Rev Prepared Sign Off Checked Sign Off Approved Sign Off Date of Issue Comments
1 M.Gough, F. Fortune
F. Fortune
E. Rollings
30/05/2105
2 F. Johnson
I. Sargent
E. Rollings 29/07/2015 Consultation response from Historic Scotland and SNH
Environmental Management Plan - Construction Works Page 1 of 54
RHK-1A-40-HSE-002-D-EMPConstructionWorks
MeyGen Tidal Energy Project Phase 1
Environmental Management Plan:
Construction Works
This document contains proprietary information belonging to MeyGen Ltd. and/or affiliated companies and shall be used only for the purpose for which it was supplied. It shall not be copied, reproduced, disclosed or otherwise used, nor shall such information be furnished in whole or in part to third parties, except in accordance with the terms of any agreement under which it was supplied or with the prior consent of MeyGen Ltd. and shall be returned upon request.
Project Title/ Location MeyGen Tidal Energy Project, Phase 1a. Inner Sound.
Date: 29/07//2015
[Redacted]
[Redacted]
[Redacted][Redacted]
[Redacted]
[Redacted]
Environmental Management Plan - Construction Works Page 2 of 54
RHK-1A-40-HSE-002-D-EMPConstructionWorks
Table of Contents
Executive Summary ................................................................................................................. 3
1 Introduction ................................................................................................................... 4
2 Scope of The Environmental Management Plan .......................................................... 5
3 Licences and Legal Requirements ............................................................................. 10
4 Communication, Roles and Responsibilities .............................................................. 10
5 Marine Mammal Management .................................................................................... 20
6 Marine Pollution Contingency Plan ............................................................................ 27
7 Invasive Non-Native Species Management ............................................................... 36
8 Reporting Protocol for the Discovery of Marine Archaeology ..................................... 38
9 Waste management ................................................................................................... 42
10 Linkages with Other Conditions .................................................................................. 43
11 EMP Review and consultation .................................................................................... 44
12 References ................................................................................................................. 45
13 List of Abbreviations ................................................................................................... 46
Appendix A: James Fisher Marine Services ISO14001 ......................................................... 48
Appendix B: Marine Mammal Reporting Log ......................................................................... 50
Appendix C: Waste Management Plan (FSH-1A-40-HSE-004-D-WasteManagementPlan-MeyGen.pdf) .......................................................................................................................... 52
Appendix D: Section 36 and Marine Licence ......................................................................... 53
Environmental Management Plan - Construction Works Page 3 of 54
RHK-1A-40-HSE-002-D-EMPConstructionWorks
EXECUTIVE SUMMARY
This Environmental Management Plan (EMP) has been prepared by MeyGen Ltd. to set out the proposed method for discharging the Condition 11 of the Section 36 Consent for the Development.
The document details the construction related mitigation methods proposed for the Development, how these are to be delivered in the construction procedures and good working practices for installing the Development, how this document integrates with the wider environmental management of the Development, and how communication will be maintained between the Principal Contractor, MeyGen Ltd. and the regulators.
The EMP presented within this document is to satisfy Condition 11 and enable construction of the Development to progress, subject to the EMP being implemented.
The EMP will be submitted to the to the Scottish Ministers for their written approval, in consultation with SNH and any other ecological, or such other advisors as required at the discretion of the Scottish Ministers., and will be used, where appropriate, to inform the discharge of other Conditions within the Section 36 Consent which refer to it.
An EMP for HDD Marine Works (RHK-1A-40-HSE-001-D-EnvironmentalManagementPlanHDD) has already been consulted on and approved by Scottish Ministers. This EMP is for the remaining Construction Works for Phase 1a; this includes the installation of:
4 x Turbine Subsea Cable (TSC);
4 x Turbine Support Structure (TSS); and
4 x Tidal Turbine Generator (TTG).
Environmental Management Plan- HDD Marine Works Page 4 of 54
RHK-1A-40-HSE-002-D-EnvironmentalManagementPlanConstructionWorks
1 INTRODUCTION
The MeyGen Tidal Energy Project Phase 1 (“the Development”) received consent under Section 36 of the Electricity Act 1989 from the Scottish Ministers 9th October 2013 (“the S.36 Consent”). This Environmental Management Plan (EMP) is prepared to enable Condition 11 of the S.36 Consent (“the Condition”) to be discharged. Condition 11 states:
The Company must, no later than 3 months prior to the Commencement of the Development, submit in writing an Environmental Management Plan (“EMP”) to the Scottish Ministers for their written approval, in consultation with SNH and any other ecological, or such other advisors as required at the discretion of the Scottish Ministers. The final draft of the EMP must have been approved by the ECoW prior to its submission to the Scottish Ministers.
The EMP (and, as the case may be, amended EMP) must detail measures that must be taken by the Company, through all stages of the Development, to prevent adverse impacts including, but not limited to, marine mammals, birds, fish and habitats as outlined in Chapter 25 of the Company’s Environmental Statement. The EMP must take account of, and implement, recommendations where appropriate and reasonable from the CMS, the Operations & Maintenance Programme, the Vessel Management Plan and the Navigational Safety Plan, as well as any other recommendations within the Company’s Environmental Statement.
The EMP must be regularly reviewed by the Scottish Ministers, at timescales to be determined by the Scottish Ministers, in consultation with SNH, the ECoW and any other ecological, or such other advisors as required at the discretion of the Scottish Ministers. Following such review the Scottish Ministers may, in consultation with SNH, the ECoW and any other ecological, or such other advisors as required at the discretion of the Scottish Ministers, require the Company to amend the EMP and submit such an amended Plan to them, in writing, for their approval. The Scottish Ministers may approve an amended Plan in consultation with SNH, the ECoW and any other ecological, or such other advisors as required at the discretion of the Scottish Ministers.
The EMP must, so far as is reasonably practicable, be consistent with any relevant monitoring requirements during construction taken from the Project Environmental Monitoring Programme.
The Environmental Management Plan must be implemented in full by the Company.
This document sets out the proposed EMP that MeyGen Ltd (“MeyGen”) intends to undertake, to allow Condition 11 to be discharged.
Environmental Management Plan- HDD Marine Works Page 5 of 54
RHK-1A-40-HSE-002-D-EnvironmentalManagementPlanConstructionWorks
2 SCOPE OF THE ENVIRONMENTAL MANAGEMENT PLAN
This EMP has been developed in accordance with the Institute of Environmental Management and Assessment (IEMA) Practitioner “Environmental Management Plans”, Best Practice Series, Volume 12, December 2008.
MeyGen commits to safeguarding the environment through the identification, avoidance and mitigation of the potential negative environmental impacts associated with the development, construction and operation of the Development.
The principle objectives of the EMP are to:
Identify avoid, minimise and control adverse environmental impacts associated with the Development; and
Define good practice as well as specific actions required to implement mitigation and monitoring requirements as identified in the ES, and the licensing and consenting process.
The Development must, at all times, be constructed and operated in accordance with the approved EMP (as updated and amended from time to time). Any updates or amendments made to the EMP by MeyGen must be submitted, in writing, by MeyGen Ltd. to the Scottish Ministers for their written approval.
The EMP must be in accordance with the Environmental Statement (ES) and Supplementary Environmental Information Statement (SEIS) as it relates to environmental management measures.
The EMP (S.36 Consent, Condition 11) includes the Marine Pollution Contingency Plan (Marine Licence, Condition 3.2.13) and Reporting Protocol for the Discovery of Marine Archaeology (S.36 Consent, Condition 16).
The EMP forms part of a suite of documents related to the consent conditions that MeyGen seek to discharge:
Construction Method Statement (CMS) (S.36 Consent, Condition 9), including Cable Installation Plan (Marine Licence 3.2.1.8) and Cable Protection Plan (Marine Licence 3.2.1.9);
Navigation Safety Plan (NSP) (S.36 Consent, Condition 17); and
Vessel Management Plan (VMP) (S.36 Consent, Condition 14).
Phase 1a of the Development is a 6MW, 4 tidal turbines initial phase to be installed and operatives under the restriction placed on the Development by Condition 2 of the S.36 Consent.
This document, as agreed with the licensing authority, covers the installation of the Phase 1a infrastructure (4 x Tidal Turbine Generators (TTG), 4 x Gravity-base Turbine Support Structures (TSS) and Turbine Subsea Cables (TSC), collectively described as “the Construction Works” (Figure 1).
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Environmental Management Plan- HDD Marine Works Page 12 of 54
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Environmental Management Plan- HDD Marine Works Page 14 of 54
RHK-1A-40-HSE-002-D-EnvironmentalManagementPlanConstructionWorks
where necessary with respect to environmental impacts and mitigation.
Ensure that all environmental incidents are reported to the ECoW and MeyGen in accordance detailed reporting requirements and the respective regulatory bodies (where required) as soon as possible.
Review environmental matters with the ECoW and MeyGen and respective regulatory bodies on a regular basis and as per project requirements.
Ensure that arrangements for liaison with Development respective regulatory bodies on all environmental issues is appropriate and maintained.
Implement and maintain a project communications strategy to manage project public relations and complaints.
Produce weekly and monthly reports and submit to MeyGen Package Manager and ECoW.
Ensure contractors are approved, operates a Safety Management System, confirm that they are suitably qualified in their line of work and have undertaken suitable environmental training to cover tasks to be undertaken.
4.4.2 HSE Advisor
Key roles and responsibilities of the HSE Advisor include, but are not limited to the following:
Verify compliance with relevant legislation.
Prepare, implement, review and update consent related documents (in conjunction with the Project Management Team) in accordance with consent condition, James Fisher Marine Services procedures and current legislation.
Advise the project team on environmental related decision making
Review Risk Assessments and Method Statements (RAMS) as and where necessary with respect to environmental impacts and mitigation.
Approve Toolbox Talks and Site / Vessel Inductions and ensure content promotes effective environmental management, specific works and Site / Vessel sensitivities and communicate associated lessons learnt.
Provide support to the Marine Coordinator and workforce on any environmental matters that may arise.
Audit contractors to confirm that they are suitably qualified in their line of work and have undertaken suitable environmental training to cover tasks to be undertaken.
Ensure suitable consideration is given to the period and frequency of environmental monitoring (particularly with respect to higher risk areas).
Inspect and audit the site / vessels on a regular basis to ensure effective implementation / operation of any environmental mitigation measures.
Ensure compliance with environmental requirements and address any shortfalls.
Provide inspection reports to the project management detailing any issues that must be addressed
E
Environmen
4.4.3
C4.5
4.5.1
tal Manage
Undertake the root/dire
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Marine Coo
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ment Plan-
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azardous obnd impactsntal impacts
ordinator
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t all contrac
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ng, ensurinmovements
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aily reportsnd ECoW.
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t reports stbelow MHW
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ster
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municating
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mit to the P
all materia
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onsibility to ters related
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al incidents s, recomme
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timely and e
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4.5.2
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4.6.1
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4.6.2
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tal Manage
All Other S
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To conductthe Develoor Project M
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nmental iss2.
g/briefing Health, Envy and Qualiogress Meete team brie
ssessment/Ment briefingx Talks inclumental pracon measureessel Induc
SHESQ an
C shall convnicate, dismental arra
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s of all sucsupplied to
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rdinary mee
ment Plan-
taff
and and im
t their work opment andManager.
all environmossible.
ation
ues will be
vironment, ty (SHESQ
eting efs Method s uding ctices and es ction
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d Progress
vene weeklyscuss and angements,
epresentativto attend t
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ch meetingseach contra
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HDD Marin
plement pro
with a viewto raise an
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2-D-gementPlan
laid out.
ronmental imMarine Coo
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es graph below
parties ers of the w
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on Site / Vking practicormance.
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4.6.3
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4.6.4
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4.6.5
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4.6.6
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R4.7
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te team mectors. Any e
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briefings wd in the tasviewed.
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ons, conducess for persmental prtanding.
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Reporting
C will comm
Details of aDetails andDetails of aincidents; Any other p
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each month
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marine ope
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ment Plan-
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ssment / Me
will take plask. Environm
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ts (MEY-1A
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heet) (every
eMammalRe
ge 17 of 54
2-D-gementPlan
e meetingsse and reso
etween the g.
nded by alles will be in
are utilised nse procedua test to
n relating topropriate sigcations medmunicate aw
ite:
f any enviro
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d objects de
y 6 Months).
eport) (dail
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l directly nstructed
to raise ures and
confirm
o Health, gnage in dia, such wareness
onmental
nning of
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.
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E
Environmen
4.7.1
The Ma
The EC
T4.8
The puknowled
In ordevessel,
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tal Manage
Daily logs aWeekly proMonthly reenvironmenstatistics, trany of the c
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arine Coord
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o Det
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raining
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ment Plan-
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ommunicati
inator is res
ng, issuing,velopment; ay Responseation and ry Response
onsible for:
n to the licenmonthly to tails of audit
ails and sta
ails of anyvironmental
y other perti
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nsport Audi
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th the licen
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environmencessfully imp
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will include
HDD Marin
when consrts tionally, conitments anvered, envir
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nsing authothe licensingts and inspe
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it Sheets; a
for the naw MHWS.
sing author
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environmenmental traini
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struction act
nfirming thend mitigatioronmental iments)
or:
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tion Procedprotocols fothe NSP).
ority detailedg authority ections;
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onmental iss
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Targmental All
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ge 18 of 54
2-D-gementPlan
e on site / ve
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Environmental Management Plan- HDD Marine Works Page 19 of 54
RHK-1A-40-HSE-002-D-EnvironmentalManagementPlanConstructionWorks
Training Target Persons aspects such as environmental sensitivities and controls, pollution prevention, waste management and emergency preparedness and response). For Marine Mammals, this should include identification, behaviour and sensitive periods for known species and introduction to Scottish Marine Wildlife Watching Code.
Vessel personnel, contractors on Site / Vessel, and visitors).
Environmental Toolbox Talks Toolbox talks will be carried out at a minimum of one per week appropriate to the construction works being carried out on Site / Vessel at that time. All persons carrying out work on site / vessel (site / vessel personnel, contractors on site / vessel) shall attend.
Environmental Bulletins / Legislation Briefings / Best Practice Briefings
All persons carrying out work on Site / Vessel (Site / Vessel personnel, contractors on Site / Vessel) shall attend.
Job specific training e.g. IOSH Working with Environmental
Responsibilities / IOSH Managing Environmental Responsibilities.
Use of Pollution Prevention Equipment. Site Waste Management.
As identified for personnel with environmental responsibilities
Project specific information, including relevant elements of: the EMP, CMS, NSP, VMP Consent Conditions
Briefed out and available for reference to all Site / Vessel staff.
Table 3 Training
Any person working on the Site / Vessel will be competent and trained sufficiently to undertake their work in a safe and efficient manner. Each Contractor will ensure that their personnel maintain the necessary level of competence for their work & will maintain the training records on site & make them available for review and audit. Records of training will be maintained and made available for inspection.
E
Environmen
5 M
K5.1
Chaptegrey se
In Scotwide ra
5.1.1
All speHabitatsas beinconserv
Harbougrey sedirectivedesigna
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5.1.3
Under tof year Scottish
tal Manage
MARINE MA
Key sensitiv
r 11 of the eal and com
tland cetacenge of natio
Habitats Di
cies of cets Directive ng of consvation statu
r porpoise eal Halichoee as specieated.
abitats Reg)) implemen
d and inshoron for SAC
s listed undthe protecti
se is requirons 41(1)(a) and (b) in
amended in
Wildlife and
ildlife and Crvation of ory species d strict protntion. The s protection g protections disturbanc
Marine (Sc
the Marine r except to h Governm
ment Plan-
AMMAL M
vities and a
Environmemon seal a
eans (whaleonal and int
rective
tacean are (European
servation ins.
Phocoena perus grypuses for which
gulations 1nt the specire waters (0
Cs, designatder Annex Ion given to
red if the risa) and (b) in The Offs2009 and 2
d Countrysid
CountrysideMigratory and their h
ection as aNature Coprovided b
s for cetacece as an off
otland) Act
(Scotland) Aalleviate sent. It is a
HDD Marin
MANAGEM
associated
ental Statems the key se
es and dolpternational l
European Union (EUnterest and
phocoena as and harboh a network
994 (as ames protectio
0-12 nauticated for habiI of the HaEPS.
sk of injury in The Conhore Marin2010).
de Act and
e Act (1981Species (Thabitats. Sn endanger
onservation by the Wildlieans from infence.
2010
Act 2010 it uffering or an offence
ne Works
MENT
d legislation
ment, Marinensitivities
phins) andlegislation.
Protected U) Directived protection
and bottlenoour seal Phk of Special
mended inon requiremal miles). Pitats listed uabitats Dire
or disturbanservation oe Conserva
Nature Con
1) ratified tThe Bonn Short-beakered migrato
(Scotland)ife and Countentional d
is an offenwhere a licto harass
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ne Mammalduring cons
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n is to ma
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4 amends ct 1981 to pto encomp
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ge 20 of 54
2-D-gementPlan
s harbour pork.
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er Annex IVthey are crestore fav
runcatus al as Annex
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Environmen
identifieharbourexploita
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5.1.4
Grey smoultin
Harbouand Aug
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M5.2
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Section 3
Marine L
Environm
Stateme
Commitm
s36
ML
tal Manage
ed for protecr seal are ation or rem
osest seal ha
Seal Puppi
eal breeding period for
r seal puppgust.
these perio
Mitigation a
y commitmemammals f
36 (S36),
Licence (ML),
mental
nt (ES)
ment
ment Plan-
ction underalso listed
moval from th
aul-out sites
ng and Mou
ng season r January –
ping season
ods seals ar
and manage
ents and cofrom the Me
or
Condi
The m(whichother eMinistewrittendetermIn partregarda) Hydmodelb) Colmammc) Distduringfor sead) MigSubjecresultsparty a
3.2.1.7Prior tdetailsauthormarinedisturblicensicomm
HDD Marin
r Section 11 on Annexhe wild to b
s are at Gill
ulting Period
is generalMarch for f
n is generall
re particular
ement com
onditions in eyGen cons
ition, or comm
monitoring set oh must be agreecological, or ers), must be n reports of sumined by the Aticular, the follding the monitodro dynamics /ling to validatelision / encoun
mals and fish oturbance and construction als at haul outratory salmonct to any legals must be madappointed at th
7 Monitoring oo the commen
s of the appoinrity. The MMOe mammals anbance being cng authority wencement of t
ne Works
17 of the Max V of the be subject to
ls Bay and t
ds
lly through females and
ly through J
rly sensitive
mmitments
place for msents, licenc
mitment
out in the PEMeed by the Scosuch other adimplemented
uch monitoringAdvisory Groulowing aspectsoring of the fo/ benthic survee EIA predictionter interactioof conservatiodisplacement and operation
ts; and nids l restrictions rede publicly avaheir discretion
of marine mamncement of thentment of a Ma
O must, as a mnd maintain a
caused to mariwith the MMO’the works, and
RHK-1A-4EnvironmWorks
arine (ScotlHabitats D
o managem
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October ad March – M
June and Ju
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MP or, as the cottish Minister
dvisors as requby the Compa
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40-HSE-002mentalManag
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onsidered andcts: able route and
al turbines for
ne mammals lso link to the
reatment of thScottish Minis
censee must al Observer (M
ntain a record action taken t The licenseeater than six mly intervals the
ge 21 of 54
2-D-gementPlan
010. Grey swhich requirres.
Figure 5).
mber followees.
by moultin
r haul-out s
al impacts oed in Table 4
an amended tion with SNHscretion of the
mpany must sut timescales to
d advice provid
d turbine locati
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and basking sspecies prote
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agree in writinMMO) with the
of any sightinto avoid any e must providemonths followereafter.
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seal and res their
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Environmen
Section 3
Marine L
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ES
ES
ES
C5.3
Summareport, CMSCo
Marine propose
5.3.1
As detadamageinto acc2009, fonoise a
tal Manage
36 (S36),
Licence (ML),
mental
nt (ES)
ment
Constructio
aries of thewhile a
onstructionW
mammals ed works:
Noise (vess
Disturbance
Ship strike
Pollution an
Noise (vess
ailed in the e might occcount highlor harbour
are also sig
ment Plan-
or
Condi
The prSpecieon min(for ex
MeyGinjurieunderswill apScotlasignific
All vesprevenSOPEchemioperatinstallasuitabunfavo
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e Constructdetailed
Works).
are conside
sel);
e (vessel pr
and collisio
nd spillage
sel)
ES the socur to eithely conservaporpoises anificantly be
HDD Marin
ition, or comm
rinciples of thees (EPS) fromnimising the risxample, reduci
en commit to s in seals andstanding of thi
pply appropriatand and SNH, cant impacts.
ssels associatntion of oil pol
EPs. All vessecal spill mop uting in similar ation, operatiole conditions tourable weath
ble 4 Marine
ion WorksConstruc
ered to be
resence and
on with duct
urce levelser cetaceanative criteriaand those pelow those
ne Works
mitment
e JNCC guidam injury and dis
sk of injury to ing the duratio
undertaking frd ducted propeis topic with rete mitigation, ashould vesse
ted with Projeclution and any
els associated up kits. Whereconditions wil
on, routine mato reduce the
her conditions.
e Mammal
and prograction Meth
potentially
d movemen
ted propelle
s for vessel s or pinnipa (being 19put forward that might
RHK-1A-4EnvironmWorks
ance on protecsturbance (JNmarine mamm
on of noise em
requent reviewellers and to reelevant regulaas deemed nels with ducted
ct operations wy vessels overwith Project o
e possible vesl be employed
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ents
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2-D-gementPlan
e European Prnd of relevant gdopted as neces).
ature regardingss advances isory bodies. Monsultation withe used, to avoi
th IMO/MCA chave on board carry on boarroven track revities associatoning will occng from the in
n Section 2EY-1A-40-H
wing aspect
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on
Environmental Management Plan- HDD Marine Works Page 23 of 54
RHK-1A-40-HSE-002-D-EnvironmentalManagementPlanConstructionWorks
cetaceans or pinnipeds.
Because of the low levels of noise generated, mitigation measures (such as a Marine Mammal Mitigation Protocol), including the use of a dedicated Marine Mammal Observer or Passive Acoustic Monitoring to prevent injury to marine mammals through the establishment of an exclusion zone, are not appropriate and should not be required as part of this EMP.
However, a number of measures are proposed to both encourage best practice and minimise any limited (although small) potential for disturbance. These measures include:
The spatial separation of at least 300m of the Construction Works (HDD exit) from MLWS of the nearest known sensitive areas for seals, the designated haul out site at Gills Bay (Figure 5), and see CMS;
During the cable laying works, when working at the HDD exit site (the closest point to the designated haul out site) the multi-cat will use an anchor spread to maintain the position on site, minimises propulsion use and vessel movement on site.
The CLV will hold station at least 50m away from the HDD exit when paying out the TSC to the HDD bore.
The TSS/TTG positions are 300m from any designated haul out sites; all DP Vessel operations will take place in the vicinity of these locations.
The proposed vessel transit routes from all ports to site ensure that the vessels keep an adequate separation distance from any sensitive seal haul-out sites wherever possible, see VMP;
Training of all on site / on vessel personnel regarding the importance and sensitivity of marine mammals and their legislative protection;
Provision of advice to staff detailing the types of activity potentially disturbing, and therefore to be avoided; and
Maintenance of a daily marine mammal log (APPENDIX B) by the Principal Contractor, into which any interaction will be noted. It is important to make clear that such a log is likely to record many approaches by marine mammals to the vessels and personnel undertaking all Construction Works. Marine mammals are intelligent and naturally curious about any in water construction works, regularly approaching vessels engaged in Construction Works.
Although some of the Construction Works will be carried out during sensitive periods for seals and also during periods where there will be greater abundance of cetaceans, it is considered that there is limited potential for disturbance offence from the construction works proposed. This is primarily due to the low levels of noise generated (gravity foundations – no drilling) and the short periods required on site for the Construction Works.
For this reasons no requirement for a licence to disturb European Protected Species (in this case cetaceans) is anticipated.
5.3.2 Physical Disturbance
The presence of any vessel in the area has the potential to cause some degree of disturbance to both cetaceans and pinnipeds; however, the key receptor in terms of numbers
Environmental Management Plan- HDD Marine Works Page 24 of 54
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and proximity of sites of interest will be seals. This is considered in detail below.
The proposed Construction Works have a number of characteristics that reduce their potential to disturb all marine mammals significantly. In particular these are:
The spatial separation of at least 300m of the Construction Works (HDD exit) from MLWS of the nearest known sensitive areas for seals, the designated haul out site at Gills Bay (Figure 5), see CMS;
During the cable laying works, when working at the HDD exit site (the closest point to the designated haul out site) the multi-cat will use an anchor spread to maintain the position on site, minimises propulsion use and vessel movement on site.
The CLV will hold station at least 50m away from the HDD exit when paying out the TSC to the HDD bore.
The TSS/TTG positions are, at closest 300m from any designated haul out sites; and all DP Vessel operations will take place in the vicinity of these locations. When waiting for slack tide windows vessels will wait in areas where at least a 500m separation distance can be maintained from any sensitive seal haul-out sites.
The proposed vessel transit routes from all ports to site ensure that the vessels keep an adequate separation distance from any sensitive seal haul-out sites wherever possible, see VMP;
The short duration of the use of vessels during Construction Works. Work is anticipated to be as follows:
- TSC installation will be limited to a neap tide window, with the CLV requiring approximately 6 hours for each TSC installation (HDD pull and TSC seabed lay) running continuously through tides once the operation has commenced;
- TSS installation will be limited to a neap tide window, with each lift requiring a slack tide. Each lift will take an estimated 1-2 hours with a minimum total time of 2 days to complete a TSS installation.
- TTG installation will be limited to one neap tide per TTG installation (4 neap tides in total). The ARL TTG installation and connection will take three slack tide to install. Each AHH TTG will take one slack tide to deploy and a 12 hour period on station to make the TSC connection.
The majority of operations are limited to periods around slack water, with vessels moving off DP to sheltered areas outside of operations. These areas will ensure a minimum 500m distance from the nearest seal haul-out;
Training of all on site / on vessel personnel regarding the importance and sensitivity of marine mammals and their legislative protection;
Provision of advice to staff detailing the types of activity potentially disturbing, and therefore to be avoided; and
Maintenance of a daily marine mammal log (APPENDIX B) by the Principal Contractor, into which any interaction will be noted. It is important to make clear that such a log is likely to record many approaches by marine mammals to the vessels and personnel undertaking Construction Works. Marine mammals are intelligent and
Environmental Management Plan- HDD Marine Works Page 25 of 54
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naturally curious about any in water construction works, regularly approaching vessels engaged in marine works.
Figure 5 Location of Construction Works in relation to designated seal haul out sites
5.3.3 Ship strike and collision with ducted propeller
Multicat type vessels (vessel specification can be found in the VMP) do not used ducted propellers and for some activities when on site will use a fixed seabed anchor system, as described in detail in the CMS. This reduced the potential for both ship strike and propeller collision significantly, as vessel movement, and use of propeller position systems are both minimised.
DP Vessels will be used for the main activities for the TSC, TSS and TTG installation, which are likely to use ducted propeller systems to maintain position (typical vessel specification can be found in the VMP).
While both cetaceans and pinniped are potentially exposed to risk of ship strike and propeller strike, there has previously been significant concern regarding the risk of corkscrew injuries to seals, initially attributed to some ducted propeller system such as a Kort nozzle or some
Environmental Management Plan- HDD Marine Works Page 26 of 54
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types of Azimuth thrusters, commonly used by DP vessels. The proximity of the proposed Construction Works to areas of importance for seals (protected haul out sites at Gills Bay and Stroma), and the numbers of individuals present meant that this was previously a key environmental concern.
Since the submission of the ES there has been ongoing research into the issue of spiral injuries in seals which has confirmed that the characteristic wounds can be caused by a seal being drawn through ducted propeller system such as a Kort nozzle or some types of Azimuth thrusters (Thompson et al., 2010, Bexton et al., 2012; Onoufriou & Thompson, 2014). To date the observed seal strandings appear to be restricted to juvenile grey seal and female harbour seal with seasonal differences evident between the species: grey seal newly weaned pups in the winter and common seal adults or pregnant females in the summer (Brownlow, 2013).
In experimental studies (Onoufriou & Thompson, 2014) it has been shown that using a combination of propeller and seal sizes, smaller seals were more likely to show the characteristic spiral lacerations; while larger seal models often became stuck in the ducted propeller system. The results of these trials and observed stranded seals suggested, at that time, that there were still a number of uncertainties as to the frequency of occurrence, and mechanisms for this type of injury.
However, bases on the most recent known research (Thompson et al., 2015; van Neer et al., 2015) there is now very strong evidence that predatory behaviour by grey seals, rather than ducted propeller injuries, is likely to be the main cause of spiral seal deaths. Although this evidence does not completely eliminate ship propellers, it is now considered to be unlikely that they are a key factor. The SNCBs have now provided interim advice (JNCC, 2015) on this issue, an update to the earlier (April 2012) advice, in order to clarify the agreed recommendations to regulators and industry.
This most recent advice suggests that, based on incontrovertible evidence, grey seal predation on weaned grey seal pups and young harbour seal can cause the characteristic spiral injuries that were the subject of preceding studies. The advice states that
‘it is considered very likely that the use of vessels with ducted propellers may not pose any increased risk to seals over and above normal shipping activities and therefore mitigation measures and monitoring may not be necessary in this regard, although all possible care should be taken in the vicinity of major seal breeding and haul-out sites to avoid collisions’.
This new advice provides a new perspective on the preceding Statutory Nature Conservation Agency (SNCA) Guidance (2012) on the potential risk of seal corkscrew injuries, which at that time suggested levels of risk and recommendations for mitigation.
The Development is more than 60km from the nearest grey seal Special Area of Conservation (SAC, Faray and Holm of Faray), and harbour seal SAC (Sanday). The presence of the Gills Bay and Stroma haul out sites relatively close to the development site, does suggest a need for careful management of works at the site, but no direct mitigation measures are advised (SNCA, 2012).
In the light of the new, compelling scientific evidence and the revise SNCB advice, the risk of
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Section 36 (S36),
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ES Consideration will be given to CIRIA guidance on the use of concrete in maritime
engineering – a good practice guide.
ES Operations will only take place during suitable weather windows.
ES A fibre optic cable will be used to monitor the level of cement, when the cement
reaches seabed level pumping of cement will cease immediately.
ES During cementing operations the cement will be separated from the open sea
conductor casing which is only removed once the cement has reached sufficient
strength to withstand current forces.
ES In the event of any unplanned discharges to sea during HDD activities the drilling
contractor would activate its emergency response plan to ensure discharges were
minimised.
ES Only recognised marine standard fluids and substances will be used in the turbine
hydraulic systems.
ES Hydraulic fluids will be mostly water based, biodegradable and be of low aquatic
toxicity.
ES Turbine sensors will detect loss of fluid pressure and leaks enabling maintenance
operatives to reduce the risk of further leaks.
S36 Condition 9 “The Company must, prior to the Commencement of the Development, submit a
CMS…Pollution prevention measures including contingency plans”
ML Condition 3.1.4 If by any reason of force majeure any substance or object is deposited other than at
the site which is described in this licence, then the licensee must notify the licensing
authority of the full details of the circumstances of the deposit within 48 hours of the
incident occurring (failing which as soon as reasonably practicable after that period of
48 hours has elapsed). Force majeure may be deemed to apply when, due to stress
of weather or any other cause, the master of a vessel, vehicle or marine structure
determines that it is necessary to deposit the substance or object other than at the
specified site because the safety of human life or, as the case may be, the vessel,
vehicle or marine structure is threatened. Under Annex II, Article 7 of the Convention
for the Protection of the Marine Environment of the North-east Atlantic, the licensing
authority is obliged to immediately report force majeure incidents to the Convention
Commission.
ML Condition 3.1.8 All chemicals utilised in the drilling operations for the works must be selected from the
List of Notified Chemicals assessed for use by the offshore oil and gas industry under
the Offshore Chemicals Regulations 2002 (this list can be viewed/downloaded at
www.cefas.co.uk). In the event that any system other that a water-based mud is
considered by the licensee for use in the drilling operation then the prior written
approval of the licensing authority must be obtained before such use. The licensee
must comply with the terms of the guidance as to the disposal of any material arising
Environmental Management Plan- HDD Marine Works Page 30 of 54
RHK-1A-40-HSE-002-D-EnvironmentalManagementPlanConstructionWorks
Section 36 (S36),
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from that operation which will be given to the licensee by the licensing authority.
The licensee must ensure that any chemical agents placed within the void of any of
the turbine bases including biocides and corrosion inhibitors etc. are selected from
the List of Notified Chemicals. The use of any chemical not contained within this list
will require prior consent from the licensing authority.
ML Condition 3.1.9 The licensee must ensure that all reasonable, appropriate and practicable steps are
taken at all times to minimise damage to the Scottish marine area caused by the
licensed activity authorised under this licence.
The licensee must ensure that any debris or waste materials placed below the
MHWS during the construction and operation of the works are removed from the site,
as soon as is reasonably practicable, for disposal at a location above the MHWS
approved by the Scottish Environment Protection Agency.
The licensee must ensure that all substances and objects deposited during the
execution of the works are inert and do not contain toxic elements which may be
harmful to the marine environment, the living resources which it supports or human
health.
The licensee must ensure that the risk of transferring invasive non-native species to
and from the site is kept to a minimum by ensuring appropriate bio-fouling
management practices are implemented during the works.
Any drill cuttings associated with the use of water-based drilling muds situated within
the outer boundary of the works need not be removed from the seabed
ML Condition 3.2.1.3 The licensee must, no later than three months prior to the commencement of the
works, submit in writing to the licensing authority for their written approval, a Marine
Pollution Contingency Plan (MPCP).
The MPCP must make provision in respect of spills and collision incidents occurring
during the construction and operation of the works and where such spills or collisions
occur then the MPCP must be adhered to in full. The MPCP must take into account
existing plans for all operations, including offshore installations that may have an
influence on the MPCP. Practices used to refuel vessels at sea must conform to
industry standards and to relevant legislation. The MPCP must set out how any oil
leaks within the turbine nacelle are to be remedied and that such relevant repairs are
required to be undertaken without undue delay.
Commencement of the works must not occur until the licensing authority has given its
written approval to the MPCP.
ML Condition 3.2.2.1 The licensee must, on the first working day of the month, create, maintain and submit
to the licensing authority a detailed transportation audit sheet for each month during
which construction associated with the works takes place. The audit sheet must
include information on the loading facility, vessels, equipment, shipment routes,
schedules and all materials listed in the licence to be deposited (e.g. piles, pipelines,
turbine components, chemicals). Where, following the submission of an audit sheet
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Oil and chemical spills
Objects lost overboard
Oil and chemical spill
In the event of a spillage sighting originating from a vessel the following actions must be taken:
All spillage sightings must be reported to the Vessel Master immediately;
The Vessel Master must notify the Marine Rescue Coordination Centre (MRCC) identifying the location and giving an initial indication of the size of the spill (based on the 3 Tier system –see below), source of the spillage if identifiable, and other information as applicable to complete a Pollution Incident Report Form;
MRCC will direct the onsite support vessel to the location;
The onsite support vessel will confirm the spillage assessment based on the 3 Tier system and notify MRCC;
The onsite support vessel will commence clean up/containment operations as applicable;
MRCC will be responsible for completing the initial Pollution Incident Report Form which will be used to notify MCA, UKHO and other relevant authorities. Subsequent reports will be submitted on a daily basis until the spillage incident is cleared.
The responsibility for elevating and incident classification from Tier 1 to Tier 2 lies with the MRCC;
The three tier system (small, medium and major) is used to attribute a proportionate response to spill incidents.
Should a small scale spill occur (<1,000 litres) local, in house resources will be deployed in the clean-up.
For a medium sized spill (1,000-150,000 litres) external assistance and resources may be utilised.
For major spills (>150,000 litres) national level assistance and resources would be required in line with the National Contingency Plan, however, it should be noted that the scale of the works proposed for this project make a major spill unlikely.
The potential for spills is most likely to stem from construction vessels which are covered by the MARPOL Convention 1978, as is pollution stemming from the unintentional loss of objects overboard. Each vessel will have its own Ship Oil Pollution Emergency Plan (SOPEP) approved by the MCA and refuelling at sea will be minimised and performed according to industry standards (there is no refuelling anticipated as part of the Construction Works).
Objects Lost Overboard
Should an unintentional loss of objects overboard from vessels occur, the GPS position of the objects lost will be logged.
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Implementing a TEZ where the location of the discovery is known;
Ensuring observation of the TEZ by all staff and contractors;
Compiling Preliminary Record sheets for discoveries;
Reporting discoveries to the Nominated Contact as soon as possible and
Arranging for any archaeological finds to be carefully contained and protected.
All project staff will be responsible for:
Safeguarding finds:
Handling with care;
Leaving marine growth, rust, sediment or concretion intact; and
Undertaking appropriate first aid measures, such as immersing waterlogged finds in seawater in a clean, covered container.
Undertaking initial recording:
Recording the positon of the discovery;
Photographing finds in the condition in which they were recovered; and
Labelling finds with a unique ID number as advised by the Implementation Service.
Reporting discoveries immediately to the Site Champion (via their supervisor if appropriate).
The current provider of the Implementation Service is:
Wessex Archaeology Ltd:
Portway House. Old Sarum Park, Salisbury, Wiltshire, SP4 6EB.
01722 326 867
MeyGen retains ultimate responsibility for the implementation of ORPAD and will ensure that all project staff, the Site Champion and the ECoW are aware of their roles and responsibilities under the terms of the Protocol. Project staff will be made available briefed on the protocol in the site induction and tool-box talks.
On reporting features of high archaeological importance, MeyGen will agree mitigation strategies with Marine Scotland.
9 WASTE MANAGEMENT
James Fisher Marine Services Waste Management Plan can be found in Appendix C.
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10 LINKAGES WITH OTHER CONDITIONS
The EMP is part of suite of consent related documents. Table 9 lists the documents and related conditions are relevant to the EMP. The Section 36 and Marine Licence can be found in Appendix D.
Con Condition summary Document Responsible for Notification
S36 9 - Construction Method Statement
S36 10 ECoW N/A
S36 11 - Environmental Management Plan
S36 12 - Project Environmental Monitoring Programme
S36 13 - Advisory Group
S36 14 - Vessel Management Plan
S36 15 - Operations and Maintenance Plan
S36 16 Reporting Protocol for the Discovery of Marine Archaeology
Environmental Management Plan
S36 17 - Navigation Safety Plan
ML 3.1.3 Notification of Vessels Construction Method Statement / Vessel Management Plan
ECoW
ML 3.2.1.3
Marine Pollution Contingency Plan
Environmental Management Plan
ML 3.2.1.4
Notification of Commencement Construction Method Statement ECoW
ML 3.2.1.5
ECoW N/A
ML
3.2.1.6
Promulgation of navigation warnings
Navigation Safety Plan
ML 3.2.1.7
Marine Mammal Observer Environmental Management Plan
ML 3.2.1.8
Cable Installation Plan Construction Method Statement
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ML 3.2.1.9
Cable Protection Plan Construction Method Statement
ML 3.2.2.1
Transport Audit Sheets Construction Method Statement ECoW
ML 3.2.2.2
Notification of Deposits Construction Method Statement ECoW
Table 9 Linkages with other conditions
11 EMP REVIEW AND CONSULTATION
Under Condition 11 of the Section 36 the EMP will be reviewed and commented on by the licensing authority, SNH, and other such advisors that may be required at the discretion of the Scottish Ministers. The EMP must be approved by the licensing authority.
The EMP will be submitted to the licensing authority for distribution to the stakeholders and for approval.
Any changes the EMP deemed necessary (working methods or procedures) must be reviewed and approved by the ECoW, before it is submitted for approval to the licensing authority (Figure 6).
Version control will be conducted by the revision review block on the front page of the EMP.
Figure 6 EMP Change Process
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12 REFERENCES
Bexton, S., Thompson, D., Brownlow, A., Barley, J., Milne, R. and Bidewell, C. (2012). Unusual mortality of pinnipeds in the United Kingdom associated with helical (corkscrew) injuries of anthropogenic origin. Aquatic Mammals 38:229-240.
Brownlow, A. (2013). Spiralling trauma? Describing a novel form of pinniped mortality in the United Kingdom. Presentation at the 27th Conference of the European Cetacean Society. Setubal Portugal April 2013.
Historic Scotland. 2012. Marine Heritage Strategy 2012-15
iX Survey (2009). Report of Survey for Atlantis Resources (METOC) for Site Survey JN3475. 16 October 2009. JN3475_Report/16/10/09_Rev_1.
JNCC. 2015. Interim advice on risk of seal corkscrew injuries. Staff briefing note.
Lucke, K., Siebert, U., Lepper, P. A. & Blanchet, M-A (2009). Temporary shift in masked hearing thresholds in a harbour porpoise (Phocoena phocoena) after exposure to seismic airgun stimuli. Journal of the Acoustical Society of America. 125(6), 4060-4070.
National Planning Framework for Scotland 2 (2009)
Onoufriou, J. & Thompson, D. 2014. Testing the hypothetical link between shipping and unexplained seal deaths: Final report. Marine Scotland Marine Mammal Scientific Support Research Programme MMSS/001/11, Task USD2.
Scottish Planning Policy 2010
Statutory Nature Conservation Agencies (2012). Guidance for staff advising on the potential risk of seal corkscrew injuries April 2012.
The Crown Estate (2014). Protocol for Archaeological Discoveries: Offshore Renewables Projects. Published by Wessex Archaeology, Salisbury, on behalf of The Crown Estate.
The Marine (Scotland) Act 2010
Thompson et al., 2015. Preliminary report on predation by adult grey seals on grey seal pups as a possible explanation for corkscrew injury patterns seen in the unexplained seal deaths. Sea mammal research unit report to the Scottish Government 12/01/15 0.1. Marine mammal scientific support research programme MMS/001/11. Project report USD 1&6 supplement.
Thompson, D., Bexton, S., Brownlow, A., Wood, D., Patterson, T., Pye, K., Lonergan, M and Milne, R. (2010). Report on recent seal mortalities in UK waters caused by extensive lacerations. Sea Mammal Research Unit report. Available online - http://www.smru.st-and.ac.uk/documents/366.pdf [Accessed 05/08/2013]
US NMFS (1995). Small takes of marine mammals incidental to specified activities; offshore seismic activities in southern California. Federal Register. 60(200), 53753-53760.
Van Neer et al., 2015. Grey seal (Halichoerus grypus) predation on harbour seals (Phoca vitulina) on the island of Helgoland, Germany. Journal of Sea Research, 97; 1-4.
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13 LIST OF ABBREVIATIONS
Abbreviation
CDM Construction (Design and Management) Regulations 2007
CLV Cable Laying Vessel
CMS Construction Method Statement
COSHH Control of Substance Hazardous to Health
DP Dynamic Positioning
ECoW Ecological Clerk of Works
EIA Environmental Impact Assessment
EMP Environmental Management Plan
ERCoP Emergency Response Co-operation Plan
ERP Emergency Response Procedures
EPS Europena Protected Species
ES Environmental Statement
HDD Horizontal Directional Drilling
HSE Health, Safety and Environment
IOSH Institute of Occupational Safety and Health
JNCC Joint Nature Conservation Committee
NSP Navigation Safety Plan
MCA Maritime and Coastguard Agency
MHWS Mean High Water Springs
ML Marine Licence under the Marine (Sotland) Act 2010
MLWS Mean Low Water Springs
MMO Marine Mammal Observer
PC Principal Contractor – James Fisher Marine Services
PEMP Project Environmental Monitoring Programme
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RAMS Risk Assessments and Method Statements
SAC Special Area of Conservation
SCIMS Seal Corkscrew Injury Monitoring Scheme
SEIS Supplementary Environmental Information Statement
SEPA Scottish Environment Protection Agency
SHESQ Safety, Health, Environment, Security and Quality
SNCA Statutory Nature Conservation Agency
SNH Scottish Natural Heritage
SPA Special Protected Area
S36 Section 36 of the Electricity Act 1989
TSC Turbine Submarine Cable
TSS Turbine Support Structure
TTG Tidal Turbine Generator
VMP Vessel Management Plan
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APPENDIX A: JAMES FISHER MARINE SERVICES ISO14001
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APPENDIX B: MARINE MAMMAL REPORTING LOG
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APPENDIX C: WASTE MANAGEMENT PLAN (FSH-1A-40-HSE-004-D-WASTEMANAGEMENTPLAN-MEYGEN.PDF)
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APPENDIX D: SECTION 36 AND MARINE LICENCE
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