archaeological, paleontological, cultural and historical value;
ƒ Sites of scientific interest (e.g. astronomy areas);
ƒ Green belts or public open spaces; or
ƒ Wetlands.
Impacts on sensitive landscapes are assessed qualitatively based on anticipated changes to sensitive
landscapes. This is directly related to the area of surface disturbance.

Estimating the magnitude of the impact is of primary importance. Typically, it is expressed in terms of relative
severity, such as major, moderate or low. Severity, as opposed to size, also takes account of other aspects
of impact magnitude, notably whether or not an impact is reversible and the likely rate of recovery

Reversibility
An indication of impact reversibility is also provided, i.e. impacts are distinguished between being reversible
and irreversible.

Overall significance rating


The significance of the two aspects, occurrence and severity, is assessed using the following formula:

SP (significance points) = (probability + duration + scale) x magnitude


The maximum value is 150 significance points (SP). The impact significance will then be rated as follows:

SP >75 Indicates high An impact which could influence the decision about whether or
environmental not to proceed with the project regardless of any possible
significance mitigation.
SP 30 – 75 Indicates moderate An impact or benefit which is sufficiently important to require
environmental management and which could have an influence on the
significance decision unless it is mitigated.
SP <30 Indicates low Impacts with little real effect and which should not have an
environmental influence on or require modification of the project design.
significance
+ Positive impact An impact that is likely to result in positive consequences/effects.

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8.5 Technical assessment


8.5.1 Geophysical data collection
Magneto-Tellurics
The geophysical data collection is largely a non-invasive process. Nominal excavation of approximately four
short trenches (40 cm deep, 20 cm wide, 100 cm long) in the field is necessary. The survey team will consist
of three to four members accessing the relevant property via vehicle (in one to two vehicles on existing
roads) and then by foot. The equipment will typically be set up during the day; record data overnight, and
then will be moved to a new location (3 to 10 km away) the following day. Should the controls outlined in
Chapter 9 be implemented, negligible impacts on land use, soil, vegetation and sensitive landscapes are
expected. Such controls include the following:

ƒ Landowners should be notified in advance that access to the site is required;

ƒ The field survey team will only make use of established farm roads and tracks.

ƒ All gates entering the property and between livestock camps on the property must be left in the state in
which they were found (gates that are closed will be closed again).

ƒ No geophysical data acquisition will be conducted within:

ƒ The bed of any river, stream or drainage line;


ƒ Any identifiable wetland area;
ƒ 500 m of any occupied dwelling
ƒ 100 m of any identifiable gravesite;

ƒ 100 m of any identifiable livestock watering point;

ƒ 100 m of any identifiable livestock feed-supplement feeding point; and

ƒ Any cultivated land.

ƒ There will be no cooking on site and no fires. Field personnel may not smoke on site;

ƒ Vehicle speed will not exceed 30 km an hour on farm roads;

ƒ The field team will be self-contained bringing their own chemical camping toilets to site;

ƒ In excavating shallow trenches for geophysical equipment, care should be taken to avoid digging out
established vegetation where ever possible. If this is unavoidable, rooted woody shrubs should be
avoided and grass tufts removed. Where grass tufts must be removed, they should be removed
together with soil around the roots and covered with excavated soil to keep the root system from drying
out.

ƒ On completion of the geophysical data acquisition, the shallow excavations must be in filled with the soil
removed from the area and tufted grasses planted back into these excavations. The aboveground leaf
mass of replanted grass tufts must be cut off one third of the length of the aboveground portion of the
plant above the soil. This is to reduce transpirational water loss from the plant and increase the chance
for survival of any plants temporarily removed from the veldt.

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Seismic acquisition
Shallow seismic
As with the Magneto-Telluric Surveys, shallow seismic techniques are largely a non-invasive process. The
surface area required by the equipment is relatively small in size. The shot used to create the acoustic
signals will be a short once-off occurrence per site. The survey team will consist of a few members accessing
the relevant property(ies) via vehicle (in one to two vehicles on existing roads) and then by foot. The
equipment will typically be set up during the day; will record the acoustic signal created by the shot, and then
will be moved to a new location. Should the controls as summarised above for Magneto-Telluric Surveys,
negligible impacts on land use, soil, vegetation, sensitive landscapes are expected.

Micro-seismic
No additional footprint or land disturbance is required as a result of recording micro-seismic data. No impacts
are therefore anticipated as a result of these activities.

8.5.2 Well site preparation


Table 24 below summarises those impacts directly related to the preparation of the well site, including the
construction/upgrading of access roads, and provides a significance rating for each impact before and after
mitigation. It is important to note that these are estimates of likely significance of these activities as the
impact is dependent upon the site and the characteristics of that site.
Table 24: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas
Exploration Application Project –Well site preparation
POTENTIAL ENVIRONMENTAL SIGNIFICANCE
ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: WELL SITE for relevant mitigation measures)
PREPARATION M D S P Total SP M D S P Total SP
1. Topography
In some cases, the land will
be cut and shaped in order
to obtain a level area on
which to position the drilling
rig. Depending on the
location of the site, it is
possible that access routes 4 2 2 2 24 Low 4 2 2 1 20 Low
will need to be constructed
and may cut into the
topography to be able to
transport the rig to the
drilling site.

2. Soil
Loss of soil resource due to
well site preparation and 8 3 1 5 72 Mod 8 3 1 5 72 Mod
construction of access road.
Loss of soil integrity due to
well site preparation and
8 5 1 3 72 Mod 4 5 1 3 36 Mod
construction of access
roads.
Heavy vehicle movement,
excavation exploration and
soil removal will potentially 4 2 1 4 28 Low 3 2 1 3 18 Low
result in soil compaction
(lithosols soils).

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: WELL SITE for relevant mitigation measures)
PREPARATION M D S P Total SP M D S P Total SP
Heavy vehicle movement,
excavation exploration and
soil removal will potentially 6 2 1 4 42 Mod 4 2 1 3 24 Low
result in soil compaction
(clay soils).
Potential spillages from
heavy machinery, vehicles,
generators, domestic 8 3 1 3 56 Mod 4 3 1 2 24 Low
wastewater, etc could
contaminate soils.
Excavation activities,
vegetation clearing and soil
4 2 1 3 24 Low 2 2 1 2 10 Low
stockpiling, could increase
the potential for erosion.
3. Land use and land capability
Approximately 1 ha will need
to be cleared around the
well; this will influence the
existing land use on that
site. In the event that soil
4 3 2 4 54 Mod 4 3 2 3 32 Mod
contamination occurs, and it
is not treated and managed
effectively, this could
influence the capability of
that land in the future.
4. Ecology (fauna and flora)
Clearing of vegetation during
the well site preparation
phase may result in the 6 5 2 3 60 Mod 4 5 1 0 24 Low
destruction of Red Data or
Protected plant species.

Clearing of vegetation may


result in loss or
6 2 2 3 42 Mod 4 2 2 2 24 Low
fragmentation of habitat for
Red Data faunal species.

Vehicle collisions with Red


Data faunal species,
especially smaller, slower 8 2 3 2 56 Mod 4 2 3 1 24 Low
moving terrestrial species,
on road networks.

Impacts on fauna may result


due to localised increases in 6 2 2 5 54 Mod 4 2 2 3 28 Low
noise, light and dust levels.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: WELL SITE for relevant mitigation measures)
PREPARATION M D S P Total SP M D S P Total SP
5. Surface water
The removal of vegetation
from the site and the
hardening of surfaces will
result in additional erosion
and runoff volumes. The 2 2 2 2 12 Low 2 2 1 2 10 Low
increased runoff could cause
local erosion and scour
around the site.

Should access roads to the


site cross watercourses, the
banks of the stream and flow
hydraulics could be 2 2 2 2 12 Low 2 2 2 2 12 Low
impacted. This impact is
only for cases where
streams are crossed.

The activities on site involve


the handling of fuels,
domestic wastewater, and
domestic waste. There is the
potential for spills from these 2 2 2 2 12 Low 2 2 1 2 10 Low
storage and material
handling facilities. The runoff
from the site therefore has
the potential to be polluted.

The site could be located


adjacent to a watercourse.
Although the area has low
rainfall, there is the potential
for floods, which can in turn 4 2 2 2 24 Low 2 2 2 2 12 Low
transfer contaminants from
the site and/or impact on
downstream flow paths.

6. Groundwater
Construction of the well site
could lead to reduction in 2 1 1 4 12 Low 2 1 1 2 8 Low
groundwater recharge.
Leakage and spillage of
fuels from vehicles / heavy
2 1 2 2 10 Low 2 1 1 2 8 Low
machinery could impact on
groundwater quality.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: WELL SITE for relevant mitigation measures)
PREPARATION M D S P Total SP M D S P Total SP
7. Air quality
Various activities during well
site preparation require
disturbing the soil to some
degree through the use of
8 1 1 5 56 Mod 4 1 1 5 28 Low
construction machinery.
Fugitive dust will be
released as well as exhaust
emissions.

8. Visual aspects
Excessive vegetation
removal, dust and night
lighting could result in visual 6 2 2 4 48 Mod 4 2 2 2 24 Low
impacts.

9. Noise
Construction of access road,
earth and concrete works,
and trucks and heavy 2 2 2 4 16 Low 2 2 2 3 14 Low
machinery will increase
ambient noise levels.

10. Cultural heritage


Construction of access
roads and the well site may
damage heritage sites and
features in the immediate
environs of the well site. The 6 5 2 3 60 Mod 2 5 2 1 16 Low
generation of dust could
pose a threat to rock
paintings in close proximity
to the site.

11. Sensitive landscapes


There is a potential for
impacts associated with site
clearance on identified or
unknown potentially
sensitive features, such as 6 4 3 3 60 Mod 4 3 3 1 28 Low
Red Data species habitat
types and paleontological
sites.

12. Socio-economic aspects


Loss of land due to
construction of well site and 4 2 1 4 28 Low 2 2 1 4 14 Low
access road.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: WELL SITE for relevant mitigation measures)
PREPARATION M D S P Total SP M D S P Total SP
Presence of foreign
exploration teams may lead
to social conflict due to 2 2 2 5 18 Low 2 2 1 5 16 Low
cultural and language
differences.
Local employment
2 2 2 1 10 Low 2 2 1 2 10 Low
opportunities.
13. Access, traffic and transport
Exploration activities will
entail additional traffic on
local roads. Additional traffic
will increase wear and tear
on the roads, increase risk 6 2 3 4 56 Mod 4 2 2 4 32 Mod
of accidents, and increase
noise and fugitive dust
levels.

Topography
Impacts on topography are anticipated due to the following:

ƒ An area of approximately 1 ha will be cleared of vegetation. In some cases, the land may be cut and
shaped in order to obtain a level area on which to position the drilling rig; and

ƒ Depending on the location of the site, it is possible that access routes will need to be constructed and
may cut into the topography to be able to transport the rig to the drilling site.
These impacts are, however, considered to be of low significance. Sites will be located in areas of relatively
flat topography, thus decreasing the probability of altering the topography.
Should disturbed areas be filled, compacted and rehabilitated, upon decommissioning, this impact is
reversible.

Soils
Loss of the soil resource
The proposed exploration project will result in a loss of approximately 1 ha44 of soil resource at eight well
sites within the application area during site preparation; this impact will continue until decommissioning. The
well site preparation process will involve clearing of the topsoil to allow for preparation of the drilling well site
and access road. The soil will be stockpiled for remediation during decommissioning.
The potential impact is likely to be of high magnitude on the soil directly impacted at each site; an impact of
moderate significance may occur. The moderate significance of the impacts is confined to the immediate
area of the activity which makes up <0.0001% of the total application area.

Should removed soils be stockpiled and replaced during decommissioning, this impact is reversible.

44
A small amount of additional area may be required should it be necessary to build an access road, temporary accommodation, additional storage and parking, etc.

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Loss of soil integrity


The soil integrity is a function of the inherent fertility, nutrient and water retention, organic matter content,
and a number of physical properties of the soil. When a soil is disturbed in any way, any number of these
may be affected and may result in negative impacts for the soil. Disturbances expected to bring about such
changes include:

ƒ Movement of vehicles over virgin soil;

ƒ Excavating;

ƒ Soil removal for well site preparation; and

ƒ Stockpiling of stripped soils.


The loss of soil integrity will occur during well site preparation, and will persist until decommissioning. During
decommissioning, the soil integrity can be remediated to a certain extent.
Without mitigation, the potential impact is likely to be of high magnitude on the soil directly impacted at each
site; an impact of moderate significance is therefore likely to occur. The moderate significance of the
impacts is confined to the immediate area of the activity which makes up <0.0001% of the total application
area. The magnitude of this impact can be further reduced, should the appropriate mitigation measures
presented in chapter 9 be implemented.
Since the soil integrity can never be fully remediated, this impact is irreversible.

Soil compaction
Soil compaction occurs when a weight is applied on the surface and soil particles including the porous
network, are rearranged as a result (Singer, 1987). Soil compaction may occur as a result of the following
activities:

ƒ Heavy vehicle movement;

ƒ Excavating; and

ƒ Soil removal and restoration.

The structured soils falling within the precinct will be more susceptible to compaction than the sandy soils.
Soil compaction will be largely limited to well site preparation.
The impacts from soil compaction are likely to be of low to moderate significance (depending on soil type)
prior to mitigation on a site specific basis. However, the implementation of the mitigation measures
presented in Chapter 9 will reduce this impact to one of low significance. This impact is reversible.

Soil contamination/pollution
There is potential for contamination of soil to occur at the site due to accidental spillages of fuels or domestic
wastewater at the site. The significance of this impact is considered moderate prior to mitigation; with the
implementation of measures described in Chapter 9, the significance of this impact can be reduced to one of
low significance.

Erosion
Erosion is a function of both the physical characteristics of that soil, and the topography it occurs on. In
general, the lighter textured, free draining soils will be less prone to erosion than heavier clay type of soils
with a wet base.
Soil situated on gentle sloped topography will be less prone to erosion compared to those on steep slopes
when it comes under disturbance of human activity. Existing and established vegetation binds and stabilises
the soils and ensures better resistance to erosion.

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Sites on gentle sloped topography will be selected to limit the potential for erosion and erosion management
measures will be implemented during well site preparation. The significance of this impact is likely to be low.
The impact of erosion is reversible, should soils be replaced in eroded areas.

Land capability and land use


Approximately 1 ha will need to be cleared for the well site; this will influence the existing land use on that
site. In the event that soil contamination occurs, and it is not treated and managed effectively, this could
influence the capability of that land in the future. The significance of this issue is dependent upon the existing
land use, and ability to rehabilitate the land during decommissioning.
Due to the relatively small area of surface disturbance, an impact of moderate significance is likely to occur.
Impact on land use is reversible; impact on land capability is irreversible (due to irreversible loss of soil
integrity).

Ecology
Loss of Red Data or Protected plant species
Red Data or Protected plant species are known to occur within the broad exploration areas. However,
detailed assessment of each proposed drilling site will precede site development as part of the site specific
EIA studies. Wherever possible, identified populations of red data species will be avoided through re-siting
the drilling site.
Due to the low level of historical transformation of the vegetation types within the precinct, one would expect
an impact of high magnitude; however, due to the limited scale of the ground clearing required for well site
preparation and access road construction, and the naturally sparse cover of the vegetation within the region,
impact magnitude is considered moderate. Should Red Data or Protected plant species be lost during well
site preparation, this impact will be permanent and irreversible. Overall impact significance is therefore
moderate.
This impact can, however, be mitigated by avoiding areas with high densities of Red Data or Protected Plant
species during the site selection process. Any Red Data or Protected Plant species encountered during
ground clearing should be translocated to a nursery area and returned to the site during the rehabilitation
phase. Should these measures be implemented, overall impact significance can be reduced to low.

Loss or fragmentation of habitat for Red Data faunal species


Red Data faunal species are expected to occur within the application area. These species are threatened
due to a variety of factors including habitat loss and fragmentation. Clearing of vegetation during well site
preparation and road construction may constitute a further loss or fragmentation of habitat for these species.
Due to the limited scale of surface disturbance required for well site preparation and access road
construction, the naturally sparse cover of the vegetation within the region, and that impacts are likely to be
localised (with birds especially), impact significance is considered to be moderate. All of the Red Data
species are limited within their ranges by very specific habitat preferences; by avoiding these habitat types,
impacts on these species can be mitigated to low. Should appropriate mitigation measures be implemented,
this impact is reversible.

Collisions with Red Data faunal species on road networks


Red Data faunal species are expected to occur within the application. While travelling on road networks,
vehicles moving to and from the site could collide with these species, especially the smaller, slower moving
terrestrial species. Impacts of high magnitude will occur over a regional scale; impact significant is therefore
rated as moderate. Should appropriate mitigation measures, such as reduced speed limits and awareness,
impact significance can be reduced to low.

Should vehicles moving to and from the site collide with Red Data faunal species, the impact will be
irreversible.

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Disturbance of Red Data fauna due to increased dust, noise and light
Exploration activities will result in a temporary localised increase in noise, light and dust levels.
Increased noise levels may affect a wide range of taxa (including avifauna, mammals, reptiles, amphibians
and arthropods) due to the associated increase in vibration. Avifauna, especially songbirds, and amphibians
may find it difficult to find mates in areas of increased noise. Most taxa will move away from areas with
increased noise. In general, most species seem to tolerate constant, even very loud, sounds better than
sudden, unfamiliar ones.
Increased atmospheric dust may occur in the vicinity of the well site and access road construction. Dust
settling on plant material can reduce the amount of light reaching the chlorophyll in the leaves, thereby
reducing photosynthesis, which in turn reduces plant productivity, growth and recruitment.
Lights at night are likely to attract insects which may in turn attract night feeding birds, lizards or amphibians
at the site.
The impact on terrestrial fauna is likely to be temporary and localised, but will definitely occur. Impact
significance is therefore anticipated to be moderate. Should the appropriate mitigation measures outlined in
Chapter 9 be implemented, impact significance can, however, be reduced to low. These impacts on
terrestrial fauna are reversible; fauna may return to the site subsequent to decommissioning; similarly,
vegetation distributed by dust may recover subsequent to decommissioning.

Surface water
Increased erosion and runoff volumes
The removal of vegetation and top soil as well as the hardening of the surfaces to construct the well pad will
result in increased runoff and erosion from the site. The runoff with the higher sediment load and flood peaks
will report to the local streams.
Due to the low probability of rainfall in the area and the small area of the site, the impact is ranked as low.
Impact significance can be reduced further by implementing mitigation measures such as collecting runoff
from the site in a sump or pond. The impact of increased erosion is irreversible and should be prevented.

Access road and watercourse crossings altering the banks of watercourses


This potential impact is dependent on the location of the sites in relation to any watercourses. The access
road may have to be constructed over a watercourse to gain access to the site. This will alter the banks of
the watercourse and affect the hydraulics of the watercourse during a runoff event. Increased inundation
areas behind the weirs could result.
Due to the low probability of rainfall in the area and the small area of the site, the impact is ranked as low.
This impact can, however, be prevented by selecting sites where the access road does not need to cross
any watercourses.

Polluted runoff leaving the site


During well site preparation, fuels and domestic wastewater (sewage) will be stored and handled on site.
There is the potential for spills from these storage and material handling facilities. The runoff from the site
therefore has the potential to be polluted.
Should the runoff from the site be collected in a sump or pond within the site, fuel handling areas be bunded,
and domestic wastewater be disposed of in an appropriate manner (and not discharged to the environment),
impact significance is expected to be very low. Should polluted runoff leave the site and enter watercourses,
the impact on water quality may/may not be reversible, depending on the nature of the pollutant.

Flooding of site
If the site is located near a surface water body, there is potential for water to enter the site during flood
events. This can potentially result in contaminants described above being transferred to the water body

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and/or alteration of the natural flow path. There will be potential for flooding of the site during all project
phases.
The site could be located adjacent to a watercourse. Although the area has low rainfall, there is the potential
for floods. There is the risk of flood waters inundating the site. Should the site selection process exclude the
areas within the 100 year flood line or within a 100 m of the watercourse (whichever is greater), this impact
can be mitigated to low.

Groundwater
Construction of the well site leading to reduction in groundwater recharge
Construction of the well site will result in reduction of recharge to the groundwater over the well site area. It is
anticipated that magnitude of the impact will be minor due to the small area of the site. An Impact of low
significance is therefore expected. Impact significance can be reduced by directing clean storm water runoff
off the well site to a soak away. The impact on groundwater recharge is irreversible.

Leakage of fuels leading to deterioration of groundwater quality at the site


During well site preparation, fuels and domestic wastewater (sewage) will be stored and handled on site.
There is the potential for spills from these storage and material handling facilities, which could result in
groundwater contamination. Should the runoff from the site be collected in a sump or pond within the site,
fuel handling areas be bunded, and domestic wastewater be disposed of in an appropriate manner (and not
discharged to the environment), impact significance is expected to be very low.
The impact on water quality may/may not be reversible, depending on the nature of the pollutant.

Air quality
The air pollution generated during site preparation would be the same as for any other general construction
activities, with the main air pollutant being airborne dust. The various activities during site preparation require
disturbing the soil to some degree through the use of construction machinery. Depending on the soil type,
this could generate significant amounts of fugitive dust during the limited period of site preparation.
In addition, combustion gases (sulphur dioxide, oxides of nitrogen, carbon monoxide, 1, 3-butadiene, diesel
particulate matter) will be emitted from vehicle exhausts.

As these vehicles may be also be fuelled on site, the potential to emit volatile organic compounds exists.
It is anticipated that the well site preparation activities could result in localised impacts in the short term;
impacts of moderate significance are therefore anticipated. Should appropriate mitigation measures be
implemented, such as dust suppression on roads, impact significance can be mitigated to low.

Visual aspects
Visual impacts will be dependent upon the location of the drilling site, characteristics of existing vegetation,
topographic features and waterways. Excessive vegetation removal, dust and night lighting could result in
visual impacts. Impacts of moderate significance are anticipated due to relatively small area of surface
disturbance required for well site preparation. Impact significance can, however, be mitigated to low, should
the appropriate mitigation measures be implemented – refer to Chapter 9 for details. Should the appropriate
mitigation measures be implemented, this impact is reversible upon decommissioning.

Noise
Noise of construction is expected to include earthworks, erection of some temporary buildings/facilities and
construction of access roads. All these require trucks and heavy machinery, and compressors and
generators. It is anticipated that during the daytime, impacts on noise levels will be very low or negligible.
Should construction be carried out at night, impacts may rise to low significance. This impact will be
reversible once well site preparation activities are completed.

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Archaeology / cultural heritage / palaeontology aspects


Construction of access roads and the well site could damage heritage sites and features in the immediate
environs of the proposed well site.
Impacts of moderate significance are expected if the proposed access road is situated within the immediate
environs of a heritage site (i.e. within 20 m), if the proposed well site is located within 50 m from heritage site,
and the proposed well site and/or access road are located within 100 m of rock art sites.
Should the following mitigation measures be implemented prior to well site preparation and construction,
impact significance will be reduced to low:

ƒ During well site selection, no sites should be placed within 100 m of declared national and provincial
heritage sites.

ƒ Once the preliminary sites are selected, a site specific cultural heritage impact assessment will need to
be conducted to identify any heritage sites and features. Based on the findings of the assessment:

ƒ No access roads should be constructed within 20 m of identified heritage sites and features which
are rated as sites of high local significance by the South African Heritage Resources Agency
(SAHRA) (see Table 1 in heritage report attached in Volume 2);

ƒ No well sites should be constructed within 50 m of heritage sites and features which are rated as
sites of high local significance by the SAHRA; and

ƒ No well sites or access roads should be constructed within 100 m of rock art sites which are rated
as sites of high local significance by the SAHRA.
The site specific cultural heritage impact assessment will therefore inform final site selection.
Note: the SAHRA usually allows for development to commence where heritage sites or features are rated as
sites of low significance (i.e. are not of any regional or local importance and/or are duplicated in many
areas).
Should heritage sites rated as sites of medium to high significance be located within the above-mentioned
buffer zones in relation to the selected well sites, appropriate mitigation measures will need to be
implemented, in consultation with the relevant heritage agency. Mitigation could entail rescue excavation,
once a permit is granted by the SAHRA.
Should any archaeological or heritage features artefacts be uncovered during exploration, all activities must
be stopped and an archaeologist accredited with the Association for Southern African Professional
Archaeologist (ASAPA) approached in order to determine appropriate mitigation measures for the
discovered finds, if necessary. Mitigation of heritage sites will be called for when they are rated as of medium
to high significance. Mitigation could entail rescue excavation of relevant heritage sites - once a permit is
granted for excavation by the SAHRA. If the relevant heritage sites include graves then the protocol provided
in Section 36 of the National Heritage Resources Act, 1999 (Act 25 of 1999), regarding grave exhumation,
will be followed.
It is recommended that a heritage awareness guide be provided to the well site preparation personnel and
drilling crew to help them identify heritage resources, should they be unearthed as a result of the exploration
related activities.
Should archaeological or heritage features artefacts be damaged during exploration, the impact will be
irreversible.
The Karoo has over the years yielded a number of significant fossil finds that are on display in numerous
museums throughout the region. It is therefore possible that fossils may be encountered during exploration
drilling activities. If this occurs, qualified specialists will be consulted and the required mitigation measures
implemented, to protect this precious aspect of cultural heritage in the area.

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Sensitive landscapes
There is a potential for impacts associated with site clearance and road construction activities on identified or
unknown potentially sensitive features such as wetlands, patches of indigenous vegetation considered to be
Critical Biodiversity Areas, Protected Areas, etc. This may result in impacts of moderate significance, due to
the relatively small area of surface disturbance associated with well site preparation.
The site selection process for the locating of the wells will be aimed at avoiding wetlands, vegetation in areas
considered to be critical biodiversity areas, as well as protected areas contemplated in terms of the National
Environmental Management: Protected Areas Act of 2003. This impact is therefore unlikely to occur.

In terms of the Astronomy Geographic Advantage Act, 2007 (Act 21 of 2007), sites declared as core
astronomy advantage areas are subject to a 3 km buffer on development; should any such sites fall within
the application area, this will need to be taken into consideration during well site selection.

Socio-economic
Loss of land and impact on livelihood
Well site preparation activities will involve the clearing of well sites (which are typically expected to be
approximately 1 ha). Access to exploration sites may be via an existing (upgraded) or new access road.
Landowners will therefore lose temporary access to these areas during well site preparation and exploration
activities. However, if initial exploration test results indicate a feasible shale gas resource, further exploration
activities may be conducted. If this leads to gas production activities under a production right, the well will be
secured for future development and production. Any non-viable exploration wells will be decommissioned.

Loss of access as a result of exploration activities and associated health and safety requirements may
require mitigating measures, such as alternative access ways. Loss of income due to loss of production and
economic resources will need to be compensated. Compensation for use of land may be provided through
lease agreements.
Site selection must take cognisance of current land use in order to minimise economic displacement. Land
compensation and lease agreements should be entered into independently with each affected landowner or
party. Where possible, engagements with local stakeholders should be held to understand grazing schedules
– these aspects need to be taken into account during final selection of the well sites.
The scale of impact is local with a definite probability and moderate magnitude, resulting in an impact of low
significance. Upon decommissioning, this impact is reversible.
Air quality, noise and vibration impacts may also impact indirectly on the livelihoods of affected landowners
or parties. The results from the air quality and noise assessment studies are presented in separate technical
reports. Increased noise levels may impact current land uses, such as game farms. With regard to air quality,
dust settling on plant material can reduce the amount of light reaching the chlorophyll in the leaves, thereby
reducing photosynthesis, which in turn reduces plant productivity and growth. Should the appropriate
mitigation measures for noise and air quality be implemented, these impacts can be mitigated to low.

Presence of (temporary) workers


Exploration is regarded as a skilled technical process that requires adherence to industry-regulated and
corporate health and safety standards. During the initial exploratory drilling, it is likely that certain
technologies and equipment will need to be imported and highly specialised expertise or personnel to be
required. Shell will establish a team that will include international staff and contractors. During operation of
the drilling site there will be between 30 to 50 staff on site. During site establishment this number is expected
to be in the order of 20 people. Accommodation of teams may be in a purpose built temporary
accommodation camp or in accommodation facilities in nearby urban centres. This decision will be evaluated
on a site by site basis taking into account proximity to off site accommodation options at the time that drill
site localities are known.
Well site preparation teams could be considered as business travellers and may stimulate the local tourism
industry, especially the hospitality sector for short periods during exploration activities. This may have an

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associated positive impact on general business in the local economy. No long-term housing requirements
are anticipated.
In contrast, the presence of foreign exploration teams may lead to social conflict due to cultural and
language differences.
Teams will work under a strict code of conduct which requires, for example, prior permission for access, non-
disturbance of farm activities and restoring any damages they may inadvertently cause. On-site camps will
have controlled access and all staff will carry personal identification.
The scale of the potential positive impact on the local tourism industry and local economy is local, with
medium probability and moderate magnitude, which equates to an impact of low significance. The negative
impact of social tension is also considered to be an impact of low significance, but will be reversible, once
the well site preparation team leaves the area.

Employment
Due to the technical nature and regulated health and safety requirements, opportunities for local employment
are limited to casual positions. Influx of job-seekers and the associated increase in crime and social ills is not
expected to occur due to the isolated character of the study area and controlled access to private property in
the area. At a regional scale, transportation and security requirements may lead to a limited increase (low
magnitude) in employment for the duration of the exploration activities. The local hospitability sector may
benefit from a low increase in employment opportunities.
Where possible, employment opportunities should be offered to local communities before others are
considered. Opportunities for skills development and training should be explored in order to maximise long-
term benefits of employment.
Due to the limited opportunities for local employment, impact significance associated with this positive impact
is considered low.

Access, traffic and transport


The drilling rig will be transported by standard prime mover and trailer trucks, and will be assembled on site.
The construction of the temporary drilling rig typically takes between 3 and 4 weeks. Additional trailer(s) will
be required to bring other portable equipment, a site office, etc. for temporary use on site. Typical traffic
associated with "rig up" operations requires approximately 50 to 70 truck loads, which includes portable
accommodation units and rig site offices. The frequency with which additional vehicle traffic visits a site will
depend upon the phase of drilling operations. For example, on average a standard re-supply to a rig will
require 2 to 4 trucks loads per day, although when pipe casing strings and mud supplies are required this
may require up to 10 truck loads per day for a short period of time. Dependent upon the distance to available
infrastructure, for example, a supply base or airport, additional may be required traffic once per week, plus
ad hoc travel of employees to/from the site on a daily basis.
Additional traffic will increase wear and tear on the roads, increase risk of accidents, and increase noise and
fugitive dust levels. Due to the number truck loads required, impact magnitude is rate moderate. In addition,
since impacts could be regional. Impact significance is therefore considered to be moderate. The
significance of this impact will, however, need to be confirmed subsequent to site selection, as part of the
detailed environmental impact assessment.
The following measures may mitigate these risks:

ƒ Locating well sites in close proximity to the supply base or airport, and existing towns;

ƒ Implementing speed limits, drivers’ education, public education, and scheduling and maintenance of
vehicles will reduce the impacts on all of roads used by heavy duty vehicles; and

ƒ Information should be provided to local residents and police on traffic movements.

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The impact on traffic will be reversible, once the exploration team leaves the area. Traffic impacts will receive
consideration through a specialist study to inform impact assessment for individual well sites once these are
known, taking into consideration transport and logistics routing at that time.

8.5.3 Exploration drilling


Table 25 below summarises those impacts directly related to the proposed exploration drilling programme,
and provides a significance rating for each impact before and after mitigation. It is important to note that
these are estimates of likely significance of these activities as the impact is dependent upon the site and the
characteristics of that site. For this reason, the significance ratings provided herein are purely a guideline.
Impact significance will be confirmed as part of the detailed EIA.
Table 25: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas
Exploration Application Project –Exploration Drilling
POTENTIAL ENVIRONMENTAL SIGNIFICANCE
ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: EXPLORATION for relevant mitigation measures)
DRILLING M D S P Total SP M D S P Total SP
1. Geology
The drill rig will penetrate
geological layers up to a
depth of 1 to 5 km
(depending on site
conditions), at each drilling
site. Core (soil,
unconsolidated material and
6 3 1 3 42 Mod 4 3 1 2 24 Low
rock) will be removed. Core
or drill chippings could
possibly contain naturally
occurring radioactive
materials (NORMs) which
could contaminate the
environment.
2. Soil
Potential spillages from
heavy machinery, vehicles,
generators, chemical
8 3 1 3 56 Mod 4 3 1 2 24 Low
storage areas, drilling muds,
hydraulic fracturing fluids,
etc could contaminate soils.
3. Ecology (Fauna and Flora)
Vehicle collisions with Red
Data faunal species,
especially on smaller, slower 8 2 4 3 72 Mod 2 2 4 2 16 Low
moving terrestrial species.

Impacts on fauna may result


due to localised increases in 6 2 2 5 54 Mod 4 2 2 3 28 Low
noise, light and dust levels.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: EXPLORATION for relevant mitigation measures)
DRILLING M D S P Total SP M D S P Total SP
4. Surface water
The activities on site involve
the handling of fuels, water
and drilling mud. These
materials will be stored on
site. There is the potential
for spills from these storage 2 2 2 2 12 Low 2 2 1 2 10 Low
and material handling
facilities. The runoff from the
site therefore has the
potential to be polluted.

There is the potential for


spills and leaks of the
potentially polluted return 2 2 2 2 12 Low 2 2 1 2 10 Low
flow fluid from the drilling
process.

5. Groundwater
Storage tanks for poor
quality water, i.e. saline /
brackish water, could 4 1 2 2 20 Low 2 1 1 2 8 Low
leak/collapse/burst leading
to contamination of aquifer.
Failure of pumps/pipes
to/from storage tanks to
4 2 2 2 24 Low 2 2 2 1 10 Low
wellhead, resulting in
spillage.
Leakage of stored drilling
fluids leading to
4 2 2 2 24 Low 2 2 1 2 10 Low
deterioration of groundwater
quality at the site.
The gas exploration well will
drill through the potential
water bearing zones present
at the well site. The well
could therefore provide a 8 5 1 4 80 High 2 5 1 1 14 Low
pathway for groundwater
loss and potential
contamination.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: EXPLORATION for relevant mitigation measures)
DRILLING M D S P Total SP M D S P Total SP
The gas exploration well will
drill to depths of up to 5 km.
A deep water bearing zone,
most likely containing
brackish or saline water,
could be intersected. If the 4 1 2 2 20 Low 2 1 2 2 10 Low
well was not adequately
cased, it could provide a
pathway for saline water to
rise to the surface, impacting
on the shallower aquifer.
The gas exploration well will
drill to depths of up to 5 km.
An unexpected fracture/fault
zone could be intersected at
depth. The well could
therefore provide a pathway
for groundwater loss to the 4 1 2 2 20 Low 2 1 2 2 10 Low
fractured zone and
potentially saline water
within the fracture rising to
the surface and impacting
on the shallower aquifer.
Failure of the steel well
casing and cement grout
could lead to loss of
groundwater via flow into the
well and contaminated 4 1 1 2 16 Low 4 1 1 1 12 Low
water, gas and hydraulic
fracturing chemicals entering
the shallow aquifer.

Inflow of groundwater into


the well causing a lowering 6 2 2 2 36 Mod 2 1 1 1 6 Low
of water levels.
Drilling of water wells as an
option to obtain a 6 2 2 3 42 Mod 4 2 2 2 24 Low
groundwater supply.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: EXPLORATION for relevant mitigation measures)
DRILLING M D S P Total SP M D S P Total SP
Poorly managed abstraction
of groundwater from the
boreholes can lead to
excessive lowering of the
water table, failure of the
borehole and possible 6 4 3 3 60 Mod 2 2 2 2 12 Low
lowering of the water level in
water supply boreholes
located within the area of
influence of the wellsite
borehole(s).
6. Air quality
Routine emissions are
expected from power
generators. Fugitive
emissions may occur at drill
rig and open air fluid 6 2 2 4 42 Mod 4 2 2 4 28 Low
impoundments, if these are
used to hold drill cuttings
and fluid.
7. Visual aspects
Dust generation and night
lighting could result in visual 6 2 2 3 42 Mod 4 2 2 2 24 Low
impacts.

8. Noise
Drilling, pumps,
compressors and
generators, and vehicles
importing and exporting
materials and staff could 4 2 2 4 32 Mod 2 2 2 4 24 Low
increase ambient noise
levels between ±150 m and
1.6 km from the centre of the
site, at night.

9. Socio-economic aspects
Refer to site preparation
10. Access, traffic and transport
Refer to site preparation

Geology
The drill rig will penetrate geological layers up to a depth of 1 to 5 km (depending on site conditions), at each
drilling site. Core (soil, unconsolidated material and rock) will be removed. Core or drill chippings could
possibly contain naturally occurring radioactive materials (NORMs) which could contaminate the
environment. This impact is considered to be an impact of moderate significance. Should, however, the
below-mentioned mitigation measures be implemented, impact significance can be reduced to low:

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ƒ Identify and log strata that could host naturally occurring radioactive materials (NORMs).

ƒ Separate drill chippings that may contain NORMs. Test natural radioactivity level. If necessary, dispose
of such material at an off site facility licensed to receive such material.

Soils
There is potential for contamination of soil to occur at the site due to accidental spillages of fuels, flowback
water or drilling muds at the site. These materials will be stored in appropriate containers. Storage facilities
used for drilling muds and flowback water will be lined to prevent infiltration into the soil.
The significance of this impact is considered moderate prior to mitigation; with the implementation of
measures described in Chapter 9, the significance of this impact can be reduced to one of low significance.
Should soils be contaminated with fuels, flowback water or drilling muds, the impact may/may not be
reversible, depending on the nature of the pollutant. Should soils be remediated using bioremediation,
impacts may, however, be reversible

Ecology
Collisions with Red Data faunal species on road networks
Red Data faunal species are expected to occur within the precinct. While travelling on road networks,
vehicles moving to and from the site could collide with these species, especially the smaller, slower moving
terrestrial species. Impacts of high magnitude will occur over a regional scale; impact significant is therefore
rated as moderate. Should appropriate mitigation measures, such as reduced speed limits and awareness,
impact significance can be reduced to low.

Should vehicles moving to and from the site collide with Red Data faunal species, the impact will be
irreversible.

Disturbance of Red Data fauna due to increased dust, noise and light
Exploration activities will result in a temporary localised increase in noise, light and dust levels.

Increased noise levels may affect a wide range of taxa (including avifauna, mammals, reptiles, amphibians
and arthropods) due to the associated increase in vibration. Avifauna, especially songbirds, and amphibians
may find it difficult to find mates in areas of increased noise. Most taxa will move away from areas with
increased noise. In general, most species seem to tolerate constant, even very loud, sounds better than
sudden, unfamiliar ones.
Increased atmospheric dust may occur in the vicinity of the drilling site and access roads. Dust settling on
plant material can reduce the amount of light reaching the chlorophyll in the leaves, thereby reducing
photosynthesis, which in turn reduces plant productivity, growth and recruitment.
Lights at night are likely to attract insects which may in turn attract night feeding birds, lizards or amphibians
at the site.
The impact on terrestrial fauna is likely to be short-term and localised, but will definitely occur. Impact
significance is therefore anticipated to be moderate. Should the appropriate mitigation measures outlined in
Chapter 9 be implemented, impact significance can, however, be reduced to low.
These impacts on terrestrial fauna are reversible; fauna may return to the site subsequent to
decommissioning; similarly, vegetation distributed by dust may recover subsequent to decommissioning.

Surface water
Polluted runoff leaving the site
The activities on site involve the handling of fuels, water and drilling mud. These materials will be stored on
site. There is the potential for spills from these storage and material handling facilities. The runoff from the
site therefore has the potential to be polluted.

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Should the runoff from the site be collected in a sump or pond within the site, fuel and drilling mud handling
areas be bunded, and domestic wastewater be disposed of in an appropriate manner (and not discharged to
the environment), impact significance is expected to be very low.
Should polluted runoff leave the site and enter watercourses, the impact on water quality may/may not be
reversible, depending on the nature of the pollutant.

Spill and leaks of drilling return flow fluid


The drilling process will generate a return flow from the wells. The return flow fluid could be polluted to an
extent that the fluid cannot be discharged to the environment. This fluid will be stored on site and disposed of
in an appropriate manner. The disposal method will depend on the water quality of the fluid. The disposal
could be to a local sewage treatment works, treatment on site before discharge or disposal at an appropriate
facility off site. The fluid will also be pumped on site and there is the potential for pipe leaks or bursts on site.
The storage container for the fluid will be in a bunded area. The water quality of the fluid will be determined
on site and the appropriate disposal method applied. Any leaks from the pumping system will be caught in
the onsite sump before entering the environment. The development and application of material handling
procedures for the site will also reduce the risk of material entering the environment.

Due to the local scale of the potential impacts, impact significance is anticipated to be low; should the above
mitigation measures be implemented, impact significance can be reduced further.
Should surface water become contaminated with drilling return flow fluid, the impact on water quality
may/may not be reversible, depending on the nature of the pollutant.

Groundwater
Water storage tanks leak/collapse/burst leading to contamination of aquifer
Poor quality water (i.e. saline / brackish water) may be used for drilling and may be stored on site. Leakage
and/or spillage of this water could result in groundwater contamination. It is anticipated that spillage of water
will result in negligible impacts, and will be restricted to the site only. Impacts of low significance are
therefore expected. Impact significance can, however, be reduced, should appropriate mitigation measures
are implemented, such as ensuring that water storage containers are located in a bunded area.
Should groundwater be contaminated, the impact on water quality may/may not be reversible, depending on
the nature of the pollutant.

Pumps/pipes to/from storage tanks to wellhead fail resulting in spillage


Poor quality water (i.e. saline / brackish water) may be used for drilling. Failure of pumps and pipes could
result in spillage of this water leading to groundwater contamination. It is anticipated that spillage of water will
result in negligible impacts, and will be restricted to the site only. Impacts of low significance are therefore
expected. Specification of high quality pumps and pipes of suitable strength will minimise the risk of bursts,
and hence reduce impact significance.
Should groundwater be contaminated, the impact on water quality may/may not be reversible, depending on
the nature of the pollutant.

Leakage of stored drilling fluids leading to deterioration of groundwater quality at the site
Drilling fluids will be stored on site. Leakage and/or spillage from these storage areas could result in
groundwater contamination. Impacts of low significance are expected; however, impact significance can be
reduced should appropriate mitigation measures be implemented, e.g. ensuring that drilling fluid storage
facilities are located in a bunded area.
Should groundwater be contaminated, the impact on water quality may/may not be reversible, depending on
the nature of the pollutant.

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Intersection of aquifers
The gas exploration well will drill through the potential water bearing zones present at the well site. The well
could therefore provide a pathway for groundwater loss and potential contamination.
Each well bore section will be lined with a steel casing, cemented in place. This process provides a barrier
between the formations (that may include water bearing zones) and the well bore. Each well section would
be lined with a steel casing, which in turn would be cemented in place. The casing and its accessories will be
of such specifications that they can withhold downhole pressures and are resistant to the composition of the
wellbore and formation fluids that they are exposed to. The casing integrity will be tested upon completion of
the drilling to confirm that the casing can withstand the expected pressures and there are no leaks in the
casing.
The cement around the casing holds the casing in place, but also is aimed to prevent communication (of
pressure or fluids) around the outside of the casing between deeper and shallower formations, or even
surface. The quality of the cement can be assessed through for example a Cement Bond Log. This log will
indicate whether there are possible communication paths through the cement. In case a so-called leak path
would be detected, secondary operations may be undertaken in order to seal off the detected communication
path.
During operations, all annuli will be monitored to confirm no leaks develop over time. Also during production
when the rig is no longer on site, it is common practice that the annuli are monitored at a regular basis. In
case pressure or fluid levels are observed to increase, a full investigation will be carried out and if required
production is halted or operations stopped (close in well). Once the investigation confirms the cause of the
increased pressure or fluid levels, appropriate action will be taken to restore the required integrity.
It is anticipated that the well construction adopted will result in negligible groundwater impacts. Impacts of
low significance are therefore expected.

Intersection of deep (saline) water bearing zones


The gas exploration well will drill to depths of up to 5 km. A deep water bearing zone, most likely containing
brackish or saline water, could be intersected. If the well was not adequately cased, it could provide a
pathway for saline water to rise to the surface, impacting on the shallower aquifer.
The same mitigation measures will be implemented as described above.

It is anticipated that the well construction adopted will result in negligible groundwater impacts. Impacts of
low significance are therefore expected.
Intersection of significant fracture zone
The gas exploration well will drill to depths of up to 5 km. An unexpected fracture/fault zone could be
intersected at depth. The well could therefore provide a pathway for groundwater loss to the fractured zone
or and potentially saline water within the fracture rising to the surface and impacting on the shallower aquifer.
The same mitigation measures will be implemented as described above.
The site selection process will ensure that the gas exploration well is drilled in a position where structures
are unlikely to be encountered. It is anticipated that the site selection process and the well construction
adopted will result in negligible groundwater impacts. Should there be doubt, the well will be
decommissioned and sealed. Impacts of low significance are therefore expected.

Failure of steel well casing and cement grout – groundwater inflow


Failure of the steel well casing and cement grout could lead to loss of groundwater via flow into the well.
Should the steel casing and high pressure cement grouting be constructed according to industry standards,
and the casing be pressure tested before installation, impacts of low significance are expected.

It is anticipated that the correct well construction and use of materials will provide protection against any
failures. Negligible impacts to the groundwater system from the well are therefore anticipated. Impacts of low
significance are therefore expected.

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Inflow of groundwater into the well


Uncontrolled inflow of groundwater into the well could lead to a lowering of water levels and reduction of
yield of surrounding water supply boreholes. This is considered an impact of moderate significance. Should,
however, the well construction be designed to isolate the well from the groundwater aquifers, and the well
not be positioned in proximity to water supply boreholes, impact significance can be reduced to low.

Drilling of water wells as an option to obtain a groundwater supply


Water is required for the drilling and hydraulic fracturing operations. If hydraulic fracturing is undertaken the
volume of water required will be 1 000 – 6 000m3 for each well, considerably less water is needed should
drilling only be required.
At this stage a range of options are being considered; these include groundwater and other sources.
The water supply could be obtained from groundwater in the general vicinity of the well site. The
groundwater supply would be obtained from dedicated water supply boreholes sited to exploit potentially
brackish or saline quality water, i.e., groundwater unsuitable for domestic or livestock use, occurring below
the main potable aquifer. The target aquifers are therefore deep water bodies probably at depths greater
than 100 to 300m.
The abstraction of groundwater could have negative impacts on the groundwater regime if not probably
managed.

The water supply would be obtained from a wellfield specifically sited and drilled to supply the well site with
water. These boreholes would be positioned within a reasonable distance of the well site and would be the
subject of a specialised survey to locate suitable target aquifers. It is probable that groundwater sources to
be developed for once-off use during the exploration phase could generally be developed within a 10 km
radius of the well.
The water supply boreholes will need to be correctly constructed with steel casings and sanitary seals to
prevent any surface contaminants entering the groundwater via the borehole annulus. It will also be
important that any new boreholes are not selected within 300 metres of existing boreholes to minimise
impacts.
Provided the water supply boreholes are correctly sited, constructed and tested, and the management
recommendations prepared are adhered to, impacts are anticipated to be low.

Abstraction of groundwater for water supply for drilling


Poorly managed abstraction of groundwater from the boreholes can lead to excessive lowering of the water
table, failure of the borehole and possible lowering of the water level in water supply boreholes located within
the area of influence of the well site borehole(s).
These impacts are considered to be of moderate significance. Should, however, the management
recommendations prepared as a result of the testing of the borehole(s) be adhered to, it is anticipated that
impact significance can be reduced to low.

Air quality
During drilling, air emissions are expected to occur from the following:

ƒ Transportation;

ƒ Power generators;

ƒ Pumps;

ƒ Drilling rig; and

ƒ Open air fluid impoundments (should these be used to hold drill cuttings and fluid).

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Pollutants include:

ƒ Fugitive dust from access roads;

ƒ Combustion gases (sulphur dioxide, oxides of nitrogen, carbon monoxide, 1,3-butadiene, diesel
particulate matter) from vehicle exhausts;

ƒ Vehicle exhaust emissions include combustion gases (sulphur dioxide, oxides of nitrogen, carbon
monoxide, 1,3-butadiene, diesel particulate matter). As these vehicles may be fuelled on site, the
potential to emit volatile organic compounds exists;

ƒ Fugitive emissions of methane from unplanned events, such as encountering a methane pocket; and

ƒ Combustion gases (same as above) and polycyclic aromatic hydrocarbons (PAHs) from power
generators.
Although emissions are likely to occur, it is anticipated that the impacts will be localised. The resulting
impacts on air concentration levels are expected to be of moderate magnitude, hence of moderate
significance. Impact significance can, however, be reduced to low, should the appropriate mitigation
measures be implemented (e.g. reducing vehicle speed, dust suppression on access roads and minimising
the surface area, if open air impoundments are used for storage).

Visual aspects
Dust generation and night lighting will result in visual impacts of moderate significance. Impact significance
can be mitigated to low, should the mitigation measures detailed in Chapter 9 be implemented.

This impact will be reversible upon decommissioning.

Noise
Noise is expected to emanate from the drilling site.
It is assumed that the noise emissions of the drilling and fracturing activities will be similar to measurements
which have been previously measured at other gas drilling operations. These measurements yielded a worse
case range of between 82 and 102 dB(A) at a nominal distance of 1.5 m from the acoustic centre of the
source.

Using the simplified attenuation by distance model and assuming uniform directivity, a flat noise spectrum,
zero ground attenuation, zero air absorbtion, and uniform atmospheric conditions, the noise level at certain
distances from the site centre, can be predicted as follows (theoretical worst case):
Table 26: Noise level in dB(A) at certain distances from the drilling site centre (worst case)
Distance 1.5m 3m 6m 12m 24m 50m 100m 200m 400m 800m 1.6km
From 82 76 70 64 58 52 46 40 34 28 22
(dB)
To (dB) 102 96 90 84 79 72 66 60 56 48 42

When compared with the acceptable values for rural areas according to the SANS standard SANS 10103,
under these worst case conditions, the limit noise level which can be accepted (according to the SANS
standard) will occur at a dwelling which is ±100 m (45 dB(A) during daytime) or ± 2 km (35 dB(A) at night)
from the drilling site centre (when using a worse case value of 82 dB(A) at a nominal distance of 1.5 m from
the acoustic centre of the source).
It needs to be emphasised that this really is the worst case scenario, and the noise level will in practice be
attenuated by relaxation of the various worse-case scenario criteria such as the actual noise level
information for the drilling rigs, individual equipment noise emissions, duration of operations and pause

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periods, site layout, local barrier effects of buildings on site, etc. Predicted noise levels will need to be
confirmed during exploration.
It is anticipated that daytime noise levels will have very low or negligible impacts within a distance of
approximately 80 m from the centre of the site. Impacts at night may, however, rise to moderate significance
within 150 m from the centre of the site. (When using a worse case value of 82 dB(A) at a nominal distance
of 1.5 m from the acoustic centre of the source).
This impact will be reversible upon decommissioning.

Socio-economic
Same as for site preparation

Access, traffic and transport


Same as for site preparation

8.5.4 Hydraulic fracturing


Table 27 below summarises those impacts directly related to hydraulic fracturing, and provides a significance
rating for each impact before and after mitigation. It is important to note that these are estimates of likely
significance of these activities as the impact is dependent upon the site and the characteristics of that site.
For this reason, the significance ratings provided herein are purely a guideline. Impact significance will be
confirmed as part of the detailed EIA.
Table 27: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas
Exploration Application Project –Hydraulic Fracturing
POTENTIAL ENVIRONMENTAL SIGNIFICANCE
ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: HYDRAULIC for relevant mitigation measures)
FRACTURING M D S P Total SP M D S P Total SP
1. Soil
Potential spillages from
hydraulic fracturing fluids, 8 3 1 3 56 Mod 4 3 1 2 24 Low
etc could contaminate soils.
2. Surface water
The activities on site involve
the handling of chemical
additives for the hydraulic
fracturing. These materials
will be stored on site. There
is the potential for spills from
these storage and material 2 2 2 2 12 Low 2 2 1 2 10 Low
handling facilities There is
the potential for the spill and
leaks of the potentially
polluted return flow fluid
from the hydraulic fracturing
process.

3. Groundwater
Storage tanks for poor
quality water, i.e. saline /
brackish water, could 4 1 2 2 20 Low 2 1 1 2 8 Low
leak/collapse/burst leading
to contamination of aquifer.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: HYDRAULIC for relevant mitigation measures)
FRACTURING M D S P Total SP M D S P Total SP
Failure of pumps/pipes
to/from storage tanks to
4 2 2 2 24 Low 2 2 2 1 10 Low
wellhead, resulting in
spillage.
Leakage / spillage of stored
hydraulic fracturing
chemicals leading to 4 2 2 2 24 Low 2 2 1 2 10 Low
deterioration of groundwater
quality at the site.
Failure of steel casing to
provide complete seal with
hydraulic fracturing zone
and leakage of gas and 6 2 2 1 30 Mod 4 2 1 1 16 Low
chemicals into the well
annulus and subsequently
into the overlying aquifers.
Hydraulic fracturing of the
well leading to invasion of
chemicals from the target
8 2 2 1 40 Mod 4 2 2 1 16 Low
shale horizon into the
overlying aquifers via
unknown fracture zones.
Larger volume of return
water from the gas
exploration well than
expected resulting in the
return water storage dam
6 2 2 3 42 Mod 4 1 1 1 12 Low
filling and overflowing and/or
spillage of saline/brackish
return water from the well
causing contamination of the
underlying groundwater.
Abstraction of groundwater
to supply water for hydraulic 6 4 3 3 60 Mod 2 2 2 2 12 Low
fracturing.
4. Air quality
Gas may be flared. Fugitive
emissions may occur at
open air fluid
impoundments, if these are 6 2 2 4 42 Mod 4 2 2 4 28 Low
used to store hydraulic
fracturing flowback water.

5. Visual aspects
An operational flare at the
well site will result in visual 8 2 2 3 56 Mod 6 2 2 2 36 Mod
impacts.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: HYDRAULIC for relevant mitigation measures)
FRACTURING M D S P Total SP M D S P Total SP
6. Noise
Drilling, pumps,
compressors and
generators, flaring and
vehicles importing and
exporting materials and staff 4 2 2 4 32 Mod 2 2 2 4 24 Low
could increase ambient
noise levels between ±150
m and 1.6 km from the
centre of the site, at night.

7. Socio-economic aspects
Refer to site preparation
8. Access, traffic and transport
Refer to site preparation

Soils
There is potential for contamination of soil to occur at the site due to accidental spillages of chemicals (such
as hydraulic fracturing fluids) at the site. All hazardous chemicals will be stored in appropriate containers.
Storage facilities used for flowback water will be lined to prevent infiltration into the soil. The significance of
this impact is considered moderate prior to mitigation; with the implementation of measures described in
Chapter 9, the significance of this impact can be reduced to one of low significance.
Should soils be contaminated with chemicals, the impact may/may not be reversible, depending on the
nature of the pollutant.

Surface water
Spill and leaks of hydraulic fracturing chemicals and return flow fluid into the environment
The chemical additives used in the fracturing fluid have not be identified at this stage and the impacts and
required mitigation measures will be investigated further in the next stage of the project based on the actual
chemical additives to be used.
The hydraulic fracturing process will generate a return flow from the wells. In other operations, Shell has
achieved recovery of up to 50% of the water used as a return flow volume. The return flow fluid will contain
the chemical additives used in the fracturing water as well as any contaminants mobilised from the
(geological) formation.
The return flow fluid could be contaminated to an extent that the fluid cannot be discharged to the
environment. This fluid will be stored on site and disposed of in an appropriate manner. The disposal method
will depend on the water quality of the fluid. The disposal could be to a local sewage treatment works,
treatment on site before discharge or disposal at an appropriate facility off site. The fluid will also be pumped
on site and there is the potential for pipe leaks or bursts on site.
The storage container for the fluid will be in a bunded area. The water quality of the fluid will be determined
on site and the appropriate disposal method applied. Any leaks from the pumping system will be caught in
the onsite sump before entering the environment. The development and application of material handling
procedures for the site will also reduce the risk of material entering the environment.

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The impact is ranked as low due to the provision of the mitigation measures and the local scale of the
impacts.
Should surface water be contaminated with chemicals, the impact may/may not be reversible, depending on
the nature of the pollutant.

Groundwater
Water storage tanks leak/collapse/burst
Same as for exploration drilling.

Pumps/pipes to/from storage tanks to wellhead failure


Same as for exploration drilling.

Leakage / spillage of stored chemicals


Chemicals used for hydraulic fracturing may be stored on site. Leakage and/or spillage of could result in
groundwater contamination. Should appropriate mitigation measures be implemented, such as storage of
chemicals in containers located in bunded areas, impact significance is anticipated to be low.
Should groundwater be contaminated, the impact may/may not be reversible, depending on the nature of the
pollutant.

Leakage and spillage of contaminated water during transport to selected disposal site
Contaminated water and chemicals may need to be removed from the site. Leakage and/or spillage while
being transported could result in groundwater contamination. Should the appropriate mitigation measures be
implemented, such as ensuring that tankers and associated pumps and pipelines are mechanically sound
and tanker drivers are experienced and trained in driving hazardous loads, impact significance is anticipated
to low (due to low probability of impact occurrence).
Should groundwater be contaminated, the impact may/may not be reversible, depending on the nature of the
pollutant.

Failure of steel casing to provide complete seal in the with hydraulic fracturing zone and
leakage of gas and chemicals into the well
Failure of the steel well casing and cement grout due to stresses caused by installation depth and/or the
hydraulic fracturing process could lead to contaminated water, gas and hydraulic fracturing chemicals
entering the shallow aquifer.
This impact is considered to be of moderate significance. Should the steel casing and high pressure cement
grouting be constructed according to industry standards, and the casing be pressure tested before
installation, impacts of low significance are expected.

Hydraulic fracturing of the well


Hydraulic fracturing of the shale is carried out under high pressure and is designed to crack the shale open
to improve the permeability around the gas well. Concern has been expressed that the hydraulic fracturing
process could lead to uncontrolled fracturing of the overlying strata. This could then provide a pathway for
contamination of the groundwater via fractures newly created by the hydraulic fracturing process.
The hydraulic fracturing process is designed to fracture the shale in the target reservoir only. The gas
exploration wells will be located away from fracture zones, dolerite dykes and other zones of potential
weakness to minimise the risk of unexpected fracturing. The ground geophysical surveys are designed to
identify such features and thus aid in positioning the well away from these lines of structural weakness.
The great depth at which the hydraulic fracturing will take place (1 000 – 5 000 m below surface) provides
substantial protection to the overlying groundwater aquifers due to the weight of the overlying rock mass
which will counteract the hydraulic fracturing pressures.

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Prior to the commencement of the drilling, an EIA will first be undertaken. This detailed assessment of the
selected site and surrounding area will involve monitoring of water levels and water quality. This monitoring
will continue throughout the drilling and hydraulic fracturing process. Should any impact be detected
hydraulic fracturing will cease.
Based on the above, it is anticipated that hydraulic fracturing will result in negligible impacts outside of the
intended target shale zone. Impacts of low significance are therefore expected.

Larger volume of return water from the gas exploration well than expected
Between 1 and 6 million litres of water may be used if hydraulic fracturing is carried out. This water will be
pumped into the well and used to achieve the desired fracturing of the target shale horizon. Fluids used in
this process return to the surface once the well is back produced. These fluids are, referred to as ‘flowback’,
can then be recycled, and mostly re-used for other drilling activities. The percentage of fluids that can be re-
used for other drilling operations will vary from one well location to another as a result of even small
variations in the geological properties of the shale formations deep underground. Similarly, the quality of flow
back water which may or may not require additional treatment, prior to re-use, will likely vary.
Any water that is no longer required for the operation will be treated and cleaned– using mobile water
processing equipment - in line with Shell’s own technical standards and relevant South African regulations.
The most suitable location for recycling will be determined subsequent to site selection.

Higher recoveries of flowback than anticipated could lead to on site storage facilities overflowing and spillage
occurring, which could in turn lead to contamination of the groundwater.
It is, however, anticipated that the implementation of the above-mentioned mitigation measures will result in
impacts of low significance.

Inflow of groundwater into the well


Same as for exploration drilling.

Abstraction of groundwater for water supply to the drilling and hydraulic fracturing
operations
Same as for exploration drilling.

Air quality
During hydraulic fracturing, air emissions could potentially occur from the following:

ƒ Combustion gases (sulphur dioxide, oxides of nitrogen, carbon monoxide, 1,3-butadiene, diesel
particulate matter) and polycyclic aromatic hydrocarbons (PAHs) from power generators;

ƒ Evaporating VOCs from open air fluid impoundments, if these are used to store flowback water; and

ƒ Combustion gases (same as above) from compressors and from well testing / flaring.
It is anticipated that a flare pit will be constructed. A flaring rate of 2 800 to 8 500 m3 (100 to 300 Mscf) is
expected during the testing period. Flaring is seen as a safer way to manage the gas than simply allowing it
to vent into the air. Flaring is also used to burn gases that would otherwise present a safety problem. It is
common to flare natural gas that contains hydrogen sulphide in order to convert the highly toxic hydrogen
sulphide gas into less toxic compounds.
Early explorations done by Soekor did not encounter hydrogen sulphide (not from the drilling reports, nor
core analyses). The gas composition that was measured in the past was a mix of mainly Methane (92%) ,
Ethane (6%) and higher hydrocarbon chains (2%) (Rowsell, D.M. and De Swardt, A.M.J., 1976, Diagenesis
in Cape and Karroo sediments, South Africa, and its bearing on their hydrocarbon potential). Transactions of
the Geological Society of South Africa 79 (1), 81-129). The likelihood of hydrogen sulphide emissions is
therefore low.

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The nature of flare emissions depend on the chemical composition of the gas being burned and the
efficiency and temperature of the flare. Flaring results in sulphur dioxide emissions if hydrogen sulphide is
present in the natural gas. There may also be additional by-products formed if some of the chemicals used
during the drilling or hydraulic fracturing process are converted to a gaseous form and are burned along with
the natural gas. The detailed EIA will address this possibility and its significance.
Fugitive emissions are unintentional leaks of gases. This may occur from breaks or small cracks in seals,
tubing, valves or pipelines, as well when lids or caps on equipment or tanks have not been properly closed or
tightened. When natural gas escapes via fugitive emissions, methane as well as VOCs and any other
contaminants in the gas (e.g. hydrogen sulphide) are released to the atmosphere. The detailed EIA will
address this possibility and its significance.

Although emissions are likely to occur, it is anticipated that the impacts will be localised. The resulting
impacts on air concentration levels are expected to be of moderate magnitude, hence of moderate
significance. Impact significance can, however, be reduced to low, should the appropriate mitigation
measures be implemented. Refer to Chapter 9 for mitigation measures.

Visual aspects
An operational flare at the well site will result in visual impacts, and indirect impacts on animal life.
Impact significance is considered to be moderate, with limited mitigation potential, due to the relatively low
visual absorption capacity of the area (as a result of little vegetation cover, topographical landforms and
existing human structures). For this reason, where possible, care must be taken to position well sites in
locations and in such ways that it will not constitute an excessive intrusion.

This impact will be reversible once flaring is discontinued.

Noise
Same as for exploration drilling.

Socio-economic
Same as for site preparation.

Access, traffic and transport


Same as for site preparation.

8.5.5 Decommissioning
Table 28 below summarises those impacts directly related to decommissioning, and provides a significance
rating for each impact before and after mitigation. It is important to note that these are estimates of likely
significance of these activities as the impact is dependent upon the site and the characteristics of that site.
For this reason, the significance ratings provided herein are purely a guideline. Impact significance will be
confirmed as part of the detailed EIA.
Table 28: Technical Assessment Matrix for the proposed South Western Karoo Basin Gas
Exploration Application Project –Decommissioning
POTENTIAL ENVIRONMENTAL SIGNIFICANCE
ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: for relevant mitigation measures)
DECOMMISSIONING M D S P Total SP M D S P Total SP
1. Soil
Potential spillages from
heavy machinery, vehicles,
8 3 1 3 56 Mod 4 3 1 2 24 Low
generators, etc could
contaminate soils.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: for relevant mitigation measures)
DECOMMISSIONING M D S P Total SP M D S P Total SP
2. Ecology (Fauna and Flora)
During decommissioning,
infrastructure will be
removed and the site will be
rehabilitated. This may result 6 3 2 3 48 Mod 4 2 2 2 24 Low
in the colonisation of the site
by invasive alien plant
species.

3. Surface water
The decommissioning
activities on site involve the
removal of equipment and
storage facilities. Runoff 2 2 2 2 12 Low 2 2 1 2 10 Low
from the site has the
potential to be polluted.

4. Groundwater
Leakage and spillage of
contaminated water during
transport to selected 2 1 2 2 10 Low 2 1 1 2 8 Low
disposal site.

Spillages and residues


during and after site clean 2 1 1 2 8 Low 2 1 1 2 8 Low
up.
Inadequate sealing of well
resulting in poor sealing of
gas and contaminated
hydraulic fracturing water 6 4 3 2 54 Mod 2 4 2 1 14 Low
and subsequent invasion of
the well and contamination
to groundwater aquifers.
Inadequate sealing of water
supply boreholes leading to 6 4 2 2 24 Low 2 4 2 1 14 Low
aquifer contamination.
5. Air quality
Various activities during site
decommissioning may
disturb the soil to some
degree through the use of 4 1 1 3 20 Low 2 1 1 2 10 Low
machinery. Fugitive dust will
be released as well as
exhaust emissions.

6. Visual aspects
Excessive dust and night
lighting could result in visual 6 3 2 3 48 Mod 4 3 2 2 28 Low
impacts.

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POTENTIAL ENVIRONMENTAL SIGNIFICANCE


ENVIRONMENTAL After mitigation (refer to Chapter 9
Before mitigation
IMPACT: for relevant mitigation measures)
DECOMMISSIONING M D S P Total SP M D S P Total SP
7. Noise
Decommissioning activities,
such as removing of
infrastructure, and trucks
and heavy machinery, will 2 2 2 4 16 Low 2 2 2 3 14 Low
increase ambient noise
levels.

8. Socio-economic aspects
Same as for well site preparation
9. Access, traffic and transport
Same as for well site preparation

Soils
Upon decommissioning, soil remediation of the site will aim to restore the soil resource back to its original
state. The remediation process will include ripping of the soil, re-application of topsoil and establishment of
vegetation cover.
There is the potential for contamination of soil to occur at the site due to accidental spillages of fuels at the
site. The significance of this impact is considered moderate prior to mitigation. With the implementation of
the mitigation measures described in Chapter 9, the significance of this impact can be reduced to one of low
significance.
Should soils be contaminated with fuel, the impact may be reversible, should the soil be remediated using
bioremediation.

Land capability and land use


In terms of Section 37 of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002), the
holder of a permit is liable for any and all environmental damage or degradation emanating from his/her
operation, until a closure certificate is issued in terms of Section 43 of the Act.
The following are preliminary recommendations for rehabilitating the well site after decommissioning the well
– these recommendations will be investigated further during the site specifc EIA:

ƒ Remove all temporary works in and around the accommodation camp and drilling site.

ƒ Fences and private roads disturbed by activities will be restored to their original condition unless
another agreement is reached with the applicable landowner.

ƒ Allow normal surface drainage except where special measures are employed to prevent soil erosion.

ƒ Loosen compacted soils along the delineation of the access road. Scarifying areas where topsoil has
been removed shall be carried out prior to the replacement of topsoil. Care shall be taken to avoid
topsoil inversion if scarifying is carried out in areas where topsoil has not been removed. Any ploughing
or scarifying operation shall not exceed a depth of 100 mm.

ƒ Where the land is naturally armoured with surface rock or stone, armouring rock should be placed over
the construction servitude to protect against erosion, in a manner similar to its original condition.

ƒ Re-establish the vegetation that existed prior to disturbance, to the greatest extent possible.

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After decommissioning and successful rehabilitation, the land use may return to the original use.

Ecology
The long term objective for rehabilitation is to in all affected areas, re-establish the vegetation that existed
prior to site preparation, to the greatest extent possible. Where the routes/affected areas pass through areas
that are disturbed or degraded to varying degrees, especially where extensive agriculture has occurred,
indigenous vegetation should be established, covering the affected areas, in order to protect the soil against
erosion.
Rehabilitation in this area will be very difficult due to climatic and vegetation conditions and the low and
erratic rainfall. A number of publications are available on rehabilitation of vegetation in the Karoo (De Villiers
et al., 2004; Beukes and Cowling, 2003; Blignaut and Milton, 2005; Simons and Allsopp, 2006; Burke, 2001;
Hanke et al., 2011; Visser et al., 2004). These publications and input from local conservation specialists will
need to be applied in developing a successful rehabilitation plan. Removing and maintaining vegetation from
the site in a nursery for transplanting back on the site during decommissioning is an option that should be
investigated.

Colonisation of the site by invasive alien plant species


During well site preparation, vegetation will be cleared and will be maintained in this state during exploration.
Upon decommissioning, infrastructure will be removed and the site rehabilitated. This may result in the
colonisation of the site by invasive alien plant species such as Prosopis sp., Salsola kali and Medicago
laciniata.
This impact can be mitigated by implementing an invasive plant monitoring programme at the site, until such
a time as the indigenous vegetation community has been re-established.
The significance of this impact is rated as moderate due to the localised nature of this impact. Should,
however, the monitoring programme be implemented and, if necessary, invasive alien plant species
removed, impact significance can be reduced to low.
Should alien invasive species become established at the site, this impact is reversible by clearing the site of
such species.

Surface water
Polluted runoff leaving the site
The decommissioning activities on site involve the removal of equipment and storage facilities. The runoff
from the site has the potential to be polluted. Due to the low probability of rainfall in the area and the small
area of the site, the impact is ranked as low. The sump should be maintained on site to collect any runoff
from the site. The sump will be removed once the site is decommissioned.
Should surface water be contaminated with pollutants, the impact may/may not be reversible, depending on
the nature of the pollutant.

Groundwater
Leakage and spillage of contaminated water during transport to selected disposal site
Contaminated water and chemicals will need to be removed from site during decommissioning. Leakage
and/or spillage while being transported could result in groundwater contamination. Should the appropriate
mitigation measures be implemented, such as ensuring that tankers and associated pumps and pipelines are
mechanically sound and tanker drivers are experienced and trained in driving hazardous loads, impact
significance is anticipated to low (due to low probability of impact occurrence).
Should groundwater be contaminated with pollutants, the impact may/may not be reversible, depending on
the nature of the pollutant.

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Spillages and residues during and after site clean up


Storage containers and the flowback water storage facility will need to be removed and rehabilitated to
minimise risk of long-term pollution of groundwater. During this process, there is the potential for spillages
and subsequent groundwater contamination. Impacts of low significance are expected.
Should groundwater be contaminated with pollutants, the impact may/may not be reversible, depending on
the nature of the pollutant.

Inadequate sealing of well


The well will provide a pathway from the gas reservoir to the surface. If the well is decommissioned, and
inadequately sealed, there is the potential that gas and contaminated hydraulic fracturing water can
contaminate groundwater aquifers. This is considered to be an impact of moderate significance. However,
should correct application of pressure grouting techniques, including maintaining records of the volume of
cement used compared to volume of the well be ensured, impact significance can be reduced to low.
Should this impact occur, it will be irreversible, unless an alternative water supply is provided to affected
groundwater users.

Inadequate sealing of water supply boreholes


The water supply boreholes will provide a pathway for poor quality surface water to enter the aquifer. The
boreholes will also provide a pathway for brackish and/or saline groundwater targeted at depth to
contaminate the overlying freshwater aquifer, should there be a positive hydraulic head acting on the deeper
aquifer. These aspects could lead to groundwater contamination.
If potable quality groundwater was suppled for the drilling/hydraulic fracturing processes, the borehole can
be incorporated into the long-term monitoring programme, or given to the landowner to use.
If the borehole provided brackish and/or saline groundwater, the well is to be decommissioned, backfilled
and sealed according to industry standards. This could involve pressure grouting the hole closed. Should the
well be sealed, impacts of low significance are anticipated.

Should this impact occur, it will be irreversible, unless an alternative water supply is provided to affected
groundwater users.

Air quality
Minimal emissions are expected upon decommissioning of the exploration well, and would mainly include
particulate emissions during the decommissioning process. Fugitive particulate matter and VOC emissions
may also occur during the rehabilitation of any fluid impoundments. It is anticipated that the site
decommissioning activities could result in low impacts.

Visual aspects
Excessive dust generation and night lighting could result in visual impacts during decommissioning. Impact
significance can be mitigated to low, should the mitigation measures detailed in Chapter 9 be implemented.
This impact will be reversible upon closure.

Noise
Decommissioning activities, such as removal of temporary buildings/facilities, and trucks and heavy
machinery, will increase ambient noise levels. It is anticipated that the impact will be of a temporary nature
and will be localised. An impact of low significance is therefore likely to occur.

This impact will be reversible upon closure.

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8.6 Human Health


This section provides a brief overview of some of the key potential risks to human health associated with
exploration drilling any hydraulic fracturing. The below description is based on reviewing literature that is
available in the public domain (specialist reports from projects in the USA and a position statement from
Europe), while considering the specific process that Shell will adopt, as described in Chapter 5. The following
potential risks to human health may be associated with the proposed exploration drilling programme:

ƒ The large amount of water required for hydraulic fracturing could lower water tables and decrease the
amount of available drinking water sources/supplies. Lower water tables may also affect water quality
by exposing naturally occurring minerals to an oxygen rich environment which may cause salination and
chemical contamination of water. Lower water tables may also stimulate bacterial overgrowth leading to
taste and odour problems;

ƒ The bulk of the hydraulic fracturing fluid comprises water and sand which acts as a proppant to keep
fractures open. Fracturing fluids do, however, contain quantities of chemicals (about 1-2% by volume).
The type and concentration of the chemicals used depends on the conditions of the specific well. While
many of the chemical additives are relatively benign, some chemicals that a company may select to use
are known to have acute (from acids and bases) and more chronic effects (ethylene glycol,
glutaraldehyde, and n,n-dimethyl formamide), if an exposure path exists;

ƒ Hydraulic fracturing may affect the mobility of naturally occurring substances especially in the gas
containing formulation. Substances such as naturally occurring radioactive material, polycyclic aromatic
hydrocarbons and mercury, lead or arsenic may be mobilised as a result. There is the potential that
these substances may find a pathway to the upper source of drinking water after the fracturing process
if the fractures extend past the target formation to reach aquifers or if the cement casing in the wellbore
fails under pressure exerted in the fracturing process.

ƒ Flow-back water occurs with a change in direction of the injected fluid whereby the injected fluid plus
naturally occurring substances that were mobilised in the subsurface move back up the borehole to
surface at the end of the fracturing process. The physical and chemical properties of flow-back and
produced water varies with the type of hydraulic fracturing fluid used and the specific geological
formation. Flow-back fluid usually contains high concentrations of total dissolves solids (TDS) but can
also have high concentrations of major ions and radionuclides as well as VOCs (including benzene,
toluene and xylenes). Potential contamination of water sources may occur at the surface and at the
upper source of drinking water.

ƒ Methane is the largest potential source of air emission associated with hydraulic fracturing. The
challenge is to manage the flow of methane before the well is put into production which may entail
venting or flaring. The high concentrations of methane may pose a significant explosion threat.

ƒ Flow-back fluids may be sources of VOCs (including acetone, benzene, toluene, phenol and ammonia)
and hydrogen sulphide.

ƒ Increased truck traffic to support the operations is potentially a major source of air emission. This can
include increased levels of NO2, CO and diesel particulates. Dust from vehicles may also increase.

ƒ There are suggestions that hydraulic fracturing activities may be associated with low magnitude
earthquakes.

ƒ There was a concern related to contamination of soil by hydraulic fracturing fluids, and also potential
exposure of domestic animals and wildlife to water impoundment dams with adverse effects to the
animals and unknown potential effects of bioaccumulation in the food chain. The same may apply to
plant material with potential bioaccumulation effects.

ƒ Concerns were expressed about public safety associated with potential chemical spills, well blowouts
and transportation of hydraulic fracturing fluids and waste water.

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ƒ Occupational risks in the workplace health and safety which includes acute and chronic health effects.
These can be divided into physical, chemical, biological and psychosocial risks.

ƒ Acute loud noise and chronic low level noise is associated with a variety of negative health effects.
These can include hearing loss but also psychological and physical health effects due to noise
annoyance.

ƒ Light disturbance at night may disrupt sleep and cause health effects by disrupting normal circadian
rhythms and hormone release.
As part of the site specific EIA, a human health impact assessment will be conducted to confirm potential
risks to human health, as well as to provide measures to manage and mitigate identified risks.

8.7 Cumulative impacts


Geophysical data acquisition
Due to the minimal area of surface disturbance associated with the MT surveys, it is not anticipated that this
exploration activity will contribute to any existing cumulative impacts on the environment.

Well site preparation, exploration drilling and hydraulic fracturing


Due to the relatively small area of surface disturbance associated with the well site preparation, exploration
drilling and hydraulic fracturing activities, it is not anticipated that these exploration activities will contribute
significantly to any existing cumulative impacts on the environment. This will, however, be verified once the
drilling sites have been selected and aspects such as current land use, and future mining and infrastructural
developments, are taken into consideration.

8.8 Assumptions and knowledge gaps / limitations


A number of assumptions have been made to complete the technical assessment. This section provides a
description of the assumptions made herein.

These knowledge gaps and limitations will need to be addressed as part of the detailed EIA, which will be
undertaken prior to commencement of drilling and/or hydraulic fracturing.

General
ƒ The locations of the sites have not yet been determined. Impacts were therefore assessed for a generic
site;

ƒ The mud programme, well design, content of the hydraulic fracturing fluids, treatment/disposal method
for backflow water, fate of hydrocarbons produced, etc are currently not yet defined;

ƒ Impact significance ratings have been estimated, as the impact is dependent upon the site and the
characteristics of that site. For this reason, the significance ratings provided herein are purely a
guideline. Impact significance will be confirmed as part of the detailed EIA; and

ƒ Impacts after mitigation are based on the assumption that mitigation measures have been put in place
and implemented correctly.

Soil
ƒ Available databases were only of a general scale; and

ƒ The study area has not been subjected to a field survey. This study is entirely based on a desktop
review and no field or groundtruthing took place. A field study is anticipated for the near feature.

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Terrestrial ecology
ƒ An intensive baseline biodiversity assessment of potential drilling sites taking seasonal variation into
consideration has not yet been conducted since sites where drilling will take place have not yet been
identified.

Surface water
ƒ The source and quantity of water has not yet been finalised. The source will affect the need for storage
and the handling approach on site; and

ƒ The quantity and quality of the return flow (backflow) fluid is currently unknown.

Groundwater
ƒ The groundwater technical assessment has been prepared without detailed knowledge of the actual
drilling sites. It is therefore indicative at this stage.

ƒ A detailed assessment of potential impacts to the groundwater aquifers will be undertaken as part of the
EIA, once site selection has been completed.

Air quality
ƒ Air pollutants from the exploration drilling activities may be divided into their potential impacts, namely
nuisance (odours and dustfall) and toxic (irritants and carcinogenic) compounds. The significance of
these impacts are determined firstly through the potential to violate relevant regulatory criteria (both
ambient air and emission limits) and secondly through the comparison to health risk criteria. Since the
air quality technical assessment was conducted at a qualitative level, direct comparison of absolute air
concentrations was not possible. Instead, only the potential sources of air emissions and the various air
pollutants have been discussed.

ƒ The final detail of the proposed exploration activities in terms of, for example, layout, is not yet
available. Sources of emissions were therefore based on typical exploration configurations.

ƒ The anticipated power generation and compressor sizes have not been fixed. It was therefore not
possible to quantify air emissions of gases and particulate matter from the equipment.

ƒ The number and types of vehicles required during the various steps for exploration drilling are still
preliminary.

ƒ The access road lengths have not been determined since the exact locations for drilling have not been
identified.

ƒ It is assumed that the flare would operate continuously during hydrocarbon flow testing.

Noise
ƒ For the purposes of the noise assessment, a range of between 82 and 102 dB(A) at a nominal distance
of 1.5 m from the acoustic centre of the source has been used.

ƒ A worst case scenario has been assumed, i.e. continuous well site preparation and road construction
and drilling activities throughout the day and night.

ƒ In addition, the precise locations of the selected drilling locations are as yet undefined; therefore, any
sensitive receptors adjacent to the sites are currently unknown.

Heritage / cultural aspects


ƒ The available heritage databases are incomplete. Large areas of the study area have never been
surveyed from a heritage perspective.

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ƒ The application area has not been subject to a field survey. The technical assessment undertaken for
the EMP is entirely a desktop based survey and no field or ground surveys were conducted. However,
these will be commissioned as part of the detailed EIA to follow.

Human health
The following has been recognised as limitations to the human health assessment:

ƒ The broad project area and the lack of definition of specific potentially affected communities. A more
detailed study will be undertaken as part of the EIA, when specific locations have been identified.

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9.0 ENVIRONMENTAL MANAGEMENT PLAN


9.1 Objectives
This section outlines the Environmental Management Plan (EMP), in draft form, that will be implemented
during the construction, operation and decommissioning phases of the proposed South West Karoo Basin
gas exploration Project (see Section 5 for a detailed project description).
The EMP comprises a series of individual plans that outline the scope of environmental management
pertaining to compliance with applicable regulatory requirements and Shell policies and procedures.
Key objectives of the EMP are to:

ƒ recognize that social responsibility and environmental management are among the highest corporate
priorities;

ƒ ensure that applicable acts, regulations and guidelines are met;

ƒ assign clear accountability and responsibility for environmental protection and social responsibility to
management and employees;

ƒ facilitate environmental planning through Project life cycle;

ƒ provide a process for achieving targeted performance levels;

ƒ provide appropriate and sufficient resources, including training, to achieve targeted performance levels
on an ongoing basis; and

ƒ evaluate environmental performance and social responsibility against Shell’s environmental and other
policies, objectives and targets and seek improvement where appropriate.
The EMP is organized into the following sections:

ƒ Project Description.

ƒ Applicable Laws, Regulations and Guidelines

ƒ Shell Policies and Procedures.

ƒ Roles and Responsibilities.

ƒ Location and Design Methods.

ƒ Environmental Management Plans and Mitigation Measures – a description of the mitigation measures
and individual EMPs that will be implemented during the Project.

ƒ Monitoring Plans – a description of monitoring plans that will be implemented during all Project phases.

ƒ Grievance Mechanism
9.2 Project description
The project description is described in detail in Section 5. In broad terms the project entails the following key
activity steps, which are not necessarily consecutive implementation.

ƒ Undertaking geophysical data acquisition. This is largely a non-invasive task although nominal
excavation is required to position the recording equipment below ground level (shallow trench the depth
of a spade head);

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ƒ The drilling of vertical boreholes to intersect the targeted Shale layer. These boreholes will be between
1500 m and 5000 m deep depending on their location within the exploration rights areas. These
boreholes will be developed using standard deep level drilling techniques but may also include the
sampling of intact geological core through the target shale layer once this layer has been intersected.
Shale samples will be analysed for gas;

ƒ The vertical intersection of the shale layer may be hydraulically fractured to test whether gas can be
stimulated to flow;

ƒ If gas can be stimulated to flow within the shale layer, a horizontal borehole may be drilled from the
base of a vertical hole extending up to 2 km into the shale layer;

ƒ Horizontal boreholes would be hydraulically fractured to stimulate gas flow and enable gas yield
properties of the strata to be tested, and lastly; and

ƒ If the exploration proves unsuccessful, gas exploration wells will need to be decommissioned and
made safe.

9.3 Applicable Laws and Regulations


The primary legislation applicable to the Project includes, but is not likely limited to, the following:

ƒ Mineral and Petroleum Resources Development Act;

ƒ National Environmental Management Act;

ƒ National Environmental Management Biodiversity Act;

ƒ National Environmental Management Waste Act;

ƒ National Water Act; and

ƒ National Nuclear Regulator Act.

Section 3 provides further details on the Project legal context.

9.4 Shell Policies and Procedures


Shell will comply with all legal requirements prior to, and during, any field activity in the Project.
The company has set business principles and standards for health, safety, security, environment and social
performance (http://www.shell.com/home/content/aboutshell/who_we_are/our_values/sgbp/), to which every
employee must abide by. Briefly, these principles include:

ƒ Contribution to sustainable development by balancing short and long-term interests and integrating
economic, environmental and social considerations into decision-making;

ƒ Applying a systematic approach to health, safety, security and environmental management in order to
achieve continuous performance improvement; and

ƒ Being a good neighbour by continuously improving the ways, in which Shell contributes directly or
indirectly to the general wellbeing of the communities within which they work and committing.
All activities will be carried out in accordance with Shell’s General Business Principles, Sustainable
Development Principles and HSE Commitment and Policy which is supported by a full suite of Shell HSE
standards (unless there is a conflict with legislation, in which case legislation takes precedence).

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9.5 Roles, Responsibilities and Training


9.5.1 Roles and Responsibilities
Shell will be responsible for the overall implementation, monitoring and quality assurance/quality control of
this EMP. The Project EMP would be provided to contractors submitting tenders for construction and
operation of any components and activities of the Project. This would provide the contractors with details on
the environmental sensitivities and requirements of the Project.
Shell will be responsible for the monitoring of the environment while each contractor is to be responsible for
monitoring working conditions, safety and occupational health of contractor’s work area.
Shell will be responsible for periodic environmental inspections of the exploration sites in general. Each
contractor shall be responsible for workplace occupational health, safety and environmental inspections.
Each contractor shall also be responsible for following up on the corrective action required as a result of
these inspections. Contractors shall report the results of all environmental inspections to Shell.

9.5.2 Training
All Shell employees will be appropriately trained and qualified to carry out their duties under the scope of the
EMP.
Shell will endeavour to employ only competent staff and contractors to carry out their operations. Where staff
or contractors do not meet the appropriate competence or awareness of standards and regulations that is
required, Shell will provide adequate and suitable training to meet the requirements.

9.5.3 Monitoring and Inspection Systems


A periodic monitoring and inspection system shall be implemented throughout the exploration phase, with
reports made on the following: adverse impacts, effectiveness of plans and remediation efforts. Any
significant impact on persons, property or the environment must be reported immediately to Shell, and a
written report shall be submitted on these incidents, including a root cause analysis.

9.6 Location and Design Methods


This section contains a description of location and design criteria for the Project that will be applied during
the Project. The location and design methods and criteria are based on:

ƒ applicable local and national laws and regulations;

ƒ applicable technical design codes;

ƒ applicable national environmental criteria and standards; and


The environmental criteria have been subdivided into qualitative and quantitative criteria. Qualitative criteria
correspond to general and specific criteria that cannot be measured with the aim of preventing or minimizing
environmental impact. Quantitative criteria correspond to those definite limit values, established in national
regulations. These limits will continue to be used as a control of the mitigation measures as detailed in the
Environmental Monitoring Plan (see Section 8.8).

9.6.1 Project Design Codes


This section will be updated to reflect standards to which project designs will be completed.

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9.6.2 Environmental Criteria


9.6.2.1 Qualitative Criteria
The following qualitative environmental criteria are related to Project location and design criteria to avoid or
minimize potential effects:

ƒ Archaeological Sites: Where feasible, avoidance of terrestrial and marine archaeological sites. If sites
cannot be avoided, adherence to regulatory protocols for protection and/or removal.

ƒ Protected Areas: Avoidance of direct Project footprint effects to nearby protected areas and avoidance
or minimization of indirect effects (e.g. marine water quality, air quality).

ƒ Wildlife Species of Conservation Status: Avoidance of direct mortality, destruction of habitats and
indirect effects to species with conservation status, including International Union for the Conservation of
Nature (IUCN) Red List species.

ƒ Key Wildlife Habitats: Avoidance or minimization of direct and indirect impacts to key wildlife habitats
(e.g., reproductive and migratory habitats).

ƒ Natural and Industrial Risks: Establish Project design parameters to help minimize environmental and
public health and safety impacts from natural and industrial hazards.

ƒ Water: Extraction of water will not occur as to result in a high impact to the environment or users of the
identified water source. Water is recycled into the process where practical and appropriate. The
discharge of untreated wastewater, spill and drainage into the environment is prohibited unless it meets
applicable water quality standards for discharge.

ƒ Atmosphere: Dust and other emissions produced by Project activities will meet applicable ambient air
quality standards at sensitive receptors.

ƒ Noise: Noise levels will meet applicable noise criteria at sensitive receptors.

9.6.2.2 Quantitative Design Criteria


This section will contains information on South African ambient standards for air, atmospheric noise, water
quality and sediment quality.
Likewise, maximum permissible limits/discharge limits are identified that were also included as design criteria
for this Project.
These criteria and limits will be defined as a discipline level during detailed impact assessment which will
precede site clearance, drilling and hydraulic fracturing.

9.7 Environmental Management Plans and Mitigation Measures


The section outlines the individual EMPs and mitigation measures that will be implemented during the
duration of the Project. The section is categorized based on primary Project activities that will require
specific mitigation measures that are unique to that activity, as follows:

ƒ Drilling and Well Installation

ƒ Hydraulic Fracturing

There is an additional subsection that provides individual EMPs that are likely applicable throughout the
Project life cycle in a more general sense. These individual EMPs include the following:

ƒ Air Quality Management Plan;

ƒ Noise Management Plan;

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ƒ Sediment and Erosion Control Plan;

ƒ Hazardous Materials Management Plan;

ƒ Non-Hazardous Solid Waste and Domestic Wastewater Management Plan;

ƒ Petroleum Management Plan;

ƒ Fish and Fish Habitat Management Plan;

ƒ Soils and Vegetation Management Plan;

ƒ Wildlife and Wildlife Habitat Management Plan;

ƒ Spill Prevention and Response Plan;

ƒ Transportation Management Plan;

ƒ Archaeological/Cultural Resources Management Plan; and

ƒ Occupational Health and Safety Plan.

9.7.1 Drilling and Well Installation


The American Petroleum Institute has published a guidelines document entitled “Hydraulic Fracturing
Operations - Well Construction and Integrity Guidelines (API 2009). The purpose of the document is to
provide guidance on recommended practices for well construction and integrity for wells that will be
hydraulically fractured.
This section discusses some of the key guidance principles in this document as they might apply to the
Project. These principles will be become further refined once a Project description is further defined and
they will be incorporated into the EIA document.
Maintaining well integrity is through the design and construction process is key to:

ƒ Isolate the internal conduit of the well from the surface and subsurface environment to protect the
environment; and

ƒ Isolate and contain the well’s produced fluid to a production conduit within the well.
The primary method used for protecting groundwater during drilling operations consists of drilling the
wellbore through the groundwater aquifers, immediately installing a steel pipe (called casing), and cementing
this steel pipe into place.
The following guiding principles will be implemented during drilling and well installation:

9.7.1.1 Casing
The casing must be able to withstand the various compressive, tensional, and bending forces that are
exerted while running in the hole, as well as the collapse and burst pressures that it might be subjected to
during different phases of the well’s life.

Casing used in oil and gas wells that will be hydraulically fractured should meet API standards, including API
Spec 5CT. API casing specifications and recommended practices cover the design, manufacturing, testing,
and transportation.
Casing manufactured to API specifications must meet strict requirements for compression, tension, collapse,
and burst resistance, quality, and consistency.
The casing used in a well should be designed to withstand the anticipated hydraulic fracturing pressure,
production pressures, corrosive conditions, and other factors.

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9.7.1.2 Cementing
ƒ Selected cements, additives, and mixing fluid should be laboratory tested in advance to ensure they
meet the requirements of the well design.

ƒ The following cement practices are recommended in order to ensure that isolation is achieved:

ƒ Prior to drilling, operators should investigate and review the history of nearby wells for cementing
problems encountered;

ƒ Computer simulation and other planning should be carried out in order to optimize cement
placement procedures;

ƒ Operators should use established, effective drilling practices;


ƒ Operators should ensure that the drilling fluid selection is appropriate for the designed well and the
geologic conditions likely to be encountered; and

ƒ Appropriate cement testing procedures should be properly carried to meet site-specific geologic
conditions.

9.7.2 Hydraulic Fracturing


Hydraulic fracturing may take place following drilling of a vertical borehole, assuming the borehole
successfully intersects the shale layer, or hydraulic fracturing may take place at a later stage once a
horizontal borehole has been drilled into the identified shale layer. .

The process of hydraulic fracturing increases the exposed area of the formation resulting in a high
conductivity path that extends from the wellbore through a targeted hydrocarbon bearing formation so that
hydrocarbons and other fluids can flow more easily from the formation rock, into the fracture, and ultimately
to the wellbore.
To conduct hydraulic fracturing, a fluid must be pumped into the well’s production casing at high pressure;
therefore it is necessary that production casing has been installed and cemented and that it is capable of
withstanding the pressure that it will be subjected to during hydraulic fracture operations (see above design
principles).
Prior to beginning this process, all equipment should be tested to make sure it is in good operating condition.
All high-pressure lines leading from the pump trucks to the wellhead should be pressure tested to the
maximum treating pressure. Any leaks must be eliminated prior to initiation of the hydraulic fracture
treatment.

9.7.3 Water Management


The objective of the water management during drilling and hydraulic fracturing is to achieve the following:

ƒ Ensure the reliability of water supply; and

ƒ Control, collect, and treat wastewater during fracturing process.


These management procedures are linked to the following other EMPs:

ƒ Hydrocarbon Management Plan (Section 9.7.5);

ƒ Hazardous Material Management Plan (Section 9.7.9);

ƒ Non-Hazardous Solid Waste Management Plan (Section 9.7.10);

ƒ Spill Prevention and Response Plan; and

ƒ Fish and Fish Habitat Management Plan.

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9.7.3.1 Water Supply


Water will be required both during drilling the well and if gas is observed in the shale layer at a certain well
site, hydraulic fracturing.
Shell recognizes that the quality and supply of shallow drinking water aquifers in the licence application
areas needs to be protected and is therefore investigating a number of potential water sources to support the
requirements of the Project.
Preliminary water assessments, as part an early feasibility scoping have been focused upon a number of
alternative water sources, such as, beneath the ground (typically at depths >100 m), sea water, surface
water, water imported by truck or recycled grey water.
Detailed evaluations will be carried out during the EIA that will focus on specific drilling locations. The
intention is to identify the most suitable water source on a per-well site basis.

9.7.3.2 Water and Fluids Disposal


During drilling operations fluids (drilling mud) return to surface where they are captured, recycled and re-
used wherever possible. The fluids returning to surface will contain chemicals and subsurface contaminants
mobilised during the drilling process. These elements will be removed from the fluids prior to reuse. If wells
are hydraulically fractured, fluids used in this process return to the surface once the well is back produced.
These fluids will be recycled, and mostly re-used for other drilling activities as much as possible.

9.7.3.3 Monitoring
Treatment Parameter Monitoring
During the hydraulic fracture treatment, certain parameters should be continuously monitored, including, but
not limited to, surface injection pressure (psi), slurry rate (bpm), proppant concentration (ppa), fluid rate
(bpm), and, sand or proppant rate (lb/min).

Pressure Monitoring
Pressure behaviour throughout the hydraulic fracture treatment should be monitored so that any unexplained
deviation from the design can be immediately identified and analysed before operations continue. Pressure
exerted on equipment should not exceed the working pressure rating of the weakest component.

Micro-seismic Monitoring
Micro-seismic mapping allows operators to monitor micro-seismic events associated with hydraulic fracture
growth. It requires a geophone array to be placed in an observation well, and utilizes the energy of the
fracturing process to map the resulting micro-seismic events. Micro-seismic monitoring provides a way to
evaluate critical hydraulic fracturing parameters such as vertical extent, lateral extent, azimuth and fracture
complexity.
Shell may conduct micro seismic monitoring. It is defined in chapter 5.

9.7.4 General Activities – Individual Environmental Management Plans


9.7.4.1 Air Quality Management Plan
The Air Quality Management Plan (AQMP) addresses the management of emissions and air quality
associated with construction and operation activities. This plan covers all activities that could result in air
emissions through all phases of the project.
The principles used to develop the AQMP include:

ƒ Meeting all applicable regulatory standards regarding air emissions;

ƒ Implementing best management practices in air emissions management;

ƒ Consulting with local communities to understand community air quality issues related to the Project; and

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ƒ Having a programme in place to monitor and verify performance standards.


The AQMP goal is to manage air emissions from the Project so that the effect on air quality is minimal. The
AQMP targets are:

ƒ Keep all air emissions within appropriate regulatory guidelines;

ƒ Keep ambient air quality within appropriate regulatory guidelines and standards;

ƒ No regulatory or community concerns regarding air quality and emissions management;


The following main emission sources are anticipated during the Project:

ƒ Vehicles, specially traffic on un paved roads;

ƒ Construction equipment; and

ƒ Fugitive emissions.
The following general management practices and measures by Project phase, include, but are not limited to:

Design Stage
ƒ Selecting equipment with low emissions that meet SA legislated emissions standards and guidelines;

ƒ Designing covers or control devices to limit the spread of dust;

Construction Phase
ƒ Using low sulphur and low aromatic fuel;

ƒ Using modern construction/ equipment that meets latest applicable emissions standards;

ƒ Ensuring proper equipment maintenance;

ƒ Limiting vehicle and construction equipment idling;

ƒ Minimising land disturbance;

ƒ Optimising vehicle movement; and

ƒ Using dust suppression measures.

Operations Phase
ƒ Using low sulphur and low aromatic diesel fuel;

ƒ Limiting vehicle idling;

ƒ Optimising vehicle movement; and

ƒ Using dust suppression measures (i.e., wetting work areas, roads, and storage piles, installing
equipment covers, and using dust hoods and shields).

9.7.4.2 Noise Management Plan


A Noise Management Plan (NMP) will be prepared for the Project before construction commences.
Elements of the NMP will include, but not be limited to:

ƒ Identification of applicable ambient noise criteria;

ƒ Implementation of noise mitigation measures as presented in the following sections;

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ƒ Development and implementation of noise monitoring plan to verify compliance with relevant standards
and criteria; and

ƒ Employee training awareness.

Construction and Operation Phase


Mitigation measures that can be implemented during the construction and operation phases include:

ƒ Schedule noisy construction activities at normal working hours (i.e., day-time) as much as possible;

ƒ Perform regular inspection and maintenance of construction vehicles and equipment to ensure that they
have good quality mufflers installed and worn parts are replaced;

ƒ Turn equipment off when not in use;

ƒ Use noise abatement accessories such as sound hood and mufflers. If required, use noise barriers,
baffles or enclosures for particularly noisy equipment, where feasible; and

ƒ Develop and implement a noise monitoring programme for the construction phase.

Noise Associated with Road Traffic


The following measures that will be implemented to minimize transportation-related noise impacts include,
but are not limited to:

ƒ Avoid trucking operations at night, where possible.

ƒ During maintenance check that noise abatement devices are in good order (e.g., brakes, exhaust
mufflers).

ƒ Place speed limits along access roads that are located off primary roads and highways.

9.7.4.3 Sediment and Erosion Control Plan


A Sediment and Erosion Control Plan (SECP) will be developed during detailed design phase of the Project.
This plan deals with the management of sediments arising from the erosion of overburden fines in areas
disturbed as part of the construction and operations activities.
Erosion and sediment management will involve the use of a number of management practices that will target
each of the erosion process stages.
Upstream and non contact diversion systems will help to keep clean water from running onto disturbed
areas, thus reducing volumes for handling and the erosive power of the water that would otherwise need to
be handled within the disturbed areas of the site. This will minimize the volumes potentially requiring
sediment control and/or treatment as well as the overall footprint of areas required for treatment facilities.
In concert with this approach is the implementation of sediment and erosion control measures. A number of
examples of effective management practices for surface erosion protection and sediment control for
consideration at the site include, but are not limited to, the following:

ƒ maximise the diversion of non contact waters (clean water) around areas of potential disturbance;

ƒ intercept sources of potential sediment-laden waters as close to source of erosion as possible and use
runoff control and conveyance measures to move these waters to a receiving waterbody;

ƒ establish self-sustaining vegetation in erosion-prone areas once disturbed but no longer required;

ƒ use appropriate sediment traps and barriers such as silt fences to minimize sheet erosion and velocity
of sheet flow in areas prone to erosion;

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ƒ use sediment catchment basins;

ƒ use ditch armouring along ditches depending on factors such as area steepness, erodability of soil
materials and presence of any immediate downstream watercourses; and

ƒ undertake sensitive operations during periods of dry weather to minimize traffic through these areas
and select equipment that will create the least disturbance.

9.7.4.4 Fish and Fish Habitat Management Plan


A Fish and Fish Habitat Management Plan will be prepared. The objective of this plan is to protect aquatic
resources during all phases of the Project.
This plan is linked to other management plans including;

ƒ Emergency Response Plan and Spill Prevention and Response Plan;

ƒ Soils and Vegetation Management Plan;

ƒ Petroleum Management Plan;

ƒ Non-Hazardous Solid Waste and Domestic Waste Water Management Plan;

ƒ Transportation Management Plan; and

ƒ Sediment and Erosion Control Plan.


Sediment-laden surface water during all phase of the Project has the potential to affect fish habitat.
Therefore, sediment and erosion control mitigation measures will be used during all Project phases. An
outline of the SECP is provided in Section 9.7.4.3 above.
Sensitive aquatic habitat areas will be avoided and appropriately marked to identify these areas to
employees and contractors during all phases of the Project. No drilling will take place within 500 meters of
any stream. Management practices and timing windows will be followed to minimize effects (particularly
during construction) on aquatic habitat during sensitive periods (e.g., spawning) to the maximum extent
practicable.

9.7.4.5 Soils and Vegetation Management Plan


Soils and vegetation effects are expected to be greatest during construction when soil is removed and terrain
and vegetation disturbed during site clearing for the Project.

Construction Phase
Soils
Topsoil materials will be salvaged before site clearing. The topsoil salvaged will be stockpiled and used as
reclamation material during decommissioning. Topsoil stockpiles will be strategically located to avoid
operational disturbance. As well, erosion control measures (including vegetating) will be applied to the
salvage stockpiles to reduce erosion.

Vegetation
Vegetation will be removed during the clearing process. Vegetation removal will occur only as necessary for
the placement of drill pads, structures and access roads. Small trees and shrubs may be mulched and
incorporated into and placed onto the topsoil piles to improve the organic matter and reduce erosion.
Burning of vegetation will be limited when practical.
All environmental monitors will have an illustrated list of rare plants that might be found in the areas to be
cleared. Rare plants will be identified by the environmental monitors and salvaged, where practical, and re-
established in suitable natural habitats unaffected by the Project construction.

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Operation Phase
Invasive Plants
An environmental monitor will conduct annual surveys for invasive plants along access roads and around the
drill pads. If found they will be removed by hand, bagged and burned.

9.7.4.6 Wildlife and Wildlife Habitat Management Plan


The following sections provide an overview of the proposed Wildlife and Wildlife Habitat Management
Programme (WWHMP) that will be implemented for the Project.
The WWHMP will work in conjunction with other management plans part of the EMP for the Project,
including:

ƒ Emergency Response Plan and Spill Prevention and Response Plan;

ƒ Noise Management Plan;

ƒ Non-Hazardous Solid Waste and Domestic Waste Water Management Plan; and

ƒ Transportation Management Plan.

Purpose
The objective of the WWHMP is to minimize interaction between the Project and its components and wildlife
receptors while acknowledging operational requirements and the safety of employees and contractors. This
objective is targeted through a series of actions designed to prevent mortalities, avoid human-wildlife
interaction and reduce wildlife disturbance.

Management Practices
The general management practices that will be implemented include, but are not limited to, the following:

ƒ restricting access to the area;

ƒ giving wildlife the right of way when of such a size that it can be readily seen from vehicles;

ƒ prohibiting hunting;

ƒ prohibiting feeding of wildlife;

ƒ managing wildlife attractants by using non-palatable seed mixtures for revegetation and road
maintenance;

ƒ ensuring waste is managed properly;

ƒ avoiding wildlife sensitive areas and periods, which will be identified in the EIA report;

ƒ educating employees during the orientation process in:

ƒ access road use and haulage operating protocols;


ƒ employee awareness of wildlife sensitive locations/timing; and
ƒ waste management procedures.
9.7.4.7 Hazardous Materials Management Plan
A Hazardous Materials Management Plan (HMMP) will be developed for the Project that will identify
potentially hazardous materials to be used at the site and provide a system for monitoring these materials.
Transportation, storage, use and ultimate disposal will be considered. Safety of the workers and the

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surrounding communities will be taken into account for all stages of materials handling during all Project
phases.
This section presents a framework for a HMMP.

Training
Hazardous materials and wastes require special handling and training procedures. All employees will be
provided with basic training so that, at minimum, they:

ƒ can identify hazardous materials;

ƒ know how to obtain appropriate information on special handling procedures required;

ƒ know what precautions and protective equipment are required;

ƒ know how to label and package hazardous materials and wastes;

ƒ know where and how hazardous wastes are to be stored; and

ƒ know how wastes are to be disposed.


Employees who are tasked with receiving, off loading and storing potentially hazardous materials or involved
in the storage and shipment off-site of hazardous wastes should receive hazardous materials handling
training.

Hazardous Waste Identification


Project designs and processes will be reviewed to identify waste streams. A system will be developed to
screen and classify waste streams according to applicable legislation.

Transport
Proper labeling, marking and placarding using proper containers will be implemented for all hazardous
materials being transported.
The following measures will be implemented during transport:

ƒ non-compatible materials will be transported by separate shipment;

ƒ fire extinguisher and fire prevention materials will be adequate and appropriate for the material being
transported;

ƒ containers will be appropriate for the material being shipped;

ƒ containers will be properly secured;

ƒ containers and trucks will be properly marked, labelled and placarded;

ƒ transport manifests will be maintained;

ƒ spill response materials will be adequate and appropriate for materials being transported; and

ƒ drivers will be adequately trained and equipped for spill first response, containment and communication.

Hazardous Materials Storage


Hazardous materials will be segregated and stored using accepted management practices including but not
limited to the following:

ƒ the storage areas will be designed to adequately and safely store a sufficient quantity over a prescribed
period;

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ƒ the storage area will be properly designed to contain and prevent contamination of the environment,
particularly soil and groundwater;

ƒ floor, curbing, walls and roofs will be designed to adequately contain spills and to protect the storage
area from weather where necessary;

ƒ spill kits, protective equipment, and other necessary equipment to clean and mitigate spills will be in the
storage area or near the storage area;

ƒ fire prevention systems appropriate and adequate for the materials being stored will be designed;

ƒ only containers that are in good condition will be used;

ƒ containers or liner materials will be compatible with the waste being stored;

ƒ incompatible (e.g., bases and acids) materials will not be stored in the same container and will be
stored safely and sufficiently far apart to prevent accidents;

ƒ to provide a safe work area, incompatible wastes will be separated by walls, dykes, or stored in
separate facilities;

ƒ drums, containers, and storage areas will be properly labelled, marked, placarded and secured;

ƒ sufficient storage space between containers will be allowed for safe access and handling of containers;
and

ƒ a no smoking policy will be implemented and fire prevention and management practices will be
developed specific to the materials being stored.

Waste Minimisation
The following procedures will be used to minimize wastes before start-up and as an ongoing programme
during operation:

ƒ using whenever possible, non-hazardous materials in lieu of hazardous materials;

ƒ keeping inventories of products to a workable minimum to prevent expiration of dated products (shelf
life) and the generation of wastes;

ƒ developing alternative methods or processes to reduce generation of high volume wastes;

ƒ properly segregating and handling waste streams to minimize cross contamination of hazardous and
non-hazardous wastes;

ƒ developing, implementing and tracking training programs and housekeeping standards to reduce
wastes; and

ƒ making waste minimisation procedures a part of employee training programs.

Inspection Programme
An inspection programme will be developed with the following objectives:

ƒ to inspect the Project area for proper waste segregation, storage, and disposal;

ƒ to inspect waste storage sites and document the volume of waste stored, type of waste, and storage
facility conditions;

ƒ to inspect spill kits and protective equipment, and reorder and replace as necessary;

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ƒ to allow periodic reviews of off site transporters including procedures, training, equipment, spill kits,
records, and employee awareness; and

ƒ to review inspection findings with operation, transporters, and off site contractors to correct deficiencies,
maintain awareness and communication, and to recognize negative or positive performance.

ƒ Inspection programme will be defined in the site specific EIA’s.

9.7.4.8 Non-Hazardous Solid Waste and Domestic Wastewater Management


Plan
This plan discusses the recycling, storage, handling, and disposal of all non-hazardous industrial and
domestic wastes including sewage.

List of Typical Wastes


Typical wastes that will be generated from construction and operations are listed below:
Domestic Wastes

ƒ food waste;

ƒ biological waste from first aid operations;

ƒ paper and cardboard;

ƒ some plastics;

ƒ general waste such as plastic food wrap during construction; and

ƒ office wastes such as used office supplies.

Inert Bulk Waste

ƒ Non-toxic, non-food solid wastes will be sorted into four types—combustible, noncombustible,
recyclable, and reusable in the waste transfer storage area;

ƒ Combustible items will be disposed in an off-site approved incinerator (if required by applicable
regulations and suitable for disposal), while non-combustible items will be land filled or recycled if
practical; and

ƒ Inert bulk wastes that cannot readily be recycled or reused, such as general debris, will be stored in the
waste transfer storage area and transferred to the landfill.

Solid Waste Management Facilities


Good housekeeping dictates the management of solid wastes. Solid waste management will be coordinated
through Shell or its contractor. Key elements in the management of inert industrial and domestic wastes will
include:

ƒ a solid waste management plan that will be finalized before construction begins; and

ƒ facilities to effectively contain and treat solid wastes, such as:

ƒ covered sheds for sorting and temporary storage of items that can be recycled;
ƒ containers for temporarily holding small solid wastes; and
ƒ a waste containment area.

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Containers
Drums, bins, receptacles, and dumpsters used for storage of waste will be selected based on waste material
requirements. All containers will be labelled to identify those wastes for which they are suitable.

Sorting
Waste must be sorted at source before it can be disposed, or transported to specific designated areas for
proper disposal. The following measures will be implemented for sorting:

ƒ containers will be located throughout Project site for immediate sorting of solid waste;

ƒ containers will be located for the collection of burnable and non-burnable materials and recyclable
wastes;

ƒ haulers will be required to have appropriate training that prevents inadvertent release of wastes or
recyclables en route; and

ƒ procedures and general education during employee orientation will be in place to ensure dumping of
wastes in unauthorised locations or facilities does not occur.

Waste Transfer Storage Area


A secured area will be established for the handling and transfer of wastes. Non-food waste products will also
be collected, sorted, and placed in designated areas within the fenced area.

Once a practical quantity of solid waste has accumulated, the waste will be collected, packaged, transported
and disposed of at a permitted landfill or other approved and licensed facility.

9.7.4.9 Petroleum Management Plan


The Petroleum Management Plan (PMP) will describe the actions that will be taken to manage petroleum
products used on the Project site. These products will be mostly diesel but will also include oils and greases
and hydraulic fluids. All products will be stored onsite in appropriate containers.
This section provides an overview of the contents of the PMP and the management practices that will be
followed.

Safe Handling Procedures


Table 29 provides a summary of safe handling procedures for that will be implemented at the Project site.
Table 29: Safe Handling Procedures for Petroleum Products

Product Safe Handling Procedure


Do not get in eyes, on skin or on clothing.

Avoid breathing vapours, mist, fumes.

Do not swallow.

Diesel Wear protective equipment and/or garments if


exposure conditions warrant.

Wash thoroughly after handling.

Launder contaminated clothing before reuse.

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Product Safe Handling Procedure


Use in areas with adequate ventilation.

Keep away from heat, sparks, and flames.

Store in a closed container in a well-ventilated area.

Bond and ground during transfer.


Motor Oil/Hydraulic
Wear protective clothing and impervious gloves
when working with oils and transmission fluids.
Oil/Transmission
Keep container closed until ready for use.
Fluid
Avoid skin contact.

Avoid breathing vapor, mist, or fumes.

Launder contaminated clothing before reuse.


Unleaded gasoline
Store in a flammable liquids area away from heat,
ignition sources, and open flames.

Bond and ground during transfer.


Avoid prolonged or repeated contact with skin.

Remove contaminated clothing; launder or dry-clean


Automotive grease before re-use.

Cleanse skin thoroughly after contact, before breaks


and meals, and at end of work period.

Fuel Handling
Fuel transfer will take place inside bermed areas. The general procedures to be followed for fuel transfer
and fueling tanks include, but are not limited to:

ƒ Before fuel transfer verify that:

ƒ all fuel transfer hoses have been connected properly and couplings are tight;
ƒ transfer hoses are not obviously damaged;
ƒ fuel transfer personnel are familiar with procedures;

ƒ for fuelling stations, personnel are located at both the fuel truck and fuel transfer tank(s) and have the
ability to shut off fuel flow manually;

ƒ a means of communication has been established between the two people transferring fuel;

ƒ transferring fuel as per established procedures of the fuelling contractor; and

ƒ ensuring that any accidents or spills are reported immediately.

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Used Petroleum Products


All used liquid petroleum products will be collected in marked tanks and disposed of appropriately.

9.7.4.10 Radioactive Waste Management Plan


Drill chippings from certain Karoo geological strata may contain naturally occurring levels of radiation. It will
need to be established whether this material requires separate handling. Radioactive waste management will
include pre-disposal management procedures to ensure:

ƒ waste prevention and waste minimisation.

ƒ the selection of suitable waste management options.

ƒ a waste package that meets acceptance criteria for disposal, storage and for any associated handling
and transportation activities.Waste or material that is suitable for authorized disposal / discharge and
clearance for disposal through regulatory approval.
During the generation of radioactive waste the emphasis shall be on the control of waste generation and
minimization. Unavoidable radioactive waste shall be classified to enable category specific waste
management.
All radioactive waste will be packaged, stored and transported according to applicable regulatory
requirements and disposed of at only those facilities licensed and authorized to accept radioactive waste.

9.7.4.11 Spill Prevention and Response Plan


Before construction of the Project commences, a Spill Prevention and Response Plan will be developed for
use by field personnel in the event of a deleterious material spill. The following sections outline the general
framework for this plan

Spill Prevention and Response Priorities


All spills occurring on the Project site will be responded to in a way which will uphold the following priorities:

ƒ protection of human life;

ƒ protection of human health;

ƒ protection of the environment;

ƒ protection of property; and

ƒ minimised disruption to operational activities.


At all times, applicable regulations will be used to guide response and cleanup activities.

Spill Prevention
Site Planning
At locations where the potential for spillage of hazardous material is highest, spill control and containment
means will be incorporated into the infrastructure.

Material Storage
All materials will be stored in a safe and appropriate manner which will mitigate accidental releases to the
environment. Management practices to be considered for use onsite, including, but not limited to, the
following:

ƒ double-walled containment tanks, with barriers to protect tank from accidental impact;

ƒ bermed storage areas for material containers, with adequate capacity;

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ƒ spill response kits readily available, specific to type of material; and

ƒ regular inspections of all storage areas and storage tanks.

Material Handling
Material handling procedures will be documented within this plan, and will likely include, but will not be
limited to:

ƒ fuelling procedures; and

ƒ fuel truck transfer procedures.

Spill Response
The objective of the spill response measures will be to ensure that where accidental spills occur, all available
resources are used appropriately to minimize the extent and severity of effect on the environment. The
following measures will be implemented:
Equipment
Spill response kits appropriate to the type and volume of material will be specified for each piece of
equipment which handles or transports contaminant materials (including fuel). As well, spill response kits will
be located at appropriate material handling and storage locations.
Spill response kit contents will be based on the potential risk associated with the material, volume of
material, and environmental sensitivity of the area. General kit contents could include:

ƒ oil absorbent pads;

ƒ absorbent socks;

ƒ granular absorbent; and

ƒ protective equipment (e.g., gloves, goggles, protective suits).


All kits will be stored in a visible location, in an appropriate weather-resistant container. Regular inspections
of the kits will be performed to ensure that kits are complete and all materials remain functional.

General Spill Action Plan


The following actions will be taken in the event of a spill:

ƒ identification and control of immediate dangers to human life or health;

ƒ identification and control of spill source;

ƒ elimination of additional potential spill sources;

ƒ containment of spill;

ƒ notification of authorities, as appropriate;

ƒ recovery and cleanup; and

ƒ incident investigation and report.


The following framework will be incorporated into the Spill Response Plan.
1) Initial Response

ƒ ensure safety of all personnel and public;

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ƒ mitigate hazards;

ƒ notification; and

ƒ identify source of spill and attempt to stop and/or contain it, if safe to do so.
2) Secondary Response

ƒ determine if additional resources are necessary (external contractors);

ƒ contain the spill, and protect any nearby water bodies; and

ƒ review material characteristics, and implement a suitable clean-up.


3) Reporting
4) Spill Cleanup and Disposal
5) Follow-up Investigation

Training
All Shell employees and contractors will undergo environmental hazard awareness training as part of their
orientation to the site. This training programme will focus on spill prevention and hazard identification, as
well as spill response and containment procedures. At minimum, employees will be educated on:

ƒ spill response plan;

ƒ applicable legislation;

ƒ environmental receptors (i.e., soil, groundwater and surface water);

ƒ field application of appropriate spill response techniques;

ƒ initial response procedures; and

ƒ spill reporting procedures.

9.7.4.12 Transportation Management Plan


Key issues to incorporate for the transportation activities during the operation of the project:

ƒ Trucking volumes;

ƒ Trucks with hazardous materials;

ƒ Bridge loading capacities;

ƒ Special measures in localities and other sensitive points (schools for example)

ƒ Any restricted use of road access during special dates (community celebrations for example)
Transportation for the Project will include personnel, materials, and supplies to the Project site and wastes
from the site. The purpose of the Transportation Management Plan (TMP) is to provide a framework of
management practices to be followed during the Project.

The following additional management plans will also apply to the TMP:

ƒ Occupational Health and Safety Plan;

ƒ Archaeological Resources Management Plan;

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ƒ Emergency Response Plan and Spill Prevention and Response Plan;

ƒ Fish and Fish Habitat Management Plan;

ƒ Sediment and Erosion Control Plan;

ƒ Hazardous Materials Management;

ƒ Soils and Vegetation Management Plan;

ƒ Petroleum Management Plan; and

ƒ Wildlife and Wildlife Habitat Management Plan.

Road and Wildlife


The protection of wildlife is important through all phases of the Project. The following management practices
will be followed to control potential wildlife injury or mortality during road use:

ƒ speed levels will be controlled to reduce dust levels and to reduce the chance of a collision with birds
and other wildlife;

ƒ areas known to be high use areas along the road will be clearly signed;

ƒ sensory disturbances, such as noise, will be minimized;

ƒ harassment of wildlife will not be tolerated on site or along the access road;

ƒ animals will have the right-of-way and areas of high use will by identified;

ƒ the road will be maintained so as to prevent potential attraction to wildlife;

ƒ no employee or contractor employee will be permitted to have firearms on site; and

ƒ no employee or contractor will be permitted to fish while on company business or during travel to and
from the project site.

Archaeological and Cultural Heritage Resources Sites


As noted in the Archaeology/Cultural Resources Management Plan, a Chance Find Procedure (CFP) will be
implemented during the construction and operation phases of the Project. If archaeological artifacts or
features are encountered during any road construction and other Project activities, Shell and its contractors
will initiate the CFP.

Guidelines for Vehicular Traffic


The following guidelines will apply to vehicular traffic:

ƒ all drivers will be properly licensed and trained according to specific vehicle type and operating
conditions;

ƒ vehicle use will be determined by local ground conditions and access requirements;

ƒ all local traffic laws and speed limits will be obeyed;

ƒ traffic on the rights-of-way will follow the posted speed limits, which might vary depending on site-
specific conditions;

ƒ all vehicular traffic will be confined to approved rights-of-way, workspace and access roads or trails; and

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ƒ site-specific features of concern (e.g., archaeological sites, sensitive wildlife habitat) will be flagged, or
otherwise designated, so that subsequent traffic can avoid these areas.

9.7.4.13 Archaeological/Cultural Resources Management Plan


The purpose of the Archaeological/Cultural Resources Management Plan (ACRMP) is to:

ƒ manage and protect existing archaeological and cultural heritage resources during construction and
operations; and

ƒ provide a framework to identify, manage, protect, or mitigate recorded and previously unrecorded
archaeological and cultural heritage resources encountered during project construction and operation.
General components of this plan include the following.

Archaeological and Cultural Heritage Resources Awareness Training


An internal awareness education and training programme will be conducted to provide personnel and
contractors with knowledge and an understanding of the importance of archaeological and cultural
resources.

Protection of Existing Sites


Existing sites will be protected using the following procedures:

ƒ all Project plans/drawings will be reviewed to ensure that all construction areas have been examined for
archaeological and cultural resources;

ƒ all project plans/drawings will be reviewed on an on-going basis to ensure that all areas affected by the
Project undergo archaeological study as necessary;

ƒ all project plans/drawings will be marked to identify any archaeological and cultural resources that
require protection or monitoring;

ƒ protective measures will be taken throughout the Project area to avoid and mitigate effects on identified
archaeological resources and culturally sensitive areas; and

ƒ if new sites are discovered, all relevant parties will determine the scope of further work or impact
management and will follow the CFP identified below.

Monitoring
A monitor will be responsible for ensuring that the designated archaeological resources areas are avoided,
protected, and monitored.
Monitoring procedures to be followed during the life of the project will include the following:

ƒ all areas (identified archaeological sites, possible archaeological sites, and areas of cultural sensitivity)
requiring archaeological monitoring or protection throughout the Project site will be clearly marked on
the development plans;

ƒ any identification, recording, removal, and reporting of artifacts or features will be conducted under the
supervision of a qualified archaeologist; and

ƒ the exposure and identification of previously unidentified archaeological resources will automatically
result in the implementation of the chance find procedures described below.
Any archaeological investigations of known sites or chance find sites discovered during construction will be
done by a qualified archaeologist.

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Chance Find Procedure


The chance find procedure (CFP) outline the protocol to be followed if a new archaeological or cultural
resource is encountered in any phase of the Project. The CFP is primarily applicable to:

ƒ construction and operations personnel and management;

ƒ contractors;

ƒ environmental team; and

ƒ visitors or other people active in the Project area.


The proposed CFP measures are as follows:
When a suspected archaeological or cultural resource find has been encountered, he/she will immediately
make efforts to protect the site by excluding traffic and further disturbance. If an artefact has been
discovered, it will not be removed from the site. All work near the site or artefact will stop immediately
and construction equipment will be kept away from the site or artefact to avoid further disturbance or
destruction. A qualified archaeologist and the applicable government ministry will immediately be
contacted.
6) An archaeological or cultural heritage resources site card will be completed by a qualified archaeologist
with the following basic information:

ƒ date (when the archaeological find was first encountered);

ƒ observer (name of the person recording the information on the site or artefact);

ƒ site location (detailed enough so that it can be relocated, GPS if possible);

ƒ type of site (archaeological site, burial site or artefact);

ƒ any obvious disturbance to the site (by equipment, animals, etc.); and

ƒ photographs.
The qualified archaeologist will assess the significance of the artefact and the location. Mitigation options for
the site or artefact will be drafted by the archaeologist, reviewed and approved by the applicable government
ministry, and an agreement on the approach will be determined by the qualified archaeologist in coordination
with the government ministry.
7) Once the site is assessed and mitigated to the satisfaction of government ministry and the site has
been cleared, construction or operations activities may recommence.

9.7.4.14 Occupational Health and Safety Plan


An Occupational Health and Safety Plan (OHSP) will be prepared prior to construction and operation of the
Project. The OHSP will uphold Shell´s commitment to a safe environment for employees, contractors and
visitors. The plan will also addresses all applicable legal requirements relating to health and safety.

The OHSP will set out the framework under which health and safety on the Project site and to and from the
site will be managed. The roles and responsibilities of the company, manager, superintendents, supervisors
and workers are set out under this plan. The programs that will be outlined under the plan include provisions
for the anticipation, recognition, evaluation and control of physical, chemical, radiological, biological,
ergonomic and psychosocial factors that may exist at the project site and in other project related activities.

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A health and safety training programme will also be implemented at the site. The objectives of this training
programme will be to:

ƒ provide appropriate orientation and support to all employees, contractors and visitors onsite so that they
can act in an appropriately safe manner;

ƒ provide ongoing training to workers;

ƒ inform at risk workers to help attain a positive and safe work environment;

ƒ instruct managers and supervisors of duties and responsibilities, including applicable legislation, risk
communication, labour relations and hazard prevention; and

ƒ instruct workers of responsibilities and rights.

9.7.5 Monitoring Plans


Shell is committed to monitoring the environment, and addressing potential effects that may arise as a result
of the Project. The objectives of the environmental monitoring is to verify the accuracy of predicted
environmental effects that will be identified in the ESIA report, to determine the effectiveness of the
measures taken to mitigate environmental effects of the Project and to promote compliance by Shell with
applicable regulatory requirements and internal policies.
Detailed monitoring plans will be developed once the ESIA is completed and Project design has been
finalized. These plans will outline the rationale for monitoring, the parameters to be monitored, monitoring
programme details and follow-up actions to be taken as appropriate.

An independent environmental monitor (EM) will be onsite during site clearing and well installation and
testing. The EM will also be onsite during any wastewater disposal activities during hydraulic fracturing, if
conducted. The primary responsibilities of the EM will be to:

ƒ Monitor the implementation and functioning of mitigation measures;

ƒ Conduct routine environmental monitoring (i.e., biophysical parameters) that will be defined in the EIA
report;

ƒ Liase with the contractor and provide daily input into the functioning and adequacy of mitigation
measures, and make recommendation for further measures if necessary; and

ƒ Have the authority to stop work in the event of an identified risk to the environment and human health.
Preliminary recommended monitoring will include the following:

ƒ Noise during construction and operation at nearby noise sensitive receptors

ƒ Surface water quality monitoring at streams near well pad sites

ƒ Monitoring of source water supplies for well production and hydraulic fracturing. Depending on the
nature and location of the source water, this may include water quality, water quantity and flow and
biomonitoring.

ƒ Monitoring of nearby groundwater wells to measure groundwater quantity and quality during well
installation and testing and hydraulic fracturing, if conducted.
Additional monitoring programmes and modifications to those listed above, if required, will be detailed in the
EIA report.
Proposed technical monitoring during well installation is described above.

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9.7.6 Grievance Mechanism


Shell will implement a grievance mechanism throughout all Project phases. This purpose and processes of
this mechanism will be communicated to all potentially affected parties and other stakeholders, as required.
The intent of this mechanism will be to allow those persons that have potential issues during the course of
the Project to communicate those issues to Shell. The issues will be tracked in a database according to
nature of issue, date, location and person/group submitting the issue. Shell will then discuss the identified
issue with the person/group, identify the nature and cause of the issue, and, if required, to take appropriate
action to mitigate the potential issue.

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10.0 UNDERTAKING AND COMMITMENTS


10.1 Financial Provision under MPRDA (Act 28 of 2002)
This section provides the financial provision from Shell as per Section 41 of the Mineral and Petroleum
Resources Development Act, 2002 (Act 28 of 2002) (MPRDA).
Section 41 of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) (MPRDA)
stipulates that:

“(1) An applicant for a prospecting right, mining right or mining permit must, before the Minister approves the
Environmental Management Programme or environmental management programme in terms of section 39 (4), make the
prescribed financial provision for the rehabilitation or management of negative environmental impacts.

(2) If the holder of a prospecting right, mining right or mining permit fails to rehabilitate or manage, or is unable to
undertake such rehabilitation or to manage any negative impact on the environment, the Minister may, upon written
notice to such holder, use all or part of the financial provision contemplated in subsection (1) to rehabilitate or manage
the negative environmental impact in question.

(3) The holder of a prospecting right, mining right or mining permit must annually assess his or her environmental liability
and increase his or her financial provision to the satisfaction of the Minister.

(4) If the Minister is not satisfied with the assessment and financial provision contemplated in this section, the Minister
may appoint an independent assessor to conduct the assessment and determine the financial provision.

(5) The requirement to maintain and retain the financial provision remains in force until the Minister issues a certificate in
terms of section 43 to such holder, but the Minister may retain such portion of the financial provision as may be required
to rehabilitate the closed mining or prospecting operation in respect of latent or residual environmental impacts.”

10.1.1 Financial Provision for Decommissioning and Rehabilitation


Shell will put in place the required financial provision for the proposed exploration programme. The
guarantee will cover the estimated costs for decommissioning and rehabilitation of sites during the initial
exploration period.
This financial provision will be provided to PASA by a Parent Company Guarantee.

Parent Company guarantee


This guarantee indicates that Shell Exploration Company B.V. has adequate financial resources to fulfil their
obligations and will be provided by Shell Finance (Netherlands) B.V., an affiliated company incorporated in
the Netherlands, with Moody’s long term credit rating of Aa1.

Quantum of Financial Provision


The guarantee will cover the estimated costs for decommissioning and restoration of sites during the initial
exploration period. The guaranteed amount will be 90 million rand (see breakdown below).

Indemnity
Shell will obtain and maintain appropriate insurance against operational risks.
Such insurance will be held for and in relation to operations, against (inter alia) pollution damage, damage to
property, the cost of clean-up operations pursuant to an operational accident, injury to employees and other
persons, in accordance with good oilfield practice and applicable law.

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Activity Cost (Rands)

Site restoration and Access roads 80,000,000

Well Abandonment, Site Clearance, disposal of waste, etc

Shaping, levelling and vegetation of subsided areas Rehabilitation of damaged existing


infrastructure (fences etc)

Monitoring, Maintenance, Management Costs 2,000,000

Follow-up monitoring, maintenance. Planting seeding and fertilizer application (to promote
vegetation establishment)

Contingencies 8,000,000

Grand Total 90,000,000

10.1.2 Obligations for Unplanned Incidents


In addition, in the unlikely event of an unplanned incident, NEMA (Section 28) imposes a primary obligation
on everyone who causes, has caused or may cause significant pollution or degradation of the environment to
take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring.
Furthermore, insofar as harm to the environment is authorized by law (such as by way of an exploration
right) or cannot be reasonably avoided or stopped, there is a duty on such person to minimize and rectify
pollution or degradation of the environment.
The entity that undertakes exploration would be liable to take reasonable measures if pollution is caused.
The National Water Act, 1998 imposes a similar duty of care to that in the NEMA, save that it does not
require “significant” pollution. Under the National Water Act, 1998 (Section 15(i) and (j)), it is a criminal
offence intentionally or negligently to pollute a water resource or to do something which is likely to pollute a
water resource”.

10.2 Commitments by Shell


Shell has made the following commitments to the people of South Africa:

General

ƒ We will set up an independent advisory committee for this project to provide expert steers and advice
on environmental and social impacts (hydraulic fracturing, water, etc) to ensure we reduce and mitigate
impacts as far as possible, take into account people’s concerns and reflect them in the project
design/execution.

ƒ This committee will also look particularly into development of the region and provide Shell suggestions
for contributing to economic and social growth over and above its commitments to social investment,
local content of suppliers, contractors and job creation.

ƒ We will create citizen advisory groups – made up of a broad cross-section of community leaders and
elected officials – who will work alongside Shell’s management team to identify and provide advice
regarding concerns related to operations, such as truck movements, noise, etc.

ƒ Shell will provide full compensation to any landowner with evidenced direct negative impact or loss on
their land as a result of their activities.

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ƒ Utilising best practices, we will work with impacted communities and landowners to address how they
can receive direct benefits from UCG development.

ƒ We are committed to lead in setting of global best practices and operational standards for
unconventional gas development in the Karoo.
Water

ƒ In the Karoo, we commit to analysing and implementing relevant recommendations arising from the US
EPA study currently underway through 2014 into the project.

ƒ We also commit to incorporate any new best practices from Provincial and/or States with existing well
design and HF regulatory primacy - especially recognizing these jurisdictions may have similar
geologic, water, etc conditions more consistent with the Karoo.

ƒ We commit not to compete with the people of the Karoo for their water needs. Nobody will go short of
fresh water because of our operations; either in the exploration phase, or if there is any further
development.

ƒ We will commit to establishing mutually acceptable protocols for the independent monitoring of the
water quality in existing water wells and surface water surrounding our activities.

ƒ We will conserve and recycle water where ever possible.

ƒ We will commission an independent study in our licence area of water resources using third party
experts to ensure that we get a better understanding, also providing information that may be useful in
further development of water supplies for the region.

ƒ When we develop plans to source water in our operations we will make sure we understand local
community needs and see how we can help meet community shortages in addition to project needs.

ƒ We will commit to make available any recovered and unwanted clean water for community use – along
with the transfer of water boreholes which are no longer required by the project.

ƒ Prior to drilling any exploration well, local experts will be consulted to identify the most suitable water
source for development areas. We will develop a water plan for each well or pad (multiple wells at same
location) site.

ƒ Impacted landowners, the relevant water authorities, local stakeholders and environmental advisors will
be consulted throughout the water source selection process.

ƒ We will share our well design and aquifer protection plans which will adopt best practices from around
the world. Best practices include the use of standards and guidelines around multiple barriers and
cementing, casing integrity testing and annuli monitoring.

ƒ Any well that is permanently plugged and abandoned will meet best practice internationally

Hydraulic Fracturing
ƒ We commit to disclose fracturing fluids at each drilling location, and consult with communities as part of
the development of hydraulic fracturing plans. The information will be available on our website.

ƒ We will recycle the flow back water as much as possible and dispose of remaining fluids responsibly.

ƒ We will not use BTEX in any hydraulic fracturing operations.

ƒ We will support the development of ‘best-in-class” regulatory standards for hydraulic fracturing in South
Africa.

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ƒ Based on the results of the water study, we will ensure a suitable natural physical barrier exists
between target gas-bearing formations and any potable water aquifers used by communities/industry.

ƒ Our well design, drilling, completions and operations standards require multiple physical barriers and
procedures to control well operations – including the fracturing process, and prevents the migration of
gas and any fluids into underground drinking water sources.

ƒ We will publish well completion reports publicly.

ƒ Shell will monitor the integrity of its wells.

10.3 Undertaking by Shell Exploration Company b.v.

Name of designated signatory


I,___________________________________________, the undersigned and duly authorised thereto by the
Company Shell Exploration Company B.V. have studied and understand the contents of this document in
it’s entirety and hereby duly undertake to adhere to the conditions as set out therein

Signed at .______________________. on this ………… day of ………………………. 2011.

SIGNATURE IN FINAL DOCUMENT DESIGNATION IN FINAL DOCUMENT

....................................... .......................................
Signature of applicant Designation

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11.0 CONCLUSIONS AND RECOMMENDATIONS


This chapter contains the consultants’ draft conclusions and recommendations for comment by stakeholders.
Firstly, conclusions pertaining to the assessment conducted for the Environmental Management Plan are
discussed. Secondly, under recommendations, key recommendations from the EMP process are provided,
as well as recommendations for an Environmental Impact Assessment (EIA) in terms of the National
Environmental Management Act (Act 107 of 1998).

11.1 Conclusions
Shell propose to conduct an unconventional natural gas exploration drilling programme in the Karoo to
confirm whether tight shale bands located between 1000 and 5000 m below ground contain unconventional
natural gas and, if present, whether this gas can be stimulated to flow. This exploration programme will entail
the drilling of up to 8 deep level exploration boreholes in the 30,000 km² exploration rights application area. It
may be necessary to hydraulically fracture the deep tight-shale gas bearing layer.
The proposed exploration programme has a number of discrete phases namely;

ƒ Geophysical data acquisition which is largely non-invasive,

ƒ Drilling and casing of deep level boreholes to intersect the targeted shale layer,

ƒ Testing the sampled shale rock samples for presence of gas,

ƒ Possibly hydraulically fracturing a part of the vertical hole through the shale layer to test whether gas
can be stimulated to flow; and / or

ƒ Drilling another vertical well from a nearby location which will have a horizontal section from the base of
the vertical hole that extends into the shale layer and hydraulically fracturing the exploratory horizontal
hole in order to stimulate gas flow for the purposes of gas yield testing.
The technology of hydraulic fracturing has been in use for many years, but only recently has it been rapidly
developed and improved for shale-gas development. It offers promise, should worthwhile natural gas
reserves be proven in the Karoo. However, the volume of recoverable gas stored in Karoo shales is
unknown at present.
The process of deep level exploration drilling and hydraulic fracturing involves fair numbers of traffic and
freight to/from each exploration well, the consumption of substantial quantities of water, and the use of
quantities of materials in the drilling and fracturing process. The traffic and the onsite development could
have marked aesthetic impacts at a local scale, while drilling and hydraulic fracturing takes place, but these
impacts will be of relatively short duration and reversible. The volume of wastewater generated will need to
be addressed in accordance with legislation, but this is not beyond what would be reasonable to manage at
an exploration site of this nature. Potential risk to groundwater resources is mitigated through installation of
well casing and thorough integrity testing of the installed casing prior to commencement of hydraulic
fracturing. The footprint of each exploration well site is roughly 1 ha in extent and will be cleared of
vegetation, stabilised and used for the duration of the exploration drilling activity on the site. There will be up
to eight such sites in each exploration licence application area (30,000 km²). There is flexibility in choosing
each drill site and the EMP document describes criteria that will govern the site selection process. Should
these be applied, the real impact of this land clearance on biota, habitat, heritage resources will be low.
Moreover, with proper siting of drill sites direct impact on landowners can be considerably reduced.
Soekor’s exploration in the 1960s was focused on drilling to find oil, not natural gas. In only one borehole did
gas flow, and then only for one day. Soekor did not make provision for hydraulic fracturing of the wells, which
is the critical technological development that has facilitated gas recovery from ‘tight shale formations’. There
still remains some evidence of gas presence in shale core samples retained in the National core archive
from this early exploration programme.

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In the absence of a license granted for exploration, the potential of these shales to supply economically
recoverable supplies of gas will remain unknown.
In Golder’s opinion, such an approach would be unnecessarily conservative. It would prevent (or delay) the
determination of the resource potential of the Karoo shale gas formations and the benefits that South Africa
could derive from this - in the absence of any material evidence that a small number of exploration wells
could result in an unacceptable level of environmental impact.
While such a determination can only be finalised once the exploration wells have been sited, it is unlikely, in
our view, that the construction of a small number of wells could, in itself, result in environmental damage that
is unacceptable, as long as the siting and management of these wells is controlled through a rigorous,
scientific, EIA process.
Although the Karoo may never see shale-gas development as intense as under way and foreseen in the
Northern Hemisphere, any development in the Karoo would require stringent risk assessment and risk
management strategies, as part of environmental impact assessment, before it could proceed. Such risk
assessment would need to be based on rigorously formulated shale-gas development risk scenarios, and
informed by high quality evidence, especially on the Karoo stratigraphy. The risk scenarios would necessarily
be based on careful specifications for the fracturing and production technologies appropriate to the Karoo
development, and scaled for a feasible development, and not simply transferred from experience elsewhere.
A benefit will be, that by the time such production scenario becomes imminent (which could be nine years
from today), the findings of current research in the Northern Hemisphere will be available to inform the
process.

11.2 Recommendations
It is acknowledged that there are concerns about the risks associated with hydraulic fracturing in shale gas
production well fields. These concerns have typically emerged in relation to shale gas production operations.
The current review of the risk to water resources posed by hydraulic fracturing, being conducted by the
USEPA bears testimony to this. However, Shell’s application does not involve production – it is for
exploration wells only and is of a much smaller scale compared to production phase operations.

While we would support the current applications for exploration rights submitted by Shell, we believe it would
be wise for decision-makers to await and consider the findings of the USEPA review45, before any licensing
of a production well field is considered.

11.2.1 Environmental recommendations made in this EMP


The principal recommendations from the Environmental Management Plan, are summarised here:

ƒ The site selection criteria presented in this report should be applied to best position identified drilling
sites in order to avoid impact to the environment and to landowners where ever possible and, where
this is not possible to minimise the operational impact of the exploration drilling site.

ƒ The environmental management plan (EMP) presented in chapter 9 of this document must be updated
for each drilling site to reflect site-specific conditions, drawing upon the findings and recommendations
of the detailed technical studies which will underpin the site-specific environmental impact assessment.
This must happen prior to commencement of site clearing and deep level drilling and hydraulic
fracturing.

ƒ An environmental impact assessment (EIA) supported by detailed technical study will need to be
conducted prior to the commencement of drill site establishment, deep level drilling and hydraulic
fracturing.

45
Draft Plan to Study to address the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources, Office of Research and Development US
Environmental Protection Agency, Washington DC, February 7, 2011

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11.2.2 Environmental Impact Assessment (EIA) in terms of NEMA


Should an exploration right be granted, the applicant may proceed with only those gas exploration activities
that do not trigger a listed activity under the National Environmental Management Act (NEMA). Drilling (drill
site establishment) and hydraulic fracturing will trigger listed activities under the NEMA, as explained in
Chapter 3, Legal Context, and Chapter 6, EMP Process.
The following two listed activities as a minimum will trigger a NEMA EIA, but there are others too, which are
outlined in Chapter 3 and will need to be confirmed once drill sites have been identified and there is greater
finality regarding the associated supporting infrastructure at each drill site.

ƒ Activity 24 of Notice 1, GN 544, requiring a basic assessment: The transformation of land bigger than
1 000 m2 in size, to residential, retail, commercial, industrial or institutional use …. (Drill sites will be
approximately 100 x 100 m, thus 10 000 sq m).

ƒ Activity 4 of Notice 2, GN 545, requiring a full EIA: The construction of facilities or infrastructure for the
refining, extraction or processing of gas, oil or petroleum products with an installed capacity of 50 cubic
meters or more per day… (It is assumed that hydraulic fracturing during exploration drilling could
stimulate 50 cubic meters or more of gas per day).
Thus, an Environmental Impact Assessment for drilling and hydraulic fracturing will be required in
terms of the NEMA.

11.2.3 Key questions to be considered in EIA


In anticipation of a future EIA, the consultants have developed initial criteria for drill site selection (see
Chapter 7, Alternatives), and a preliminary list of key questions to be considered by the EIA. The questions
are based on stakeholder and authority comments, and input from technical specialist who conducted
assessments to inform the current EMP.
The key questions will guide the terms of reference for Specialist Studies to be conducted during the EIA.
Importantly also, these key questions largely reflect concerns raised by stakeholders and landowners and
have been drafted to ensure that these concerns get carried forward into subsequent detailed EIA.

The EIA will thus need to address these questions during EIA scoping and reflect competent scopes of work
during the EIA scoping phase for inclusion into the EIA Draft Scoping Report which will be available to
stakeholders for comment and review prior to the initiation of detailed specialist study to inform site-specific
impact assessment.
The key questions are listed below for comment by stakeholders. In considering these key questions during
the EIA, applicable laws, regulations, conventions, standards, guidelines and other legal instruments or
guidelines will need to be considered in the assessments.

11.2.3.1 Physical environment


Groundwater

ƒ How can the potential impacts of hydraulic fracturing on groundwater be determined given the limited
groundwater information for the Karoo? What can we learn from how this is done in other parts of the
world?

ƒ Will shallow aquifers from which landowners draw domestic and stock water be at risk from hydraulic
fracturing or other project activities in terms of water supply? Will the yield of aquifers be affected by
hydraulic fracturing?

ƒ Will shallow aquifers from which landowners draw domestic and stock water be at risk from hydraulic
fracturing or other project activities in terms of water quality in particular because of the chemicals
required for hydraulic fracturing and potentially also through naturally occurring radioactive materials
brought to surface in drill chippings? Will the quality of water from aquifers be affected by hydraulic
fracturing?

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ƒ Will hydraulic fracturing cause fractures to open between aquifers?

ƒ Should one aquifer be contaminated, will the water flow via fractures or pathways created by well holes
to another aquifer cause contamination there too?

ƒ Should shallow aquifers be contaminated, can the water be treated and if so, how and where?

ƒ Are shallow aquifers at risk from surface storage of waste water contaminated with fracturing
chemicals?

ƒ One alternative for the applicant to obtain water for drilling and fracturing purposes is from groundwater
resources; should this option be exercised, what will the impact be to the groundwater resources used
by surrounding landowners?

ƒ What mitigation measures are available to manage impacts to groundwater?

ƒ What monitoring needs to be done to monitor the potential impacts to groundwater resources?

Surface water

ƒ Are groundwater sources linked to surface water sources? If so, what is the possibility of contaminated
aquifers polluting surface water sources?

ƒ Are surface water resources at risk from surface storage of waste water contaminated with fracturing
chemicals?

ƒ Will horizontal drilling below surface water resources, including wetlands, affect these surface water
resources through for example subsidence, fractures opening etc?

ƒ What mitigation measures are available to manage impacts to surface water?

ƒ What monitoring needs to be done to monitor the potential impacts to surface water resources?

Air quality

ƒ What quantities of shale gas will be released per well during exploration?

ƒ Will air quality be negatively affected by the release of shale gas during exploration?

ƒ Will air quality be negatively affected by the flaring of gas during exploration?

ƒ Will dust be generated by vehicles and activities on drill sites?

ƒ What gaseous emissions and volumes of gaseous emissions will be released by exploration activities
including vehicles, release and/or flaring of gas, chemicals in waste water vapourising, etc

ƒ How far will air pollutants be dispersed in the atmosphere?

ƒ Will air pollutants settle on vegetation used by livestock, homes or farming activities and if so, what will
be the consequences of this?

ƒ What will be the contribution to greenhouse gas emissions as a result of this project?

ƒ What mitigation measures are available to manage impacts to air quality?

ƒ What monitoring needs to be done to monitor the potential impacts to air quality?

Archaeology and history

ƒ Will any archaeological and historic sites be disturbed and if so, what will be the impacts of this?

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ƒ What will be done when there are ‘chance finds’ during land clearing or drilling?

ƒ What mitigation measures are available to manage impacts to archaeological, paleontological and
historical sites?

ƒ What monitoring needs to be done to monitor the potential impacts to archaeological, paleontological
and historical sites?
Astronomy

ƒ Drill sites for exploration will operate 24 hours per day. What light at night will be needed, and how far
will this light project?

ƒ Will light at night as a result of exploration affect the efficiency of the SALT and the proposed MeerKAT
telescopes?

ƒ What mitigation measures are available to manage impacts of light at night?

ƒ What monitoring needs to be done to monitor the potential impacts of light at night?

Soils

ƒ Will high-potential agricultural soils be sterilized by establishment of drill sites, access roads and other
project infrastructure?

ƒ Will hygromorphic soils be disturbed by establishment of drill sites, access roads and other project
infrastructure?

ƒ What is the existing land use, land capability and soil types at site?

ƒ What is the likelihood of erosion from drill sites, access roads and other infrastructure?

ƒ Will soils be affected as a result of the storage of chemicals, machinery and other equipment on drill
sites, and as a result of the storage of waste water containing fracturing chemicals or drill cuttings that
may be radio-active on site?

ƒ What mitigation measures are available to manage impacts to soils?

ƒ What monitoring needs to be done to monitor the potential impacts to soils?

Seismicity

ƒ Will the depth of proposed drilling have effects on seismicity in the Karoo?

ƒ Will the high pressures used in hydraulic fracturing have effects on seismicity in the Karoo?

ƒ What mitigation measures are available to manage impacts on seismicity?

ƒ What monitoring needs to be done to monitor the potential impacts of drilling on seismicity?
Waste

ƒ What types of wastes will be generated from the exploration activities?

ƒ How and where will waste classified as hazardous be disposed of? Are there sufficient licensed
hazardous waste sites to do so?

ƒ How and where will other wastes be disposed of? Are there sufficient licensed waste sites to do so?

ƒ How will wastes be transported and what are the risks of spillage and contamination off the drill sites?

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ƒ What mitigation measures are available to manage impacts of different types of waste?

ƒ What monitoring needs to be done to monitor the potential impacts of different types of waste?

11.2.3.2 Biological environment


Terrestrial ecosystems (flora)

ƒ What proportion of different vegetation types will be affected by land clearing?

ƒ How significant will land clearing be in terms of impacts on different vegetation types?

ƒ Will any Red Data Plants, medicinal plants, threatened taxa or locally protected taxa be affected?

ƒ What mitigation measures are available to manage impacts to different vegetation types and Red Data
species?

ƒ What monitoring needs to be done to monitor the potential impacts to different vegetation types and
Red Data species?

Animals (Fauna)

ƒ What animals (mammals, birds, reptiles, amphibians, insects, arachnids etc) are likely to be affected by
land clearing and how?

ƒ How significant will land clearing be in terms of impacts on different animals?

ƒ Will any Red Data species be affected?

ƒ Are any animals likely to affect drilling activities and cause risk of failure of the operations?

ƒ What mitigation measures are available to manage impacts to different animals and Red Data species?

ƒ What monitoring needs to be done to monitor the potential impacts to different animals and Red Data
species?

Biodiversity

ƒ Will the high biodiversity in the Karoo be affected by land clearing, drill site operations, waste water
storage and other project activities?

ƒ What mitigation measures are available to manage impacts to biodiversity?

ƒ What monitoring needs to be done to monitor the potential impacts to biodiversity?

Rehabilitation

ƒ Given the low ecological resilience of Karoo ecosystems, what measures will be taken to rehabilitate
disturbed areas?

ƒ What is the likelihood of disturbed areas recovering, and how long will it take?

ƒ What mitigation measures are available to manage rehabilitation?

ƒ What monitoring needs to be done to monitor rehabilitation? For how long should that monitoring be
done and who will be responsible for it once the developer has left the sites.

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11.2.3.3 Social environment


Aesthetics / visual

ƒ What visual impacts will be caused during the day and at night by the proposed gas exploration
activities, and to whom?

ƒ Will the landscape quality, quietude and sense of place be disturbed and if so, over what distances?

ƒ What mitigation measures are available to manage visual impacts?

ƒ What monitoring needs to be done to monitor visual impacts?

Noise

ƒ What noise impacts will be caused during the day and at night by the proposed gas exploration
activities, and to whom?

ƒ Who are the noise receptors in proximity to each site and what will be the noise impact of proposed
activities be on these receptors?

ƒ Will the landscape quality, quietness and sense of place be disturbed and if so, over what distances?

ƒ What mitigation measures are available to manage noise impacts?

ƒ What monitoring needs to be done to monitor noise impacts?

ƒ What noise impacts will be caused by vehicles transporting equipment and materials to and from the
site?

Health

ƒ What is the likelihood of health impacts to humans, their stock or wild animals as a result of any of the
exploration activities?

ƒ What types of health impacts can be caused by chemicals used for hydraulic fracturing, potentially
radio-active drill cuttings and other project inputs and outputs?

ƒ Will there be an increased likelihood of dreaded diseases like cancer or contamination by radio-activity
in project areas?

ƒ What mitigation measures are available to manage health impacts?

ƒ What monitoring needs to be done to monitor health impacts?

Property value

ƒ Will the gas exploration project cause a negative impact to property values?

ƒ What is the negative impact likely to be?

ƒ Would home owners and landowners have redress should their property values be affected?

ƒ What mitigation measures are available to manage impacts to property values?

ƒ What monitoring needs to be done to monitor impacts to property values?

Safety and security

ƒ How and where will construction workers be accommodated and for how long?

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ƒ How and where will drill site workers be accommodated and for how long?

ƒ What will be the safety and security impacts to surrounding landowners as a result of construction
workers?

ƒ What will be the safety and security impacts to surrounding landowners as a result of drill site workers?

ƒ What mitigation measures are available to manage impacts to safety and security?

ƒ What monitoring needs to be done to monitor impacts to safety and security?


Traffic

ƒ What will be the increase in traffic as a result of construction of project elements?

ƒ What will be the increase in traffic as a result of operation of drill sites?

ƒ How will provincial, regional and local roads be impacted as a result of increased traffic? Who will
maintain the roads?

ƒ Will there be an increased risk of traffic accidents?

ƒ Will there be an increased nuisance to surrounding landowners and others as a result of increased
traffic?

ƒ What mitigation measures are available to manage traffic impacts?

ƒ What monitoring needs to be done to monitor traffic impacts?

Socio-economic issues

ƒ Will the proposed gas exploration cause negative impacts to the economy of the Karoo, e.g. income
earned from sheep farming, other agricultural practices, tourism etc?

ƒ What will be the impacts on employment, migration and urbanization?

ƒ How will informal settlement and its resulting social ills be avoided?

ƒ What are the potential socio-economic benefits of this project at national, provincial and local scales?
Who will benefit and how?

ƒ What mitigation measures are available to manage negative socio-economic impacts?

ƒ What mitigation measures are available to enhance positive socio-economic impacts?

ƒ What monitoring needs to be done to monitor negative socio-economic impacts?

ƒ What monitoring needs to be done to monitor enhancement of positive socio-economic impacts?


Cumulative assessment and Risk Assessment

ƒ Will be cumulative impact of the project be assessed?

ƒ How will the project impact regional planning?

ƒ Will detailed risk assessment be carried out?

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11.3 Declaration of Independence by the EAP

I, Name of EAP , declare under oath that I –

• act as the independent environmental practitioner in this application ;


• do not have and will not have any financial interest in the undertaking of the activity, other than
remuneration for work performed in terms of the Environmental Impact Assessment Regulations, 2006;
• have and will not have no vested interest in the proposed activity proceeding;
• have no, and will not engage in, conflicting interests in the undertaking of the activity;
• undertake to disclose, to the competent authority, any material information that have or may have the
potential to influence the decision of the competent authority or the objectivity of any report, plan or
document required in terms of the Environmental Impact Assessment Regulations, 2006;
• will ensure that information containing all relevant facts in respect of the application is distributed or
made available to interested and affected parties and the public and that participation by interested and
affected parties is facilitated in such a manner that all interested and affected parties will be provided
with a reasonable opportunity to participate and to provide comments on documents that are produced to
support the application;
• will ensure that the comments of all interested and affected parties are considered and recorded in
reports that are submitted to the competent authority in respect of the application, provided that
comments that are made by interested and affected parties in respect of a final report that will be
submitted to the competent authority may be attached to the report without further amendment to the
report;
• will keep a register of all interested and affected parties that participated in a public participation process;
and
• will provide the competent authority with access to all information at my disposal regarding the
application, whether such information is favourable to the applicant or not.

SIGNATURE IN FINAL DOCUMENT

Signature of the environmental practitioner:

Golder Associates Africa Pty Ltd

Name of company:

Insert date

Date:

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