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Totally Unacceptably Toxic

Oceans Not Oil has responded to TotalEnergies EP South Africa B.V. (TEEPSA) and its partners proposal to drill 10 exploratory offshore wells. We have major concerns, apart from its impact to global warming, and they are how many wells (10), how much noise, toxins, radioactivity for an extended period of time. We estimate pollution might go on for up to 7 years!

There are already 3 other applications in the same area, which may or may not run concurrently.

The DWOB Licence Block the draft scoping report (12/3/343 ER), located off the West Coast of South Africa

TEEPSA is proposing to undertake various exploration activities, including:

  • Sonar bathymetry surveys throughout the years;
  • Vertical Seismic Profiling
  • Drop core sampling; and
  • Exploration well drilling.
  • Discharging toxic drilling wastes overboard

There is still time for members of the public to draft your own questions and objections. Please see the Draft Scoping summary and submission details here.

These are our questions and concerns based on their draft scoping report. Please read to the end to understand the detail and significance of threat this application involves:

PUBLIC PARTICIPATION 

  1. Radio Announcements – 

    a) What languages will be used for these announcements?

    b) Which radio stations will be used?

    c) Which time slots will be utilised for these announcements?
  2. Please explain how the once-off, presented participation activities will be a meaningful people-centred process?
  3. Will public meetings happen after hours when workers are able to attend?
  4. What time allocation will be given to the Question and Answer periods? 
  5. Will the meeting end when all questions are answered in full – including all questions in chat columns online etc? 
  6. Will any of the online chat be redacted?
  7. Will questions be answered to the satisfaction of the questioner before the engagement is terminated? In other words, will the appropriate experts be in the room to answer all questions?

NEED AND DESIRABILITY 

TEEPSA_ DWOB Drill Executive Summary states in reference to the need and desirability of the project,

8. There is a drive from National Government to stimulate development and grow the economy of South Africa with a strong focus on job creation in all sectors, whilst protecting the environment. 

a) This project involves pollution-intensive activities and higher emission levels, please show how it might be ‘needed’ or ‘desired’ in context of “protecting the environment”?

b) Please highlight which, and how many, fixed term (for longer than three months) jobs (for South African citizens) will be created?

c) Given that this project’s goal is better understanding of “the viability of developing indigenous gas resources “, proposing the caveat that it has “no direct influence on South Africa’s reliance on fossil fuels and whether consumers use more or less oil or gas, nor on which types of fossil fuels contribute to the country’s energy mix”, how does it propose stimulating development and growing the economy?

9. Justification for this project is “better understanding of the extent, nature and economic feasibility of extracting these potential resources” 

then, “The proposed exploration project will potentially lead to South Africa optimising its own indigenous resources to provide its identified oil and gas needs until the 2050 deadline to achieve carbon neutrality, rather than having to mainly import, as at present. It won’t necessarily change how fossil fuels are used in the short- to medium- term in the transition towards the goal of carbon neutrality by 2050.”

a) Please explain the time period involved until oil or gas resources would come online should resources be discovered, from the first potential well to the last?

b)Please explain the need for additional fossil fuels coming online in light of the IPCC’s 2022 report being resolute that global oil and gas production and consumption must decrease by 30% by 2030 and that new oil and gas development and exploration must end immediately. These findings are supported by the IEA’s Net-Zero by 2050 report[i].

c) It is misleading to suggest that oil and gas exploration “won’t necessarily change how fossil fuels are used” in the transition to carbon neutrality. There is only one reason to explore for oil and gas and that is to use it if you find it. Once “used”, the increase in produced GHGs will significantly impact South Africa’s emissions budget.

10. The “Just Transition and Climate Pathways Study” (NBI, 2021) concludes that a lack of gas supply threatens South Africa’s decarbonisation strategy because the synfuels, power and industrial sectors would rely on carbon-intensive fuels (e.g., coal and diesel) for longer.

a) Firstly, it must be clarified that NBI (National Business Initiative) is a coalition of 86 major companies, including BP, Engen, Shell, Sasol and Eskom. Their more recent report in February 2022, The Role of Gas in South Africa’s Path to Net-Zero, showed that the electricity sector likely needs just 17 petajoules (PJ) of gas a year until 2035. South Africa already imports 180 PJ a year from Mozambique, repudiating any demand for further exploration. 

b) It further refutes the need for new exploration projects, favouring “optimal” imported LNG because it minimises the risk of stranded assets and gas infrastructure lock-in post-2040.

11. In this regard, South Africa needs to balance the three core dimensions of what has been defined as the “energy trilemma”: (1) affordability and accessibility, (2) energy security, and (3) environmental sustainability. In weighing up these core dimensions, the South African Government policy currently supports exploration for indigenous oil and gas resources and currently promotes the use of natural gas as part of the energy mix in the short- to medium-term up to 2030 (as per the Integrated Resource Plan (IRP) 2019). 

a) Please show comparisons between costs per kilowatt hour for methane and solar and wind as electricity generation options with the actual costs based on current energy prices. This should give clarity to points 1) and 3) in the DSR above.

12. These National strategic policy issues relating to energy and climate change fall beyond the scope of this exploration project ESIA. 

a) The issue of global warming is not broader than the scope of the ESIA and should be centralised within it. The ESIA should draw on the Sustaining the Wild Coast NPC & Others v Minister of Mineral Resources and Energy & Others, High Court of South Africa, Eastern Cape Division, Makhanda – Case No. 3491/2021, to produce a climate impact assessment to place all relevant considerations before the decision-maker, as contemplated under Section 6(2)(e)(iii) of the Promotion of Administrative Justice Act.

OVERVIEW OF PROPOSED PROJECT ACTIVITIES 

TIMING 

13. Please clarify the total anticipated time for this project: 

a) Is it true that potentially this project could take up to 280 days per well (45 days mobilisation; 90 days drilling; 120 days appraisal well, 15 days well plugging, 10 days demobilisation)?

b) Does this then mean there is the potential for TEEPSA to be occupied in this ocean space for 7 and a half years?

i. If not, how will the wells be managed concurrently?

ii. Please describe this operation, including how many vessels etc will be managed.

iii. Please give details on the maximum amount of time this whole project could take.

TOXICITY, RADIOACTIVITY & POLLUTION

14. Please provide a detailed report, describing the compound ingredients, levels of expected toxicity and radioactivity of the lubricants used, and their effects to species (including human), as well as larval stages.

15. How and where in the water column will drill cuttings discharge to sea be dispersed?

a) A detailed composition of these emissions and effluents regarding their toxicity, biodegradation, polynuclear aromatic hydrocarbon content and their metal content, need to be made public/ described in the ESIA.

16. What assurances are there that drill cuttings will be treated to reduce oil content before disposal overboard? 

17. Will the NADFs be oil based or synthetic? Please describe their classification.

18. Offshore thermal desorption offers an alternative method to treat drilled cuttings offshore and reduce the oil concentration on cuttings to typically less than 0.5% by weight prior to marine discharge. Is this a method being considered?

19. The Drilling Discharges Modelling Study must evaluate the contamination by not only Kilograms of Non-aqueous Drilling Muds per well, but also model for the risk of the cumulative exposure to toxic and non-toxic stressors (dissolution of the chemicals, transport and deposition of particles, biodegradation, attachment of chemicals to particles, and eventually the formation of agglomerated particles), and the fates of the discharge compounds in the sediment (e.g., concentrations and biodegradation in the sediment, bioturbation, equilibrium partitioning for organic chemicals and heavy metals, oxygen content in the porewater, change of grain size, and burial) from the tonnes of discharge from 10 wells. 

20. Please advise as to which actual licenced waste contractor will be used for disposing of volumes of NADF remaining from the project. It is in the public interest to know the name of the contractor should the option be employed.

21. Radioactive sources may be used for certain types of data acquisition. Please identify, and declare the half-life/rate of radioactive decay, of the radioactive sources. 

22. Please advise as to which actual licenced waste contractor will be used for disposing of hazardous wastes from the project, for the same reasons as above.

23. Total Energies and Shell have endorsed the Zero Routine Flaring by 2030 (Shell ZRF by 2025) initiative launched by the World Bank and the United Nations in 2015 for new field development, so what consequence does this hold for this operation?

24. Please give a realistic determination of the volume of gas to be flared per test, its emissions quantity and concentration, and expand estimates given that there may be up to ten wells in total. 

25. What carbon budget has been allocated by the Minister of Forestry, Fisheries and the Environment for this project? 

26. Has a greenhouse gas mitigation plan been prepared and submitted to the Minister for approval?

WELL ABANDONMENT

27. Well failure is a common enough issue[ii] and serious. Please advise as to which actual contractor will be used for well plugging.

28. Will the well abandonment be permanent or temporary? 

29. Please provide information on the types of well barriers utilised, types of plugging materials utilised, their functioning and verification. 

30. Please describe the well-integrity testing methodology to be utilised.

31. Incidents involving radiation sources in well logging have occurred mainly as a result of operator error or equipment failure. According to the International Atomic Energy Agency 2020 Radiation Safety In Well Logging: Specific Safety Guide report, the hazards involved and the necessary control measures should be identified for each of the following conditions:

a) Storage of the well logging sources;

b) Calibration and operation of the well logging tools; 

c) Transport of the sources;

d) Work at the site with the well logging tools;

e) Maintenance of the tools;

f) Disposal of disused sources; and

g) The possibility of theft and sabotage of radioactive sources. 

Please identify control measures for each of these conditions.

32. Please provide a report on how the applicant will ensure well monitoring to identify bubbling/leaking events will be carried out after drilling/ /logging/ production/ de-commissioning has ceased.

NOISE EMISSIONS 

33. South Africa is a signatory to a resolution passed at the 67th International Whaling Commission (IWC) 2018 for the elimination of acoustic pollution that affects whales (of all 13 species and populations considered under the IWC), and therefore has a duty to cooperate. Please explain how South Africa can fulfil this duty given that this project may take up to 7 and half years to complete (TBC) and will create significant disturbance for an extended period for protected and unprotected species. 

a) The identified marine noise specialist must be capable and equipped to undertake in situ measurements (if they do not already exist) of the sound scape, and have the ability to interpret hearing thresholds (both Temporary Threshold Shift-based thresholds (TTS) and Permanent Threshold Shift (PTS)) of marine fauna in the proposed area. Rather than establishing the safety zone radius solely based on a fixed distance, the safety zone radius should be, at most conservative, of either 500 meters or a radius determined using propagation models based on the best available data and science for a pre-determined acoustic threshold (McQuinn and Carrier, 2005).

34. Please clarify whether the sonar surveys will take 4 weeks for the entire project (all 10 wells) or whether they’ll operate for 4 weeks per well?

35. Please include seabed coring in your noise modelling.

36. Please include Vertical Seismic Profiling in your noise modelling.

a) Please include the decibel attenuation for the Vertical Seismic Profiling.

37. What alternatives to Vertical Seismic Profiling have been investigated?

38. Please include the number and size of airguns being used.

39. Please establish cumulative acoustics limits for relevant species for the following:

a) Multi beam echo-sounder (70-100 kHz) 

b)Single beam echo-sounder (38-200 kHz) 

c)Sub-bottom profiler (2-16 kHz) 

d)Vertical Seismic Profiling (please confirm the relevant Hz range)

e)Sea bed coring

f)Noise from the rig

g)Noise from the many vessels operating simultaneously

h) Dynamic Positioning Systems from all vessels, including support vessels.

40. Please indicate when these operations may run concurrently, such as VSP while drilling, and across wells or individually?

41.Key findings and modelling must be projected for the full length of the proposed operation.

42.What international operational guidelines will be followed for mitigation of noise during this operation?

43. Please assess the full scale of this acoustic footprint including impacts caused by vibration through drill string and casing, vibration into the seabed, vibration of drill bit.

44. Please indicate how precautionary protocols will be established in areas of steep bathymetry close to seismic surveys and multibeam bathymetric sonar. Ocean depth, multibeam echo sounders sweep a swath up to 7.4 times water depth and so affect a wide area. Potential impacts on marine mammals may range from physical damage, including gross damage to ears and the ‘bends’, temporary and permanent threshold shift (deafness), to perceptual (masking biologically significant noises) and behavioural impacts (temporary or permanent displacement and stress) as well as indirect effects (reduced prey availability) (Gordon et al., 1998). High intensity, low and mid-frequency sonar has been implicated in some fatal strandings (Frantiz, 1998).

45. Please indicate how precautionary protocols to limit the disruption of rest will be established for the extended period of this project. Perhaps one of the most overlooked aspects of anthropogenic noise impacts is the ‘disruption of rest periods’, which are important to migrating, or even generally moving, marine animals. Significant stress due to prolonged exposure to seismic and anthropogenic underwater noise has been measured in a number of species (Finneran et al., 2002; Eckert et al. 1998; McCauley et al. 2003; Rollard et al. 2012). These studies indicate cumulative effects could result in metabolic maladaptation, suppressing growth, immune system function, thermoregulation and the reduction of reproductive rates, with implications for individual and population fitness. Chronic problems of this kind are a legitimate conservation concern. 

46. Cumulative acoustic limits should be established, since there is a very real risk of displacement from feeding or breeding areas which could have far-reaching effects not only for whole, and vulnerable, animal populations, but also on the fishing sector and our food security. These limits should be appropriately matched to the spatiotemporal scale and exposure rate of the risks to individuals and populations. Measurement of noise budget, such as those under consideration under the EU Marine Strategy Framework Directive (Tasker et al. 2010), should lead to limits on the source levels that are introduced on a regional scale.

47. Please assess the various technologies available for detecting marine animals in low-visibility conditions. Technologies that need to be explored include, active acoustic monitoring (AAM), radio detection and ranging (RADAR), light detection and ranging (LIDAR), satellite, and spectral camera systems, especially infrared (IR).

EMERGENCY RESPONSE 

48. Please describe the protocol and time frame of response if there are accidental leakage/blowout from more than one well. 

49. Oil Spill Contingency Plan (OSCP) for Subsea and Surface Release, detailing Oil Spill Response, including the Blowout Management Protocol, Planning and Capacity, must be reported to both stakeholders and the public relevant for each exploration, extraction or decommissioning operation; must include the possibility of more than one event; and must be made available for proper stakeholder and I&AP engagement.

a) Any deficit of technological expertise / resources / difficulty of effective co-ordination with all government or conservation agencies that have a statutory responsibility for some aspect of offshore oil and gas activities regarding incident management, should be highlighted

50. The delegated National Incident Commander, along with the intended lines of responsibility for inter-agency efforts, should be made available for proper stakeholder and I&AP engagement. The citizens of South Africa need assurance that incident management is fully informed and has capacity to deal with the latest technology, practices and risks associated with, and due to, the different geological and ocean environments being explored, prior to the commencement of drilling. 

51.The ESIA must provide an Assessment of Onshore Environment and Mitigation in case of oil pollution. Buried oil contaminants can resurface as the beach erodes. Buried oil must be removed through mechanical excavation. The DEIAR needs detailed modelling of cross-shore distribution of oil contaminants relating to beach morphodynamic terminology to help optimize beach clean-up planning.

52. The ESIA must clarify a Dispersant Use Plan:

a) The most appropriate dispersants must be listed. An explanation of their chemical components, toxicity, and potential for bioaccumulation, ecological impacts through the water column and on the shoreline, and their specific function must be also provided. 

b) There are many situations where the net environmental benefits of chemical dispersion are not clear. The dispersant effects on local flora and fauna must be indicated for all potential choices of dispersant in order for regulators to confidently decide on dispersant use issues.

c) The ability to provide timely and scientifically sound outcome and effects information is essential to support the regulators in their decision-making role when approving the initial use of dispersants and whether to continue or cease their use during an incident.

i. Predictive migration / movement maps of dispersants based on sound oceanographic and metrological science must be provided. 

ii. Developers must provide proof of immediate availability of dispersants considering this is of primary importance in effecting recovery rates. 

BIOLOGICAL OCEANOGRAPHY / MARINE PROTECTED AREAS AND OTHER CONSERVATION AREAS

53. The ESIA understates the Project’s direct area of influence by saying it doesn’t ‘overlap’ Critical Biodiversity Areas (CBAs) and Ecological Support Area (ESAs).The project does however abut CBA 1 and 2 Natural areas, plus CBA 1 and 2 Restore areas and an ESA on all sides of the Area of Interest. The DSR has all but scoped these areas out. 

The environmental assessment process is used to understand the potential environmental impacts of a development. This project will produce intense man-made noise pollution, produce carcinogenic, radioactive and polluting wastes in the water column and on the sea bed, over an extensive area possibly for years, next to critical biodiversity areas. 

It is also evident that this Area of Interest was clipped out during the spatial planning processes when the CBA’s were created by SANBI. This highlights the complete disregard for marine biodiversity and conservation in  South Africa when oil majors and DMRE has intent for an area. 

54. A full evaluation of each of these CBAs and ESA and their sensitivities are expected to be fleshed out in the ESIA. 

55. In addition, the buffer areas surrounding these areas are expected to be noted and added to the operational plan. 

56. Considering that the Area of Interest is surrounded on all sides Critical Biodiversity Areas (CBAs) and an Ecological Support Area (ESA) alternatives to release of drill cuttings overboard must be reassessed. 

SOCIO ECONOMIC ENVIRONMENT 

57. The significance of impact of both cumulative effects and extended  duration should be considered high and compensation for loss of income must be established through a Cost Benefit Analysis. All fisheries should be evaluated.

58. Reduction in income and livelihood related to short-term disruption of commercial fisheries.(7.2.3. Exec Summary)

a) Please define “short term disruption “ given this project could last years.

b) Have all West Coast fisheries and small scale fishers been informed as to the potential full duration of this project?
Evidence that the Fisheries sector have been fully consulted and are in full support of the exploration drilling should be written into the ESIA. Up to now, fisheries appear to have had little to no say that their areas are being intercepted and they are expected to stay out of the areas. 

59. It is not enough to “determine the fishing effort and catch” and “assess the impact that the proposed project will have on these sectors during normal drilling operations and upset conditions (small accidental spills and large blow-out)“. A cost-benefit analysis in the event of a spill and the consequences thereof on private individuals, the commercial sector and the ecosystem itself must be provided. The significance of the economic toll a spill would have on livelihoods dependent on a healthy ocean must be considered and compensation calculated in Rands and cents.

60. A total catch value must be assigned to the total fishing effort in the vicinity of the oil operations. This will place a measurement on the pre-spill status of the given fishing sector and related businesses, including its economic losses by disruptions, loss of earnings plus the effects of negative publicity, persisting public perceptions and potential fishing and harvest bans.

ENVIRONMENTAL AND SOCIAL INTERACTION MATRIX 

61. Please support your view that a blow-out or accidental leak from the operations would be positive for employment. Please identify who are most likely to be employed in the clean-up operation and who might experience job losses due to the disaster. Please support how a net increase in employment and wages was tallied and based on what criteria, over what duration and area and what kind of persistence.

62. Scoping out public health and safety for “accidental hydrocarbon spills / releases (minor) waste management and air emissions” minimises the potential ecological risks, and the consequential impacts to lives and livelihoods of small offshore spills, and erases their actual impact as cumulative environmental hazards. This coastal region has a large informal economy as well as intangible heritage dependent on a healthy ocean. Since these are not benign events it is the exact purpose of the ESIA to assess for them to inform the development of mitigation measures and decision-making.

63. Please describe “routine discharges at sea”, and how they might differ from the toxic, radioactive well cutting discharges’.

64. The screening out of Cultural Heritage from well drilling (including ROV site selection, installation of conductor pipes; wellhead, BOP and riser system, well logging and plugging) is unacceptable. The sea floor is seen as a sacred resting place in many South African cosmologies and its penetration and disturbance and its soiling needs to be taken into consideration in the light of this. 

SUMMARY OF KEY IMPACTS AND PRELIMINARY MITIGATION 

65. Pre-drilling sampling surveys (with ROV) and implement buffer around sensitive hardgrounds and vulnerable habitats is not a mitigation measure. How will mitigation to avoid these areas be implemented ?

66. A copy of TEEPSA’s local content policy is imperative to the ESIA. 

67. Implement a ritual event/s that permits engagement with ancestral spirits and nature to alleviate potential and future negative impacts of non-consultation and poor cultural/nature respect. 

68. Please explain this process/es in detail and who will be involved and consulted and when?

69. Please explain how the polluter “implementing, where necessary, a ritual event/s” after a well blow out is mitigation.

For all the reasons stated above, it is our urgent request that the proposed exploration does not proceed.

CITATIONS

Gordon, J.C.D., Gillespie, D., Potter, J., Frantiz, A., Simmonds, M.P. and Swift, R. (1998). The effects of seismic surveys on marine mammal. In Tasker M.L., and Weir, C. (editors) Proceedings of the seismic and marine mammals workshop. 

IEA (2021), Net Zero by 2050, IEA, Paris https://www.iea.org/reports/net-zero-by-2050, License: CC BY 4.0

INTERNATIONAL ATOMIC ENERGY AGENCY, (2020) Radiation Safety in Well Logging, IAEA Safety Standards Series No. SSG-57, IAEA, Vienna 

McQuinn, I.H. and Carrier D. (2005). Far-field measurements of seismic airgun array pulses in the Nova Scotia Gully Marine Protected Area. Can. Tech. Rep. Fish. Aquat. Sci. 2615: v + 20 p.Tasker, M. L., Amundin, M., Andre, M., Hawkins, A., Lang, W., Merck, T., … & Zakharia, M. (2010). MARINE STRATEGY FRAMEWORK DIRECTIVE Task Group 11 Report Underwater noise and other forms of energy. Report No. EUR24341, 2010.


[i] Bouckaert, S., Pales, A. F., McGlade, C., Remme, U., Wanner, B., Varro, L., … & Spencer, T. (2021). Net Zero by 2050: A Roadmap for the Global Energy Sector.

[ii] Vignes, Birgit, and Bernt S. Aadnoy. “Well-Integrity Issues Offshore Norway.” Paper presented at the IADC/SPE Drilling Conference, Orlando, Florida, USA, March 2008.

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