Penguins Redevelopment

PENGUINS FIELD REDEVELOPMENT PROJECT
Environmental Statement
May 2016
STANDARD INFORMATION SHEET
Project Name: Penguins Field Redevelopment Project
Project Reference Number: PRD-PT-GEN-00-D-HE-0702-00007
DECC Reference Number: D/4184/2015
Type of Project: Field Redevelopment
Undertaker name: Shell U.K. Limited
Undertaker address: 1 Altens Farm Road, Nigg, Aberdeen, AB12 3FY

UKCS Block Shell U.K. Limited Esso Exploration and
Licensees/Owners: Production U.K Limited
211/13a and
211/14 REST 50% 50%
211/29F1 50% 50%
Short description: The Penguins fields were brought onstream in 2003 as a

subsea development via a tie-back to the Brent Charlie
Platform. Cessation of production at Brent Charlie is anticipated
to occur in the next few years; therefore an opportunity exists to
extend Penguins Field life through a tie-back to an alternative
host.
The Project comprises the drilling and completion of new wells

which will be produced via a new cylindrical Floating
Production Storage and Offloading (FPSO) facility. The existing
development will be produced via this new FPSO.
Produced oil will be exported via shuttle tanker and produced

gas will be exported via the Far North Liquids and Associated
Gas System (FLAGS) pipeline to the St. Fergus Gas Terminal.
Anticipated commencement of works: Circa 2020
Date and reference number of any

DTI Project reference No: D/1199/2001
earlier Statement related to this project:
Significant environmental impacts No significant impacts identified after the implementation of

identified: appropriate mitigation measures.
Environmental Resources Management Ltd (ERM) and Shell U.K.

Statement prepared by:
Limited
THIS PAGE IS INTENTIONALLY LEFT BLANK
PENGUINS REDEVELOPMENT PROJECT
TABLE OF CONTENTS
TABLE OF CONTENTS
NON-TECHNICAL SUMMARY ............................................................................................................... i

1. INTRODUCTION ...................................................................................................................... 1-1
1.1. Field History and Project Purpose ............................................................................................. 1-1
1.2. Environmental Impact Assessment ............................................................................................ 1-2
1.3. Structure of Report .................................................................................................................. 1-4
2. MANAGEMENT SYSTEM AND REGULATORY CONTROL ............................................................ 2-1
2.1. Introduction ........................................................................................................................... 2-1
2.2. Shell UK Management System ................................................................................................. 2-1
2.3. Contractor Management ......................................................................................................... 2-5
2.4. Penguins HSSE-SP Plan and Environmental Commitments .......................................................... 2-6
2.5. Environmentally Critical Elements............................................................................................. 2-7
2.6. Regulatory Control ................................................................................................................. 2-7
2.7. Consultation Process ............................................................................................................... 2-8
3. PROJECT DESCRIPTION............................................................................................................ 3-1
3.1. Project Overview .................................................................................................................... 3-1
3.2. Project Alternatives ................................................................................................................. 3-8
3.3. Offshore Facilities and Equipment.......................................................................................... 3-11
3.4. Main Project Activities .......................................................................................................... 3-30
3.5 Project Uncertainties and Asumptions .................................................................................... 3-38
4. ENVIRONMENTAL BASELINE .................................................................................................... 4-1
4.1. Overview ............................................................................................................................... 4-1
4.2. Physical Environment .............................................................................................................. 4-3
4.3. Biological Environment ......................................................................................................... 4-12
4.4. Designated Sites and Protected Habitats ................................................................................. 4-24
4.5. Human Environment/socio-economic ..................................................................................... 4-28
5. EIA APPROACH ....................................................................................................................... 5-1
5.1. Introduction ........................................................................................................................... 5-1
5.2. EIA Screening and Scoping ..................................................................................................... 5-1
5.3. Stakeholder Consultation ........................................................................................................ 5-1
5.4. Environmental and Social Aspects Identification (ENVID) ........................................................... 5-2
5.5. Impact Assessment Methodology ............................................................................................. 5-2
5.6. Assessment of the Environmental Risk from Accidental Hydrocarbon Releases ............................. 5-9
TABLE OF CONTENTS
6. PHYSICAL PRESENCE ............................................................................................................... 6-1

6.1. Introduction and Key Activities ................................................................................................ 6-1
6.2. Summary of Resources and Receptors ...................................................................................... 6-2
6.3. Description of Impacts............................................................................................................. 6-3
6.4. Mitigation .............................................................................................................................. 6-7
6.5. Residual Effects ...................................................................................................................... 6-7
6.6. Cumulative and Transboundary Effects ..................................................................................... 6-7
7. DISCHARGES TO SEA .............................................................................................................. 7-1
7.1. Introduction and Key Activities ................................................................................................ 7-1
7.3. Description of Impacts............................................................................................................. 7-2
7.4. Mitigation .............................................................................................................................. 7-6
7.5. Residual Effects ...................................................................................................................... 7-7
7.6. Cumulative and Transboundary Effects ..................................................................................... 7-7
8. ATMOSPHERIC EMISSIONS ...................................................................................................... 8-1
8.1. Introduction ........................................................................................................................... 8-1
8.3. Description of impacts ............................................................................................................ 8-1
8.4. Mitigation Measures ............................................................................................................. 8-17
8.5. Residual Effects .................................................................................................................... 8-17
8.6. Cumulative and Transboundary Effects ................................................................................... 8-18
9. UNDERWATER NOISE.............................................................................................................. 9-1
9.1. Introduction ........................................................................................................................... 9-1
9.2. Basis of the Assessment ........................................................................................................... 9-1
9.3. Key Project Activities ............................................................................................................... 9-2
9.4. Receptors to Underwater Noise ............................................................................................... 9-3
9.5. Underwater Noise Modelling Results ........................................................................................ 9-7
9.6. Description of Impacts........................................................................................................... 9-13
9.7. Mitigation ............................................................................................................................ 9-18
9.8. Residual Effects .................................................................................................................... 9-18
9.9. Cumulative and Transboundary Effects ................................................................................... 9-23
TABLE OF CONTENTS
10. WASTE MANAGEMENT ......................................................................................................... 10-1

10.1. Introduction ......................................................................................................................... 10-1
10.2. Regulatory Control ............................................................................................................... 10-1
10.3. Waste Management Policy .................................................................................................... 10-2
10.4. Waste Generation ................................................................................................................ 10-3
10.5. Waste Management ............................................................................................................. 10-6
11. ACCIDENTAL HYDROCARBON RELEASES ............................................................................... 11-1
11.1. Introduction ......................................................................................................................... 11-1
11.2. Scenario Identification .......................................................................................................... 11-1
11.3. Likelihood ............................................................................................................................ 11-2
11.4. Consequence ....................................................................................................................... 11-2
11.5. Mitigation Measures ........................................................................................................... 11-20
11.6. Environmental Risk ............................................................................................................. 11-21
11.7. Conclusions ....................................................................................................................... 11-25
12. CONCLUSIONS ..................................................................................................................... 12-1
12.1. Introduction ......................................................................................................................... 12-1
12.2. Environmental Effects ............................................................................................................ 12-1
12.3. Commitments Register ........................................................................................................... 12-2
ACRONYMS
REFERENCES
APPENDIX A – SUMMARY OF ENVIRONMENTAL LEGISLATION

APPENDIX B – HABITAT ASSESSMENT DESK TOP STUDY
APPENDIX C – AIR QUALITY IMPACT ASSESSMENT
APPENDIX D – UNDERWATER NOISE MODELLING REPORT
APPENDIX E – OIL SPILL MODELLING REPORT
NON-TECHNICAL SUMMARY
1. NON-TECHNICAL SUMMARY
1.1. INTRODUCTION
Shell U.K. Limited (Shell) is proposing to redevelop
the Penguins fields. The Penguins cluster of fields is
located in the UK Northern North Sea within UK
Continental Shelf Blocks 211/13a (Penguins West)
and 211/14 REST (Penguins East). The field is
operated by Shell U.K. Limited on behalf of its
License partner -Esso Exploration and Production
UK Limited -under the License P.296 (Shell 50% :
Esso 50%).
The fields are located in around 160 to 170 m
water depth in the Northern North Sea, around
150 km from the Shetland Islands and adjacent to
the UK/Norway border (Figure 1). The Penguins
fields, a cluster of oil and gas condensate
accumulations, were discovered in 1974 and were
brought onstream in 2003 as a subsea
development via a tie-back to Brent Charlie
Platform. The existing development consists of nine
producing wells, four production manifolds or Drill
Centres (DC2 to DC5), a multiphase production
flowline, a gas lift line and an integrated umbilical
for control, power and chemicals. Cessation of
production (CoP) at Brent Charlie Platform is
anticipated to occur in the next few years;
therefore an opportunity exists to extend Penguins
Field life through a tie-back to an alternative host.
The proposed redevelopment aims to extend the
field life of the existing producers and drill
additional wells which will maximize oil and gas
condensate recovery and develop new reservoirs. Figure 1 Location of the Penguins Field
The existing and the new development will be
produced via additional subsea infrastructure to a new Floating, Production, Storage and Offloading
(FPSO) installation.
Prior to the arrival of the FPSO, the Penguins field will be fully disconnected from the Brent Charlie
installation.
This document provides details of the Environmental Impact Assessment (EIA) that has been undertaken
under the requirements set out in the Offshore Petroleum Production and Pipelines (Assessment of
Environmental Effects) (Amendment) Regulations 1999 (as amended 2007 and 2010), hereafter referred to
as the EIA Regulations. The purpose of the Regulations is to require the Secretary of State (SoS) for Energy
and Climate Change to take into consideration environmental information before making decisions on
whether or not to consent certain offshore activities.
This process includes a period of public consultation and a comprehensive review by the regulator, the
Department of Energy and Climate Change (DECC), and its statutory consultees, including Marine Scotland
and the Joint Nature Conservation Committee (JNCC).
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1.2. PROJECT DESCRIPTION
1.2.1. Overview
The development concept for the Penguins Redevelopment Project comprises:
 New Floating, Production, Storage and Offloading (FPSO) facility;
 Seven new production wells (Tranche 1) followed by an additional four new wells (Tranche 2 & 3)
depending on the performance the Tranche 1 wells;
 Four new drill centre manifolds supporting the new development wells (DC6 – DC9). These
production manifolds are installed on the seabed to gather production from several wells before it
is conveyed via flowlines to the FPSO;
 New subsea facilities, including pipelines, installed on the seabed and risers that connect the
flowlines on the seabed via a new riser base manifold (RBM) to the FPSO;
 New 16" pipeline to tie–in the FPSO gas export pipeline directly to the Far North Liquids and
Associated Gas System (FLAGS) bypassing the Brent Charlie platform; with the associated
Penguins Gas Export Pipeline End Manifold (PLEM); and
 New control umbilicals.
In addition, the existing multiphase production flow line will be reconfigured for gas export within the
redevelopment. The existing wells will continue to be produced via a tie-in to the new FPSO. The existing
wells and associated subsea infrastructure will form the Low Pressure (LP) system of the redevelopment and
the new wells and associated subsea facilities will form the High Pressure (HP) system. The proposed and
existing field layout and facilities for the project are shown schematically in Figure 2. The produced oil will
be stored on the FPSO and will be offloaded to a shuttle tanker for export. The produced gas will be routed
via the existing FLAGS pipeline system to St Fergus Gas Terminal.
The majority of the new infrastructure will be located in UKCS blocks 211/13a and 211/14 REST. This is
referred to as the project area. In addition, the new tie-in to Far North Liquids and Associated Gas System
(FLAGS) network will be located near the existing Brent platforms in UKCS block 211/29F1 (this is referred
to as the Brent area) (Figure 3).
1.2.2. Schedule
The current timeline for execution of the project is not determined yet; however it is expected to be circa
2020. A notional project schedule (undated) is provided in Table 1 for the purpose of assessing the
activities defined in this ES. Subsequent activities and dates are shown to provide details of scope and
durations and may be subject to change.
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Table 1 Notional Project Schedule
Year 1 Year 2 Year 3

ACTIVITY
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
FPSO ARRIVAL IN THE NORTH SEA

SUBSEA INFRASTRUCTURE INSTALLATION
Pipeline/Umbilical installation
Manifolds/Spools and mattresses Installation
Rockdump
Mooring Lines Installation
Multiphase pipeline conversion to Gas Export line
Riser and umbilical installation to the FPSO
DRILLING CAMPAIGN
Tranche 1 (7 wells)
FPSO FIRST OIL
Schedule for drilling Tranche 2 and 3 wells will be defined upon completion of Tranche 1.
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Figure 2 Existing and Proposed Field Layout and Facilities for Penguins Re-development
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Figure 3 Project Infrastructure Locations
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1.2.3. Project Alternatives

The Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999,
as amended, require that the alternatives considered by a project are described in the EIA. This section
describes the work carried out to select the design concept and the process that was followed for assessing
design options.
The aim of considering alternatives is to establish whether there are reasonable options which could be
pursued which meet a project’s objectives with less impact on the environment, and if there are, to explain
what other factors determined the choice of proposal.
For the Penguins Redevelopment Project a Concept Select Phase was first undertaken to select a preferred
option for the project. Subsequently alternatives within that option were considered as part of the Front
End Engineering Design (FEED).
1.2.4. Concept Selection

A series of Concept Selection Sessions were completed between 2012 and 2014 to review all development
concepts. In total, 15 concepts were initially identified, including seven fixed platform concepts and eight
floating facility concepts. Following the workshops, ten concepts were deselected as they were considered
to be either technically or economically unattractive. The following five concepts were carried forward for
further consideration:
 Redeployment of an existing FPSO: The option considers the redeployment of the Munin FPSO,
which is leased from a third party. The FPSO was built in 1997 to North Sea specification and is
DNV (Det Norske Veritas) certified.
 New conversion or new build ship-shape FPSO: Shell has an Enterprise Framework Agreement
(EFA) with a number of companies to supply and lease FPSOs. This option considers the
conversion or new-build of a ship-shaped FPSO following the specification of the EFA.
 Production via BP Magnus installation: The option considers a new tie-back from the Penguins
Field to the existing BP Magnus Platform. BP Magnus is a steel jacket platform dating from 1983
and is the closest infrastructure to Penguins, approximately 10 km from DC2 and 21 km from
DC5.
 New cylindrical FPSO (non-ship-shape): This option considers the construction of a new
cylindrical FPSO. There are two similar units in the North Sea and two units being built for
European fields. The concept has been identified as proven technology and suitable for
consideration for Penguins.
 Continue production via existing tie-back to Brent Charlie (BC): Penguins Fields could continue to
produce via Brent Charlie Platform past the anticipated CoP date if extensive modifications were
undertaken.
The new cylindrical FPSO option was selected as the preferred concept, based on there being no technical
showstoppers identified and it being the most suitable within the project timeframe.
1.2.5. Technical Selection

Following concept selection, a selection process was undertaken to inform decisions on specific
technologies within the concept for three particularly issues:
 produced water handling (water found in the underground reservoir) – re-injection or overboard
discharge;
 combustion equipment; and
 flare systems and cargo oil tank inerting.
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The technical selection was informed by additional studies including Best Available Techniques (BAT)
assessments and feasibility studies.
1.3. BASELINE ENVIRONMENT
1.3.1. Introduction
The project is located in an area where there are no key bathymetric features or environmental features of
high sensitivity. The project area does not contain any protected habitats and is not located within any
other areas of special interest.
The baseline assessment considered the following aspects and is summarised below:
 Physical Environment;
 Biological Environment;
 Human Environment/ Socio-economics;
 Designated Sites and Protected Habitats; and
 Coastal Sensitivities.
1.3.2. Physical Environment

The seabed at the project area is relatively flat and gently slopes down from the east-northeast to the west-
southwest. Sediments are characterised as mixed and coarse with sand, gravels and occasional cobbles,
boulders and clay areas.
Mean sea surface temperatures in the project area range from 8.5 °C in winter to 13 °C in summer.
Corresponding mean bottom temperatures for winter and summer are >4 °C and 8 °C, respectively.
Temperature stratification occurs during summer to approximately 40 m depth. There is little seasonal
variation in surface salinity which is approximately 35 %.
The mean monthly significant wave height in the region of the Project is 3.76 m to 4.29 m in the winter
months and 1.5 m to 1.71 m in the summer months. There is a circulation of water in and around the
project area which results in a low speed current of typically 0.2 m/s towards the south.
There are seasonal variations and winds in the area that tend to be variable both in terms of direction and
force, predominantly from a south and south west direction, with easterly winds being less frequent.
1.3.3. Biological Environment

The community of plankton (small or microscopic drifting organisms) in the North Sea is strongly influenced
by inflows of water from the North Atlantic. The phytoplankton community (plant) is dominated by the
genus dinoflagellate and its biomass, which is an indicator of productivity, has increased over several
decades. The zooplankton community (animal) is dominated by copepods. Other major components of
the planktonic community include larvae of echinoderms, molluscs and crustaceans.
The benthic community (bottom living) of the northern North Sea is made up predominantly of cold water
species and has a lower biomass compared to southern areas, particularly of infauna species which live in
seabed sediments, as opposed to epifauna that live on the seabed. The project area supports scare
epifauna communities of echinoderms and cnidarians including sea stars, sea cucumbers and sea urchins.
Several fish species occur within the northern North Sea which are likely to be present in the project area
including whiting, cod, haddock, saithe, Norway pout, herring, sandeel and mackerel. Cod, haddock,
saithe and Norway pout are species which have a high intensity use of the project area for spawning/
reproduction. The project area is located close to or within nursery areas for some fish, namely blue
whiting (high intensity area), ling, mackerel, spurdog and herring.
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Offshore areas in the North Sea support peak numbers of seabirds following the breeding season and
during the winter, while birds are likely to remain closer inshore during breeding seasons in spring and
early summer. The area of the North Sea to the northeast of Scotland is situated within a major migratory
seabird flyway between wintering and breeding grounds. Both Shetland and the closest Norwegian coast
support major seabird colonies, from which birds will forage across the wider area. However, the project
area is sufficiently far from these colonies that only northern gannet and northern fulmar are likely to
forage within project area during the breeding season. The relative importance for seabird conservation of
the project area is low.
There is evidence that protected marine mammals, principally harbour porpoise and minke whale, use the
project area however this is relatively low compared to other areas in the North Sea. Both
harbour/common seals and grey seals may also be present in the area albeit in limited numbers.
1.3.4. Human Environment

The North Sea is a major fishing area. The northern North Sea has particular importance for demersal
fisheries targeting a mix of cod, haddock and whiting throughout the year. The main gear types used are
otter trawls and seine nets. Offshore fisheries in the area target herring, using purse seines and trawls, and
mackerel, using trawlers. The project area is of moderate commercial fishing value.
The project area lies within an area of the North Sea heavily developed for oil and gas extraction.
1.3.5. Designated Sites and Protected Habitats

There are no marine designated sites or protected habitats within the project area, with no known Special
Areas of Conservation (SACs), Marine Protected Areas (MPAs) or Annex I EU Habitats Directive Habitats
within the Blocks 211/13a, 211/14 REST and 211/29 or within 10 km of the project area.
1.3.6. Coastal Sensitivities

The nearest landmasses to the project area are the east coast of the Shetland Islands and the west coast of
Norway. Both coasts have areas of high value for marine species and have national or international level
designations.
1.4. ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
1.4.1. Scope
The EIA covers the project stages as set out in Section 1.2.1. The impact assessment addressed the
following topics:
 Physical presence of the project;
 Emissions to the atmosphere;
 Discharges to the sea;
 Underwater noise;
 Waste management and
 Unplanned hydrocarbon releases.
Elements of the project which have not been considered as part of the EIA process and hence are out with
the scope of this assessment include offsite fabrication of the FPSO and subsea infrastructure, transit of the
FPSO from the construction yard, export shuttle tanker and vessels in transit, existing pipeline infrastructure,
and potential future developments.
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1.4.2. Process
The impact assessment process is illustrated in Figure 4 and has the following four main steps:
1. Identify impacts that will happen as a consequence of project activities;
2. Predict the magnitude of an impact, taking into consideration all the mitigation measures the project
team is committed to that are relevant to that impact; and (where appropriate);
3. Evaluation of the significance of the residual effect taking into consideration the importance and
sensitivity of the affected resource or receptor; and,
4. The residual effects are reported in the ES.
Figure 4 Prediction, Evaluation and Mitigation of Impacts
Mitigation measures Shell intends to implement in order to avoid, reduce, remedy or compensate for
potential negative effects and the actions to be taken to create or enhance positive benefits of the project
are defined in the ES. These mitigation measures include operational controls as well as management
actions.
The significance of the impacts that remain following application of the mitigation measures (also called
residual effects) was then assessed against the matrix in Table 2.
Impacts were assessed as either having an effect or as having no effect. Those that were assessed as
having an effect were classified, in ascending order, as Negligible, Minor, Moderate or Major
Significance. The degree of significance attributed to residual impacts is related to the weight the EIA team
considers should be given to them by the authorities in making decisions on the proposed Project and
developing conditions for approval.
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Table 2 Significance evaluation matrix
IMPORTANCE/SENSITIVITY
LOW MEDIUM HIGH
NO EFFECT No effect No effect No effect
SLIGHT Negligible Negligible Negligible
MAGNITUDE SMALL Negligible Minor Moderate
MEDIUM Minor Moderate Major
LARGE Moderate Major Major
1.4.3. Physical Presence

There is the potential for impacts from the physical presence of the project on seabed sediments, marine
habitats and species and other sea users. The project aspects which have been assessed for their physical
presence include:
 vessels associated with all project phases (drilling, installation and operation) including the FPSO
and associated seabed anchoring; and
 subsea infrastructure including new manifolds and flowlines for the production of fluids, gas export
and gas-lift.
Vessel presence and anchoring is predicted to have a small magnitude impact on the seabed as anchor
damage will be localised and the affected areas are expected to recover quickly. The seabed in the project
area is considered to have low importance and sensitivity and is largely representative of the wider area
with isolated areas of potential contamination towards the Brent area. The seabed supports species of low
to high conservation value in low abundance. The residual effect has been assessed as negligible. Impacts
on the marine habitats and species the seabed supports (which are intrinsically linked to the physical
characteristics of the seabed) are also predicted to be small and have negligible residual effects.
The installation of seabed infrastructure on the seabed is also expected to have a small magnitude impact
on the seabed. Areas underneath installed infrastructure will be permanently lost for the duration of the
project. However, the size of the directly affected area is very small and these will not be unique. The
pipelay in the Brent area has the potential to mobilise contaminated sediments (historical cutting piles) but
these will be avoided by carrying out a survey of the route beforehand. Given the low importance and
sensitivity of the seabed, the residual effect has been assessed as negligible. Impacts on the marine habitats
and species the seabed supports are also predicted to be small and have negligible residual effects.
Vessel exclusion zones and anchoring is predicted to have a small magnitude impact to other sea users due
to the small affected area and the wider availability of space in the marine environment. Other marine
users are considered of medium importance and sensitivity. The area is of moderate importance to the
commercial fishing industry and shipping industry. The Penguins fields have been producing oil and gas
via the Brent Charlie Platform since 2003. The supporting operations and all associated environmental
interactions have not resulted in any significant effects. The redeveloped project is expected to have very
similar or improved environmental performance. The residual effect on other sea users is assessed as
being of minor significance.
The impact magnitude from subsea infrastructure is considered small as it is designed to minimise fishing
gear interaction. The FPSO mooring lines will extend beyond the 500 m safety exclusion zone which is set
around the FPSO. Shell will inform the fishing community of the lines through consultation, by having the
area marked and identified on Admiralty charts, the Kingfisher Information Service and FishSAFE. The
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Emergency Rescue and Recovery Vessel (ERRV) present in the field will be able to warn 3rd party vessels of
FPSO and mooring lines position. Given the medium importance of other marine users in the area, the
residual effect is assessed as being of minor significance. No significant cumulative effects are expected
given the limited impacts of the project and that the area is already well developed by the oil and gas
industry. No transboundary impacts are expected as all vessel activity and installed infrastructure will be in
UK waters.
No significant effects are expected on fish, marine mammals and seabirds, given their transient and mobile
nature, from the physical presence of the project.
1.4.4. Discharges to Sea

There is the potential for discharges to sea from the project to impact on water quality and adversely affect
supported marine habitats and species. The discharges considered in the assessment are as follows:
 Discharges from drilling activity primarily drilling fluids (muds) and cuttings. Drilling muds are
pumped down the well during drilling to maintain positive pressure in the well, cool and lubricate
the drill bit, protect and support the exposed rock, and lift cuttings out the well. Cuttings are the
rock fragments broken off during drilling.
 Discharges associated with installation and commissioning activities. This includes corrosion and
scale inhibitors, oxygen scavengers, biocides and dyes used for inspection, testing and leak
detection.
 Discharges associated with hydrocarbon production operations, primarily produced water.
Formation Water is naturally present in oil and gas reservoirs and it is produced together with the
hydrocarbons as a portion of the produced fluids.
Other potentially significant impacts associated with discharges to sea from the project include ballast
water, waste water and chemical use.
The impact of drilling discharges on water quality is predicted to be of small magnitude given it will be
short term and localised to the point of discharge. Only those drilling muds that are water based will be
discharged at the seabed. The larger components of the mud and cuttings will settle out of the water
column quickly forming accumulations known as cuttings piles. The smaller components will form a
discharge plume which is expected to settle out within 100 metres of the well. Drilling muds that are oil
based will only be used when there is a closed system between the drilling rig and well. The associated Oil
based mud cuttings will be shipped onshore for disposal. The majority of drilling chemicals that will be
discharged are inert in the marine environment. Those that are not will be managed according to UK
regulations and will require a risk assessment and possibly further justification for their use via the chemical
permitting process. The water in the project area is considered of low sensitivity. The residual effect is
assessed as negligible significance.
Drilling discharges are expected to cause localised smothering (burial) of sessile organisms from cuttings
deposition and the finer particles may interfere with the breathing of others. However, no toxic effects are
expected and the impact is considered of small magnitude. Affected communities are expected to take 3-
10 years to recover. The residual effect is assessed as negligible significance.
The impact from installation and commissioning discharges is predicted to be of small magnitude. The
types of chemicals used have a relatively low toxicity or will be used in concentrations such that adverse
effects will be minimised. All discharges are expected to disperse and dilute rapidly in the offshore
environment. Larger volumes such as that of hydrotest will lead to at most temporary, small and localised
effects. The surrounding water is considered of low sensitivity and therefore the residual effect is assessed
as negligible significance.
The impact from produced water is predicted to be of small to medium magnitude. Based on analysis of
the reservoir the project is expected to produce relatively small volumes of produced water (less than 7% of
the production fluids). The reinjection of produced water back into the reservoir is the favoured
management solution in the UK. However, this is not technically feasible for the project so it will be
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discharged to sea following appropriate treatment. The plume that results from a continuous discharge will
likely be detectable within a few tens of metres from the discharge point. This volume will have a very
small amount of entrained hydrocarbons (and other chemicals) but will meet UK regulatory standards. The
surrounding water is considered of low sensitivity, supporting species of low to high importance in low
abundance. The residual effect is assessed as minor significance.
No significant cumulative effects are expected given the limited impacts of the project. The potential for
drilling discharges to contribute to cumulative regional scale contamination in the North Sea is considered
negligible. Other discharges will be undetectable within a few metres of the discharge point due to natural
dispersion and dilution. No transboundary water quality impacts are expected given the project is located
more than 1 km from closest maritime border (UK/Norway).
1.4.5. Atmospheric Emissions

Emissions of carbon dioxide (CO2), oxides of nitrogen (NOx) and sulphur dioxide (SO2) have been
assessed. The main sources of emissions are summarised as follows:
 Power generation during installation and commissioning;
 Drilling rig emissions; and
 Operational power generation and flaring.
Potential worst case emissions scenarios were modelled as part of the EIA process. These scenarios were
normal operations operating on gas, normal operations operating on gas with emergency flaring, and
upset conditions with the turbine generator operating on diesel and emergency flaring.
The total CO2 emissions from combustion sources are calculated to represent 0.17% of the reported 2013
UKCS total CO2 emissions from fixed installations.
Emissions during drilling are associated with the drilling rig using diesel for power generation and are
considered to be of small magnitude, and as having a short term impact that is localised to the point of
discharge. The sensitivity of the local air quality to atmospheric emissions is considered low due to the
absence of existing pollution sources and absence of sensitive receptors in the area. The residual effects
are therefore assessed as negligible significance.
The primary sources of emissions during installation and commissioning phases are associated with power
generation and vessel transportation with estimates for helicopter and vessel usage and tug boats being
included in the assessment. The emissions are considered to be of small magnitude, and as having a short
term impact that is localised to the point of discharge. Given the low sensitivity of local air quality the
residual effect is assessed as negligible significance.
The impact magnitude of emissions during normal operations (production) is considered low. However,
based on worst case upset conditions when diesel (rather than gas) fuel is required for power generation
and flaring is continuous could potentially result in temporary, localised adverse effects. Given the low
sensitivity of local air quality the residual effect is assessed as negligible significance.
Cumulative effects from project emissions are considered negligible. Transboundary impacts are possible
during upset conditions given the distance to the UK/Norwegian border but these are not likely to result in
any significant effects as there are no sensitive receptors present. During normal conditions residual effects
are only expected in the immediate vicinity of emissions sources.
1.4.6. Underwater Noise

Marine fauna including whales, dolphins, seals and fish use sound for navigation, communication, and the
identification and capture of prey. High levels of sound introduced by offshore construction and production
activities can affect the behaviour of marine fauna and cause auditory injury in some cases.
xii
Underwater noise created during the project’s drilling, installation and production activities was modelled.
The FPSO anchors will be secured by piles driven into the seabed by a hammer which generate loud
sounds over a short period.
The modelling predicted that there would be no auditory damage to fish beyond 500 m from piling activity
and a low risk of behavioural effects beyond 1 km. The overall impact magnitude is considered small and
the area of low importance to fish of low sensitivity. The residual effect is assessed as negligible
significance.
The modelled sound pressure does not exceed the threshold for mortality and potential mortal injury for fish
eggs and larvae. However, continued exposure and the planktonic nature of fish eggs means that the
threshold for injury or mortality may be reached over time during periods of piling activities. Individual
eggs have low adaptability and tolerance but high recovery due to the reproductive strategy of fish (i.e.
spawning large quantities of eggs). Moreover, fish spawn over very large areas. Fish are therefore
considered to have a low sensitivity to piling noise. Given that piling will be short term and only injure
within 500 m of the sound source the magnitude is considered small. The residual effect is assessed as
negligible significance.
The residual effect of drilling noise and operational noise from the FPSO is assessed as negligible
significance for fish and fish eggs and larvae.
No auditory injury is expected to marine mammals beyond 500 m and mitigation will be in place to ensure
no marine mammals are within this zone. Therefore the residual effect on marine mammals is assessed as
negligible significance despite their high sensitivity and high importance.
There is uncertainty over the sound levels at which marine mammals are affected by underwater noise. The
lower levels which suggest a lower tolerance to sound are used as precautionary criteria where the high
levels are used as alternative criteria. Using a precautionary approach the modelling predicted that marine
mammals would show a behavioural response to piling noise beyond 60 km. Using an alternative criteria
species of cetacean (whales and dolphins) with hearing in the low frequency range would show a
behavioural response beyond 60 km. Those in the mid frequency range would show a response within 4.5
km from the source, and those in the high frequency range within 44.5 km. All species of cetacean have a
high sensitivity to sound and are of high importance. Residual effects are assessed as minor to moderate
significance, depending on the hearing range of the affected animal. Seals have a medium sensitivity and
high importance and are predicted to show a behavioural response within 30 km. Residual effects on seals
are assessed as negligible significance.
The project will adhere to the JNCC piling noise protocol which is considered best practice. The protocol
includes the use of trained Marine Mammal Observers (MMOs) during piling works, pre-piling searches
within a 500 m mitigation zone, and ‘soft-starts’. Piling will be delayed until no marine mammals are
present within the mitigation zone. Soft-starts will be implemented whereby the hammer will use a slower
blow-rate giving marine mammals the opportunity to move away.
Drilling noise and operational noise from the FPSO is predicted to have minor significant effects to
cetaceans and a negligible effect on seals. Auditory injury is not expected at any distance. The distances
over which behavioural responses are predicted are highly variable depending on whether animals swim
constantly within zones where the most noise is predicted. In these instances behavioural responses may
be observed beyond 60 km. However, up to 1 km for drilling noise and 5 km for FPSO operation is more
likely.
Cumulative effects can arise from broadly two scenarios: when project activities overlap with other noise
generating activities such that sensitive receptors are disturbed or potentially injured over a larger area,
and/or project activities are run back-to-back with other noise generating activities such that receptors are
disturbed or potentially injured over a longer period of time. There are no known plans for other noise
generating activities taking place in the immediate vicinity of the project area (or within 60 km). It is
therefore unlikely that any significant cumulative effects will arise. Given the proximity to the UK/
xiii
Norwegian border behavioural responses to noise from the project will be transboundary. However,
species of marine mammal are highly mobile and travel over large ranges.
1.4.7. Waste
Waste management is included in the ES on the basis that it is a regulatory control aspect of the project
which will require management. It has not been assessed in the EIA process.
Waste will be generated during all phases of the project and Shell is committed to reducing waste
production and managing all produced waste in line with regulations, by applying approved and practical
methods such as the waste hierarchy (reduce, reuse, recycle, recover and dispose) and development of a
Waste Management Plan (WMP). The WMP produces details and quantities for the types of waste
generated and the specific management procedures for each waste stream. Shell’s waste policy commits to
all wastes being disposed of in compliance with legal regulations and Shell Group Policy and Standards,
which includes audits and second party checks.
It is likely that operational waste volumes on the Penguins FPSO would be comparable to that of other
FPSOs operated by Shell in the United Kingdom Continental Shelf. The largest volumes of waste are
expected to be generated during drilling operations.
1.4.8. Accidental Hydrocarbon Release

The risk of an accidental oil spill into the marine environment is inherent in all offshore oil developments.
However, the likelihood of significant oil spills (i.e. those that can reach the shoreline or other sensitive
areas) from the project is very low.
It is a requirement of the EIA Regulations to model and assess the potential impacts which would result from
the worst case scenario from an accidental hydrocarbon release to sea. As oil spills are accidental and
unplanned, they are looked at in terms of their environmental risk rather than through the standard EIA
process where significance is defined. Environmental risk (or oil spill risk) is the combination of the
likelihood of an event occurring multiplied by the consequences of the event should it occur.
The ES identified and modelled the following oil spill scenarios:
 Well blowout.
 Total loss of crude inventory.
The oil spill modelling studies used the Oil Spill Contingency and Response (OSCAR) model which is
industry approved. It is important to note that the modelling scenarios are run with the assumption that no
oil spill response measures (e.g. use of skimmers, booming etc.) were implemented and that no mitigating
actions were taken at the point of spillage (e.g. pumping out of ruptured oil tanks). Therefore the results of
the modelling are ‘worst case’ and in reality response procedures would be initiated.
Table 3 sets out the assessment matrix for the environmental risk from accidental hydrocarbon releases. The
results of the assessment are shown in Table 4. The rating is assigned based on the risk matrix presented
below. The lowest risks are located in the top left hand corner (i.e. very unlikely with a low severity) while
the highest risks are located in the bottom right (i.e. very likely with a much greater severity). Scenarios
which fall within the green zone are considered Acceptable, where remedial action is discretionary and
procedures are put in place to ensure the risk level is maintained; those in the yellow zone are considered
as low as reasonably practicable (ALARP), where remedial action is taken as appropriate and the risk is
tolerable if it can be demonstrated as ALARP. Finally scenarios in the red zone are considered
Unacceptable, where immediate action, further review, consultation and further risk assessment is required.
xiv
Table 3 Environmental Risk matrix
Likelihood of Event
Extremely Remote Unlikely Possible Likely
remote
No effect No Effect
Slight Acceptable
Consequence of Event
Minor
Moderate ALARP
Major
Massive Unacceptable
xv
Table 4 Risk of Accidental Hydrocarbon Spills
SCENARIO LIKELIHOOD CONSEQUENCES OVERALL

RISK
Remote. A blowout is an Massive. Oil from a blowout will affect waters of the UK, Norway, Denmark, Sweden and
Well blowout uncontrolled release of the Faroe Islands; it would take around 6 hours to cross into Norwegian waters. There is a As Low as
3 hydrocarbons from a well after 100% probability that oil will reach the shoreline under all seasonal conditions, and under Reasonably
413,367 m /
pressure control systems have failed. worst case conditions up to 14,264 tonnes of emulsion could reach nearby coastlines. The Practicable
352,003 tonnes
Blowouts are the most severe type of quickest time to shore is 6 days to the Shetland Islands. The extent and severity of a (ALARP)
hydrocarbon release as oil is blowout will be similar under all seasonal conditions. Based on the predicted amount and
continuously released until the well distribution of oil, and vulnerability of receptors in the area, the overall consequence of a
is brought back under control or a blowout is considered massive. This assumes that there will be:
relief well is drilled to divert the flow
 long-term degradation to the quality and availability of habitats and wildlife which is not expected to
so it can be managed. The recover for more than 5 years;
likelihood of a well blowout
 major impacts on conservation interests of internationally and nationally designated protected sites,
occurring is considered remote, habitats and populations;
having previously happened in the
 major transboundary effects; and
industry and occurring every 100 to
10,000 years.  persistent severe environmental and socioeconomic damage that will lead to loss of commercial,
recreational use or loss of natural resources over a wide area of open water and coastline.
Total loss of crude Remote. A total loss of crude Major. Oil from a total loss of inventory would affect the waters of the UK and Norway. ALARP
inventory inventory refers to a situation where There is a 92% to 97% probability that oil would reach the shore depending on the season.
the entire volume of stored Under worst case conditions up to 3,860 tonnes of oil (emulsion) could reach nearby
88,006 m3 / hydrocarbons onboard the FPSO is shores, reaching the Shetland Islands in just over 6 days. Based on the predicted amount
74,935 tonnes lost. The rate of release could and distribution of oil, and vulnerability of receptors in the area, the overall consequence
potentially be greater than that of a of a blowout is considered major. This assumes that there will be:
blowout in the case of a
 widespread degradation to the quality and availability of habitats and wildlife requiring significant
catastrophic loss but the volume is long term restoration effort. Recovery is likely within 2 to 5 years following clean-up;
fixed. The likelihood of an
 moderate to minor impact on conservation interests of internationally and nationally designated
inventory loss is considered remote, protected sites, habitats and populations;
having previously happened in the
 transboundary effect that require a response; and
industry and occurring every 100 to
10,000 years.  coastal and open water impacts on areas of social, economic, recreational and aesthetic value.
xvi
It is important to consider that the oil spill scenarios that have been assessed assume that no intervention
measures will be implemented to stop oil from reaching the UK and Norwegian coastlines. The mitigation
of oil spill incidents is addressed through the implementation of oil spill prevention (controls and barriers)
and oil spill preparedness (response and recovery) measures. The primary mitigation measure for avoiding
the impacts of an oil spill is to prevent any such spill taking place in the first instance. This is achieved
through both technology applications as well as operational controls.
Specific risk management and oil spill preparedness measures for the project will be developed and
incorporated into the project’s Oil Pollution Emergency Plan (OPEP). Shell will implement the OPEP to
respond efficiently to any oil spill event. The response system described in the OPEP is designed on the
tiered approach with the capacity to handle the worst case credible scenario.
1.5. MITIGATION MEASURES, CONTROLS AND SAFEGUARDS

Throughout the assessment, embedded management and design measures aimed at reducing the
magnitude of impacts were incorporated into the assessment. Where significant effects persisted, suitable
mitigation measures, safeguards and controls where identified and additional assessment was undertaken
for all impacts to determine their residual impact (or risk for accidental hydrocarbon releases).
The UK oil and gas industry is heavily regulated and many of the control measures / mitigation which Shell
will implement are standard industry practice. This includes using chemicals pre-registered with the UK
authorities, compliance with discharge limits (e.g. MARPOL), no routine flaring and participation in the EU
Emissions Trading Scheme. Table 5 summarises additional measures which are proposed by the project.
Some of these are inherent in the project design whereas others are considered necessary based on the
outcome of the assessment such as adhering to the JNCC guidance for piling operations.
xvii
Table 5 Control Measures / Mitigation that Shell will implement
ASPECT ACTIVITY POTENTIAL IMPACT CONTROL MEASURE/COMMITMENTS
STANDARD INDUSTRY PRACTICE / LEGISLATIVE PROJECT SPECIFIC

REQUIREMENTS
Atmospheric Well testing Contribution to Climate Well test programme and procedures Use of clean burn heads to maximise combustion;
Emissions change
No planned extended well test (>96 hours).
Acidification
Reduction in air quality
Vessel Contribution to Climate Contractor selection and audit for compliance with MARPOL Annex Shell integrated activity planning
operations change VI requirements
Shuttle tankers will always be dynamically
Reduction in air quality Contractor management audits and performance reviews positioned. Dynamic Positioning thrusters will be
used for keeping the accuracy and control of
position which will have an influence on emissions.
Cooling systems Ozone depletion and Contractor selection to ensure certified contractors
contribution to climate
No use of Halons or HCFCs in accordance with MARPOL and Shell
change HSSE & SP Control Framework
Flaring and Contribution to Climate Flare management strategy The hydrocarbon Vapour recovery unit to recover
venting change gas vented from the Cargo Tanks Blanketing and
Flare metering and allocation philosophy
other smaller sources.
Acidification No routine flaring (continuous gas pilot will be provided)
Nitrogen purge to reduce CO2 Hydrocarbon gas
Reduction in air quality blanketing
Power Contribution to Climate Compliance with EU Emissions Trading Scheme and Pollution Waste heat recovery system
generation change Prevention Control requirements Use of dry low emissions (DLE)burners (including
Acidification Externally verified energy efficiency improvement plan the HP compressor with DLE)
Reduction in air quality Programmed maintenance as per manufacturer’s recommendations
Spare parts philosophy
Atmospheric emissions monitoring and reporting procedure
xviii

REQUIREMENTS
Discharges to Sea Chemical use Reduction in water Use of CEFAS registered chemicals Slimming of wellbore diameters where feasible to
and discharge – quality Monitoring and reporting of use and discharge via EEMS reduce mud and cuttings
all project Toxic impact on species Chemical management procedures Review of chemicals identified for substitution (e.g.
phases and habitats study on replacement of the existing corrosion
Chemical awareness training for personnel
inhibitor)
Seabed disturbance
Drilling – Reduction in water Treatment of oil contaminated reservoir fluids to < 30 mg/l prior to
discharge of quality discharge
reservoir Toxic impact on species Well test programme and procedures
hydrocarbons – and habitats
well testing
Ballasting Introduction of non- Ballast water management procedures in accordance with MARPOL
during transit native species
Produced water Reduction in water Routine sampling and analysis of produced water and slops Drains/slops treatment system is designed to meet
quality discharges oil content < 15 mg/l for discharge overboard
Toxic impacts to biota Compliance with Oil Discharge Permit requirements Produced water treatment system (hydrocyclone
and water column and degasser) designed to meet < 30 mg/l
dispersed oil in water concentration
Provisions within the design to allow for the future
inclusion of injection points for chemical treatment
if required.
Drainage, Reduction in water FPSO and vessels designed to meet MARPOL requirements for
foodwaste and quality drainage and blackwater.
blackwater Toxic impacts to biota
discharges Drains/slops treatment system is designed to meet
and water column DECC UK limit of monthly average 40mg/l oil discharge
oil content < 15 mg/l for discharge overboard
xix

REQUIREMENTS
Noise Drilling Disturbance to fish and Use of JNCC guidelines for piling activities Optimization of number of Drilling Centre
operations marine mammals Manifolds which will reduce scope of piling
Installation operations.
operations
Piling activities
Production
operations
Physical Presence Installation of Loss of access to other Notifications to Mariners circulated Snagfree (not overtrawlable) structures (see Section
new FPSO and sea users Locations of structures provided on admiralty charts/kingfisher 3.3.1.3)
seabed Benthic species and 500 m safety zone surrounding FPSO and Drill Centres
infrastructure habitat disturbance Additional area to be identified and notified to
Consent to locate will be obtained
mariners to cover FPSO mooring line area beyond
Compliance with International Association of Lighthouse Authorities
500m safety zone
requirements
Guard and/or ERRV to cover additional area.
Emergency Response Rescue Vessel (ERRV) / Guard vessel coverage
Disruption of Benthic species and Cuttings piles should not be impacted as subsea
cuttings piles habitat disturbance installation and drilling activities are not in the area
of historic cuttings piles at penguins.
Surface lay of the Brent area pipe section which
minimises disturbance to historic cuttings in this
area.
Unplanned Events Lifting activities Effects on other sea Certification for lifting equipment Dropped Objects Study
(Dropped Objects) users Lifting Procedures Pipe-in-pipe design for subsea pipelines – offer
Disturbance of benthic Permit to Work better protection from dropped objects
species and habitats Dropped object reporting and recovery
Toxic impact on species Emergency Response Plan
and habitats
Oil Pollution Emergency Plan
xx

REQUIREMENTS
Unplanned Events Vessel Effects on other sea Notifications to Mariners circulated Additional area to be identified and notified to
movement users 500 m safety zone enforced mariners to cover FPSO mooring line area beyond
(Collision Risk) 500 m safety zone
Emergency Response Plan
Safety Case
Consent to locate will be obtained including vessel traffic survey and
collision risk assessment
Certified vessels (positioning systems, radar, communications etc.)
Compliance with International Association of Lighthouse Authorities
requirements
Establishment of temporary safety zone Navigation risk assessment
Marine operations manual
Adverse weather policy
Compliance with IALA requirements
SIMOPS Planning and Procedures
Unplanned Events Loss of Reduction in water Emergency Response Plan
containment – quality Oil Pollution Emergency Plan
(Chemical spill)
chemicals Bunkering procedures
Toxic impact on species
and habitats Equipment maintenance and inspection
Tertiary containment e.g. bunds, drip trays
Trained personnel
Chemical management procedures
Chemical Awareness Training
Monitoring and reporting of use and discharge
Subsea ROV inspection of umbilicals
Spill kits
Continuous flow and pressure monitoring on hydraulic systems
xxi

REQUIREMENTS
Unplanned Events Loss of Other sea users Oil Pollution Emergency Plan
containment – Emergency Response Plan
(Hydrocarbon spill) Disturbance of benthic
well blowout Well design and management
species and habitats
(drilling / Blow-out preventer when drilling
production) Toxic impact on species Well cap containment system
and habitats Well designs robust against cap and contain
Impact on offshore and Relief well planning
coastal conservation Adverse weather policy (stop drilling / disconnect)
areas Well control procedures (including well examination scheme, well
integrity management system, over balance drilling, two barrier
policy)
Contractor selection to ensure certified contractors and performance
monitoring by procedure
Continuous flow monitoring of wells
SSSV and downhole safety valves
Pressure monitoring at wellheadsWell completion design optimised
to prevent blowout during production phase
xxii

REQUIREMENTS
containment – Ship Oil Pollution Emergency Plan (transit)
FPSO Cargo species and habitats Fire and explosion risk assessment
Tanks / cargo Emergency shutdown procedures
offloading Toxic impact on species
Gas monitoring
and habitats
Fire detection systems
Impact on offshore and Inert gas in tanks and wet to prevent pyrophoric scale
coastal conservation
Cargo Oil Tanks (COTs) procedures
areas
Double skinned vessels
No bulkhead penetrations between COTs
Equipment maintenance
Hose testing and certification
Supply and tanker vessel specification
Marine breakaway coupling and emergency shutdown system
Contractor selection to ensure certified contractors and management
audits
Spill kits
Bunding containment
Leak detection system including communications between FPSO and
shuttle tanker during offloading
Waste Generation of Soil and ground water Waste Management Plan Environmental awareness training
hazardous and contamination Garbage management plan(s) and waste management and Shell UK wide programme to minimise packaging
non-hazardous Use of space minimisation plan(s) will be developed. waste
waste Consignment waste and waste manifesting Contractor selection to
Climate change
ensure certified contractors
Reduction in air quality Waste segregation
Duty of care audit
xxiii
1.6. OVERALL CONCLUSION AND KEY RESIDUAL ISSUES

A detailed assessment of the environmental impacts associated with the Penguins Redevelopment Project
has been carried out, and the environmental assessment and management process will continue throughout
the life of the project. The Penguins Redevelopment Project will include use of best practice, and comply
with the relevant regulations in order to minimise the chance of impacts occurring.
In conclusion, the execution of the proposed Penguins Redevelopment Project, incorporating the mitigation
measures, safeguards and control measures identified and committed to within this ES, is not expected to
have a significant effect on the environment.
xxiv
INTRODUCTION
1. INTRODUCTION
This Environmental Statement (ES) presents the findings of the Environmental Impact Assessment (EIA)
conducted by Environmental Resources Management Ltd (ERM) on behalf of Shell U.K. Limited (Shell) for
the proposed redevelopment of the Penguins fields. The Penguins Redevelopment Project (hereafter referred
to as the Project) is currently in the Front End Engineering Design (FEED) Phase.
The Project comprises the drilling and completion of new wells and the installation and operation of new
subsea equipment and a cylindrical Floating Production Storage and Offloading (FPSO) facility. Produced
oil will be exported via shuttle tanker and produced gas will be exported via the Far North Liquids and
Associated Gas System (FLAGS) pipeline. The Field Development Plan (FDP) is anticipated to be submitted
by Q4 2016.
1.1. FIELD HISTORY AND PROJECT PURPOSE

The Penguins cluster of fields is located in the UK Northern North Sea within UK Continental Shelf Blocks
211/13a (Penguins West) and 211/14 REST (Penguins East). The field is operated by Shell U.K. Limited on
behalf of its License partner -Esso Exploration and Production UK Limited -under the License P.296 (Shell
50% : Esso 50%).
The Penguins fields are a cluster of oil and gas condensate accumulations discovered in 1974. The fields
are located in around 160 to 170 m water depth in the Northern North Sea, around 150 km from the
Shetland Islands and adjacent to the UK/Norway border (Figure 1-1). The Penguins West field (Penguins
Block A) consists of Magnus sandstone reservoirs, while the Penguins East field (Penguins Blocks C, D and
E) consists of Brent, Statfjord and Triassic (Cormorant) reservoirs.
The fields were brought on-stream in 2003 as a subsea development tied-back to Brent Charlie Platform
(Figure 1-2). Additional wells were subsequently drilled and gas lift was installed from Brent Charlie
platform. The existing development consists of nine production wells, four production manifolds or Drill
Centres (DC2 to DC5), a multiphase production flowline, a gas lift line and an integrated umbilical for
control, power and chemicals (Figure 1-3). Cessation of production (CoP) at Brent Charlie is expected to
occur in the next few years; therefore an opportunity exists to extend Penguins Field life through a tie-back
to an alternative host. The proposed redevelopment aims to extend the field life of the existing producers
and drill additional wells which will maximize oil and gas condensate recovery and develop new
reservoirs. The existing and the new development will be produced via additional subsea infrastructure to a
new Floating, Production, Storage and Offloading (FPSO) installation.
1.2. ENVIRONMENTAL IMPACT ASSESSMENT
1.2.1. Requirements and Purpose

EIA has been a legal requirement for offshore developments since 1998. Current requirements are set out
in the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999
(as amended 2007 and 2010), hereafter referred to as the EIA Regulations. The purpose of the Regulations
is to require the Secretary of State (SoS) for Energy and Climate Change to take into consideration
environmental information before making decisions on whether or not to consent certain offshore activities.
The purpose of the EIA is to ensure that the environmental impacts associated with a project are identified;
assessed and appropriate mitigation and control measures are implemented to ensure all risks to the
environment are mitigated or removed by the application of practicable available technology or
management procedures.
The EIA Regulations require an ES to be submitted and prepared for:
1-1
INTRODUCTION
 Developments which have, as their main objective, storage or unloading activities as required
under the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection)
Order 2010;
 Developments which will produce 500 tonnes or more per day of oil or 500,000 m3 or more per
day of gas; and
 Pipelines of 800 mm (31") diameter and 40 km or more in length.
Figure 1-1 Location of the Penguins Field
1-2
INTRODUCTION
This ES is Shell’s opportunity to reassure the Regulator, the Department of Energy and Climate Change
(DECC), and its consultees that it is informed and understands the likely consequences of its activities, the
surrounding environment, the nature of the environmental and commercial issues arising from other
resources and receptors, and that the optimum engineering solutions have been chosen to reduce the
environmental impact to the lowest practicable level.
The ES is legally binding and the mitigation and commitments set out in it must be implemented by Shell.
1.2.2. Scope of the Environmental Statement

The scope of the EIA includes the:
 Drilling and completion of new development wells;
 Installation of subsea equipment on the seabed;
 Installation of a FPSO facility; and
 Operation
The EIA investigates and evaluates the impacts of any emissions to air, discharges to sea, seabed
disturbance, noise, waste production and resource use from the Project on a range of resources and
receptors within the physical, biological and human environments. These aspects are considered for both
planned and unplanned events.
Figure 1-2 Penguin Cluster relative to Brent Charlie and other UKCS infrastructure
1-3
INTRODUCTION
Figure 1-3 Existing Penguins Field Layout
1.3. STRUCTURE OF REPORT

The remainder of this Environmental Statement is structured as follows:
 Chapter 1: Introduction
 Chapter 2: Management System and Regulatory Control
 Chapter 3: Project Description
 Chapter 4: Environmental Baseline
 Chapter 5: The Environmental Impact Assessment Process
 Chapter 6: Physical Presence
 Chapter 7: Discharges to Sea
 Chapter 8: Atmospheric Emissions
 Chapter 9: Underwater Noise
 Chapter 10: Waste Management
 Chapter 11: Accidental Hydrocarbon Releases
 Chapter 12: Conclusions
Appendix A Summary of Environmental Legislation

Appendix B Habitat Assessment Desk Top Study
Appendix C Air Quality Modelling Report
Appendix D Underwater Noise Modelling Report
Appendix E Oil Spill Modelling Report
1-4
MANAGEMENT SYSTEM AND REGULATORY CONTROL
2. MANAGEMENT SYSTEM AND REGULATORY CONTROL

2.1. INTRODUCTION
This chapter describes Shell’s Environmental Management System (EMS) which is integrated into the
Corporate Management System (CMS). It sets out Shell’s policy documentation and the standards which
underpin the policy to ensure protection of the environment and minimisation of impacts. This section also
includes the regulatory controls applicable to the Penguins Redevelopment Project.
2.2. SHELL UK MANAGEMENT SYSTEM

Shell’s EMS is embedded in its CMS, a system of internal controls that demonstrates how Shell complies
with laws and regulations, and which facilitates the implementation of the company’s health, safety and
environmental (HSE) policy. The EMS is independently verified to ISO 14001 Standard, which meets the
requirements of OSPAR Recommendation 2003/5. A brief description of the Shell EMS is given in the
Environmental Management Section of the Shell annual environmental statement, which is available upon
request.
This section provides a summary of all elements of the EMS, illustrated in Figure 2-1, and describes how
these will be applied to the Penguins Redevelopment Project for management of environmental and social
aspects.
Figure 2-1 Environmental Management System
2.2.1. Policy and Strategic Objectives

Shell’s Commitment and Policy on Health, Safety, Security, Environment and Social Performance (HSSE-SP)
is presented in Figure 2-2. The policy provides a framework for setting HSSE-SP objectives which are
applicable to all activities related to the Penguins Redevelopment Project.
All companies contracted to Shell U.K. Limited are required to work to similar, consistent high standards
and to achieve comparable levels of performance adopted by Shell U.K. Limited. Project and contractor
employees, on their part, have a clear responsibility to exercise discipline, maintain a high level of
awareness, prevent injury to themselves and others, protect the environment and comply with all statutory
obligations.
2-1
Figure 2-2 HSSE-SP Commitment and Policy
2-2
2.2.2. Organisation, Responsibilities, Resources and Competency

The EMS describes the organisational structure and the roles and responsibilities for environmental
management. The competency of personnel carrying out roles within the EMS is addressed as are the
resources necessary to ensure the EMS is in place and maintained. Communication processes around
environmental issues both within and outside of Shell are detailed.
The general responsibilities for health, safety and environmental protection are specified in Shell’s policy
booklet (which is issued to all staff and contractors). The management of HSE protection by contractors is
an important area for Shell. All contractors are required to fulfil defined standards in HSE management
before they work with Shell, and their performance in this area is monitored and reviewed. Specifically,
the Floating, Production, Storage and Offloading unit (FPSO) Engineering and Procurement Contractor
(EPC) and the other prime contractors will have in place environmental management systems that align with
Shell’s EMS and adopt Shell’s requirements. Shell provides training to ensure that personnel are competent
and have the required skills to carry out assigned activities and, where there are specific responsibilities for
environmental protection, specific training is provided. Contractor companies are expected to provide an
equivalent level of training and relevant qualifications. These are verified at the tender stage of projects. In
addition, the Project promotes and welcomes the active participation of all personnel in the establishment
and observance of measures to reduce HSSE-SP impacts related to their involvement in the project.
Communication on environmental aspects takes place primarily via line managers and supervisors. In
addition, Shell has a comprehensive system of committees, meetings and publications that ensure the flow
of information between all parts of the organisation. Communication with the authorities and interested
parties is also an important part of Shell’s approach to environmental management. External consultations
have taken place as part of the EIA process and details are provided in Section 2.7.
2.2.3. Risk Management

Shell’s EMS specifies the method to identify environmental aspects, legal and other requirements related to
them. The EMS also contains the operational framework for managing significant environmental aspects.
The EIA methodology which has been adopted for the assessment of impacts associated with the Project is
provided in Chapter 5.
2.2.4. Processes, Assets and Standards

The EMS describes the processes undertaken to support Shell’s assets and the relevant standards.
Processes and standards incorporate environmental information to ensure that the EMS is effectively
implemented in the assets.
The HSSE-SP Control Framework contains the environmental and social requirements that apply to every
Shell company, as well as joint ventures where it has operational control. More specifically, it contains a
simplified set of mandatory standards that define high level HSSE-SP principles and expectations. The
framework covers 11 areas presented in Figure 2-3. A supporting manual is provided for each of the
areas to help operations put the mandatory standards into practice.
The Environmental Manual of the HSSE-SP Control Framework sets out specific requirements relating to:
 Biodiversity;
 Continuous Flaring and Venting;
 Greenhouse Gas and Energy Management;
 Ozone Depleting Substances;
 Soil and Groundwater;
 Sulphur Oxides (SOx) and Nitrogen Oxides (NOx);
 Volatile Organic Compounds;
 Waste; and
 Water in the Environment.
2-3
Figure 2-3 HSSE-SP Control Framework
2.2.5. Planning
The Project will be managed in accordance with Shell’s EMS and supporting plans and procedures. Shell
promotes compliance and continuous improvement in performance by establishing appropriate
environmental objectives and targets within an annual HSE Plan.
A project specific HSE Plan will be developed for all phases of the Penguins Redevelopment Project and will
be applied to all work carried out on the project, regardless of location, describing how HSE issues will be
managed aligned with relevant legislation and Shell's HSE Policies and Standards.
The Project sets out to achieve the overall environmental objectives and targets set by Shell.
2.2.6. Implementation (Reporting and Monitoring)

Documented operational control, emergency response and monitoring procedures will be developed and
implemented for every stage of the Project. This will include monitoring of activities that can have a
significant environmental impact as well as environmental performance and the periodic evaluation of
compliance with legal and other requirements.
Shell will set performance targets and will monitor a range of key performance indicators in accordance
with the Shell Group requirements stipulated in the Performance Monitoring and Reporting Specification.
Proposed activities and operations will be reviewed against these targets, enabling performance to be
evaluated and improvements in technical and operational controls to be identified and implemented, if
required.
Regularly scheduled performance reports will be used for assurance by the project managers and by Shell
Group, as required. Statutory reporting to the authorities will be carried out via the Environmental
Emissions Monitoring Scheme (EEMS).
2-4
2.2.7. Assurance (including Management Review)

Shell has an extensive assurance programme which includes a comprehensive programme of
environmental audits. Shell also has HSE Interface Documents with Contractors, and Contractor audits are
carried out. This ensures that the competence and standards of Contractors are checked.
Project reviews and installation audits and inspections will be conducted by Shell, the regulatory authorities
and verification bodies, to ensure standards are being maintained and corrective action is taken where
necessary.
The leadership teams throughout Shell carry out regular reviews of the CMS. The reviews take into account
any relevant matters including the findings of audits, non-conformances and environmental performance.
2.3. CONTRACTOR MANAGEMENT

The level of involvement of the Shell project team with respect to HSSE-SP during contract execution for the
Project will be based on Shell’s Contractor HSSE-SP Management standards. They stipulate how HSSE-SP
issues are to be managed with respect to contractors during all phases of the contract process from pre-
qualification to completion.
Based on these standards the following HSSE-SP related activities and reporting will be undertaken for the
Penguins Redevelopment Project:
 Shell and Contractors will jointly produce an Interface and Management Plan which includes the
management of HSSE-SP aspects.
 Contractors will produce an HSSE-SP management plan for the works under their scope; this plan
will be subject to review and approval by Shell.
 Contractors will report on regular basis their HSSE-SP performance.
 Regular HSSE-SP liaison meetings will be held between Shell and its contractors; this will facilitate
the review and discussion of HSSE-SP related issues.
The Contractor’s HSE-SP Management Plan will be in place for the primary contractors involved in the
FPSO’s detailed design and construction, drilling, and installation of the subsea infrastructure. The Interface
and Management Plan will detail the management organisation, the communication and reporting lines
and the division of responsibilities during operational and emergency situations. The interface documents
will be written to meet the requirements of Shell and Penguins Redevelopment Project. Figure 2-4 shows
how the company management systems will interface.
These documents will be held by the relevant HSE manager, agreed and implemented by all parties and
periodically reviewed. An assurance programme, including a comprehensive plan of environmental audits
will be in place to monitor contractor competence and standards with regards to HSE management and the
effective delivery of Shells HSSE-SP policy objectives.
2-5
Figure 2-4 Contractor Management System Interface
2.4. PENGUINS HSSE-SP PLAN AND ENVIRONMENTAL COMMITMENTS

A Penguins HSSE-SP Plan will be developed which specifies how HSSE-SP issues will be managed and how
Shell’s HSE policies and CMS will be implemented effectively throughout the project. The HSSE-SP Plan will
apply to all work carried out on the Project be it onshore within offices or construction sites or offshore on
the FPSO and other vessels.
A register of commitments has been developed to address each aspect of the Project and reflect the
outcomes of the EIA. The commitments register will form part of the HSSE-SP Plan and will be integrated
into the relevant project execution and operational phases. The commitments register provides a summary
of key management and mitigation measures identified during the EIA process, above and beyond those
required through legislation. The commitments register will be updated as each element of the project
continues into detailed design, execution and subsequent operational phases. Mitigation measures
identified and commitments made will also be embedded into the following documents to ensure
appropriate execution and management:
 Detailed engineering specifications;
 Contracts; and
 Execution and operation plans.
The commitments register will be owned by Shell and the key pertinent mitigation and management
measures will be embedded into the project contracts for the different stages of the project. Each
commitment will be assigned an owner within the Project team and will be reviewed periodically by Shell to
ensure that the commitment is being met.
During implementation of the project, objectives and targets will be jointly developed and used by Shell
and the key contractors to set goals for continuous improvement in performance. In this way, it ensures
environmental management is an ongoing iterative process, continuing beyond mitigation measures
identified and implemented during this EIA process. It also ensures the development remains responsive to
continual improvement and changing regulatory requirements.
2-6
2.5. ENVIRONMENTALLY CRITICAL ELEMENTS

Environmentally critical elements (ECE) are any systems/equipment where the failure of which could cause,
or contribute to, a significant impact to the environment.
Shell manages the inspection and maintenance of their process equipment through a robust risk based
process linked into their maintenance system provided by SAP (Systems Applications and Products). The
specific Environmental Critical Elements (ECE) Strategy has not yet been implemented within our
organization; however, a pilot has been initiated in one of our offshore platforms which will enable Shell to
have a better understanding on how to incorporate ECEs into our processes. A full roll out programme for
offshore facilities and projects will be conducted after completion of this Pilot.
2.6. REGULATORY CONTROL

In addition to Shell’s requirements within its management systems, the Project will be subject to the
requirements of UK and EU legislation, as well as other international treaties and agreements. The key
piece of environmental legislation with regard to Environmental Assessment is the Offshore Petroleum
Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended). These
regulations require the undertaking of an EIA and the production of an Environmental Statement (ES) for
offshore oil and gas projects that are likely to have a significant effect on the environment. The approval of
the ES is required before approval of the Field Development Plan (FDP) under the Petroleum Act, 1988.
The UK environmental legislation plays an important role in ES approval process. Key regulations pertinent
to the project are listed in Table 2-1. A detailed summary of applicable UK and international regulations is
provided in Appendix A – Summary of Environmental Legislation.
Table 2-1 Key Regulations Pertinent to the Project
UK/DECC INTERNATIONAL/EC
The Petroleum Act, 1998 Public Participation Directive 2003/35/EC
Convention for the Protection of the Marine
Environment of the North East Atlantic 1992
(OSPAR Convention) and its related decisions
OSPAR Decision 2000/3 on the Use of Organic-
The Offshore Petroleum Production and Pipelines Phase Drilling Fluids (OPF) and the Discharge of
(Assessment of Environmental Effects) Regulations OPF-Contaminated Cuttings
1999 (as amended) OSPAR Recommendation 2006/5 on a
Management Regime for Offshore Cuttings Piles.
OSPAR Recommendation 2001/1 for the
Management of Produced Water from Offshore
Installations.
OSPAR Recommendation 2010/5 on assessments
The Coast Protection Act, 1949 of environmental impact in relation to threatened
and/or declining species and habitats
The Offshore Marine Conservation (Natural The Merchant Shipping (Prevention of Oil Pollution)
Habitats, &c.) Regulations 2007 (as amended) Regulations 1996 (as amended)
The Offshore Petroleum Activities (Conservation of International Convention for the Prevention of
Habitats) Regulations 2001 (as amended) Pollution from Ships (MARPOL) 73/78
The Offshore Chemicals Regulations 2002 (as PARCOM Recommendation 86/1 of a 40 mg/l
amended) Emission Standard for Platforms
The Offshore Petroleum Activities (Oil Pollution International Convention for the Control and
2-7
UK/DECC INTERNATIONAL/EC
Prevention and Control) Regulations 2005 (as Management of Ships' Ballast Water and Sediments
amended) (OPPC) (BWM) – adopted 2004
OSPAR Recommendation 2001/1 for the
Management of Produced Water from Offshore
Installations as amended by OSPAR
Recommendation 2006/4
Convention on Environmental Impact Assessment in
a Transboundary Context (Espoo, 1991)
The Offshore Installations (Emergency Pollution International Convention on Oil Pollution
Control) Regulations 2002 Preparedness, Response and Co-operation (OPRC
Convention)
Merchant Shipping Act 1995
Directive 2010/75/EU of the European Parliament
The Offshore Combustion Installations (Pollution and of the Council on industrial emissions
Prevention and Control) Regulations 2013 (integrated pollution prevention and control) - The
Industrial Emissions Directive
UNESCO Convention for Protection of Underwater
The Energy Act 1976
Cultural Heritage, 2001
Council Directive 2003/87/EC establishing a
The Greenhouse Gas Emissions Trading Scheme
scheme for greenhouse gas emission allowance
Regulations SI 2012/3038
trading with the community
The Environmental Information (Scotland)
Regulations 2004
The Merchant Shipping (Prevention of Pollution by
International Convention for the Prevention of
Sewage and Garbage from Ships) Regulations
Pollution from Ships (MARPOL) 73/78
2008
2.7. CONSULTATION PROCESS

Consultation with stakeholders is an important part of the EIA process to assess the environmental impact of
the Penguins Redevelopment Project. To date, meetings have been held with DECC, the Joint Nature
Conservation Committee (JNCC), Scottish Fishermen’s Federation (SFF) and Marine Scotland (Table 2-2).
The process of consultation will continue throughout the project.
2-8
Table 2-2 Summary of consultations
Scoping Meeting with DECC/ JNCC/ Marine Scotland/ Scottish Fisheries Federation (SFF) held on
19/05/2014
ES CHAPTERS
ISSUE /CONCERNS
ADDRESSED
Scoping Meeting:
4
 Adequacy of the existing surveys: Scoping report to include survey
rationale based on existing survey data and potential use of geophysical
survey result in 2011 for habitat mapping study.
3, 4, 6
 Installation Activity: Piling, mooring standby vessels, rockdumping, pile
size, and 500 m safety zone.
 Fishing: Cover any associated impact on trawl fleet within the Penguins 4, 6, 7, 11, 12
site in the ES. Check coordinate system that should be used for accurate
locations for interim period when Kingfisher/FishSafe required updating.
3
 Concept Selection: A brief description of the concept select study will be
described in the scoping report.
 Produced Water: Submit the Produced Water Disposal Philosophy report

to DECC which supports the scoping report statement with regard to PW. 3, 7
The report presents the reasons on the unsuitability of PWRI for this
project.
4, 6, 7, 11
 Species vulnerability: Seabird vulnerability to be included in the ES.
 Air Emissions: Minimal operational flaring and venting will be included in

3, 8
the project design.
 ES Quality and Length,

3
o Uncertainties should be highlighted including options still being
explored
o Concentrating on the project site impacts (10km, do not consider
areas within 50-60km of the area except oil spill related impacts)
 Others
o Issues with potential use of new chemicals in the process raised,
3, 7
to be confirmed during FEED, e.g. those with high RQ.
o Decommissioning
2-9
Meeting with JNCC/DECC on Project’s Habitat Assessment information held on 01/10/2014
ES CHAPTERS
ISSUE /CONCERNS
ADDRESSED
Desk Top Habitat Assessment Study
 Confirm the proposed infrastructure and installation method 3, 6
 Clarify which areas were assessed against the stony reef criteria 4
4
 Latest ROV data from 2005
4, 6
 Quite a lot of oil and gas and fishing activity in the area, and it is
likely that (epi)fauna that may be associated with stony reefs has
changed over the 7- 10 years since the last visual and benthic
surveys. Epifauna coverage is one of the criteria for stony reefs
assessments and may have changed over this period
 Video transects were available to confirm presence/absence of
4, 6
MDACs. JNCC further highlighted that acoustic data is not
sufficient to characterise the communities created by/ around
MDACs
 Asked if habitat / biotope classification was supported by sediment 4
sampling or only based on visual assessment
 Asked if a pipeline route survey is planned before the pipeline 4, 6
installation and whether it would also include the anchors
 Confirmation that Desk Top Habitat Assessment Study is adequate
4, 6, 7, 9,11
for the purpose of IA.
 Clear map should be included in the ES indicating the location of
sediment sampling and video transects in relation to the proposed 4, 5
infrastructure. DECC also emphasised that the ES size should be
proportional to size of the project/the magnitude of potential
impacts
Meeting with DECC on produced water management held on 21/10/2014
 Subsurface issues with Produced Water Reinjection (PWRI) 3, 7

identified so option of PWRI to be compared with overboard
discharge.
 BAT Assessment discussed. 3
Follow up communication with DECC on produced water management dated 11/12/2014
 Technical unfeasibility of Produced Water Re-injection validated by 3, 7

DECC.
 Produced Water Discharge overboard as the base case. 7
2-10
PROJECT DESCRIPTION
3. PROJECT DESCRIPTION
3.1. PROJECT OVERVIEW
The existing Penguins development consists of four Production Manifolds or Drill Centres (namely DC2 to
DC5), a multiphase production pipeline, a gas lift pipeline and an integrated umbilical for the control
system and supply of power and chemicals. The DCs are currently tied back to the Brent Charlie platform,
50 km to the south of DC5 (Figure 1-3). The proposed redevelopment will include the following new
infrastructure:
 New cylindrical Floating, Production, Storage and Offloading (FPSO) facility;
 Seven new production wells (Tranche 1) with the potential for an additional four wells (Tranche 2
and 3) depending on the performance of the Tranche 1 wells;
 Four new infield production manifolds or Drilling Centres supporting the new development wells
(namely DC6 to DC9), and a new Riser Base Manifold (RBM);
 New subsea facilities including flowlines and risers for production of fluids, gas export and gas-lift;
 New 16" pipeline to tie–in the FPSO gas export pipeline directly to the Far North Liquids and
Associated Gas System (FLAGS) bypassing the Brent Charlie platform; and a new Penguins Gas
Export Pipeline End Manifold (PLEM)
 New control umbilicals.
In addition, the existing multiphase production flow line will be reconfigured for gas export within the
redevelopment.
The existing development will be produced via a new tie-in to the FPSO. The existing wells and associated
subsea infrastructure will form the Low Pressure (LP) system of the redevelopment and the new wells and
associated subsea facilities will form the High Pressure (HP) system.
3.1.1. Project Location

Figure 3-1 illustrates the location of the Project area in relation to UKCS licence blocks and the Brent area.
The Project will have a similar extent to the existing development, covering blocks 211/13a and 211/14
REST. The new DCs will be located relatively closed to the existing DCs. The FPSO is currently located
approximately 2.5 km northwest of Penguins DC5 and 4 km from the UK/Norway median line. The
Penguins development (‘Penguins area’) is illustrated in Figure 3-2.
The new 16" pipeline will extend from the reconfigured export pipeline south, bypassing the Brent Charlie
platform and tying in to the FLAGS pipeline (7 km long). The FLAGS pipeline transports liquids and
associated gas from a number of North Sea fields to St Fergus Gas Terminal near Peterhead. The project
scope located in the Brent area is illustrated in Figure 3-3.
Given the geographic separation of these areas, when reference is made to the Project area, this is
considered to include the area around the existing Penguins field and the works within Blocks 211/13a
and 211/14 REST. When reference is made to the new gas export pipeline in Block 211/29 this will be
referred to as the Brent area. There will be no new infrastructure installed between the Project area and
Brent area.
3-1
PROJECT DESCRIPTION
Figure 3-1 Project Location in relation to UKCS Licence Blocks and the Brent Area
3-2
PROJECT DESCRIPTION
Figure 3-2 Penguins Area (Penguins Re-development Project)
3-3
PROJECT DESCRIPTION
Figure 3-3 Brent area (Penguins Re-development Project)
3-4
PROJECT DESCRIPTION
3.1.1. Project Schedule

The current timeline for execution of the project is not determined yet; however it is expected to be circa
2020. A notional project schedule (undated) is provided in Table 3-1 for the purpose of assessing the
activities defined in this ES. Subsequent activities and dates are shown to provide details of scope and
durations and may be subject to change.
Table 3-1 Notional Project Schedule
Year 1 Year 2 Year 3

ACTIVITY
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
FPSO ARRIVAL IN THE NORTH SEA
SUBSEA INFRASTRUCTURE INSTALLATION
Pipeline/Umbilical installation
Manifolds/Spools and mattresses Installation
Rockdump
Mooring Lines Installation
Multiphase pipeline conversion to Gas Export line
Riser and umbilical installation to the FPSO
DRILLING CAMPAIGN
Tranche 1 (7 wells)
FPSO FIRST OIL
Schedule for drilling Tranche 2 and 3 wells will be defined upon completion of Tranche 1.
3.1.2. Penguins Fields and Reservoirs

The Penguins cluster of fields was discovered in 1974 and comprises a combination of oil and gas
condensate accumulations of Jurassic and Triassic age. The Penguins West field (‘Penguins Block A’)
consists of Magnus sandstone reservoirs, while the Penguins East field (‘Penguins Blocks C, D, E’) consist of
Brent, Statfjord and Triassic (Cormorant) reservoirs. The geological context of the Penguins fields is
illustrated in Figure 3-4. The Hydrocarbon fluids are oil in the northern fields trending to gas condensate in
the south. The reservoir characteristics are presented in Table 3-2.
3-5
PROJECT DESCRIPTION
Table 3-2 Reservoir Fluid Characteristics
PENGUIN WEST (BLOCK A) AND EAST FIELDS (BLOCKS C, D & E)/RESERVOIRS
Penguins West Penguins West Penguins East Penguins Penguins

Field (Block A) Field (Block A) Field (Block C) East Field East Field
PARAMETER from well from well A2 from well C3 (Block D) (Block D)
A1(Magnus (Magnus (Brent (Brent (Triassic
reservoir) reservoir) Reservoir) Reservoir) Reservoir)
Reservoir Pressure (psia) 7,379 7,300 8,025 7,150 8,030
Reservoir Temperature (°C) 131 130 130 127 138
H²S (ppmv) <10
API Gravity (from
39 38 41 44 48
separator test)
Wax Appearance (°C) 31 - 39
3-6
PROJECT DESCRIPTION
Figure 3-4 Geological Context
3-7
PROJECT DESCRIPTION
3.2. PROJECT ALTERNATIVES

The Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999,
as amended, require that the alternatives considered by a project are described in the EIA. This section
describes the work carried out to select the design concept and the process that was followed for assessing
design options.
The aim of considering alternatives is to establish whether there are reasonable options which could be
pursued which meet a project’s objectives with less impact on the environment, and if there are, to explain
what other factors determined the choice of proposal.
For the Penguins Project a Concept Select Phase was first undertaken to select a preferred development
option for the project. Subsequently alternatives within that option were considered as part of the Front
End Engineering Design (FEED).
3.2.1. Concept Selection

A series of Concept Selection sessions were completed between 2012 and 2014 to review all development
concepts. In total, 15 concepts were initially identified, including seven fixed platform concepts and eight
floating facility concepts. Following the workshops, ten concepts were deselected as they were considered
to be either technically or economically unattractive. The following five concepts were carried forward for
further consideration:
 Redeployment of an existing FPSO: The option considers the redeployment of the Munin FPSO,
which is leased from a third party. The FPSO was built in 1997 to North Sea specification and is
DNV (Det Norske Veritas) certified.
 New conversion or new build ship-shape FPSO: Shell has an Enterprise Framework Agreement
(EFA) with a number of companies to supply and lease FPSOs. This option considers the
conversion or new-build of a ship-shaped FPSO following the specification of the EFA.
 Production via BP Magnus installation: The option considers a new tie-back from the Penguins
Field to the existing BP Magnus Platform. BP Magnus is a steel jacket platform dating from 1983
and is the closest infrastructure to Penguins, approximately 10 km from DC2 and 21 km from
DC5.
 New cylindrical FPSO (non-ship-shape): This option considers the construction of a new
cylindrical FPSO. There are two similar units in the North Sea and two units being built for
European fields. The concept has been identified as proven technology and suitable for
consideration for Penguins.
 Continue production via existing tie-back to Brent Charlie (BC): Penguins Fields could continue to
produce via Brent Charlie past the anticipated CoP date if extensive modifications were
undertaken.
A brief description of the remaining concepts and the decision taken on their selection is set out in Table
3-3.
3-8
PROJECT DESCRIPTION
Table 3-3 Final Concept Select Decisions
OPTION DECISION
Deselection was based on high costs, poor technical fit,
Redeployment of an expected lease elsewhere before commitment by the Project
Deselected
existing FPSO (Munin) and marginal cost difference between the owned / operated
cylindrical FPSO option.
Work was carried out on a number of options with Shell’s
existing contractors for FPSOs. It was found that these
New conversion or new concepts did not meet the requirements of Shell’s technical
Deselected
build ship-shape FPSO specification and were therefore not feasible. This option also
presented a high CAPEX commitment with no significant
technical benefits.
Production via BP The option to utilise Magnus was deselected due to

Magnus Platform commercial uncertainties with the Operator and misalignment
Deselected
with the Penguins project timeline and the ability to undertake
modifications on Magnus for Penguins.
The cylindrical FPSO option was selected as the preferred
New Cylindrical FPSO concept, based on there being no technical showstoppers
Selected
(non-ship-shape) identified and it being the most suitable within the project
timeframe.
Continue Production via The extension of the life of the BC platform to serve as host
Brent Charlie installation for Penguins Redevelopment project was
Deselected
deselected. It was not a competitive option due to limited
lifespan and hence poor economics.
Alongside the concept selection process, a sustainable development comparative analysis was undertaken
for each option. During this analysis the options were scored based on sustainable development criteria
such as profitability, value for customers, community benefit, environment, resource management, and
respect and safeguard of people.
The cylindrical FPSO option was selected as the base case for the development as there were no technical
show stoppers identified, and it scored best during the comparative sustainability analysis. It also
represented the best commercial development option in terms of the required project timeframe.
3.2.2. Technical Selection

Following concept selection, a selection process has been/is been undertaken to inform decisions on
specific technologies within the concept for three particular issues:
 produced water handling;
 combustion equipment; and
 flare systems and cargo oil tank inerting.
3.2.2.1. Produced Water Handling

The two options considered for the disposal of Produced Water (PW) were:
 reinjection downhole to an available and suitable subsurface formation; and
 overboard discharge.
3-9
PROJECT DESCRIPTION
3.2.2.1.1. Produced Water Reinjection

A Produced Water Reinjection (PWRI) feasibility study was carried out to assess disposal of PW into a
shallower overburden zone and the conversion of one of the existing producer wells into a PW injector
well.
No suitable permeable zones were identified in the existing reservoir structure. The majority of sand-
bearing zones are relatively shallow. Therefore it is expected that any reinjection could result in induced
fractures propagating to the surface. Furthermore, none of the sand-bearing zones are believed to have the
required capacity for PW reinjection.
Four existing wells were assessed for conversion for PW reinjection based on their proximity to existing
wellbores, connectivity, reservoir quality and injectivity. However, none of the wells were found suitable
due to restricted access, the loss of potential future side-tracks for access additional hydrocarbon reservoirs,
and poor injectivity. Therefore, conversion of an existing well for reinjection was not considered feasible.
Drilling a dedicated injection well was also considered unfeasible given the unsuitability of the overburden
areas identified above and issues associated with injecting into a producing reservoir.
Additionally, the relatively low volume of produced water forecasted over the production lifetime of
Penguins fields will result in relatively small quantities of oil discharges to sea. This is based on historical
data and results from the reservoir depletion plan.
For the reasons set out above, overboard disposal was selected as the base case for the Project. PW
reinjection was removed as an option following consultation with DECC in February 2015.
3.2.2.1.2. Overboard Discharge

Following selection of the base case, a Best Available Technique (BAT) study was undertaken to inform the
selection of technology for PW treatment prior to overboard disposal. The study concluded that the use of
hydrocyclones and an enhanced degasser was the BAT compared to other treatment technologies. These
systems are well established in the industry, are technically reliable and suitable for the Project in terms of
cost and footprint. PW treatment will meet the regulatory requirement of 30 mg l-1 monthly average oil
content in water.
3.2.2.2. Combustion Equipment (power generation)

The base case for power generation is conventional gas turbines which will be dual fuel (gas and diesel)
and dry low NOx emissions (DLE) turbines. Turbine selection will be based on a BAT assessment of the
power generation options during FEED. Considerations include installed capacity, configuration, sparing
strategy, single or dual fuel, efficiency, heat production, reliability and availability, available models and
economics.
3.2.2.3. Flare Systems and Cargo Tank Inerting
3.2.2.3.1. Flaring Systems

The Penguins FPSO design premise is that High Pressure (HP) and Low Pressure (LP) flare systems will be
installed. Consideration was given whether to use a conventional open header flare system or a closed
header flare system.
The closed system would include a fast-acting full bore high integrity block valve being installed in the flare
header. In the event of a pressure relief scenario, a pressure sensor in the header acts to open the block
valve, allowing the system to relieve via the flare. Should the block valve fail to open, a burst disk would
also be provided in parallel to the block valve.
3-10
PROJECT DESCRIPTION
During normal operation, the fast-acting block valve remains closed and gas would flow from the cargo
tanks into the header, where it is recovered by the VRU and directed to the LP compressor and ultimately
back to process.
The conventional open flare system would mean fugitive gas is vented to atmosphere and the VRU is
connected directly to the cargo tank vent header, from where the displaced hydrocarbon vapour is
recovered and returned to process.
The following aspects were considered in the assessment of these alternatives.
 For both systems, other near-atmospheric pressure sources would also be directed to the VRU, such
as compressor seal gas.
 The closed system can recover all gases directed to the flare header; this is not the case with the
open system.
 The conventional open system requires the use of a continuous purge to prevent the formation of a
flammable atmosphere in the flare header. However, the closed header system does not remove
this requirement as it is still required downstream of the block valve.
 The closed system relies on an instrumented system for its safe operation, backed up by a large
diameter bursting disk. This type of installation introduces its own hazards and maintenance
requirements.
 While the open system does not capture all fugitive emissions compared to the closed system, the
permanent availability of a clear flow path in the event of a major relief scenario is considered to
be a significant advantage.
The final point in particular supported the selection of the open system as the base case design. The design
will also include a Vapour Recovery Unit (VRU) to minimize any hydrocarbon venting from cargo tanks and
other minor sources.
3.2.2.3.2. Cargo Oil Tank Inerting

An ALARP study has been undertaken to compare hydrocarbon (HC) and inert gas (IG) blanketing options
for inerting the cargo tanks. The provision of a HC blanketing system does not remove the need for IG
plant; which is required for start-up, tank entry operations and as back-up if the HC blanketing gas system
fails. Therefore the assessment is of IG blanketing alone against HC blanketing plus IG blanketing.
The assessment aimed to establish the ALARP option considering both safety and environmental issues. The
study showed that there are both safety benefits and disadvantages of the proposed HC blanket system, but
none of these are considered significant. The environmental benefits are however considered to be
significant for the HC blanketing; as well as having production/ operational advantages.
Overall, the HC blanketing (combined with IG blanketing) was selected for the design of the FPSO as
considered the best options due to its safety, environmental and operational benefits.
3.3. OFFSHORE FACILITIES AND EQUIPMENT

The new and existing wells (HP and LP systems respectively) will be supported by the new and existing
Production manifolds (Drilling Centres). The Penguins production fluids (oil, produced water, associated
gas) will be transported through two subsea production flowlines (HP and LP) to the FPSO via the two
flexible risers.
Following processing, oil will be temporarily stored on the vessel and offloaded to shuttle tankers. Gas will
be compressed, dehydrated and exported through an export pipeline that will join the existing FLAGS
pipeline system. Gas will also be used for gas lift and fuel gas. Produced water will be treated and
discharged overboard.
Control, utilities and chemicals will be provided to the DC manifolds and wells via an umbilical system that
runs parallel to the infield pipeline. A gas-lift pipeline will also be installed.
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PROJECT DESCRIPTION
Definitions of terms are provided in Box 3.1.

Box 3.1 Subsea Equipment: Definition of Terms
Production / Drill Centre manifolds
Production manifolds are subsea equipment installed on the seafloor, comprised of valves and pipes, which act as a
gathering point for the produced fluids/gas from individual production wells.
Production trees
Production trees (sometimes referred to as Xmas trees) are comprised of a set of control valves that are installed on
production wellheads to control production fluids/gas.
Spools, flowlines and risers
Spools are generally rigid insulated pipes that connect wellheads to manifolds. Flowlines are dual insulated pipes that
carry production fluids from production or drill centre manifolds to riser. Risers carry production fluids from the riser
base on the seabed to the FPSO.
Umbilicals
Umbilicals are used to convey chemicals, data (control system information, pressure and temperature) electrical power
and high/low pressure hydraulic fluid supply to allow manipulation of infrastructure valves, tree safety valves and flow
chokes.
Pipeline End Manifold (PLEM) / Pipeline End Termination (PLET) and In-Line Tee (ILT)
A PLEM is a subsea component that includes a flange and makes it possible to connect a rigid pipe to another structure
such as a manifold or a tree through a jumper. It is also called a PLET, especially when serving a single pipeline valve
or having only one vertical connector. An ILT is a pipeline tie-in structure that provides tie-in points along a pipeline.
3.3.1. Subsea Infrastructure

Figure 3-5 illustrates the general subsea arrangement for the Project. Subsequent Figures 3-5a and 3-5b
differentiates between new and existing infrastructure.
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PROJECT DESCRIPTION
Figure 3-5 Penguins Redevelopment Project Field Layout (Overview)
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PROJECT DESCRIPTION
Figure 3-5a Penguins Redevelopment Project Field Layout (Penguins area)
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PROJECT DESCRIPTION
Figure 3-5b Penguins Redevelopment Project Field Layout (Brent area)
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PROJECT DESCRIPTION
3.3.1.1. Wells
The Project will involve the phased drilling of new production wells over three tranches. The first tranche
will include seven wells (six new production wells and a side-track). The second and third tranches involve
four additional production wells to be drilled depending on the performance of the Tranche 1 wells. The
coordinates for the proposed wells are set out in Table 3-4. This EIA assumes that all 11 wells are drilled.
Table 3-4 Proposed Penguins Wells
COORDINATES (WGS84)
DRILL CENTRE TRANCHE WELL NAME
LATITUDE LONGITUDE
DC6 PAN-W 61° 37' 43.428"N 01° 29' 42.999"E

1
PAN-N 61° 3'8 59.868"N 01° 28' 54.939"E
PAN-NW 61° 39' 02.835"N 01° 28' 58.548"E
2
PAC TBC TBC
DC7 C-Triassic 61° 36' 26.788"N 01° 32' 36.694"E
1 PC4 61° 36' 26.292"N 01° 32' 37.688"E
C-UpDip 61° 36' 27.285"N 01° 32' 35.633"E
3 PAS TBC TBC
DC8 1 Rockhopper (RH) 61° 33' 48.960"N 01° 36' 11.910"E
3 PC5 61° 33' 49.651"N 01° 36' 10.928"E
DC9 1 E1-ST (sidetrack) 61° 31' 47.996"N 01° 39' 35.225"E
Steel casings will be installed in each of the wells during drilling. Each casing is cemented into place to
form a seal between the casing and the formation. A well design schematic for Penguins C Triassic is
provided in Figure 3-5 which illustrates the different geological formations.
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PROJECT DESCRIPTION
Figure 3-5: Conceptual Well Design Schematic (C-Triassic)
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PROJECT DESCRIPTION
3.3.1.2. Trees
Production from individual wells will be controlled by a production tree. The production trees include a
standard valving and instrumentation, gas lift facilities, three chemical injection points and a sand detector
connection. A wellhead protection device, known as a “Cocoon” (see Figure 3-6), will be installed over the
production trees as well as a ‘deflection skirt’ around their bases to provide protection from accidental
damage from fishing gear. The wells will be connected to the DC manifolds using tie-in spools installed on
concrete mattresses.
Source: offshore-mag.com Source: strongwell.com

Figure 3-6 Example Cocoon Well Protection Devices
3.3.1.3. Production or Drill Centre Manifolds

Details of the DC manifolds to be installed are as follows:
 DC6 and DC7: 4 slot manifold;
 DC8: 2 or 4 slot manifold; and
 DC9: 2 slot manifold.
All DC manifolds will include chemical injection points for injection into the produced fluids.
The manifolds will not be overtrawlable. However, they will be designed as snag-free structures taking into
account fishing gear loads and impacts from dropped objects. This is the same approach taken with the
structures already located on the seabed at Penguins. The DC manifolds will be secured to the seabed
using 4 piles.
3.3.1.4. Risers
The FPSO will be connected to the subsea equipment by dynamic flexible risers and a dynamic control
umbilical. Each riser will be approximately 450 to 500 m in length, in a tethered wave arrangement with
buoyancy modules and hold down/hold back anchors. The riser system will comprise:
 One 10" HP production riser (HP Production System);
 One 10" LP production riser (LP Production System);
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PROJECT DESCRIPTION
 A 10" gas export riser which may be later reduced to a 8" riser following the results of an
optimisation study;
 A 6" gas lift riser; and
 A dynamic control umbilical.
As noted above, a dynamic control umbilical will be included within the riser system. The umbilical will
include cores for hydraulic and chemical supply, electrical cores for power/signal and fibre optics. The
umbilical will terminate subsea with an umbilical termination assembly (UTA) installed within the riser base
manifold (RBM) structure.
3.3.1.5. Riser-Base Manifold and Pipeline End Manifold

The RBM will terminate the dynamic risers and umbilical and also allow subsea pigging from the infield
infrastructure to the riser base. The RBM will provide Subsea Isolation Valves (SSIVs) for each of the risers
(gas export, gas lift, HP & LP Production). The manifold will be located within 500 m of the FPSO
geostationary point and outside the mooring footprint to allow access for interventions.
A Pipeline End Manifold (PLEM) will be installed at the southerly end of the new 16" gas export pipeline to
tie into the existing NL-WL PLEM for entry into the FLAGS system.
3.3.1.6. Flowlines and Pipelines

The project will use the existing pipelines where possible but will also require the installation of the
following new pipelines:
PIPELINE LOCATION LENGTH
10" HP production flowline (pipe-in-pipe From the RBM to DC6 (via 18 km

within 16" Carrier) DC9, DC8 and DC7)
10" Low Pressure (LP) production flowline 2.75 km
From the RBM and DC9
(Pipe-in-pipe within 16" Carrier)
6" HP production flowline (pipe-in-pipe 2.5 km
From DC6 to PAN-N well
within 10"Carrier)
4" gas lift pipeline piggybacked to the 6" HP 2.5 km
production flowline (pipe-in-pipe within From DC6 to PAN-N well
10"carrier)
6" gas lift line From the RBM to DC6 (via 18 km
DC9, DC8 and DC7)
16" gas export pipeline From the FPSO to DC9. At DC9 2.75 km
it will tie-back to existing 52
km 16" multiphase pipeline
(pipe-in-pipe with 22" carrier)
to Brent Charlie
16" gas export pipeline From the existing Brent Charlie 7 km

SSIV to the Penguins Gas
Export PLEM structure tied-in to
the NL-WL PLEM.
Total pipeline length 54 Km
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PROJECT DESCRIPTION
3.3.1.7. Pipeline Protection and Crossings

All new flowlines and pipelines will be surface laid due to the seabed conditions and the presence of
numerous boulders. Rock-dump may be required in specific areas to mitigate upheaval buckling, provide
protection at pipeline crossings and to ensure that there are no freespan areas. Mattresses and grout bags
will also be required to support or protect pipelines at crossings and tie-in locations. A total of 600
mattresses are estimated to be required. No trenching is anticipated.
All flowlines and pipelines less than 16" diameter will be rock-dumped for protection as such rock dump
for the full 20.5 km of pipeline has been assumed as this represents the environmentally worst case. It is
estimated that a total of 7 tonnes of rock per meter will be required. For the purpose of rock dumping
estimations, the 4" gas lift pipeline is not included (2.5 km) as this is piggybacked to the 6" HP production
flowline. Based on this information the anticipated width of impact associated with pipeline protection is
approximately 0.3348 km2.
The existing multiphase pipeline crosses a number of shell operated and 3rd party pipelines and umbilicals
which are listed below. Further pipeline crossings will be required as a result of the project; however the
exact details will be determined during the detailed design stage.
 16" Oil Murchison to Dunlin;
 6" Gas Murchison to Thistle A;
 Umbilical NLGP tie-in to Murchison;
 12" Gas NLGP to Statfjord B;
 Umbilical NLGP to Statfjord B; and,
 Brent C – Brent B Pipeline (out of service).
3.3.1.8. Subsea Control System

Control, utilities and chemicals will be provided to the DC manifolds and wells via an umbilical system that
runs parallel to the infield pipeline. Umbilicals will be connected to equipment using jumpers.
The existing control system will be tied into the new control system via an umbilical between DC9 and the
existing DC5 umbilical terminal server (UTS) structure.
3.3.2. Floating, Production, Storage and Offloading (FPSO) Unit

The FPSO selected for Penguins has a cylindrical hull, with a storage capacity of 63,600 m3 (400,000
bbls). It will be moored using a spread-mooring system eliminating the need for a swivel/turret. Risers and
umbilicals will connect to the FPSO through i-tubes located in the outer ballast tanks.
The process deck (referred to as the topside) is divided in two areas: the hazardous process area and the
non-hazardous accommodation and utility area. The areas are separated by a fire and blast wall. The
lifeboats and living quarters are situated on the opposite side of the FPSO to the process area. The FPSO is
also equipped with a flare, cargo offloading facilities and a helideck. Figure 3-7 shows the arrangement
of the FPSO.
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PROJECT DESCRIPTION
Figure 3-7 Penguins FPSO Layout
3.3.2.1. Capacities
The processing design capacities for Penguins FPSO are provided in Table 3-5.
Table 3-5 Penguins Processing Design Capacities
SYSTEM DESIGN BASIS
Oil Processing Capacity 5,440 m3/day

Produced Water Processing Capacity 190 m3/day
Total Liquid Processing Capacity 5,490 m3/day
Maximum Gas Processing Capacity (includes recycled gas lift) 3.40 x 106 sm3/day
Gas Lift 1.16 x 106 sm3/day
Oil offloading capacity 4,500 m3/hour
3.3.2.2. Processing and Export Facilities

The processing and export facilities will be designed to meet the stated quality specifications for oil and gas
export, and produced water discharges. Oil will be temporarily stored on the vessel and offloaded to
shuttle tankers. Gas will be compressed, dehydrated and exported through an export pipeline that will join
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PROJECT DESCRIPTION
the existing FLAGS pipeline system. Gas will also be used for gas lift and fuel gas. Produced water will be
treated and discharged overboard.
A simplified process flow diagram for the Penguins topsides is provided in Figure 3-8.
3.3.2.2.1. Oil Processing System

The oil processing system will consist of the following:
 Inlet heater;
 1st stage separator;
 Interstage heater; and
 2nd stage separator.
The produced fluids will flow through the HP and LP production risers into the inlet heater before entering
the 1st stage separator. The inlet heating ensures that the incoming fluids are free of wax precipitation and
also improves oil-water separation by lowering the viscosity of the fluids.
The heated fluids will be separated in 1st stage separator. This is a horizontal GLL (gas / liquid / liquid)
separator. The separated gas will enter the gas processing system for fuel use or export into the FLAGS
system to St Fergus. Produced water will be treated by the produced water treatment system
(hydrocyclones/degasser) before been discharged overboard. Crude will continue through the interstage
heater to the 2nd stage separator. Any additional gas recovered at the 2nd stage separator will enter the LP
compression system before being fed into the High Pressure (HP) gas compression system where it will be
used for fuel gas or exported into the FLAGS system. Any water recovered at this stage will enter the
produced water system for treatment before discharge to sea. Final treated oil from the 2nd stage separator
will be cooled and stored in cargo tanks before offloading to export tankers. A reeled offloading system
will be used to transfer the oil to the export tankers.
3.3.2.2.2. Gas Processing System

The gas processing system will consist of the following:
 HP gas compressor;
 glycol contactor;
 LP gas compressor; and
 metering.
The gas from the 1st stage separator will be compressed and dehydrated to meet export specifications. The
HP gas compression system comprises three stages of gas compression including the glycol contactor where
moisture is removed from the gas stream to produce dry gas. This system will be driven by a dedicated gas
turbine with a rated capacity of 16,000 Kw. Dry gas can then be either utilised as fuel gas, lift gas or
exported into the FLAGS pipeline to St Fergus.
The LP gas compression system compresses gas from the 2nd stage separator and volatile organic
compounds (VOCs) from the crude storage tanks allowing it to be fed back into the HP gas stream.
Fiscal metering will be installed on the gas system for measurement of imported gas, fuel gas, flare gas and
gas exported. The import gas option is been considered during the detailed design in order to meet
fuelling requirements during times when fuel gas is unavailable for start-up, gas-lift, and gas blanketing.
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PROJECT DESCRIPTION
Figure 3-8 Penguins FPSO Process Flow Diagram
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PROJECT DESCRIPTION
3.3.2.2.3. Produced Water

The produced water which is separated from the produced oil and gas will be discharged overboard.
The produced water treatment system will be designed to process the peak water rate expected for the
Penguins Fields (190 m3/day or 1,200 barrels/day). However, provision has been made in the design to
allow for future expansion to 10,000 barrels/day to allow for the processing of additional produced water
from any future third party tie-backs from other fields. The produced water treatment system consists of the
following:
 Produced water hydrocyclones;
 Produced water degasser;
 Metering system; and
 Produced water disposal caisson.
Produced water from the 1st and 2nd stage separators will enter the produced water treatment system.
Produced water first enters the hydrocyclones where oil is removed. The lighter oil phase migrates into the
core and is removed from the produced water stream. Produced water then enters the produced water
degasser where light end dissolved hydrocarbons are removed. These gaseous hydrocarbons are
recovered to the process by the Vapour Recovery Unit.
The produced water system is designed to ensure oil in water (OIW) quality of less than 30 mg/l. As per
relevant legislation, flow measurement and sampling facilities will be provided on the discharge line to sea.
The produced water will be discharged to sea via a produced water caisson. Any off-spec produced water
will be routed to the slops tanks for further treatment.
3.3.2.2.4. Crude Storage and Offloading

Stabilised crude oil from the 2nd stage separator will be pumped to the crude oil cooler. The crude oil will
be stored in cargo tanks prior to offloading to the export tanker. Blanket gas for the storage tanks will be
hydrocarbon (HC) gas taken from the fuel gas system. An inert gas generator will be installed as a back-
up to HC gas blanketing in event that the fuel gas system is unavailable. Volatile Organic Compounds
(VOCs) and blanket gas from the cargo tanks will be recovered through the vapour recovery units (VRU)
back to the LP compressor and then to the HP compression system.
The offloading strategy is to utilise ‘standard’ North Sea Dynamic Positioning (DP) shuttle tankers with DP2
capability. A full offloading parcel of 54,000 m3 will be pumped to a shuttle tanker in a period of 12 hrs.
3.3.2.2.5. Gas Export

In the normal FPSO operating mode, processed dehydrated gas exiting the last stage of compression will
undergo fiscal metering and will be routed from the FPSO to the gas export pipeline which is tied-in to the
FLAGS pipeline. Facilities for importing gas through the gas export pipeline are been considered in
detailed design to address fuelling requirements during process start-ups (i.e. well gas lift, for fuelling the
HP compressor turbine and as purging and blanketing gas).
3.3.2.3. Flare System

The flare system will be divided into two separate streams, HP releasing hydrocarbons above 10 barg
pressure and LP releasing hydrocarbons from sources with a pressure less than 10 barg. There will be no
routine flaring.
Each system will consist of a network of flare pipes and headers, releasing hydrocarbons to dedicated
knock-out (KO) drums and flare tips. The LP flare KO drum shall also function as a closed drain drum
where hydrocarbon liquids are drained by gravity to the drum.
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PROJECT DESCRIPTION
The HP flare system will be designed for all pressure and relief scenarios, and gather and safely dispose of
hydrocarbon fluid discharges from moderate to high pressure sources such as flow lines, gas compression
systems, primary separator and heat exchange equipment, etc. The HP flare system will consist of multiple
flare headers for high / low temp and high / low pressure scenarios.
The atmospheric (LP) flare system will be used to safely dispose of recovered gas from vessels operating at,
or near atmospheric pressure in the event of an emergency or process trip. A Vapour Recovery Unit (VRU)
will be fitted to recover gas from the cargo tanks; a review will be performed during the define project
phase to determine which other sources may be directed to this.
3.3.2.4. Utilities and Living Quarters
3.3.2.4.1. Power Generation

The main power generation system for the FPSO will comprise three gas turbine driven generators with a
rated capacity of 6,680 kW each. All turbines installed for power generation will be capable of dual fuel
(fuel gas and diesel).
The emergency diesel generator will have a rated capacity of 2,660 kW and will provide power to
equipment such as radio and navigational equipment, emergency lighting, un-interruptible power source
(UPS) and other life support systems.
The emissions associated with FPSO power generation are estimated in Chapter 8.
3.3.2.4.2. Diesel System

The main purpose of the diesel oil system is to bunker, store, purify and distribute diesel to the turbine
generators and intermittent consumers. Intermittent consumers comprise:
 Inert gas generator.
 Fire pump engine day tanks.
 Emergency generator day tank.
 Lifeboat stations.
The diesel oil system comprises two diesel storage tanks, a diesel settling tank and a diesel service tank. The
diesel storage tanks are part of the hull structure. The settling and service tanks are vertical steel tanks
located at main deck level. Diesel storage tanks design capacity is 25 days at maximum diesel
consumption.
3.3.2.4.3. Sewage and Grey Water

A comminution system will macerate waste from accommodation (associated with black and grey water
including mess and galley) and run this through the Living Quarter drainage system for overboard
disposal.
3.3.2.5. Drainage system

The open drains are gravity based atmospheric drains collecting surface waste liquids. The FPSO topside is
divided in two areas: the hazardous process area and the non-hazardous accommodation and utility
areas. The FPSO topsides open drainage system consists of segregated hazardous and non-hazardous
drainage areas.
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PROJECT DESCRIPTION
3.3.2.5.1. Open Non-Hazardous Drainage System

The open non-hazardous drainage system provides drainage to areas designated non-hazardous. These
areas are segregated from all other drainage systems to eliminate the possibility of flammable vapour
transmission through the drains from other areas. Drainage into this system is via open gullies, drip pans,
floor drains and a tundish for instrument drains.
The collected liquid flows by gravity into the non-hazardous open drain tank, where oil in water content is
reduced to less than 15 mg/l before been discharged overboard. Flow measurement and sampling
facilities will be provided on the discharge line to sea as per relevant legislation requirements.
3.3.2.5.2. Open Hazardous Drains

The open hazardous drains system provides drainage from those areas which are designated hazardous
(process area and main deck). The drainage from hazardous areas are completely segregated from any
other drainage system to eliminate the risk of hydrocarbon vapour transmission to other areas.
The open hazardous drains system handles liquids collected from decks, drip pans, main deck gullies and
tundishes in hazardous areas. The collected liquid flows by gravity into the hazardous open drain tank,
where oil in water content is reduced to less than 15 mg/l before been discharged overboard. Flow
measurement and sampling facilities will be provided on the discharge line to sea as per relevant
legislation requirements. If the water quality is off-specification this stream can be routed to the slops tanks
for further treatment.
3.3.2.6. Hull Tank Arrangement

The FPSO will have 19 ballast tanks, 13 cargo tanks, 2 diesel tanks, 2 slop tanks and a miscellaneous tank.
The tank arrangement is illustrated in Figure 3-9.
The cargo tanks will be used to store processed crude oil ready for offloading via shuttle tanker.
The slops tanks will be used to collect liquids such as settled water from the Cargo Tanks (produced water),
off-spec produced water and flushing liquid from the offloading hose. The slops tanks have a capacity of
1,500 m3 each (9,400 bbls each). These tanks allow further oil / water separation by gravity. If effluent is
not within the specification for overboard discharge, an additional drains-slops polishing unit treatment will
be available.
The ballast tanks are positioned outward of the cargo tanks to function as a double hull.
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PROJECT DESCRIPTION
Figure 3-9 Hull Tank Overview
3.3.2.7. Mooring system

The FPSO will use a spread mooring system in a semi-taut configuration. The mooring system consists of
three clusters of 4 mooring lines. The mooring clusters are separated at 120 degree intervals. The mooring
lines will be constructed of polyester, using long segments of polyester ropes, with chain at the upper and
lower sections.
Figure 3-11 illustrates the layout and profile of the mooring lines.
The footprint of this semi-taut mooring system will extend outside the 500 metres safety zone.
The mooring lines will be secured to the seabed using piles. The hammer-driven piles will be 2.5 m
diameter and 25 m long.
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PROJECT DESCRIPTION
Figure 3-10 Mooring Line Layout and Profile
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PROJECT DESCRIPTION
3.3.3. Project Footprint

Table 3-6 sets out the indicative temporary and long term footprint of the project.
Table 3-6 Summary of Project Footprint
ASPECT FOOTPRINT DESCRIPTION AREA (km2)

Temporary
MODU anchors and 8 x anchors. Mooring lines of 1,100 m length of which 300 m 0.0768
mooring is expected to contact the seabed with 4 m lateral movement.
Assuming deployment of MODU at 8 drilling locations (5
locations in Tranche 1, 1 location in Tranche 2 and 2 locations in
Tranche 3).
Long Term
FPSO anchor piles 12 x anchor piles of 2.5 m diameter. Mooring lines of 0.0025
and mooring 1,600 m length of which 200 m is expected to contact seabed
with 1 m lateral movement.
Production trees 10 x trees of 4.9 m x 4.9 m area installed on production wells. 0.0002
(10 new wells and 1 side track)
Manifolds 4 production manifolds (DCs), 1 Riser Base Manifold (7 m x 0.0004
10 m each) and 1 Pipeline End Manifold (5 m x 8 m).
Pipelines 54,000 m length of pipeline of 0.5 m diameter 0.0270
Production risers 5 x 350 m risers lays on seabed 0.0018
Control umbilicals 20,500 m of umbilicals (included in estimate for rock N/a
dumping)
Tree supply control 9 x 30 m length and 2 x 250 m length (included in estimate N/a
jumpers for concrete mattresses)
Tie-in spools 95 x 25 m length (included in estimate for concrete mattresses) N/a
Rock dumping 20,500 m with rockberm base of 15 m which includes: 0.3240
(140,000 tonnes)
A. 18,000 m over combined Gas Lift and umbilical
B. 2,500 m over 10" PAN-N carrier pipe / 4"
piggyback Gas Lift and umbilical laid adjacent to Gas
Lift
500 m of crossings between Brent Charlie and Brent Alpha
with rockberm base of 18 m
500 m of additional rockdump coverage as contingency with
rockberm base of 15 m
Concrete mattresses 600 x concrete mattresses of 6 m x 3 m area 0.0108
Temporary Footprint (during drilling) 0.0768

Long Term Footprint (throughout installation and operation) 0.3666
Total 0.4434
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PROJECT DESCRIPTION
3.4. MAIN PROJECT ACTIVITIES
3.4.1. Drilling
3.4.1.1. MODU
The wells will be drilled by a moored semi-submersible Mobile Offshore Drilling Unit (MODU). It will be
held in position using up to eight anchors.
The anchor mooring spread will be defined by a mooring analysis which will be undertaken prior to the
MODU arriving in-field and will take account of water depth, currents, prevailing wind conditions and any
seabed features at the drilling location. Each anchor will weight approximately 15 tonnes with the mooring
lines (chains) measuring approximately 1100 m in length. The anchors will produce a linear scar of
approximately 50 m length during setting before sinking into the seabed. The anchors and chains will be
recovered on completion of drilling before the MODU departs. Whilst in position, a statutory 500 m safety
zone will be established around the MODU. Unauthorised vessels will not be permitted within this area.
Details of the selected MODU will be included in the subsequent drilling operation drilling applications
which will be submitted to DECC via the UK Oil Portal. Details of the placement of anchors as well as any
possible contingency rock-dumping required for stabilisation will be provided in the Consent to Locate.
Figure 3-11 Deepsea Delta, an Indicative Moored Semi-Submersible MODU
3.4.1.2. Drilling Process

Drilling uses a rotating drill bit attached to the end of a drill pipe (the ‘drill string’) to bore into the earth to
reach oil and gas deposits. The first stage in drilling (known as ‘spudding’) is to place a conductor and
surface casing (including a wellhead) into the seabed which will allow the MODU to be connected to the
well via a blowout preventer (BOP) and marine riser. Once this is in place, drilling continues using a series
of two to three (or more) progressively smaller diameter drill bits and casings which are cemented in place
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PROJECT DESCRIPTION
forming a seal with the formation. The majority of the wells will use a conventional five casing design.
Rockhopper will use a four casing design and E1ST and C Updip will use a six casing design.
The drilling campaign will use a 689 bar (10,000 psi) BOP fitted with pipe rams and shear rams capable
of shearing the drill-pipe and closing the well in the event of an emergency. The BOP’s rated pressure is
higher than that expected within the reservoir.
The rotating drill bit breaks off small pieces of rock (called drill cuttings) as it penetrates rock strata. The
cuttings typically range in size from clay to coarse gravel and their mineral composition will vary
depending on the types of sedimentary rock penetrated by the drill bit.
Drilling fluids (also called muds) are pumped down the drill string during drilling to maintain a positive
pressure in the well, cool and lubricate the drill bit, protect and support the exposed formations in the well
and lift the cuttings from the bottom of the hole to the surface. Drilling fluids are slurries of various solids
and additives (used to control the fluids’ functional properties such as density). For the top-hole sections
(36" and 26") the drilling fluids (mainly seawater) and cuttings are discharged onto the seabed but once
the surface casing is in place the drilling fluids can be re-circulated between the MODU and the well.
Returned drill cuttings and drilling fluid will be separated and cleaned on the MODU using solid control
equipment, typically shale shakers.
There may be small discharges of cement from the top-hole when casings are cemented back to the
seabed.
3.4.1.3. Types of Drilling Fluids

There are broadly two types of drilling fluid used in offshore exploration and development drilling
operations namely water based fluids or muds (WBMs) and oil based drilling muds (OBM). For both types
of drilling fluid a variety of chemicals are added to the water or base oil to modify the properties of the
fluids. Additives include clays and barite to control density and viscosity and polymers such as starch and
cellulose to control filtration. The type of drilling fluid used for a particular well or drilling programme will
depend largely on the technical requirements of the well, local availability of the products and the
contracted drilling fluid supplier. Often, both WBMs and OBMs are used in drilling the same well. WBMs
will be used to drill the top sections of the well and then OBMs will be used for the deeper sections to the
bottom of the well.
OBMs are often required for particular sections of the well as they offer better well stability (particularly
when drilling through water-sensitive formations such as shales). They also offer better lubricity and high
temperature stability and reduce the formation of gas hydrates (which is a particular issue for deep sea
wells). In addition, OBM use results in more efficient drilling, fewer drilling problems and requirement for
remedial work, thereby reducing the potential for health and safety risks.
For the Penguins wells, seawater and bentonite sweeps (water based fluids) will be used to drill the upper
sections (36" and 26") of each well and a Low Toxicity Oil Based Mud (LTOBM) will be used for the mid
and lower sections of each well sections (16", 12 ¼", 8 ½" and where relevant the 6"). In alignment with
company policy and legislative requirements, all LTOBM-contaminated fluids will be totally contained
within a closed loop system. The contaminated LTOBM and cuttings will be returned to the drilling rig
through the mud return line and will fall over a series of vibrating, screen-like devices, known as shale
shakers, which will sieve the cuttings from the mud. The recovered mud will be recycled back down the hole
by the mud pump. The LTOBM contaminated cuttings will be skip and ship to shore for disposal.
The volume of cuttings for the first seven wells (Tranche 1) is set out in Table 3-7. Each of the four potential
Tranche 2 and 3 wells is estimated to produce a similar volume of cuttings as well C4B. It is estimated that
a total of 5,042 tonnes of WBM cuttings resulting from 11 wells will be discharged to sea.
Full details of the mud volumes and other chemicals to be used at each well will be provided in subsequent
drilling permit applications.
3-31
PROJECT DESCRIPTION
Table 3-7 Estimated Cuttings (tonnes) and Disposal Route
WELL ROCK-
C4B CT PAN-N PAN-W C UPDIP E1S1 FATE
SECTION HOPPER
36" 102 94 107 107 107 110 - Discharge to seabed
26" 381 380 541 541 394 - - Discharge to seabed
17½" - - - - - 246 - Discharge to seabed
16" 296 384 426 464 322 - - Onshore treatment
12¼" 433 228 420 386 348 382 379 Onshore treatment
8½" 57 172 97 101 26 111 4 Onshore treatment
6" - - - - 53 - 11 Onshore treatment
Total (tonnes) 1,269 1,258 1,591 1,599 1,250 849 394
3.4.1.4. Well Clean-up and Completions

After drilling is complete, the wells will be secured with a liner system that will be cemented in place.
Following this a wellbore clean-up will take place to remove mud from the well using surfactants and either
a clear weighted brine or seawater. Once the well is clean the upper completion can be run. Well
completion is the process of making wells ready for production.
Most completions will be designed to allow future access to the reservoir for well surveillance, data
gathering and reservoir management purposes. The upper completion design will incorporate a polished
bore receptacle (PBR), permanent downhole gauges, gas lift mandrels as required (oil wells only) and
surface controlled subsurface safety valve (SCSSV). The completion tubing size will be either 5½" or 4½",
and will be selected on an individual well basis to optimise flow performance.
Artificial lift will be provided by gas-lift where required. Downhole chemical injection is not anticipated to
be required.
3.4.1.5. Testing
The wells will be tested for performance by measuring flowrates and pressures under a range of conditions.
A limited amount of fluid is allowed to flow through the formation and wellbore being tested and will be
disposed of via a well test package and flare on the rig. There are no plans to carry out extended well tests
(> 96 hrs).
Information on well test flaring will become available during the detailed design stage. Well clean-up will
be specified on an individual well basis, and will be defined during the detailed design phase. The options
to be assessed and therefore assumed in this EIA include:
 Clean the well up after perforating by flowing to a well test spread on the rig; and
 Clean the well up by flowing to the FPSO after the well has been handed over to the Operations.
During the well completion process, the brine will be displaced to base oil through a sliding side door
(SSD) to underbalance the well prior to production.
Hydrocarbons produced during well clean-up will be flared. Once the wells have been cleaned-up, they
will be closed in before being connected to the new infrastructure.
3-32
PROJECT DESCRIPTION
3.4.1.6. Interventions
Given the extended life of the Penguins field, it is anticipated that well intervention will be required on
existing and proposed wells to enhance recovery of well fluids. Well interventions involve downhole re-
entry inside an existing completion and will be carried out from a dedicated vessel to be confirmed as the
need for well intervention arises.
3.4.2. Installation
3.4.2.1. Subsea Infrastructure

The following is a summary of subsea infrastructure installation. The timing and the estimated duration is
also provided.
 Pipelines will be installed by a reel lay vessel and will take approximately 68 days to complete in
year 1 (summer season);
 Umbilicals will be installed by a reel lay vessel and take approximately 42 days and be
undertaken in the summer of year 1;
 The gas export PLEM, the four production manifolds (DCs) and the RBM will take approximately 6
days each to be installed (assuming individual load-outs and transits) in the summer season of
year 2. Depending on the final designs an ROV support vessel (ROVSV) or a heavy lift vessel
(HLV) may be used for installation; and
 Riser installation will take approximately 30 days and will be undertaken in the summer season of
year 3.
The most commonly adopted piling method for subsea manifolds and protection structures is the Spring-lok
connection system that enables diverless driving of the piles. A total of 6 manifolds will be installed, each
requiring 4 piles. The piling installation duration for the 24 piles is expected to be completed in 12 days.
3.4.2.2. Conversion of Multiphase Pipeline

The conversion of the existing multiphase production line to the gas export pipeline is anticipated to be
executed in Year 1 and will entail a pipeline flushing and cleaning scope:
 Pipeline blowdown to approximately seabed ambient pressure and isolation at each tree and each
drill centre manifold;
 16"/22" pipe-in-pipe pipeline flushing, using inhibited seawater, to displace the production fluids
from DC3 to the Brent Charlie Platform. The flushing process will likely utilise chemicals and
potentially debris pick-up gels to remove any loose solids. Pipeline flushing activities will be
performed from DC3. The existing 10" pipeline between DC2 and DC3 will be left hydrocarbon
filled at subsea ambient pressure and isolated from the 16"/22" pipe-in-pipe pipeline until start-
up of the Redeveloped Penguins Fields.
 Foam pigs to prove bore and perform initial cleaning;
 Mechanical cleaning pigs; and
 The pipeline will then be disconnected from the existing Drill Centre 5 downstream tie-in point and
the existing Brent Charlie SSIV upstream tie-in point and left inhibited seawater filled until it is
connected to the new gas export infrastructure and undergoes a change of service.
3.4.2.3. FPSO
The mooring system will be installed and load tested before the FPSO arrives on site. The mooring pile
anchors will be driven into the seabed. It is anticipated that this operation including bottom chain
installation will take approximately 38 days to complete and will be undertaken in the summer season of
Year 2.
3-33
PROJECT DESCRIPTION
The FPSO will be towed to location. Following its arrival, hook-up of the mooring system will be performed
by a dynamically positioned vessel.
3.4.3. Pre-Commissioning and Start-up

Pre-commissioning is the process of proving the integrity of pipelines and piping systems. It typically
involves the following:
 cleaning – removing any debris from within the pipeline;
 gauging – checking the internal diameter of the pipeline;
 filling (flooding) – done in order to propel ‘pigs’ through the pipeline for cleaning and
maintenance;
 hydrotesting – pressure testing to a pressure over the pipelines intended operating pressure; and
 dewatering – using pigs propelled by gas to remove water from the pipeline.
Subsea discharges of treated seawater (biocide, corrosion inhibitor and dye) from flooding, cleaning and
gauging (FCG) are expected during testing.
It is assumed that Monoethylene Glycol (MEG) will be used for dewatering.
3.4.4. Production
The Penguins production fluids (comprising a mix of oil, water and associated gas) will be transported
through the subsea flowlines and onboard the FPSO via two risers. As with the existing wells, all new wells
will be produced under natural depletion with gas-lift available to enhance production rates if required.
The processing facilities will be designed to meet the stated quality specifications for oil and gas export,
and produced water discharge to sea. Oil will be temporarily stored on the vessel and offloaded to shuttle
tankers. Gas will be compressed, dehydrated and exported through the gas export pipeline tied into the
existing FLAGS pipeline system. Gas will also be used for gas lift, fuel gas and cargo tank blanketing.
Produced water will be treated and discharged overboard.
An indicative chemical usage during operations is set out in Table 3-8. The chemical applications below
are widely used in the UK North Sea. Once specific chemicals are identified, a site specific risk assessment
will be conducted as part of the Chemical permitting process.
3-34
PROJECT DESCRIPTION
Table 3-8 Penguins Redevelopment Chemical Injection Requirements
CHEMICAL NEED CURRENTLY INJECTION POINT INJECTION TYPICAL CON- MAXIMUM 7 DAYS VOLUME
FUNCTION USED? STREAM CENTRATION INJECTION RATE
Demulsifier Improve oil dehydration No Upstream 1st stage Gross liquid 1 – 10 ppmv 0.06 m3/d 0.4 m3
to meet cargo spec separator & test
separator
De-oiler Improve produced water No Separator water Produced water 1 – 50 ppmv 0.003 m3/d 0.02 m3
quality to meet discharge outlets/upstream
spec hydrocyclones
Antifoam Prevent separator liquid Yes Upstream 1st stage Gross liquid 1 – 10 ppmv 0.06 m3/d 0.4 m3
carryover separator & test
separator
H2S Scavenger Reduce gas H2S Yes 1st stage separator & Produced gas ~20 kg/kg H2S 0.61 m3/d 4.3 m3
concentration to meet test separator gas
export spec offtake
Biocide Inhibit microbial growth No Inlet to slops Produced water 500 ppmv batch 3 m3
in slops tanks and treatment for 2
prevent corrosion hours twice a
week
Corrosion Protect LP carbon steel Yes Subsea manifolds Gross liquid 200 – 300 ppmv 0.5 m3/d 7 m3
Inhibitor pipeline from corrosion
Scale Inhibitor Inhibit any scale No Subsea wellheads Produced water 5 – 50 ppmv 0.003 m3/d 0.02 m3
formation downstream of
wellhead
Wax Inhibitor Prevent wax build up in No Subsea manifolds Oil 200 – 1000 0.8 m3/d 5.6 m3
subsea flowlines ppmv
Note: Methanol is not included in the table as its volume is not known yet.
3-35
PROJECT DESCRIPTION
3.4.4.1. Production Profiles

The expected oil and gas production profile for the project lifetime is provided in Figure 3-12. Oil
production in the first year is forecast to be up to 850 tonnes per day, rising to a maximum of 2,740
tonnes per day the following year. It is then expected to decline sharply to 670 tonnes per day by the 6th
year in production, and then decline more gradually to 130 tonnes per day after 20 years of production.
Gas production rates are expected to follow a similar profile, starting at 550 m3 per day in the first year,
increasing to a peak of 2,440 m3 per day on the third year of production, and decreasing more gradually
than oil to 290 m3 per day after 20 years of production.
3,000 3,000
Oil Gas
2,500 2,500
OIl (tonnes/day)
2,000 2,000
Gas (m3/day)
1,500 1,500
1,000 1,000
500 500
0 0
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Year 20
Year 21
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Years in production
Figure 3-12 Oil and Gas Production Profile (High case)
The expected produced water profile for the project lifetime is provided in Figure 3-13. The volume is
highest in year one at 190 m3 per day. It is expected to reach a plateau of approximately 100 m3 per day
after 6 years into production. The volumes of produced water from the Penguin fields are considered
modest due to the prevailing operating philosophy and reservoir energy capacity.
250
Water production (m3/day)
200
150
100
50
0
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Year 20
Year 21
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Years in production
Figure 3-13 Produced Water Profile (High case)
3-36
PROJECT DESCRIPTION
3.4.5. Support Operations

The number and type of vessels supporting the redevelopment will vary depending on project phase.
 Drilling: The MODU will be towed to location via a route selected in consultation with other sea
users to minimise disruption by a number of Anchor Handling Vessels (AHVs). During drilling, it
will be serviced by supply vessels. The supply vessels will transport drilling equipment and supplies
to the MODU and return wastes and surplus equipment to shore. While infield the MODU will be
accompanied by an ERRV.
 Installation: A number of vessels will be required during installation and hook-up including a reel
lay vessel, supported by survey/utility vessel; a diver support vessel (DSV) for tie-in activities;
Anchor Handling Vessels (AHV) for mooring installation; and either an ROV support vessel
(ROVSV) or a heavy lift vessel (HLV) depending on the final design of the manifolds. All vessels
involved in the installation activities are expected to be dynamically positioned (DP).
 Operation: The FPSO will be supported by supply vessels and a dedicated ERRV.
Helicopters will be used to transfer personnel.
Table 3-9 sets out the indicative number of work-days per vessel type during the project. Fuel use and
emissions are estimated in Chapter 8.
Table 3-9 Estimated duration for usage of vessels (number of work-days)
TUG BARGE ANCHOR HEAVY TOWING

HANDLING CONSTRUCTION TUG
VESSEL VESSEL
Mobilisation 6 3 6 4 9
/Demobilisation
Transit 2 5 9 7 3
Working 7 5 42 21 28
Growth 2 2 9 5 6
Total 17 15 66 37 46
3.4.6. Decommissioning
Decommissioning will be carried out in compliance with UK Government legislation and international
agreements in place at the end of the field life. Agreement to the Cessation of Production (CoP) will be
sought from DECC as a pre-requisite for approval of the Decommissioning Programme. Consideration will
be made in the design, construction and operational phases of the development to matters that will
facilitate decommissioning of the field facilities.
It is anticipated that the FPSO will be towed off field, potentially re-used or recycled elsewhere. The
mooring lines for the FPSO will be removed. Wells will be plugged and abandoned and any spools and
structures removed. All other subsea structures, including the PLEM, will be removed.
Pipelines will be subject to a Comparative Assessment to determine the best decommissioning option on the
basis of five main criteria (Safety, Environment, Technical, Societal and Economic). A decommissioning
programme and associated EIA will be prepared in support of any decommissioning activities as per
regulations.
3-37
PROJECT DESCRIPTION
3.4.6.1. Well Abandonment

At Cessation of Production (CoP), each well will be abandoned in accordance with the provisions of Shell
Technical Standards and regulatory guidance at the time. The abandonment design will be specified on an
individual well basis, and is likely to consist on the following:
 The reservoir formations will be abandoned by setting a composite cement plug above the
completion Polished Bore Receptacle (PBR)
 An environmental plug will be set at a shallow depth in order to contain any residual oil-based
mud within the well.
3.5. PROJECT UNCERTAINTIES

This ES was prepared during the design process for the proposed development and, as such, some
assumptions have been made in order to undertake the EIA. Where assumptions have been made, the
environmentally ‘worst case’ option was assessed in line with the EIA Regulations Guidance. The
assumptions and uncertainties detailed in Table 3-10 were made for the purposes of conducting the EIA
and preparing this ES.
Table 3-10 Uncertainties and Assumptions
SUBJECT ASSUMPTION
Currently the Well Engineering Team is conducting an optimisation exercise which may
cause some wells to move locations within a maximum of 1 Km radius (subsurface
Well locations
targets are unchanged). As a result the location of the FPSO and associated pipelines
may be subject to change.
A pipeline bundle system is being assessed to potentially replace the current base case
of single, rigid pipelines (pipe in pipe).
The bundle system will incorporate all of the services for the production and the gas
Subsea
export such as the HP and LP production lines, gas lift, controls and gas export line.
pipeline
This will reduce the project’s footprint. For the purposes of the ES, the single rigid
optimisation pipeline system will be assumed as this represents the largest footprint on seabed.
At the time of writing this ES, the final locations for the Drilling Centres are yet to be
determined pending the outcome of the wells optimisation exercise.
At the time of writing this ES, the final FPSO location is yet to be determined pending
FPSO location
the outcome of the wells optimisation exercise.
Maximum anticipated quantities of rockdump and mattresses are presented in the ES to

assess the worst case scenario in terms of impacts on the seabed. The requirements for
Pipeline
rockdump, mattresses and grout bags will be further assessed and confirmed in
protection Subsidiary Application Template (SAT) applications / Pipeline Works Authorisation
(PWA) applications and supporting Deposition Consent (DepCon) applications.
Combustion Due to on-going project developments, the exact model of the gas compressor and
Equipment power generators to be utilised onsite are still be to determined. The most-conservative
and Emissions case option, in terms of emissions, is used for this assessment.
3-38
ENVIRONMENTAL BASELINE
4. ENVIRONMENTAL BASELINE
4.1. OVERVIEW
This chapter provides a description of the physical, biological and human baseline in the Penguins
Redevelopment Project area and surrounding marine areas. This chapter draws upon a number of
previously commissioned environmental surveys and data collected from a variety of sources. These are
shown in Table 4-1. The studies and surveys covered a number of locations which will be affected by the
Project. Their coverage can be seen detailed on Figure 4-1.
As identified in the Chapter 3 - Project Description, when reference is made to the project area, this is
considered to include the area around the existing Penguins field and the proposed works within Blocks
211/13a and 211/14 REST. When reference is made to the new gas export pipeline in Block 211/29
this will be referred to as the Brent area.
Table 4-1 Previous Studies and Surveys in the Project and Brent Area
STUDY METHOD OF SURVEY

Environmental Statement, The Geophysical (bathymetry and topography) and sediment sampling
Penguins Cluster Development (physico-chemical and biological).
(2001) (Shell UK Ltd, 2001)
Penguin 4" Gas Lift Pipeline Pre- Remote operated vehicle (ROV).
route Survey (November 2005).
ROV Boulder and Debris Survey.
Habitat Assessment Report (Gardline
Environmental Ltd, 2005)
Habitat Investigation Don SW & Don Sediment sampling (physico-chemical and biological) and
SW to Thistle, UKCS 211/18, 2007 underwater video.
(Fugro Surveys Ltd, 2007)
Don South West and West Don Geophysical (bathymetry and topography), sediment sampling
Development Projects Environmental (physico-chemical and biological), underwater video, fish and
Statement, 2008 (Petrofac, 2008) marine mammal.
Pipeline route survey, UKCS Along the centre line and the 30 m offset line, data was acquired
211/14, 18 & 19. Proposed with single and multi-beam echo sounders, side scan sonar (410
Penguin FPF to SALB – geophysical kHz, 75 m range) and hull mounted profiler and magnetometer.
survey, 2011 (Shell UK Ltd, 2011). Along the four wing lines, data was acquired with single and multi-
beam echo sounders, side scan sonar (100 kHz, 150 m range) and
hull mounted profiler.
Pipeline Route Survey UKCS Block Data was acquired with single and multi-beam echo sounders, side
211/14 Penguin DC4-DC5 scan sonar (410 kHz, 75 m range), and hull-mounted profiler.
Survey Period: 3 - 17 September
2011
4-1
Figure 4-1 Existing survey plots in and around the Penguins area
4-2
This chapter makes particular reference to the results of the Environmental Habitat Assessment Desk Top
Study (full report appended in Appendix E). This report was completed by Fugro EMU Limited on behalf of
Shell UK Limited based on existing geophysical and camera data from the project area in UKCS Block
211/14 REST and 211/13a. The purpose of this report was to identify potential Annex I Reef Habitats
and protected areas, prior to the installation of the FPSO and associated subsea facilities. The coverage of
the historical geophysical data, at the proposed FPSO location, is presented in Figure 4-2. Video data,
used to validate the geophysical seabed features interpretation data, was collected during the 2005 ROV
pipeline survey between well 211/13aW and the Brent C platform in the Brent area.
The remainder of the baseline chapter has been set out as follows:
 Section 4.2 Physical Environment;
 Section 4.3 Biological Environment;
 Section 4.4 Designated Sites and Protected Habitats; and
 Section 4.5 Human Environment/Socio-economics.
4.2. PHYSICAL ENVIRONMENT

The physical environment considers the relevant characteristics of the seabed, water column and
meteorology in the Project area.
4.2.1. Bathymetry
The seabed within the Project area is relatively flat and gently slopes down from the east-northeast to the
west-southwest with water depth across the area ranging from a minimum of 158.3 m lowest astronomical
tide (LAT) in the southeast to a maximum of 165.1 m LAT in the southwest (Fugro, 2015).
Two shallow (0.2 to 0.3 m deep) relict iceberg plough marks run in a north to south direction across the
central part of the project area and are depicted on Figure 4-3. Several small depressions are present
around the project area, along with an increased density of these depressions to the east. The depressions
were found to range in depth from between 0.1 and 0.3 m (Fugro, 2015).
The 2011 Penguins to Brent Pipeline Route Survey reported water depths of 167.9 m LAT at the beginning
of the route near DCs 1 and 2 (see Figure 4-1). However, from DC1 and DC2 the seabed gently shallows
to 166 m LAT. The route then descends to the base of a trough reaching a maximum depth of 197 m LAT.
The route undulates along the base of the trough before rising up its southern flank to a depth of 160 m.
Beyond this point the seabed generally shallows very gently, occasionally undulating at negligible
gradients, to a depth of 141 m LAT close to Brent C. Maximum gradients of approximately 1° are
associated with the flanks of the trough (Shell UK Ltd, 2011).
No distinct bathymetric features have been identified in the project or Brent area.
4-3
Figure 4-2 Coverage of historical and comparative survey data
4-4
Figure 4-3 Bathymetry in the Project area 2011 (Fugro, 2015)
4-5
4.2.2. Seabed
4.2.2.1. Characteristics
The majority of the seabed in the project area has been classified using geophysical data as ‘Sand and
gravel with cobbles, boulders and clay outcrops’. Numerous patches were delineated and classified as
‘Areas of coarse sediment – cobbles boulders and clay outcrops’ (Fugro 2015). This was supported by the
ROV transects of the seabed which also identified ‘gravelly sand with occasional cobbles and boulders’,
and ‘slightly gravelly sand’ (Fugro 2015) see Figure 4-4. Based on the European Natural Information
System (EUNIS) classification scheme these would be as ‘deep circalittoral mixed sediment’ (EUNIS
reference A5.45) and ‘Deep circalittoral coarse sediment’ (EUNIS reference A5.14) respectively.
A number of channel features, interpreted as relict iceberg ploughmarks, have been observed in the
Penguins FPSO area (Fugro, 2015). The nearest plough mark to the proposed Penguin FPSO location is
160 m to the west. It is approximately 99 m wide and 0.4 m deep, with a maximum gradient 1.0°.
Figure 4-4 Sediment boundaries from ROV video data overlain on interpreted seabed features (Fugro,
2015)
4.2.2.2. Contamination
Sediment contamination in the northern North Sea is higher than in the southern North Sea due to the
higher surface area (and therefore absorptive capacity) of the finer sediments found in deeper waters. In
addition there is generally greater dispersion and dilution of chemicals prior to deposition in the southern
North Sea due to the stronger current conditions.
For most of the Penguins field in the project area the extent and distribution of previous drilling activity
suggests that the existing level of contamination is expected to be similar to background. However,
localised areas of contamination are expected close to historical/existing well sites.
The existing Brent C platform area is expected to have some level of contamination due to historical drilling
discharges, particularly where oil-based fluids were used. Historical surveys have found elevated levels of
metals with the exception of Barium surrounding all four Brent locations (metals assessed included Barium,
Lithium, Aluminium, Arsenic, Cadmium, Chromium, Copper, Lead, Nickel, Vanadium and Zinc). The
surveys also found that sediment characteristics were significantly different within 100 m of the Brent
locations compared to more distant sampling stations, including elevated concentrations of hydrocarbons
and a higher proportion of fines indicating the presence of historical depositions of drilling mud and
cuttings. Based upon previous survey work conducted in the Brent Fields, there is no evidence of having
historical cutting piles present on the route of the new gas export pipeline from Brent Charlie to the new tie-
in to FLAGS.
4-6
The Environmental Statement (ES) for the Don Southwest and West Don Development projects (Petrofac,
2008) reported consistent hydrocarbon contamination across the development’s drill centres and pipeline
routes. Total hydrocarbons concentrations, n-alkanes, total polycyclic aromatic hydrocarbons (PAHs) and
NPD (naphthalene, phenanthrene, anthracene and dibenziothene) were elevated above levels previously
recorded in an adjacent block with similar sediment type, although no spatial trends could be confirmed.
Table 4-2 sets out concentrations of metals recorded at Don SW and West Don sites, and along the export
and production pipeline routes. In general these concentrations were similar to the background levels of
the North Sea (see Table 4-2) (CEFAS, 2001). Higher concentrations are likely to be the result of a number
of historic wells.
Table 4-2 Comparison of Metal Concentrations in Sediments for Don Southwest and West Don
Development Areas
CONCENTRATION RANGE (µg g-1)
ELEMENT North Sea

Don Export Don Production
Don SW West Don background
pipeline pipeline
level
Cadmium 0.26 – 0.4 0.20 – 0.59 0.25 – 0.48 0.28 – 0.61 0.43
Nickel 4–6 4 – 14 4–6 4–8 9.5
Zinc 11 – 29 11 – 29 11 – 41 12 – 20 20.87
Mercury ≤0.01 ≤0.01 – 0.03 ≤0.01 ≤0.01 – 0.03 0.16
Source: (Fugro Survey Ltd, 2007a) (Fugro Survey Ltd, 2007b) (CEFAS, 2001)
4.2.3. Salinity and Temperature

The mean sea surface temperatures in the project area is 9.5°C, ranging from 8°C in winter to 12.9°C in
summer. The mean seabed temperatures in the project area is 7.5°C, ranging from 6.6°C in summer to
8.6°C in winter (Marine Scotland, 2015). A thermocline occurs through the summer down to a depth of
approximately 40 m. There is little seasonal variation in surface salinity which is approximately 35%
(Marine Scotland, 2015).
4.2.4. Waves and Currents

The circulation in the northern North Sea is of mixed water from the Fair Isle inflow via the Dooley Current,
and Atlantic water derived from southward flow to the east of Shetland (see Figure 4-5, (DTI, 2001). The
resultant gyre (Svendsen E, 1991) is generated by the bathymetry of the area. The Project area is in a
location where there is a greater influence of Atlantic water, and is characterised by a general low speed
residual current, typically 0.2 m/s towards the south.
4-7
Figure 4-5 Residual circulation of the central and northern North Sea (DTI, 2001)
4-8
Semi-diurnal tidal currents are relatively weak in

the offshore northern and central North Sea, with
maximum speed approximately 0.4 m/s (DTI,
2001). Figure 4-6 shows the depth average total
current speed rose and directional distribution in
Block 211/13. The typical current in the location
of the Penguin field at the sea surface is 0.09-0.16
m/s in a north west to south east direction. At the
seabed total currents are typically 0.05-0.08 m/s
(Shell UK Ltd., 2006).
Figure 4-6 Depth-average total current speed rose and directional distribution (all year) (Shell P&T Metocean
Engineering in association with PhysE Ltd)
4-9
The mean monthly significant wave height in the

region of the Project is 3.76 m to 4.29 m in the
winter months and 1.5 m to 1.71 m in the summer
months (Fugro Survey Limited, 2007a). Figure 4-7
shows the significant wave height rose and
directional distribution in Block 211/13. The
frequency of wave height exceeding 5 m is
approximately 10.7% (Shell P&T Metocean
Engineering in association with PhysE Ltd, n.d.).
Worst case wave conditions are typically
encountered during December and January.
Figure 4-7 Significant wave height rose and directional distribution (all year) (Shell P&T Metocean Engineering
in association with PhysE Ltd)
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4.2.5. Meteorology
The predominant wind directions in the vicinity of Block 211/13 are from a south and south west
direction, with easterly winds being less frequent. There are seasonal variations and winds in the
area that tend to be variable both in terms of direction and force (Shell P&T Metocean
Engineering in association with PhysE Ltd). Figure 4-8 shows the hourly mean wind speed rose
and directional distribution in Block 211/13. Wind speeds are between 9 and 28 ms-1 (fresh
breeze to gale force winds) throughout the year. Between the months of April and July, wind
speeds range from 0.5 to 17 ms-1 (light to moderate gale), whereas strong winds (exceeding
17.5 ms-1) occur most frequently between September and March. The average yearly wind
speeds range from 7 to 12.05 ms-1 (Fugro, 2001).
Figure 4-8 Hourly mean wind speed rose and directional

distribution (all year) (Shell P&T Metocean
Engineering in association with PhysE Ltd, n.d.)
4-11
4.3. BIOLOGICAL ENVIRONMENT

The biological environment considers the species which could be present within the project area. This
includes consideration of protected species.
4.3.1. Plankton
The plankton community of the North Sea is strongly influenced by inflows of water from the North Atlantic
(DTI 2001). The northern North Sea’s phytoplankton community is dominated by the dinoflagellate genus
Ceratium. There has been a long term increasing trend for this group, along with a decrease in the
abundance of most diatom species. The biomass of phytoplankton in the North Sea as a whole has also
increased over several decades. The zooplankton community is dominated by copepods and in particular
by smaller species such as Para-Pseudocalanus spp, Acartia spp and the young stages of Calanus spp.
Other major components of the plankton community in the northern North Sea include the larvae of
echinoderms, molluscs and crustaceans (SAHFOS, 2001).
4.3.2. Benthos
The benthic community of the northern North Sea is made up predominantly of cold water species and has
a lower biomass of benthic infauna than southern areas (Heip and Craeymeersch, 1995).
A ROV survey of the project area found that the seabed supports scarce epifaunal communities of
echinoderms and cnidarians. The most common species recorded within the community were echinoderms
such as seastars (Asteroidea including Astropecten irregularis), cushion stars (Asteroidea), sea cucumbers
(Holothuroidea) and sea urchins (Echinoidea). Anemones (Actiniaria) and sea pens (Pennatulacea) were
also occasionally observed. Due to the low resolution of the video data and the absence of any still
photographs, identification of taxa to species level was problematic and smaller epifaunal species may
have been missed during the analysis (Fugro, 2015).
The epifaunal community was found to be similar to the community recorded during the environmental
survey of the Don SW site (UKCS Block 211/18, 2007) in the areas of coarse sediment. Echinoderms were
also prominent with sea stars (Astropecten irregularis, Asterias rubens, Luidia sp. and Henricia sp.),
cushion stars (probably Ceramaster sp. or Porania sp.) and sea urchins (probably Echinus sp.) being
recorded in many of the stills (Fugro, 2015).
Higher abundances of both sessile and motile epifauna were found during the Don SW survey (Fugro
Survey Ltd, 2007a) in areas of cobbles and boulders which were not as prevalent in the Penguins project
area. Sponges were also recorded across the majority of the Don SW site including in the habitats which
were very similar to those found during the survey of the Project area. It is likely that sponges were also
present within the Project area. However, due to the low resolution of the video data they may have not
been recorded during the analysis (Fugro, 2015).
The similarities in sediment type, depth and epifaunal community mean that it is likely that a similar
infaunal community is present within the Penguins project area as was found at the nearby Don SW survey
(2007) site. The community at Don SW was dominated by annelids, making up 52.6% of the recorded taxa
and 57.5% of individuals with the most dominant taxon being the spionid polychaete Spiophanes kroyeri,
along with the polychaetes Galathowenia oculata and Glycera lapidum. The cockle Parvicardium also
occurred in very high abundances and was found to occur across all stations along with the barnacle
Verruca stroemia (Fugro, 2015).
Infaunal communities were influenced by sediment size across the Don SW site. Where higher proportions
of coarse material were recorded, higher abundances of epilithic taxa were also recorded, these taxa
included the barnacle Verruca stroemia, the cup coral Caryophyllia smithii, anemones and brachiopods
such as Macandrevia cranium. Areas with high proportions of coarse material also tended to have an
increased diversity of colonial epifaunal taxa, these taxa included sponges, the hydroid Clytia
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hemispherica and bryozoans such as Alderina imbellis, Ramphonotus minax and Hemicyclopora polita
(Fugro, 2015).
4.3.3. Fish
More than 330 fish species are thought to inhabit the shelf seas of the UKCS (Pinnegar et al., 2010).
Pelagic species (e.g. herring (Clupea harengus), mackerel (Scomber scombrus), blue whiting
(Micromesistius poutassou) and sprat (Sprattus sprattus)) are found in mid-water and typically make
extensive seasonal movements or migrations. Demersal species (e.g. cod (Gadus morhua), haddock
(Melanogrammus aeglefinus), sandeels (Ammoddytes tobianus & A. Marinus), sole (Solea solea) and
whiting (Merlangius merlangus)) live on or near the seabed and similar to pelagic species, many are
known to passively move (e.g. drifting eggs and larvae) and / or actively migrate (e.g. juveniles and
adults) between areas during their lifecycle.
Fish occupying areas in close proximity to offshore oil and gas installations will be exposed to aqueous
discharges and may accumulate hydrocarbons and other contaminating chemicals in their body tissues.
The most vulnerable stages of the life cycle of fish, to general disturbances such as disruption to sediments
and oil pollution, are the egg and larval stages. Hence, recognition of spawning and nursery times and
areas within a development area is imperative.
The proposed development is within ICES rectangle 52F1 and is within 1 km of ICES rectangle 51F1. Table
4-3 lists approximate spawning and nursery times of fish species occurring in both of these ICES rectangles
while Figure 4-9 shows the distribution fish nursery and spawning grounds in relation to these ICES
rectangles. All other fish species spawning and nursery grounds are greater than 50 km from the
proposed project location so are not considered further. Within ICES rectangle 52F1 and 51F1there is
high intensity and peak spawning grounds for cod and peak spawning for Norway pout. The area also
falls within the wider spawning grounds for haddock, saithe and whiting (Coull et al 1998, Ellis et al
2012).
The area is also located within the high intensity nursery area for blue whiting as well as the wider nursery
areas for mackerel, herring, whiting, haddock, Norway pout, hake, spurdog and ling (Coull et al 1998;
Ellis et al, 2012). From the list of species known to have nursery grounds, there is the probability of
presence of 0 group aggregations (fish in the first year of their life) of blue whiting, hake, Norway pout
and haddock (Aires et al (2014).
In addition to those species listed in Table 4-3, Ellis et al. (2012) also identified that in ICES rectangle 52F1
sandeels and mackerel juveniles had been recorded in one to 40% of groundfish survey tows, anglerfish
(Lophius piscatorius) had been recorded in 50-69% of tows, while Cod and horse mackerel (Trachurus
trachurus) had been recorded in more than 70% of tows.
Of the species identified anglerfish, herring, mackerel, blue whiting, cod, horse mackerel, ling (Molva
molva), Norway pout (Trisopterus esmarkii), saithe (Pollachius virens), sandeels and whiting have been
assessed by SNH and JNCC as Priority Marine Features (PMF) in Scotland (SNH, 2014).
Table 4-3 also identifies the probability of juvenile fish being present at any one time. These data were
generated by Marine Scotland (Aires et al., 2014) using Species Distribution Modelling (SDM) to predict
where aggregations of 0 group fish (fish in the first year of their life) may be found based on environmental
information and catch records. These data indicate that juvenile haddock, hake, whiting and Norway pout
could be present in the area. However, these maps do not include all commercially important species and
have therefore been considered alongside earlier data from Coull et al. (1998).
Figure 4-9 shows fish nursery and spawning grounds in the Penguins Project area (Coull et al., 1998) .
4-13
Table 4-3 Timing of Spawning and Presence of Nursery Grounds
SPECIES ICES BLOCK JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
(1)
Cod 51F1
52F1
Haddock(1)(3)
51F1 NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ
Saithe(1) 52F1 & 51F1
Norway Pout 52F1 &

NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ
(shelf)(1)(3) 51F1
Blue whiting 52/F1 N N N N N N N N N N N N

(1)(2)(3)
51/F1 NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ
Mackerel(1)(2) 51/F1 N N N N N N N N N N N N
(2)
Herring 51/F1 N N N N N N N N N N N N
(2)
Spurdog 51/F1 N N N N N N N N N N N N
(2)
Whiting 51/F1 N N N N N N N N N N N N
Ling(2) 51/F1 N N N N N N N N N N N N
(2)(3)
Hake 51/F1 NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ
N Nursery area
Cod High intensity spawning area
Blue whiting High intensity nursery area
J Juveniles
Spawning area
Peak spawning area
Source:
(1)
Coull, et al. (1998)
(2)
Ellis et al. (2012)
(3)
Aires, et al. (2014
4-14
Figure 4-9 Fish nursery and spawning grounds in the Penguins Project area (Coull et al., 1998)
4-15
4.3.4. Sharks, Rays and Skate

The distribution of Chondrichthyes in the UKCS is not extensively documented. However available literature
(Ellis, et al., 2004) suggests that at least six species regularly occur in the Central and Northern North Sea
with total numbers recorded for each of these species are low (Ellis, et al., 2004):
 Spiny dogfish / spurdog (Squalus acanthias);
 Tope shark (Galeorhinus galeus);
 Thorny skate / starry ray (Amblyraja radiata);
 Cuckoo ray (Leucoraja naevus);
 Lesser spotted dogfish (Scyliorhinus canicula);
 Thornback Ray (Raja clavata).
sharks, rays and skates (class Chondrichthyes) have relatively slow growth, reproduction and maturity rates
and therefore tend to be vulnerable to anthropogenic activities. Species, such as common skate (Dipturus
batis), long-nose skate (Dipturus oxyrinchus) and angel shark (Squatina squatina) have been subject to
commercial fishing activities. More recently these species tend to be taken as bycatch to such an extent that
the stocks are still being depleted in UK waters. Work is underway to develop National Plans of Action for
the conservation and management of the Chondrichthyes. Those species identified as being in need of
immediate protection are the angel shark (S. squatina), common skate (D. batis), longnose skate (Raja
rhina), Norwegian skate (Dipturus nidarosiensis) and white skate (Rostroraja alba). It has been proposed to
protect these species in UK waters in the same way as the basking shark is protected, under the Wildlife
and Countryside Act (1981).
4.3.5. Seabirds
The North Sea is of high importance for a number of seabird species. Substantial portions of some species’
global populations make use of the area for feeding and breeding either seasonally or throughout the year.
However, the relative importance for seabird conservation of the Project area is low (DTI, 2001). The area
of the North Sea to the northeast of Scotland is situated within a major migratory flyway between wintering
and breeding grounds (DECC, 2004). Both Shetland and the closest Norwegian coast support major
seabird colonies, from which birds will forage across the wider area (DECC, 2004). However, given the
distance of colonies from the Project area (approximately 150 km and 175 km from Shetland and Norway
coasts, respectively), only Northern gannet (Morus bassanus) and Northern fulmar (Fulmarus glacialis) are
likely to forage within project area during the breeding season (Thaxter, 2012). Seabirds present in the
wider region are as follows:
 Northern gannet (Morus bassanus);
 Northern fulmar (Fulmarus glacialis);
 Arctic skua (Stercorarius parasiticus);
 Great skua (Stercorarius skua);
 Iceland gull (Larus glaucoides);
 Glaucous gull (Larus hyperboreus);
 Lesser black-backed gull (Larus fuscus);
 Greater black-backed gull (Larus marinus);
 Herring gull (Larus argentatus);
 Black-legged kittiwake (Rissa tridactyla);
 Common tern (Sterna hirundo);
 Sandwich tern (Sterna sandvicensis);
 Arctic tern (Sterna paradisaea);
 Guillemot (Uria aalge);
4-16
 Atlantic puffin (Fratercula arctica);

 Razorbill (Alca torda); and
 Black guillemot (Cepphus grylle).
Offshore areas in the North Sea support peak numbers of seabirds following the breeding season and
during the winter, while birds are likely to remain closer inshore during breeding seasons in spring and
early summer. An assessment of the vulnerability of seabirds to surface pollution provided by the JNCC
indicates that the Project area falls within a region of relatively low vulnerability throughout most of the
year, as shown in Figure 4-10.
The Brent area falls within an area of moderate vulnerability in November. This evidence suggests that
seabirds are not present in and around the Project area in large numbers.
4-17
Figure 4-10 Seabird vulnerability
4-18
4.3.6. Marine Mammals
4.3.6.1. Cetaceans
Many activities associated with the offshore oil and gas industry have the potential to impact on cetaceans
by causing physical injury, disturbance or changes in behaviour. Activities with the potential to cause
disturbance or behavioural effects include: drilling, seismic surveys, vessel movements, construction work
and decommissioning (JNCC, 2008).
Cetaceans feed on fish and / or plankton and disturbance from noise or contamination of the water
column affecting these food sources could have a negative impact, either directly as a result of a lack of
prey or indirectly as a result of bioaccumulation of contaminants.
The JNCC has compiled an Atlas of Cetacean Distribution in North-West European Waters (Reid J.B.,
2003), which gives an indication of the types of cetaceans and times of the year that they are likely to
frequent areas of the North Sea. The atlas is based on a variety of data sources including:
 At sea surveys carried out by the JNCC;
 The UK Mammal Society Cetacean Group;
 Dedicated survey data collected in June and July 1994 and July 2005 by the Sea Mammal
Research Unit at St Andrews University (SCANS – Small Cetacean Abundance in the North Sea).
It has been estimated that a total of 21 cetacean species are either resident in, or regularly pass through
the UK SEA 2 area (CEFAS, 2001). Of these, the harbour porpoise, killer whale, Atlantic white-sided
dolphin and minke whale are the most likely to occur in the area of the proposed operations (Reid et al.
2003).
For many cetaceans in UK waters, particularly those occurring predominantly on the continental shelf, the
best available population estimates are those provided by the SCANS II survey blocks, as shown in Figure
4-11 (SMRU, 2006). The Project area is located within Area T. The data suggest that those most likely to
occur in the area of the proposed development, albeit in low numbers, are the Harbour porpoise
(Phocoena phocoena), Atlantic bottlenose dolphin (Tursiops truncatus), White-beaked dolphin
(Lagenorhynchus albirostris), Atlantic white-sided dolphin (Lagenorhynchus acutus), Killer whale (Orcinus
orca) and Minke whale (Balaenoptera acutorostrata) (SMRU, 2001). Shipboard survey estimates of
abundance and densities (animals per km2) of these species are provided in Table 4-4.
The distribution of sightings of those cetacean species listed above in the northern North Sea using both the
SCANS-II and additional data from the Norway Institute of Marine Research (NIMR, 2013) for killer whale,
minke whale and harbour porpoise is shown in Figure 4-12.
Table 4-4 Animal densities (animals / km2) SCANS area T.
SCANS Area T
Species
Animal abundance Animal density (per km2)
Harbour porpoise 19,396 0.15
Atlantic bottlenose dolphin 151 0.001
White-beaked dolphin 1,530 0.01
Minke whale 1,783 0.01
Source: (Hammond et al., 2013).
4-19
Figure 4-11 SCANS-II Survey Blocks

Harbour porpoises are the most abundant cetacean species in UK waters (DECC, 2009) and the most
frequently recorded for the region. The results of the SCANS and SCANS II found no evidence that total
harbour porpoise abundance in the North Sea changed between the two surveys, however a marked
difference in summer distribution was observed with the main concentration in the North Sea shifting from
the northwest in 1994 to the southwest in 2005, the high densities around coastal Denmark in 1994 had
dissipated in 2005 (Hammond, et al., 2013). Part of this shift could be inter-annual variation, however a
systematic change over this period is corroborated by increases in sightings and strandings of porpoises in
French, Belgian, Dutch and German waters over the last decade (Hammond, et al., 2013). Data from
Norwegian surveys in the North Sea also show an approximate 20-fold decline in sighting rates of harbour
porpoise in the northern North Sea between 1998/2004 and 2009 suggesting that low porpoise density in
this area persists (Hammond, et al., 2013).
Sightings of minke whale, Atlantic white sided dolphin and killer whale are relatively common in waters
surrounding the Project area, in similar depths and at similar distances from shore. Sightings of white
beaked dolphin show a more coastal distribution and sightings of bottlenose dolphin are relatively
uncommon (Reid J.B., 2003). The Project area is situated in a high density population area and feeding
area for minke whale and an area of high levels of movement for killer whale (NIMR 2013). Most
observations within the surrounding area of the six cetacean species regularly occurring in the North Sea
4-20
are in July, and there are relatively few sightings or no sightings of these species in the area during May
and June (Reid J.B., 2003).
All cetacean species that may be present in the vicinity of the Project area are listed within Annex II of the
EC Habitats Directive, and therefore deliberate killing or disturbance of these species is prohibited. All
cetaceans are also protected under the Wildlife and Countryside Act of 1981.
4.3.6.2. Pinnipeds
Two species of seal breed within the North Sea, the harbour seal (also known as common seal, Phoca
vitulina) and the grey seal (Halichoerus grypus). Harbour seals occur throughout the North Sea whereas
grey seals almost exclusively occur around the northern UK. Both harbour seals and grey seals may be
present in the area (NIMR, 2013), but they are not commonly found offshore within this part of the North
Sea (Sea Mammal Research Unit, 2001).
The UK harbour seal population belongs to a European sub-species (Phoca vitulina vitulina) with
approximately 33% (estimated 37,300 individuals in 2012, 26,836 counted in UK between 2007 and
2012) of the global population occurring in UK waters (SCOS, 2013). The pupping period is between
June and July, and the moulting period between August and September (DECC, 2009). Common seals are
widespread throughout coastal waters, however, their offshore range is limited by the need to periodically
return to shore (DECC, 2009). Therefore the occurrence of common seal in offshore waters of the northern
North Sea near the Project area is likely to be relatively low.
Approximately 38% of the world’s grey seals breed in the UK (50,200) and 88% of these breed at colonies
in Scotland with the main concentrations in the Outer Hebrides and in Orkney (SCOS, 2013). Most grey
seals will be on land for several weeks between October and December for the breeding and pupping
season, and again in February and March during the annual moult. As a result offshore densities will
likely be lower during these periods. Outside of these periods they spend most of the time at sea and are
known to travel long distances between haul out sites and to/from foraging areas.
Figure 4-13 presents refined, population scale, at-sea usage maps developed using telemetry data
obtained from grey and harbour seals. The data suggests that seals are unlikely to be present in the
vicinity of the Project area and if so only in very low numbers (0-1 individuals) (SCOS 2013).
Both seal species are listed within Annex II of the EC Habitats Directive, and therefore deliberate killing or
disturbance of these species is prohibited.
4-21
Figure 4-12 Cetacean distribution
4-22
Grey seal Harbour seal

Note: The approximate location of the survey area is marked in red.
Figure 4-13 Estimated At-sea and Hauled-out Area Usage by Seal Species (SCOS, 2013)
4-23
4.4. DESIGNATED SITES AND PROTECTED HABITATS

Figure 4-14 presents the designated sites in the vicinity of the Project area. The sites closest to the Project
area and their protection status are described where relevant in the following sections.
4.4.1. European Natura 2000 Network

The key mechanism for conservation is the designation and management of protected sites for nationally
and internationally important habitats and species. The European Union (EU) Habitats Directive
(92/43/EEC) and the EU Birds Directive (79/409/EEC) are the main legal instruments for safeguarding
biodiversity in Europe.
The Habitats Directive lists those habitats (Annex I) and species (Annex II) whose conservation requires the
designation of special interest areas. Once adopted, these areas are referred to Special Areas of
Conservation (SACs) in the UK. The designated process comprises a number of stages summarised in
Table 4-5. For the purposes of EIA, all types of SACs are considered the same and significant effects are
assessed.
Table 4-5 Definition of UK SAC/SCI Sites
SITE DESCRIPTION
SAC SACs are sites that have been adopted by the European Commission (EC) and
formally designated by the government of each country in whose territory that site
lies.
Sites of SCIs are sites that have been adopted by the EC but not yet formally designated by
Community the government of each country.
Importance (SPI)
Candidate SAC cSACs are sites that have been submitted to the EC and not formally adopted.
(cSAC)
Possible SAC pSACs are sites that have been formally advised to UK government, but not yet
(pSAC) submitted to the EC.
Draft SAC (dSAC) dSACs are areas that have been formally advised to the UK government but not yet
approved by it.
Four habitat types listed within Annex I of the Habitats Directive may be present on the UK continental shelf:
sandbanks which are slightly covered by seawater at all times; reefs; submarine structures made by leaking
gases; and submerged or partially submerged sea caves.
All species of marine mammal species that may occur in the Project area are listed on Annex II of the
Habitats Directive. All marine mammal species are granted European Protected Species (EPS) status. EPS
are species of plants and animals (other than birds) protected by law throughout the EU whose natural
range includes any area in the UK. They are listed in Annexes II and IV of the Habitats Directive. Under the
Habitats Regulations 1994 (as amended in Scotland), it is an offence to deliberately disturb any EPS, or to
capture, injure or kill an EPS at any time.
Special Protection Areas (SPAs) are strictly protected sites classified in accordance with Article 4 of the
Birds Directive. They are classified for rare and vulnerable birds (as listed on Annex I of the Directive), and
for regularly occurring migrating species.
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Adopted SACs and SPAs form the European Natura 2000 network. The Habitats and Birds Directives are
transposed into UK law by the following:
 The Conservation of Habitats and Species Regulations 2010 and The Conservation (Natural
Habitats, &c.) Regulations 1994 (as amended). These regulations transpose the Habitats and
Birds Directives into Scottish law. They apply to land and to territorial waters out to 12 nautical
miles from the coast.
 The Offshore Marine Conservation (Natural Habitats, &c.) Regulations 2007 (as amended).
These regulations are the principal means by which the Habitats and Birds Directives are
transposed in the UK offshore marine area (i.e. outside of the 12 nautical mile territorial limit).
Under these regulations it is an offence to deliberately disturb any EPS.
 The Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001 (as amended).
These regulations apply the Habitats and Birds Directives in relation to oil and gas plans or
projects wholly or partly on the UKCS outside the 12 nautical mile territorial limit.
No SACs or SPAs designated for these features are located within the Blocks 211/13a, 211/14 and
211/29 or within 10 km of these areas. The closest Natura 2000 site to the Project area is Pobie Bank
SAC bedrock reef habitats located approximately 120 km away.
4.4.1.1. Potential for Annex I Habitat in the Project Area

According to JNCC Annex I habitat mapping data, the Project area falls within a region of the North Sea
where there are potential Annex I stony reef habitats. A desk top habitat assessment study using the recent
site geophysical survey data was commissioned by Shell in 2014 (Fugro, 2015) and is provided in
Appendix E. During the environmental surveys of the area in 2007 and 2011 (Gardline, 2011) specific
attention was given to identifying of any potential reef habitats, which have the potential to support a
diverse faunal community. No reefs were identified in any of the areas covered by the ROV video transect.
The results of a seabed survey conducted along the existing Penguins gas lift pipeline route (Shell UK Ltd.,
2006) did not identify any Annex I habitats or other biogenic reefs along the route of the pipeline that
could be impacted by rock dumping.
No Pockmarks were identified in the Project area. During the habitat assessment, depressions were
identified from the geophysical data across much of the site, ranging from 0.1 m to 0.3 m deep and from
10 m to 20 m in diameter. These depressions were thought likely to be created by seabed scouring due to
their shallow depth and small diameter. Several of these depressions were found to contain hard contacts.
The heights of these contacts, between 0.4 m and 1.0 m, were more consistent with boulders than
Methane-derived authigenic carbonate (MDAC), which tends to be encountered as low-level, slab-like
structures. The contacts also displayed more distinct rounded shapes, which would typically be evident for
boulders, whereas MDAC often displays more indistinct and irregular edges on the side scan sonar record.
4.4.2. Marine Protection Areas

Marine Protection Areas (MPAs) are designated to protect marine life while allowing sustainable and
legitimate use of the seas to continue. The UK is committed to contribute to a well-managed network of
MPAs by 2016. The MPA network is to ensure the UK meets its commitments under the Conservation of
Biological Diversity (CBD) and contribute to measures aimed at achieving Good Environmental Status
across Europe’s seas by 2020 under the EU Directive 2008/56/EC on establishing a framework for
community action in the field of marine environmental policy (Marine Strategy Framework Directive) which
was formally adopted by the EU in 2008.
Marine Scotland has identified Nature Conservation Marine Protected Areas (NC MPAs) in Scotland to
either protect a range of biodiversity or geodiversity features in their current state, or to allow them to
recover to the state in which they should be in order to remain healthy and productive.
4-25
There are no MPAs located within the Blocks 211/13a, 211/14 REST and 211/29 or within 10 km of
these areas. The closest MPAs are the North-East Faroe-Shetland Channel MPA and Fetlar to Haroldswick
MPA, located approximately 67 km and 138 km from the Project, respectively.
4.4.3. Priority Marine Features

Priority Marine Features (PMFs) are habitats and species which are considered to be marine conservation
priorities in Scottish waters. The list contains 81 features characteristic of the Scottish marine environment
ranging from flame shell beds in coastal waters, to cold-water coral reefs of the deeper seas, and mobile
species such as minke whale and basking shark.
Of the fish species identified as utilising the Project area for spawning, nursery ground or where juveniles
are present, anglerfish, herring, mackerel, blue whiting, cod, horse mackerel, ling (Molva molva), Norway
pout (Trisopterus esmarkii), saithe (Pollachius virens), sandeels and whiting have been assessed by SNH
and JNCC as PMFs in Scotland. For cetaceans harbour porpoise, Atlantic white-sided dolphin, white-
beaked dolphin, bottlenose dolphin, killer whale and minke whale are also all PMFs in Scottish waters
(SNH, 2014). No benthic or seabed habitat or species PMFs were identified from the geophysical or video
data for the Project area.
4.4.4. UK Biodiversity Action Plan (UK BAP)

The UK Biodiversity Action Plan (UK BAP) was published in 1994 in response to the CBD, which the UK
signed up to in 1992. The UK BAP describes the biological resources of the UK and provides detailed
plans for conservation of these resources. Action plans for the most threatened species and habitats were
set out to aid recovery, and national reports produced every three to five years showed how the UK BAP
was contributing to the UK’s progress towards the significant reduction of biodiversity loss called for by the
CBD.
The UK Post-2010 Biodiversity Framework, superseding the UK BAP priority habitats, covers a wide range
of semi-natural habitat types. They are habitats identified as being the most threatened and require
conservation action under the UK BAP. Similarly, the Scottish Biodiversity List (SBL) lists habitats of principal
importance for biodiversity conservation in Scotland.
4.4.5. NOFO Areas

The Norwegian coast supports a number of sites which have been identified by Norsk Oljevernforening for
Operatørselskap (Norwegian Clean Seas Association for Operating Companies) (NOFO) as priority areas
for oil spill response purposes. These sites typically encompass natural parks, recreational areas, and
areas identified as important to wildlife such as breeding and moulting areas for seabirds or spawning and
nursery areas for fish. The closest is Atløy/Værlandet approximately 160 km directly east. Brief
descriptions of the NOFO areas relevant to the Project are provided in Chapter 11.
4-26
Figure 4-14 Environmental designations
4-27
4.5. HUMAN ENVIRONMENT/SOCIO-ECONOMIC

The human environment has considered human activity and infrastructure within the project area.
4.5.1. Commercial Fisheries

The North Sea is a major fishing area for UK and international fleets. The northern North Sea has
particular importance for demersal fisheries targeting a mix of cod, haddock and whiting throughout the
year. The main gear types used are otter trawls and seine nets. Pelagic offshore fisheries in the area
target herring, using purse seines and trawls, and mackerel, using trawlers. Both fisheries are active
throughout the year, with peak landings in the summer and early autumn (CEFAS, 2001). The intensity of
fishing effort in the area is shown in Figure 4-15.
The Project area is within ICES rectangle 52F1. Table 4-6 provides average landed weight and value for
all species landed from ICES rectangles 52F1 and two rectangles passed through by the pipeline in the
Brent area (50F1 and 51F1). The recent 2013 landings data (Scottish Government, 2013) show no catch
for pelagic fish in the project area and in 2011, less than 2,000 tonnes were reported.
4-28
Figure 4-15 UK fishing intensity
4-29
In comparison to the other areas of the North Sea, it is considered that the Project area has a low to
moderate commercial fishing value. It has the lowest landings and value compared to the two nearest ICES
Rectangles.
Table 4-6 Total Annual Fish Landing in the Project Area
YEAR RECTANGLE VALUE (£) QUANTITY (TONNES)

2013 51F1 1,422,491 1,094
52F1 394,544 386
50F1 2,340,596 1,851
2012 51F1 556,236 361
52F1 521,876 372

50F1 2,758,215 2,277
2011 51F1 740,787 490
52F1 105,420 90
50F1 3,475,852 3,235
Source: (Scottish Government, 2013)
Figure 4-16 demonstrates the value and importance of commercial fish species in the area.
Fish species landing value -52F1

400,000.00
350,000.00
300,000.00
250,000.00
200,000.00
150,000.00
100,000.00
50,000.00
Value (£)
0.00
Cod
Haddock
Ling
Megrim
Redfishes
Turbot
Conger eel
Pollack
Witch
Hake
Whiting
Halibut
Halibut - Greenland
Squid
Blue Ling
Plaice
Saithe
Monks or Anglers
Conger Eels
Torsk (Tusk)
Catfish
Greater Forked Beard
Lemon Sole
Other Flatfish
Source: The Scottish Government, 2013

Figure 4-16 Fish landing value 52F1
Fishing activity is well established in the Project area with vessels spotted frequently over the past two years
(see Table 4-7 and Table 4-8 and Figure 4-17 and Figure 4-18).
4-30
Table 4-7 All Fishing Vessels 2013
TOTAL SIGHTINGS OF CLOSEST POINT OF CLOSEST POINT OF INFRINGEME

MONTH FISHING VESSELS APPROACH >1 MILE APPROACH <1 MILE NT
Jan-13 7 1 6 0
Feb-13 30 20 10 0
Mar-13 28 16 12 0
Apr-13 36 10 26 0
May-13 70 46 24 0
Jun-13 9 0 9 0
Jul-13 27 15 12 0
Aug-13 50 30 20 0
Sep-13 11 7 4 0
Oct-13 15 8 7 0
Nov-13 6 4 2 0
Dec-13 0 0 0 0
Source: (SFF Services Limited, 2015)
80
70
60
No. of Sightings
50
40 Total FVs Sightings

CPA>1 mile
30
CPA<1 mile
20
Infringement
10
Month
Note: CPA = Closest Point of Approach

Figure 4-17 Monthly fishing vessel sightings 2013
4-31
Table 4-8 All Fishing Vessels 2014
TOTAL SIGHTINGS OF CLOSEST POINT OF CLOSEST POINT OF

MONTH FISHING VESSELS APPROACH >1 MILE APPROACH <1 MILE INFRINGEMENT
Jan-14 7 7 0 0
Feb-14 25 23 2 0
Mar-14 14 13 1 0
Apr-14 42 25 17 0
May-14 52 21 30 0
Jun-14 36 30 6 0
Jul-14 35 29 6 0
Aug-14 41 34 7 0
Sep-14 24 24 0 0
Oct-14 21 21 0 0
Nov-14 29 29 0
Dec-14 4 4 0 0
60
50
40
No. of Sightings
30 Total FVs Sightings

CPA>1 mile
20
CPA<1 mile
10 Infringement
Month
Figure 4-18 Monthly fishing vessel sightings 2014
The fishing vessels are not only from the UK but also from Europe and other regions (see Table 4-9 and
Table 4-10 with associated charts).
4-32
Table 4-9 Penguins Fishing Vessel Activity by Nationality 2013
2013
Norwegian 55
British 6
French 6
Danish 4
German 4
Irish 2
Dutch 1
Icelandic 1
Faroese 0
Lithuanian 0
Swedish 0
Unknown 0
TOTAL 79
4-33
Table 4-10 Penguins Fishing Vessel Activity by Nationality 2014
2014
Norwegian 54
British 11
French 6
Danish 6
German 4
Irish 4
Dutch 3
Icelandic 3
Faroese 1
Lithuanian 1
Swedish 1
Unknown 0
TOTAL 94
4-34
4.5.2. Existing Oil and Gas Activity

The project area lies within an area of the North Sea heavily developed for oil and gas extraction. Existing
oil and gas fields, platforms and significant discoveries are shown on Figure 4-19. The existing pipeline
which will be converted for gas export by the Project runs south to the Brent field.
4.5.3. Shipping
The northern North Sea supports a moderate level of shipping traffic, largely comprising merchant ships,
supply vessels and tankers. A number of shipping routes pass through the area within which the Project is
located (DTI, 2001). The Project is located close to several known oil and gas fields and a number of
existing well platforms. Vessel traffic in the area is likely to include support vessels for these activities.
Fishing vessels are also users of this area with activity described in 4.5.1 above.
4.5.4. Other Infrastructure

There are no known submarine cables in the vicinity of the Project. The south-west area of Block 211/13 is
traversed by a gas pipeline and an oil pipeline, which originate from the Magnus field to the west of the
project area. Some wrecks and obstructions are also located within close proximity to the project site.
4-35
Figure 4-19 Oil and gas activity
4-36
ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
5. EIA APPROACH
5.1. INTRODUCTION
The Environmental Impact Assessment (EIA) presented within this Environmental Statement (ES) has
followed a systematic process that predicts the impacts of the proposed Penguins Redevelopment and
evaluates the effects they are expected to have on aspects of the physical, biological and human
environment. It identifies measures that will be taken to avoid, minimise or reduce adverse impacts.
The overall approach followed is shown schematically in Figure 5-1 and the key steps are described in the
subsequent sections. It should be noted that the EIA is not a linear process, but an iterative one, in which
findings are revisited and modified as the application and EIA progress.
5.2. EIA SCREENING AND SCOPING
5.2.1. Screening
In accordance with the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects)
Regulations 1999 (as amended), an ES is a mandatory requirement for the Penguins Redevelopment
project as it will produce greater than 500 tonnes or more per day of oil or 500,000 cubic metres or more
per day of gas (not including well testing).
5.2.2. Scoping
Scoping is an integral part of the IA process, the aim of which is to identify matters that should be covered
in the detailed EIA (or ES). An initial scoping of possible impacts for the Project has identified those
impacts thought to be potentially significant, those thought to be not significant and those whose
significance is yet to be determined (uncertain).
Those impacts considered not significant or negligible are eliminated. Those in the uncertain category are
added to the initial category of other potentially significant impacts. This refining of focus to the most
potentially significant impacts will continue throughout the IA process and through the design, construction
and operation phases of the project. This allows the flexibility to adapt to any new issues, for example the
discovery of additional impacts arising from detailed baseline studies resulting in the investigation of new
impacts, alternatives and mitigation measures as necessary.
5.3. STAKEHOLDER CONSULTATION

A key component of the EIA process is engagement with public and key stakeholders. The main objectives
of the project consultation are:
 To identify potential issues and concerns during the early stage of the project;
 To build transparent and meaningful relationships with key stakeholders including the joint venture
(JV) partner and the regulators;
 To leverage on the good will and the experiences of the Penguins’ assets to relate effectively with
stakeholders;
 To provide a platform for receiving feedbacks from and disseminating project update to key
stakeholders throughout the duration of the project;
 To build relationships and establish a dialogue with a variety of organizations, agencies and
interest groups at local and national level; and
 To conduct an on-going monitoring of key stakeholders’ concerns and grievances.
5-1
5.4. ENVIRONMENTAL AND SOCIAL ASPECTS IDENTIFICATION (ENVID)

Two ENVID workshops have been undertaken for the Project. An ENVID was initially undertaken during the
Select Phase and revisited during the Front End Engineering Design (FEED) Phase taking account of the
latest project and design decisions, studies and data. The key objectives of ENVID are as follows:
 To validate impacts identified through a scoping exercise;
 Identify any additional potential environmental and social issues likely to arise from the proposed
project; and
 To agree the appropriate control and practicable measures to put in place to manage and
minimise the environmental and social risks to as low as reasonably practicable (ALARP).
5.5. IMPACT ASSESSMENT METHODOLOGY
5.5.1. Overview
The IA methodology is shown and described in Figure 5-1. The following sections provide more detail on
how each of the elements (i.e. magnitude, sensitivity and importance) is defined.
Assessing the significance of effects on the environment and people is usually based on a combination of
the magnitude of impact experienced by a resource or receptor and how the receptor responds to that
impact (or its ‘sensitivity’). It is important to note that sensitivity alone is not an inherent characteristic of a
resource or receptor and can vary from one type of impact to another (e.g. increased noise or introduction
of an aqueous pollutant). It is therefore also usual to consider the importance of an affected resource or
receptor in terms of factors such as its level of protection and role in the ecosystem.
For some impacts the magnitude can be quantified and compared with a numerical standard that is
pertinent to the topic being assessed. Assessing significance is then usually simplified in terms of assessing
whether a standard or limit may be breached.
5.5.2. Predicting Impact Magnitude

Considering extent, duration, frequency and elevation above baseline in combination allows magnitude to
be derived as shown in Figure 5-2. However, professional judgement is still important. For example a
very small elevation above baseline is most likely to comprise a small magnitude impact regardless of its
duration, frequency or areal extent.
5-2
Figure 5-1 EIA Overview
5-3
Small Magnitude Large Magnitude
Extent
Site-specific/local Sub-regional Regional/Transboundary
Duration
Temporary Short-term Medium-term Long-term Permanent
Frequency
One-off/Remote Rare Intermittent Occasional Routine
Change Relative to Baseline

Low Medium High
Figure 5-2 Predicting Magnitude
The relevant details regarding how magnitude has been predicted and described for each impact are
presented in the topic specific chapter of the ES.
Some Project activities will result in changes to the environment that may be immeasurable or undetectable
or within the range of normal natural variation. Such changes are assessed as having no effect or to be of
negligible magnitude.
5.5.3. Importance/Value/Sensitivity of Resources or Receptors

The significance of the effects resulting from an impact of a given magnitude will depend on the
characteristics of resources and receptors subject to that impact in terms of their inherent importance /value
and /or their sensitivity to the impact concerned.
The importance or value of a resource is judged by taking into account factors such as its local, regional,
national or international designation, its importance to the local or wider community, its ecosystem
function, or its economic value. For habitats, the consideration is based on factors that include naturalness,
extent, rarity, fragility, diversity and importance as a community resource. For species, conservation status
and role in the ecosystem are considered.
The assessment of the sensitivity of human (socioeconomic characteristics) receptors, for example local
amenity users (if any), commercial fisheries or other economic users, takes into account their likely response
to the change and their ability to adapt to and manage the effects of the impact.
The sensitivity of each receptor that could be exposed to Project impacts is assessed, noting that sensitivity is
impact specific. Such an assessment may, to some extent, be regarded as subjective; however, expert
5-5
judgement and the evidence base provide a reasonable degree of consensus on the sensitivity of a receptor
to an impact. The sensitivity of each receptor is assessed according to three criteria to the extent that they
are applicable to the receptor in question.
The impact prediction also takes note of inter-relationships between different resources and receptors and
the potential for secondary effects (e.g. along a food chain from prey to predator).
Overall sensitivity is then determined by considering a combination of adaptability, tolerance and
recoverability, and applying professional judgment, past experience and the evidence base, where:
Tolerance: is the extent to which the resource or receptor is adversely affected by a particular impact.
Adaptability: is the ability of a receptor to avoid adverse impacts that would otherwise arise from a
particular Project Activity.
Recoverability: is a measure of a resource or receptor’s ability to return to a state close to that which
existed before the impact caused a change.
Each of these characteristics may be rated as low, medium or high, as defined in Figure 5-3 .
Low Importance/Sensitivity High Importance/Sensitivity
IMPORTANCE
Low High
SENSITIVITY
Tolerance
High, not adversely Low, destroyed by
affected by this impact this impact
Adaptability
High, can avoid Low, cannot avoid
this impact this impact
Recoverability
High, will recover Low, recovery not
within one year or less possible within 10 years
Figure 5-3 Assessment of Importance and Sensitivity
It is important to note that the above approach to assessing sensitivity is not appropriate in all
circumstances. Where a different approach is applied in topic specific assessments this is explained as
required.
Table 5-1 sets out example definitions for importance and sensitivity.
5-6
Table 5-1 Importance and Sensitivity Definitions
SENSITIVITY DEFINITION
Receptor with low value or importance attached to them, e.g. habitat or species which is
Low abundant and not of conservation significance.
Immediate recovery and easily adaptable to changes.
Receptor of importance e.g. recognised as an area/species of potential conservation

significance for example, Annex I Habitats and Annex II species.
Medium
Recovery likely within 1-2 years following cessation of activities, or localised medium-
term degradation with recovery in 2-5 years.
Receptor of key importance e.g. recognised as an area/species of potential

conservation significance with development restrictions for example SACs, MPAs.
High
Recovery not expected for an extended period (>5 years following cessation of activity)
or that cannot be readily rectified.
5.5.4. Evaluating Significance

To provide information to decision makers and other stakeholders on the importance of different impacts,
an evaluation of the significance of their effects is determined by the EIA process.
Evaluating the significance of effects is based on the professional judgement of the EIA team, which is
informed by legal standards, national and regional government policy, the evidence base (especially peer-
reviewed published literature), current industry good practice and the views of stakeholders.
Magnitude and sensitivity are considered in combination to evaluate whether an effect is, or is not
significant and if so its degree of significance (defined in terms of Minor, Moderate or Major, although
terms may vary for some technical disciplines). Effects classed as Negligible include those that are slight or
transitory, and those that are indistinguishable from the range of natural environmental and social change.
Any impact of negligible magnitude is deemed not to have a significant effect. This general principle is
illustrated schematically in Table 5-2.
Table 5-2 Significance Evaluation Matrix
SENSITIVITY
LOW MEDIUM HIGH
NO EFFECT No effect No effect No effect
SLIGHT Negligible Negligible Negligible
MAGNITUDE SMALL Negligible Minor Moderate
MEDIUM Minor Moderate Major
LARGE Moderate Major Major
5-7
Topic-specific criteria for assessing the significance of effects are defined for each issue and type of impact
in the relevant chapters of this ES. For example, likelihood is a factor for unplanned events but not
considered for routine operations resulting in environmental impacts.
5.5.5. Mitigation
The EIA Regulations require that where significant effects are identified, “a description of the measures
envisaged in order to avoid, reduce and, if possible remedy significant adverse effects on the environment”
should be included in the ES.
One of the key objectives of an EIA is to identify and define socially and environmentally acceptable,
technically feasible and cost effective mitigation measures. In this context, mitigation measures are taken to
include design measures and installation practices, as well as management actions. These measures are
often established through industry standards and best practice:
 Alternatives and best available technique (BAT) inclusions into the design process (e.g. loss
prevention measures, use of dry low emissions (DLE));
 Installation working practices (e.g. soft start for noisy activities if marine mammals are known to be
present); and
 Operational plans and procedures (e.g. Environmental Management Systems, Emergency
Response Plans).
For effects that are initially assessed to be of Major significance, a design alternative usually required to
avoid, minimise or reduce these, followed by a reassessment of significance. For effects assessed to be of
Moderate significance, specific mitigation measures such as engineering controls are usually required to
reduce the impacts and their effects to as low as reasonably practicable levels. This approach takes into
account the technical and financial feasibility of mitigation measures. Effects assessed to be of Minor
significance are usually managed through good industry practice, operational plans and procedures.
The mitigation measures developed during the EIA process, as well as standard industry practice measures,
have been fully committed to by Shell as integral aspects of the Project. EIA is intended to ensure that
decisions on projects are made in full knowledge of their likely effects on the environment and society. As
noted below, the residual effects and their significance reported in this ES are based on the Project as
planned and designed fully inclusive of all proposed mitigation.
5.5.6. Reporting Residual Effects

In reporting the outcome of the EIA process, the degree of significance attributed to residual effects is
related to the weight the EIA team considers should be given to them in making decisions on the Project
and, where appropriate, the application of conditions for approval.
Ideally, through the design, EIA and consultation processes, by the time of an application a project should
be designed to avoid residual effects of major significance.
Effects of moderate significance are considered important to decision making, warranting careful attention
to ensure conditions regarding mitigation and monitoring employ the most appropriate (technically feasible
and cost-effective) measures.
Effects of minor significance are brought to the attention of decision-makers but will be identified as
warranting little if any weight in the decision; mitigation will typically be achieved using normal good
design and working practice.
5-8
5.6. ASSESSMENT OF THE ENVIRONMENTAL RISK FROM ACCIDENTAL HYDROCARBON RELEASES

For accidental hydrocarbon releases the likelihood of such an unplanned event occurring requires
consideration in addition to the consequence. For example, based on magnitude of oiling and
characteristics of the affected resources alone a hydrocarbon spill associated with a well blowout would be
classed as having major impact significance. However, the likelihood of such an event occurring is very
low and so it is more appropriate to talk about ‘environmental risk’ rather than ‘significance of effects’. In
addition, the mitigation measures for such events focus on reducing the likelihood of the event occurring in
the first place as opposed to reducing the magnitude of the impact itself. Thus Chapter 11 - Accidental
Hydrocarbon Releases have an assessment approach that differs from that for planned events and
expresses predicted outcomes in terms of ‘environmental risk’.
As with planned activities, the potential consequences of unplanned events is identified in terms of
magnitude of impact and the sensitivity of the potentially affected resources (especially important ones) to
the effects of oil (while other materials will be used in the construction and operation of the Project it is only
a spill of oil that is likely to be transported any distance in the environment). Consequence is expressed in
terms of different levels of effect in Table 5-3. The consequence is then combined with the likelihood of the
event occurring (Table 5-4) in order to determine its overall environmental risk as summarised in Table 5-5.
Mitigation measures to reduce the likelihood of such an event occurring are described as appropriate.
It should be noted that approaches to assessing environmental risks can be used in order to understand
where risks are highest in terms of prioritising and planning spill response measures. For the purposes of
this EIA environmental risks from accidental hydrocarbon releases are assessed with the objective of
demonstrating that the residual risks are either low and acceptable or reduced to ALARP and are tolerable.
5-9
Table 5-3 Consequence Categories and Descriptions for Assessing Accidental Hydrocarbon Releases
CONSEQUENCE CONSEQUENCE DESCRIPTION OF IMPACT

LEVEL CATEGORY
0 No effect A spill is avoided or contained on the facility
1 Slight Slight environmental damage contained within the Exclusion Zone
2 Minor Minor environmental damage that extends beyond the Exclusion

Zone, but has no lasting effects and no intervention required
Temporary impact on water quality
Unlikely to contribute to transboundary or cumulative effects
3 Moderate Environmental damage extending beyond the Exclusion Zone that
will require a response
Potential to affect species, especially seabirds over a measurable part
of their range
Impact on status of locally important sites or species, recovery within
one year
Possible minor trans boundary effects but which would not require a
response
4 Major Severe environmental damage that will require extensive measures to
restore beneficial uses of the environment
Widespread degradation to the quality or availability of habitats
and/or wildlife requiring significant long-term restoration effort
Recovery likely within 2-5 years following clean up
Moderate-minor impact on the conservation objectives of
internationally/nationally protected sites, habitats or populations
Transboundary effects that require a response
Coastal and open water impacts on areas of economic and aesthetic
value
5 Massive Wide spread long-term degradation to the quality or availability of
habitats and/or wildlife with recovery not expected for an extended
period (>5 years) or that cannot be readily rectified
Major impact on the conservation objective of
internationally/nationally protected sites, habitats and populations
Major transboundary effects expected
Persistent severe environmental and socioeconomic damage that will
lead to loss of commercial, recreational use or loss of natural
resources over a wide area of open water and coastline
5-10
Table 5-4 Likelihood Categories for Assessing Accidental Hydrocarbon Releases
LIKELIHOOD DEFINITION
CATEGORY
A Never heard of in the industry - Extremely remote
<10-5 per year
Has never occurred within the industry or similar industry but theoretically possible
B Heard of in the industry - Remote
10-5 – 10-3 per year
Similar event has occurred somewhere in the industry or similar industry but not likely
to occur with current practices and procedures
C Has happened in the Organisation or more than once per year in the industry –
Unlikely
10-3 – 10-2 per year
Event could occur within lifetime of similar facilities. Has occurred at similar facilities.
D Has happened at the location or more than once per year in the Organisation –
Possible
10-2 – 10-1 per year
Could occur within the lifetime of the development
E Has happened more than once per year at the location – Likely
10-1 - >1 per year
Event likely to occur more than once at the facility.
Table 5-5 Environmental Risk Matrix for Assessing Accidental Hydrocarbon Releases
LIKELIHOOD OF EVENT
A B C D E
0 No Effect
1 Very low risk -
acceptable
CONSEQUENCE 3
OF EVENT Tolerable if
ALARP
5 Very high risk -

unacceptable
5-11
5-12
PHYSICAL PRESENCE
6. PHYSICAL PRESENCE
6.1. INTRODUCTION AND KEY ACTIVITIES
This chapter provides an assessment of the potential effects from the physical footprint of the Project and
discusses the measures to be implemented to mitigate those effects. The term physical footprint refers to the
physical presence of the offshore installations, vessels and subsea equipment and the effects of these on the
physical environment and associated resources and receptors.
The Project aspects which have been assessed for their physical presence include:
 Installations and vessels associated with all project phases (drilling, installation, commissioning and
operations) including the FPSO, drilling rig and associated seabed anchoring; and
 subsea infrastructure such as new wells, manifolds, umbilicals and pipelines and associated
protections (rock berm or concrete mattresses) installed on the seabed.
Chapter 3 provides a detailed description of the key project components and activities. The seabed
footprint from the new infrastructure associated with the Project is summarised in Table 6-1.
Table 6-1 Summary of Project Footprint

Temporary
MODU anchors and 8 x anchors. Mooring lines of 1,100 m length of which 300 m 0.0768
mooring is expected to contact the seabed with 4 m lateral movement.
Assuming deployment of MODU at 8 drilling locations (5 locations in
Tranche 1, 1 location in Tranche 2 and 2 locations in Tranche 3).
Long Term
FPSO anchor piles 12 x anchor piles of 2.5 m diameter. Mooring lines of 0.0025
and mooring 1,600 m length of which 200 m is expected to contact seabed
with 1 m lateral movement.
Production trees 10 x trees of 4.9 m x 4.9 m area installed on production wells. 0.0002
(10 new wells and 1 side track)
Manifolds 4 production manifolds (DCs), 1 Riser Base Manifold (7 m x 0.0004
10 m each) and 1 Pipeline End Manifold (5 m x 8 m)
Pipelines 54,000 m length of pipeline of 0.5 m diameter 0.0270
Production risers 5 x 350 m risers lays on seabed 0.0018
Control umbilicals 20,500 m of umbilicals (included in estimate for rock N/a
dumping)
Tree supply control 9 x 30 m length and 2 x 250 m length (included in estimate N/a
jumpers for concrete mattresses)
Tie-in spools 95 x 25 m length (included in estimate for concrete mattresses) N/a
6-1
PHYSICAL PRESENCE

Rock dumping 20,500 m with rockberm base of 15 m which includes: 0.3240
(140,000 tonnes)
 18,000 m over combined Gas Lift and umbilical
 2,500 m over 10" PAN-N carrier pipe / 4"
piggyback Gas Lift and umbilical laid adjacent to Gas
Lift
500 m of crossings between Brent Charlie and Brent Alpha
with rockberm base of 18 m
500 m of additional rockdump coverage as contingency with
rockberm base of 15 m
Concrete mattresses 600 x concrete mattresses of 6 m x 3 m area 0.0108
Temporary Footprint (during drilling only) 0.0768

Long Term Footprint (throughout installation and operation) 0.3666
Total 0.4434
6.2. SUMMARY OF RESOURCES AND RECEPTORS

The aspects of the baseline considered in the assessment of physical presence include the seabed, marine
habitats and species, and other marine users. The sensitivity of these resources and receptors to impacts
from physical presence is summarised in Table 6-2.
Table 6-2 Summary of Relevant Resources and Receptors
RESOURCE OR SENSITIVITY / QUALITY / IMPORTANCE

RECEPTOR
Seabed (Features The seabed in terms of its features and sediments are considered to have low
and Sediments) sensitivity to impacts from the project footprint. The seabed shows isolated areas of
contamination but is largely representative of the wider area which is subject to
historic and ongoing oil and gas development. The seabed sediments are at a
relatively remote deep water location and support species of low to high conservation
value in low abundance. No habitats of conservation value have been identified.
Marine habitats Most of the interaction between the Project and marine habitats and species will be at
and species the seabed. The area does support species of fish, seabird and marine mammals of
low to high importance but these are not expected to be affected by vessel presence.
The benthic species in the area are considered of low to high importance and are
characteristic of the wider area. They are found in low abundance. The supported
species are also subject to existing disturbance from existing oil and gas development
and fishing activity. The overall sensitivity is considered low.
Other sea users The area is considered of low to moderate value to commercial fishing and is located
within a wider area characterised by oil and gas development and moderate
shipping activity. The sensitivity of other marine users and the commercial fishery to
impacts from physical presence is considered medium.
6-2
PHYSICAL PRESENCE
The effects of underwater noise and discharges to seas (including drill cuttings) are considered in Chapters
9 and 7 respectively.
6.3. DESCRIPTION OF IMPACTS
6.3.1. Overview
Each of the Project aspects identified in Section 6.1 has been considered in relation to their potential effect
on the marine environment.
6.3.2. Presence of Installations, Vessels and Anchoring
6.3.2.1. Overview
There will be a range of installations and vessels present in the Project area over the lifetime of the project.
The majority of these will be temporary such as the drilling rig and installation vessels, whereas the FPSO
will be present for up to 25 years. These aspects are described below.
 Mobile Offshore Drilling Unit (MODU). The drilling unit will be a semi-submersible MODU which
will be towed to the Project area and between drilling locations by tugs and then maintained in
position by anchors laid and removed by anchor handling vessels. During drilling a 500 m safety
zone will be in place around the MODU. The MODU will be serviced by supply vessels and an
Emergency Response and Rescue Vessel (ERRV) will be present in the field. Depending on the final
number of wells, drilling will occur over several years. Once drilling is complete the MODU will
exit the Project area. The MODU will interact with the seabed at anchor locations and at contact
points between the mooring lines and seabed.
 Floating, Production, Storage and Offloading unit (FPSO). The FPSO will be linked to the seabed
by flexible risers and control umbilicals. It will be held on station by mooring lines connected to
piled anchors installed in the seabed. The FPSO will be geostationary and unable to manoeuvre
under normal circumstances. It will therefore present a long term navigational hazard to other
marine users and will prevent access to an area of sea immediately surrounding its location. There
will be a 500 m safety zone around the FPSO. However, the mooring lines will extend beyond the
500 m zone and therefore an extended area will be marked on charts and other sea users will be
made aware of the potential hazard. The FPSO will interact with the seabed at anchor locations
and at contact points between the mooring lines and seabed.
 Installation Operations. The installation vessels used to install the infrastructure (e.g. reeled
pipelay vessel) will be temporarily present within the Project area.
 Support Operations. The supply vessels will transport drilling equipment, supplies, water, fuel and
food to the MODU and FPSO and return wastes and surplus equipment to shore. Helicopters will
be used for personnel transfer. All support operations will be temporarily present within the
Project area.
6.3.2.2. Seabed
Anchors and the mooring line will physically disturb the seabed which will result in localised scarring.
Removal of anchors, in the case of the MODU, will leave pull-out scars and/or anchor mounds as it is
moved between the drilling locations. The MODU anchors will have an estimated seabed footprint of
0.0096 km2 per drilling location, and 0.0768 km2 should all eight drilling locations be used for the 11
wells.
The disturbance of sediments and any associated contaminants during anchor deployment or retrieval will
result in the mobilisation of sediments into suspension in the water column and subsequent sedimentation of
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PHYSICAL PRESENCE
these sediments onto the wider seabed. Seabed sediments are generally described as ‘coarse’ and any
disturbed coarse sediment will drop out of suspension very rapidly close to the point of disturbance.
On the basis of the factors considered above, the magnitude of impacts on seabed sediments associated
with vessel operation and for anchor handling is predicted to be small. The operational impact of the
FPSO is considered of negligible magnitude. Given the low sensitivity of the seabed in the Project area, the
effect is assessed to be of negligible significance.
6.3.2.3. Marine Habitats and Species

Physical disturbance to the seabed can cause mortality or displacement of benthic species in the affected
area. Direct loss of habitat and direct mortality of sessile seabed organisms would be expected at the
anchor locations and the contact points between the seabed and anchor chains.
There is little quantitative information on the likely recovery time of the seabed and benthic organisms from
small areas of localised physical disturbance. The closest indications might be derived from studies carried
out on the physical impacts and biological effects to the seabed caused by towed fishing gear (Løkkeborg,
2005) (Collie, et al., 2000). The studies indicate that the longevity of trawl scarring depends on the
sediment type and the energy of the local environment. Scars in high energy shallow, sandy environments
may disappear within days or months following the initial disturbance, whilst those in quiescent, deeper,
siltier areas may still be faintly visible after 18 months. Collie, et al. (2000) found that sandy sediment
communities were able to recover rapidly, although this was dependent upon the spatial scale of the
impact. It was estimated that recovery from a small scale impact, such as a fishing trawl (the impact width
of which is similar to a pipeline trench), could occur within about 100 days. The UK OESEA 2
Environmental Report compares the effects on habitats of temporary physical disturbance like that of
anchoring by comparing it with the disturbance from wave action during storms. Habitats in shallow sand
and gravel areas are likely to recover rapidly from disturbance (approximately one to five years), while
habitats in low energy areas with muddy substrates are more sensitive to disturbance and will take longer
to recover (DECC, 2011).
Physical disturbance to the seabed caused by anchoring will not alter the existing physical characteristics of
substrate (e.g. particle size distribution) or the habitat types present in the area. The seabed in the
Penguins area is likely to be more similar to the quiescent areas, with the seabed scarring likely to be
visible for more than 18 months and benthic communities taking longer than five years to recover, albeit
with the areas affected being very small in comparison with other sources of seabed disturbance such as
beam trawling.
In terms of benthic species, the larger the affected area of seabed the longer the community is likely to take
to recover. Larger areas are generally recolonised through larval dispersion whereas smaller areas can be
recolonised more quickly by recruitment of organisms from adjacent undisturbed areas (Løkkeborg, 2005).
This recovery of the benthic community may take place even when physical seabed scarring is still visible.
de Groot (1979, 1986) reported recovery of sandy sediments following dredging activities within
approximately 3 years. Where substrates and habitats are able to return to a state similar to their pre-
disturbance condition, it is likely that they will be recolonised by the same types of organisms that were
present pre-disturbance (Lewis, et al., 2003).
The FPSO anchors will be in place over the lifetime of the project and will likely disturb the same areas of
seabed (the contact points between the seabed and anchor chains) on a regular basis. The area affected
by the mooring piles and chains is expected to be 0.0025 km2, which is negligible compared to the
combined area of licence blocks 211/13a and 211/14 REST (132.0 km2). The seabed contact points will
be unable to recover to their previous condition until the anchors are removed during decommissioning.
On the basis of the factors considered above, the magnitude of impacts on benthic habitats and species
associated with vessel operation is predicted to be small. The operational impact of the FPSO mooring
chains is considered of small magnitude. Given the overall sensitivity of marine habitats and species
present in the Project area is low, the effect is assessed to be of negligible significance.
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PHYSICAL PRESENCE
6.3.2.4. Other Marine Users / Fishing Exclusion Zone

A 500 m safety zone will be in place around the MODU during all drilling operations that will prevent
unauthorised access by other marine users including fishermen. Drilling operations at eight drilling
locations will continue for two to four years depending on how many wells are drilled. However, the
impact will be temporary.
A 500 m safety zone will also be in place around the FPSO for the entirety of Project (up to 25 years)
preventing long term access by marine users. The mooring lines will extend beyond the 500 m safety zone
and are a snagging risk to fishing vessels using pelagic or demersal gears.
Vessels in transit will potentially increase the local vessel density but within a wider sea area and context of
an operational offshore oil and gas area. Analysis of vessel traffic within 10 nautical miles of the FPSO
location identified 746 passing vessels per year along 23 passing routes, corresponding to an average of
14 vessels per week. Approximately 50% of these vessels pass within 5 nautical miles or less. Supply
vessels are the most common type (approximately 81%), which usually slow to speeds of around 3 knots
when nearing installations. Fishing vessels were found to contribute 155 passes per year (Lloyds Register
Consulting, 2015).
Project vessels at anchor or otherwise on-station (e.g. using dynamic positioning) will present a local
navigational hazard to other marine users. The greatest vessel activity is likely to be during installation
when various vessels including pipelay, dive support, tugs and anchor handlers will all be in operation in
addition to a number of smaller support vessels. Many of these vessels will be limited in their ability to
manoeuvre during operations. Given an average of 14 vessel passes per week, the presence of project
installation vessels will substantially increase vessel traffic in the area.
These vessels and their associated activities or safety exclusion zones will affect other marine users over a
small area within the context of the wider marine environment and for a short time period within the
context of the overall project lifetime. The collision risk frequency suggests an event could take place
approximately every 52 years (Lloyds Register Consulting, 2015). On the basis of the factors considered
above, the magnitude of impacts on other marine users associated with vessel operations is predicted to be
small. Given the moderate importance of the Project area to other marine users, the effect is assessed as
minor significance.
6.3.3. Subsea Infrastructure
6.3.3.1. Overview
The project will require the installation of a range of infrastructure on the seabed including:
 up to eleven new production wells and associated production trees ;
 Six new manifolds (DC6 – DC9, RBM and Gas Export PLEM) supporting the new development
wells;
 new subsea facilities for production of fluids, gas export and gas-lift including a range of pipelines
ranging from 4" to 16"; and
 New pipeline to tie–in the FPSO gas export pipeline directly to the FLAGs End Manifold (PLEM).
The existing multiphase 16" Penguins pipeline will be repurposed for the gas export pipeline.
Pipelines will be laid on the seabed surface and will be subject to a range of protection measures including
mattresses and rockdump cover for those less than 16" diameter. The installation process of the seabed
infrastructure will result in localised disturbance of seabed sediments comparable to that described in
relation to anchoring. This will be temporary during the installation only and surrounding areas affected
by disturbance would be expected to recover quickly. Once installed the seabed under the footprint of the
infrastructure will be covered at least for the lifetime of the Project. Decommissioning including the decision
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PHYSICAL PRESENCE
to remove infrastructure or potentially leave it in-situ will be subject to a specific planning and assessment
process at that time.
In terms of physical presence, the infrastructure described will be in-situ for at least the operational life of
the Project. Wider areas disturbed by installation or maintenance and any decommissioning or removal
will be affected temporarily. The total footprint of the subsea infrastructure (excluding the FPSO mooring
system) is 0.3642 km2.
6.3.3.2. Seabed Sediments

Installation, decommissioning and maintenance may result in disturbance of the seabed in the immediate
area around the infrastructure. An additional area of seabed will be taken up under the actual footprint of
the infrastructure and this will be in place for the operational life of the project. The area affected is small
within the wider contiguous seabed which is comparable in terms of sediment type and sensitivity.
In addition, depositions of cuttings from well drilling will be present at all drilling locations. The effects of
discharges of WBM and associated cuttings on water quality and benthic organisms are discussed in
Chapter 7. WBM and cuttings are expected to settle out of the water column within 100 m radius of the
wells, each well affecting 0.031 km2. Assuming all 11 wells are part of the development, a total of 10 top
holes will be drilled (E1ST is a side track) and up to 0.31 km2 may be affected by cuttings deposition.
with the presence of subsea infrastructure and cuttings deposition is predicted to be small. Given that the
overall sensitivity of the seabed is considered low, the effect is assessed as negligible significance.
6.3.3.3. Marine Habitats and Species

As described above, the seabed infrastructure installation, maintenance and potential decommissioning will
result in temporary disturbance of an area of seabed and associated benthic habitat around the
infrastructure. Benthic communities in this area would be expected to recover with a few years, so well
within the project lifetime. In addition the habitat under the footprint of the infrastructure will be lost for at
least the operational life of the project and potentially beyond depending on the decommissioning plans
developed. The infrastructure may provide some habitat for encrusting organisms or foraging ground for
fish which is not currently present. As previously described the scale of the area affected within the wider
area of benthic habitat is small.
with the presence of subsea infrastructure is predicted to be small. Given the sensitivity of habitats and
species in the Project area is considered low, the effect is assessed to be of negligible significance.
6.3.3.4. Other Marine Users/ Fishing Exclusion Zone

The subsea infrastructure will present a long term hazard to fishing gear. The infrastructure will be
designed to be ‘anti-snagging’ to avoid damaging the equipment of other marine users or being damaged.
The infrastructure will create an additional seabed hazard in a wider area of offshore oil and gas
development. The project area and any associated hazards to shipping will be detailed in notices to
mariners and on navigational charts and communicated to relevant marine stakeholder groups through
existing fora as appropriate.
On the basis of the factors considered above, the magnitude of impacts on other marine users associated
with the physical presence of the seabed infrastructure is predicted to be small. Given the moderate
importance of the Project area to other marine users, the effect is assessed as minor significance.
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PHYSICAL PRESENCE
6.4. MITIGATION
Throughout the EIA process, measures have been established for the Project to avoid and/or minimise
potential significant effects as far as practicable. These mitigation measures were agreed at an ESMP
workshop and form part of the Project design. In addition the design of the project has sought to facilitate
decommissioning at such time as it will be required. This would allow for the removal on much of the
subsea infrastructure.
Penguins has been producing oil and gas through Brent Charlie for over 10 years and operations including
those of supporting vessels and all associated environmental interactions have not resulted in significant
effects. The new configuration at Penguins and associated operations is expected to have comparable
performance.
Mitigation is required to account for the extent of FPSO mooring lines beyond the 500 m safety zone. Shell
will inform the fishing community of the presence of the mooring lines. This will be done through
consultation, by having the area marked and identified on Admiralty charts, the Kingfisher Information
Service and FishSAFE, and having the ERRV in the project area to communicate directly with using radio
communication.
6.5. RESIDUAL EFFECTS

The magnitude of an impact and the sensitivity/value/importance of the affected resources or receptors are
considered in combination to evaluate whether an effect is significant or not, and its degree of significance.
Table 6-3 below provides the significance of the residual effects resulting from the project’s presence.
6.6. CUMULATIVE AND TRANSBOUNDARY EFFECTS

The effects resulting from the physical presence of the Project has the potential to act cumulatively with both
existing and new developments and other activities. The project will be located in a well-developed area of
the North Sea. It will create temporary disturbance from the MODU and installation vessels operating on
the surface and vessel anchoring on the seabed. Long term disturbance will be from the FPSO on the
surface and subsea equipment installed on the seabed. The total footprint of 0.4434 km2 is considered
negligible with respect to the available area of the North Sea that is of similar habitat type. Furthermore,
the temporary vessel presence is expected to result in a small increase to existing levels of traffic. The
presence of the FPSO considered in combination with other surface facilities in the region is not expected to
cause any significant disturbance to other users of the sea and will be cleared marked on Kingfisher fishing
map system. The project is not expected to have any significant cumulative effects.
The Project FPSO and subsea equipment will be installed within UK waters so there will be no
transboundary effects.
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PHYSICAL PRESENCE
Table 6-3 Significance of Residual Effects
ENVIRONMENTAL ASPECT AND SENSITIVITY PROJECT ASPECT MAGNITUDE OF IMPACT RESIDUAL

SIGNIFICANCE
Seabed (Features and Sediments) Presence of Small –limited to those from anchor handling, impacts localised, Negligible
Low – The seabed in terms of its features and sediments installations, vessels and seabed and associated communities predicted to recover.
are considered to have low sensitivity to impacts from the and Anchoring
project footprint. The seabed shows isolated areas of Subsea Infrastructure Small –seabed disturbance impacts will be common to those Negligible
contamination but is largely representative of the wider described above, the seabed infrastructure footprint will be ‘lost’
area which is subject to historic and ongoing oil and gas for at least the project lifetime, but this affected a small part of
development. The seabed sediments are at a relatively the wider comparable seabed environment.
remote deep water location and support species of low to
high conservation value in low abundance. No habitats
of conservation value have been identified.
Marine Habitats and Species Presence of Small –limited to those from anchor handling, impacts localised, Negligible
installations, vessels and seabed and associated communities predicted to recover.
Low – Most of the interaction between the Project and
and Anchoring
marine habitats and species will be at the seabed. The
area does support species of fish, seabird and marine
Subsea Infrastructure Small – disturbance of the seabed and associated marine Negligible
mammals of low to high importance but these are not
habitats will be common to those described above, the seabed
expected to be affected by vessel presence. The benthic
infrastructure footprint will be ‘lost’ for at least the project
species in the area are considered of low to high
lifetime, but this affected a small part of the wider comparable
importance and are characteristic of the wider area. They
seabed environment. Benthic communities in the wider
are found in low abundance. The supported species are
disturbed area would be expected to recover within the lifetime
also subject to existing disturbance from existing oil and
of the project.
gas development and fishing activity.
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PHYSICAL PRESENCE
ENVIRONMENTAL ASPECT AND SENSITIVITY PROJECT ASPECT MAGNITUDE OF IMPACT RESIDUAL

SIGNIFICANCE
Other Marine Users Presence of Small - vessels and their associated activities or safety exclusion Minor
installations, vessels zones and the area influences by the mooring lines will affect
Medium – The area is considered of low to moderate
and Anchoring other marine users over a relatively small area within the
value to commercial fishing and is located within a wider
context of the wider marine environment. In addition the
area characterised by oil and gas development and
mitigation proposed to identify the risk presented by the
moderate shipping activity. The sensitivity of other marine
mooring lines should reduce the risk of negative effects.
users and the commercial fishery to impacts from physical
presence is considered medium.
Subsea Infrastructure Small – the long term presence of seabed infrastructure will Minor
present an additional sea bed hazard, but will affect other
marine users over a small area within the context of the wider
marine environment and exiting oil and gas development. The
seabed infrastructure will be designed to minimise snagging.
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DISCHARGES TO SEA
7. DISCHARGES TO SEA
7.1. INTRODUCTION AND KEY ACTIVITIES
Discharges to sea can result in impacts on water quality that may lead to potentially significant effects on
the marine environment. The discharges considered in this section are as follows:
 Drilling related discharges including water based mud (WBM), cuttings and cementing material;
 Discharges associated with installation and commissioning activities; and
 Discharges associated with production operations including produced water.
Other planned discharges include those from the heating, ventilation and air conditioning system, the fresh-
water maker and the fire-water system. The volume of drainage water discharged will vary significantly
depending on rainfall. Deluge drains and uncontaminated effluents e.g. from the helideck, are routed
directly overboard without entering the drainage system. These have been scoped out of the assessment
given that they will be discharged in relatively small volume and are not expected to cause adverse affects
to water quality.
All discharges from the Floating, Production, Storage and Offloading (FPSO) unit during transit and
installation will be subject to the International Convention for the Prevention of Pollution from Ships
(MARPOL) 73/78, and once operational are subject to UK environmental legislation (detailed in Chapter
2). All other Project vessels will comply with MARPOL throughout the project.
Accidental hydrocarbon discharges to the marine environment are assessed separately in Chapter 11.

The aspects of the baseline considered in the assessment of discharges to sea include water quality and
marine habitats and species. The sensitivity of these resources and receptors to impacts from discharges to
sea is summarised in Table 7-1.
Table 7-1 Summary of Relevant Resources and Receptors
RESOURCE OR SENSITIVITY / QUALITY / IMPORTANCE

RECEPTOR
Water Quality The existing water quality in the Penguins area is expected to be good given its
offshore location, away from point source pollution. The area supports species of low
to high sensitivity in low abundance. The highly sensitive species are transient within
the project and surrounding area. The overall sensitivity is considered low.
Marine habitats Most of the interaction between the Project and marine habitats and species will be at
and species the seabed. The area does support species of fish, seabird and marine mammals of
low to high importance but these are not expected to be affected by vessel presence
on the surface. The benthic species in the area are considered of low to high
importance found in low abundance. These species present are characteristic of the
wider area and are not unique. The area and supported species are also subject to
existing disturbance from other development and fishing activity. The overall
sensitivity is considered low.
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DISCHARGES TO SEA

This section describes other potentially significant effects associated with discharges to sea from the Project.
7.3.1. Ballast Water

As part of the operation of the FPSO, Mobile Offshore Drilling Unit (MODU) and support vessels, seawater
will be pumped into designated ballast tanks and released to sea to maintain the stability and trim of
vessels. The potential effects associated with inappropriately managed ballast water include discharge that
contains oil or other potentially polluting chemicals, and the possibility of introducing invasive species that
may adversely affect the North Sea ecosystem. To mitigate these potential effects vessels discharging
ballast water will undertake ballast water management measures in accordance with the requirements of
the International Concentration for the Control and Management of Ships Ballast Water & Sediments
(BWM) of 2004 including the implementation of a ballast water management plan (BWMP).
The FPSO, MODU and support vessels are highly unlikely to release contaminated ballast water to sea as
vessels are designed so that ballast water does not come into contact with oily or other contaminated areas.
Invasive species are typically only an issue if vessels are discharging high risk ballast from different marine
areas. Therefore the risk of vessels that operate exclusively in the North Sea of introducing or spreading
invasive species is negligible.
The FPSO will arrive to the North Sea from a different marine area, therefore high risk ballast will be
exchanged at distances no less than 50 nautical miles from shore in at least 200 m water depth in
compliance with the BWM 2004 Convention. It is therefore considered that ballast water discharges are
not significant and are not assessed further.
7.3.2. Waste Water

All phases of the project will involve routine operational discharges including that of sewage, grey water
(with macerated food waste), and deck drainage. These discharges will be in line with the regulatory
requirements and are not considered significant due to the relatively small volumes. They are therefore not
assessed further.
7.3.3. Drilling of Wells

The largest volume of waste generated during drilling operations will be drill cuttings. These comprise
water based mud (WBM) and Low Toxicity oil based mud (LTOBM) cuttings depending on the drilling fluid
used. The base case design is for all LTOBM cuttings to be shipped onshore for treatment and disposal.
The management of this process is discussed further in Chapter 10. This section focusses on discharges of
WBM cuttings.
WBM and LTOBM will be used at the different stages of well drilling depending on well requirements. The
well top sections (36" and 26" holes) are drilled using water based drilling fluids (formed largely of
seawater with bentonite) and for the lower well sections of 16" diameter or less are drilled with Low
Toxicity Oil Based drilling fluids.
The drilling fluids and cuttings returned from the top well sections will be discharged to the seabed. An
estimated 3,110 tonnes of WBM cuttings will be discharged during the Tranche 1 drilling campaign (7
wells). It is estimated that a total of 5,042 tonnes of WBM cuttings resulting from 11 wells will be
discharged to sea if the additional tranches are progressed. The muds selected comprise mainly naturally
occurring minerals and clays, inorganic salts which are water soluble dissociating easily into the natural
constituents of seawater, and organic materials which are biodegradable. The chemical additives are
managed via the Offshore Chemical Notification Scheme (OCNS), which regulates the use and discharge
of chemicals in order to prevent adverse environmental effects in the sea. These discharges are likely to
result in the formation of localised cuttings piles on the seabed at each drill centre. Smaller particle sizes
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DISCHARGES TO SEA
within the discharge plume are expected to settle out within 100 m of the well, resulting in changes to the
sediment composition.
The larger material will be formed primarily of cuttings from the wellbore, whereas the finer material will
be made up of mud components such as barite. The deposition of mud and cuttings is likely to affect the
benthic community in the immediate area by burying (smothering) some animals and impairing the feeding
and respiratory system of others. Increased concentrations of suspended particles may also cause irritation,
abrasion to protective mucous coatings and increasing susceptibility to parasites and infections. Different
faunal groups are tolerant to different degrees of smothering and suspended sediment. In general,
burrowing species such as polychaetes have a high tolerance to burial as they are able to burrow through
the deposits, while encrusting species such as ascidians and bivalves have a lower tolerance as they are
unable to avoid the effects (Tyler-Walters & Jackson, 1999). The project area supports scarce epifaunal
communities of echinoderms and cnidarians.
The effects of cuttings deposition on benthic communities described above are well documented (Neff,
2005) (OSPAR, 2007) (Jones, et al., 2007) and have been shown generally to be localised to within
approximately 50 to 100 m of the discharge point. However, the recovery period of benthic communities
within these areas is less well understood. Recent studies from the Norwegian Sea (Gates & Jones, 2012)
and Faroe-Shetland Channel (Jones, et al., 2012) show that the recovery of megabenthic fauna in areas
covered by cuttings is poor even after 3 years and 10 years, respectively, with recovery largely dependent
on the rate of removal of cuttings from the seabed by natural processes. It is important to note that these
studies were undertaken for sites in approximately 400 m water depth which is considerably deeper than
the Penguins area. Evidence from the northern North Sea suggests the timescale for dispersion of cuttings
on the seabed is in the order of one to ten years, mainly through resuspension and bedload transport due
to tidal and, in shallower waters, wave-induced currents (DTI, 2001).
Other impacts associated with the discharge of WBM cuttings may include elevated levels of barium and
other metals (cadmium, zinc and lead) sometimes associated with the barite used in drilling muds. These
metals may leach into sediments once cuttings have settled on to the seafloor, or into the water column
while cuttings are suspended as a plume following discharge. Barium is present in drilling muds as barium
sulphate which is an insoluble, chemically inert mineral powder that normally contains measurable
concentrations of several trace metals. As such, barium is considered virtually unavailable to biological
organisms and will have no measurable effect on the benthic fauna (Neff, 2005) (Hartley, 1996). The
impact of other metals will depend on their concentration in the barite, which largely depends on its
geological source. Discharge plumes will settle quickly out of the water column and any dissolved
contaminants will disperse quickly (Neff, 2005), therefore impacts to water quality will be localised and
short lived.
Studies of the impacts of WBM discharges have generally found the effects on seabed fauna to be very
small or undetectable, and for the most part limited to physical effects (e.g. burial) rather than toxicological,
even in the presence of chemically detectable levels of drilling material at the seabed (DECC, 2011).
Where toxic effects of WBM and associated cuttings have been observed they are generally thought to be
caused by sulphide and ammonia by-products of organic enrichment (Neff, 2005). A study by (Strachan,
2010) also found that exposure to standard grade barite (the most commonly used weighting agent in
WBM) affected filtration rates of filter feeding bivalves under experimental conditions, resulting in mortality,
but was not acutely toxic during field studies. However, persistent exposure to standard grade barite was
found to alter benthic community structure in the field. Any toxic effects from drilling discharges are
expected to be highly localised to the point of discharge, as the contaminants are rapidly diluted to below
effective concentrations away from the source (DECC, 2011).
Other discharges from drilling include small amounts of cement and well completion and clean-up fluids.
Cementing operations may involve small discharges of chemicals when cementing the tophole sections back
to the surface and when the cement unit is cleaned between each cementing operation. It is anticipated
that cement will be mixed and used as required. As such there should be limited discharges of any mixed
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DISCHARGES TO SEA
cement or mixwater. All cement discharged from the deeper well sections would take place via the route
for the WBM cuttings discharges.
Some of the additives in both the drilling fluid and cement may contain components identified for
substitution. However, these chemicals are only used in specific scenarios where they can be justified on
technical and safety grounds. The Project will avoid using chemicals that will have an adverse effect on the
marine environment.
The magnitude of impact from drilling discharges on water quality and marine habitats and species is
considered small.
7.3.4. Installation and Commissioning

Installation and commissioning activities will cover subsea infrastructure, inspection, hydrotesting and leak
testing operations. Subsea infrastructure will either be pre-filled with chemicals onshore, including
corrosion and scale inhibitors, oxygen scavengers and biocide, which will then be discharged during hook-
up and commissioning or flooded into the system during installation offshore. Dye will also be used to
identify any leaks in the system. Discharges will occur during the following activities:
 Flooding and gauging;
 Strength testing;
 Tie-in (connection) of the subsea components;
 Leak testing; and
 De-watering.
These releases will be at the seabed and will temporarily expose seabed dwelling organisms to chemicals
contained in commissioning fluids. Typical oxygen scavengers react with water to consume oxygen and
produce sulphates. This is a one-off reaction with no harmful by products. In addition, a substantial
proportion of the original scavenger dose is expected to be consumed inside the flowlines prior to release.
In common with the oxygen scavenger, a proportion of the biocide chemical is also likely to be
consumed/degrade in the flowlines depending on how long it resides there. Tracer dyes are typically
poorly biodegradable but are water soluble and will rapidly disperse in the marine environment.
The exact location of the discharge points and the quantities of chemicals to be used and discharged will
be determined during the detailed design and will be provided in a subsequent Chemical Permit
application as required under the Offshore Chemicals Regulations 2002 (as amended).
The magnitude of impact from installation and commissioning discharges is considered small.
7.3.5. Production
Formation Water is naturally present in oil and gas reservoirs and it is produced together with the
hydrocarbons as a portion of the produced fluids. Produced water will be separated from the hydrocarbons
on the FPSO and transferred to the produced water treatment system where it will be treated prior to
discharge to sea.
Penguins has been producing oil via Brent Charlie Platform since 2003 and all produced water has been
discharged to sea with no significant effects on the environment. The cumulative water production for the
Penguins Field to date (2003-2015) is approximately 560,000 bbls, with historical peak water rate of
1,100 bbls/day. The water production profile is shown in Figure 7-1. Produced water trend is not
expected to rise significantly in the short and medium term due to the prevailing operating philosophy and
reservoir energy capacity. Mid-and late field life water production is expected to be modest (up to circa
10% water cut in the reference case).
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DISCHARGES TO SEA
Figure 7-1 Penguin Fields Historical Water Production 2003-2015 (Field was Shut-in from 2011-2013 due to
Unavailability of Host Installation)
A technical feasibility study has been carried out to assess the possibility of produced water reinjection
(PWRI) at the Penguins field. The study considered disposal into a shallower overburden zone and the
conversion of a current producer well into a re-injection well. Of the four wells identified, none of them
was deemed suitable for PWRI, as discussed further in Chapter 3.
Due to the limitations identified with PWRI, overboard discharge has been identified as the base-case for
the Penguins Redevelopment Project. Produced water will be compliant with the approved Oil Discharge
Permit and will meet the regulatory requirement of less than 30 mg/l monthly average dispersed oil in
water. Conventional clean-up technologies (separation, hydrocyclones and degasser), which constitute the
base case treatment for Penguins FPSO, are capable of meeting this requirement. These are systems which
are well established in the oil and gas industry and have proven to be technically reliable.
The plume resulting from a low and continuous volume of produced water discharge is likely to be
detectable within a few tens of metres of the discharge point. There would be the potential for impacts on
water quality (as a consequence of entrained hydrocarbons and other components such as metals) in the
vicinity of the FPSO as a result of produced water discharges.
There would also be possible secondary effects on marine organisms (e.g. plankton, larger invertebrates
and fish). Phytoplankton and zooplankton communities seasonally present in the vicinity of the FPSO are
likely to be the most sensitive group to produced water discharges due to the presence of hydrocarbons
and other chemicals in the discharge. Although fish will be present under and around the FPSO they are
unlikely to be exposed to any significant effects as they are mobile and the residence time within the
discharge plume will be short. Toxicity studies on produced water discharges have shown that the
concentrations of toxic chemicals in most produced waters are well below the test species 96 hour LC50
(lethal concentration for 50% of the individuals tested over a 96 hour period) indicating that acute toxicity
is unlikely beyond the immediate vicinity of the discharge (GESAMP, 1993). Given the small scale and
small relative to the baseline, the magnitude is considered small to medium.
Provision will be made to allow injection of additional chemicals including deoiler, water clarifier and
demulsifier if required to improve separation during operations
In the event of the oil in water content going ‘off-spec’ the produced water can be routed to the FPSO slop
tanks to be treated further by a polishing unit in order to meet the 30 mg/l dispersed oil in water content.
7-5
DISCHARGES TO SEA
7.3.5.1. Chemical Use during Production

Specialist chemicals are used during production to maintain process efficiency. Depending on their
properties these chemicals will partition between the oil and the water in the process. The reaction
products and residual chemicals from those that partition to the water phase will be released to the marine
environment with the produced water discharge. The exact details and quantities of the chemical usage and
discharge will be provided within subsequent Chemical Permit applications.
Chemicals used during production operations include the following.
 Hydrate inhibitors;
 Corrosion inhibitors;
 Scale inhibitors;
 Slugging chemicals;
 Erosion assessment chemicals; and
 Asphaltene removers.
Chemicals will also be used to maintain pipelines and ensure pipeline integrity; including biocides and
oxygen scavengers.
It is expected that methanol injection will be required in order to inhibit the formation of natural gas
hydrates in pipelines. The required volume will be determined by hydrate prevention during field start-up.
In addition to subsea hydrate prevention, methanol may also be used topsides on an intermittent basis, for
example, upstream of pipeline depressurising valves, or to dose liquids in flexible riser sag bends following
a shutdown.
Historically, flowing temperatures in the Penguins field have been within or below the nominal wax
appearance range, with no noticeable issues. However, continuous or intermittent wax inhibition may be
required in future, and will be routed via dedicated cores in the umbilical to the appropriate manifold.
Continuous or intermittent scale inhibition may be required in the future to certain wells, and will be routed
via dedicated cores in the umbilical to the production trees.
The corrosion inhibitor system will be designed to deliver corrosion inhibitor to the drill centre manifolds.
For the LP system this will be continuous. Corrosion inhibitors are not required for the HP system as the
pipelines will be made from corrosion resistant alloys.
The small volume discharges of relatively low toxicity effluent will disperse rapidly in the receiving
environment. The larger volumes discharged during hydrotesting may lead at most to temporary, small,
localised effects to benthic communities given that the discharge will be rapidly diluted. These effects are
likely to be limited to a few tens of metres from the discharge point and will primarily relate to the nature
and residual concentrations of the biocide and oxygen scavenger that are used; noting that these chemicals
will be partially consumed while residing in the flowlines.
The magnitude of production discharges is considered small to medium.
7.4. MITIGATION
Throughout the EIA process, measures have been established for the project to minimise impacts as far as
practicable. These mitigation measures were agreed at an environmental and social management plan
(ESMP) workshop carried out for the project and are detailed in Chapter 12 (table 12.1).
7.4.1. Storage, Treatment and Discharge Systems

Where required, machinery, chemicals, fuel and lubrication oil storage areas on vessels will be bunded in
order to contain drips and spills, and minimise the risk of overboard discharge. For safety reasons,
7-6
DISCHARGES TO SEA
however, it is usually required that any spillage of aviation fuel during the refuelling of helicopters on the
rig, will be directed to sea, where it will rapidly disperse and evaporate.
No additional measures beyond the treatment systems and legal compliance and reporting processes
already present on the FPSO and supporting vessels will be adopted for this project. These inherent
measures include oil/water separators, food waste macerators and designated ballast tanks.
7.4.2. Chemical Selection

Chemical selection is undertaken to identify the most environmentally acceptable chemical with the required
technical performance.
All chemicals used during the project will be approved under the Offshore Chemical Regulations 2002
prior to use and discharge to sea. Where possible the use of chemicals will be minimised or eliminated
altogether. All use and discharge of chemicals will be monitored offshore to ensure compliance with the
chemical permit, which is then reported to regulators.
Chemical awareness training will be provided to staff and contractors to include chemical management,
storage and handling offshore and chemical permitting requirements.

Table 7-2 below provides the significance of the residual effects resulting from discharges to sea from the
project.

Drilling discharges such as the mud, cuttings and cements deposited on the seabed are likely to persist for
several years after drilling has ceased. The potential for these discharges to contribute to cumulative,
regional scale contamination in the central North Sea is considered negligible. The constituents of WBM
are mainly minerals and clays which are found naturally occurring in the seabed sediments of the UKCS.
These constituents, together with inorganic salts which are water soluble, dissociate easily into the natural
constituents of seawater. There will therefore be no associated cumulative effects in the marine environment.
Other discharges such as those from operation of the FPSO (particularly produced water) and support
vessels will be undetectable within a few tens of metres from the discharge point due to natual dispersion
and dilution. Therefore cumulative effects from these sources are not expected.
The Penguins FPSO will be located approximately 4 km from the UK/Norway median line, and therefore,
no significant transboundary effects are predicted from surface discharges.
7-7
DISCHARGES TO SEA
SENSITIVITY/ IMPORTANCE PROJECT ASPECT MAGNITUDE RESIDUAL

SIGNIFICANCE
Water Quality Drilling discharges Small – short term impact localised to the point of discharge. Negligible
Localised discharges and inert components of muds, cuttings
Low – The existing water quality in the Penguins area is
and cement.
expected to be good given its offshore location, away from
point source pollution. The area supports species of low to
Installation and Small – relatively low toxicity effluent will disperse rapidly. Negligible
high sensitivity in low abundance. The highly sensitive
commissioning Larger volumes leading to at most temporary, small, localised
species are transient within the project and surrounding area.
Discharges effects.
Production Small to medium – produced water discharge continuously for Minor

discharges the lifetime of the project but at small scale with only small
change to baseline. Small discharges of other low toxicity
production chemicals will have localised effects to fauna within
a few tens of metres from the discharge point.
Marine habitats and Species Drilling Discharges Small – localised smothering of sessile organisms from cuttings Negligible
deposition, no toxic effects expected. Affected communities
Low – Most of the interaction between the Project and
expected to recover in 3-10 years.
marine habitats and species will be at the seabed. The area
does support species of fish, seabird and marine mammals of
low to high importance but these are not expected to be
affected by vessel presence on the surface. The benthic
species in the area are considered of low to high importance
found in low abundance. These species present are
characteristic of the wider area and are not unique. The
area and supported species are also subject to existing
disturbance from other development and fishing activity.
7-8
ATMOSPHERIC EMISSIONS
8. ATMOSPHERIC EMISSIONS
8.1. INTRODUCTION
Emissions to the atmosphere are expected to occur at multiple stages throughout the Penguins
Redevelopment Project, from installation through to operation and from both controlled and uncontrolled
sources. At this Front End Engineering Design (FEED) stage, the exact model and arrangement of the gas
compressor and power generators to be used are not finalised. The worst-case option, in terms of
emissions, was selected for the assessment.
The main sources of emissions assessed are summarised as follows:
 Power generation during installation and commissioning;
 Drilling rig emissions; and
 Operational power generation, venting and flaring.
Emissions of carbon dioxide (CO2), oxides of nitrogen (NOx) and sulphur dioxide (SO2) have been
considered and assessed in relation to proposed activities associated with the Project. Calculations have
been based on the emission factors contained within DECC’s Environmental Emissions Monitoring System
(EEMS) guidance for Atmospheric Emissions Calculations. In relation to greenhouse gas emissions,
consideration has been given to CO2 (and equivalent) emissions potentially arising from the Project. These
have then been evaluated against their contribution to the corresponding quantities of atmospheric
emissions from all oil and gas activities on UKCS using latest reference industry data up to the end of 2013
(UKOG, 2014). This assessment also draws upon the atmospheric emissions modelling in Appendix C – Air
Quality Modelling Report. This assessment specifically considers the potential worst case operational
scenarios and associated equipment use for the Project. The operational equipment and activities
considered as the main emissions sources are the three dual fuel turbine generators, one gas compressor
turbine and flaring. Three worst case operational scenarios are presented, namely; normal operations
operating on gas; normal operations operating on gas with emergency flaring; and upset conditions
operating with diesel gas turbine generator use and emergency flaring.
The potential effects of the drilling and commissioning phases, together with the effects of the auxiliary
generators were not included in the dispersion modelling as they were not considered to be significant.

The assessment of atmospheric emissions is primarily done by comparison against Air Quality Standards.
The standards used in this assessment are set out in Section 8.3.3.1. In general terms, the sensitivity of local
air quality in the Penguins area is considered low due to the absence of existing pollution sources and the
absence of sensitive receptors.
8.3.1. Emissions Sources

For each phase of the project, the principle emissions to atmosphere have been identified and discussed
below.
8.3.1.1. Drilling
Emissions from the drilling activities principally related to the engine emissions from the drilling rig which is
typically fuelled with diesel. Although completely separate from emissions associated with the Penguins
FPSO, an estimate of these emissions has been made.
8-1
At this stage, the drilling rig for the project has not yet been selected; however it is expected to be similar to
the Ocean Guardian used in previous drilling campaigns. Table 8-1 presents fuel usage and Table 8-2
estimated emissions from previous Penguins well campaigns (C Triassic, C4 Brent, PAN-N, PAN-W, D3s1
and Rockhopper) using the Ocean Guardian drill rig and provides an indication of the expected level of
CO2, NOx and SO2 emissions from the drilling associated with the project. Calculations have been based
on the emission factors contained within EEMS guidance for Atmospheric Emissions Calculations.
Table 8-1 Fuel Consumption during Drilling Activities
ESTIMATED PENGUIN REDEVELOPMENT CAMPAIGN USAGE
Well C C4 Brent PAN-N PAN-W D3s1 Rockhopper

Units
Campaign Triassic (RH)
Rig Duration days 113 99 109 112 115 77
Diesel tonnes/day 8.31 8.31 8.31 8.31 8.31 8.31
consumption
Diesel tonnes 939 823 906 931 956 640
consumed
Source: (Shell, 2015)
Table 8-2 Atmospheric Emissions from Drilling Activities
ESTIMATED PENGUIN REDEVELOPMENT CAMPAIGN EMISSIONS
Well C Triassic C4 Brent PAN-N PAN-W D3s1 Rockhopper

Units
Campaign
tonne CO2 3.17
CO2 Emission
/ tonne
Factor
diesel
tonne NOx 3.7x10-3
NOx Emission
/ tonne
Factor
diesel
tonne SO2 1.28x10-5
SO2 Emission
/ tonne
Factor
diesel
CO2 2980 2610 2870 2950 3030 2030
tonnes
Emissions
NOx 3.47 3.04 3.35 3.44 3.54 2.37
tonnes
Emissions
1.20x10 1.05x10-2 1.16x10-2 1.19x10-2 1.22x10-2 8.19x10-
SO2 Emissions tonnes -2 3
8-2
8.3.1.2. Installation and Commissioning

The primary sources of emissions during the initial installation and commissioning phase are associated
with power generation and vessel transportation. Emissions from helicopter and vessel usage and tug boats
are currently unknown at this stage. Overall, these additional sources of emissions will be minor sources
compared to those associated with power generation; however they have been estimated and included in
Table 8-3 and Table 8-4 for completeness. The emission factors used in the calculations are set out in Table
8-5.
Table 8-3 Ancillary Fuel Use
VESSEL FUEL USE (TONNES/DAY)

DURING DURING OPERATIONS
MOBILISATION/DEMOBILISATION
Semisubmersible drilling rig 25 30
Anchor handling tug vessel 50 5
Standby vessel 10 5
Supply vessel 10 5
Floating, production, storage and 7 -

offloading vessel
Dynamic positioning construction 22 18
vessels
Trenching and backfill vessel 8 15
Dynamic positioning reel-lay 8 15

vessel
Dive support vessel 22 18
Survey vessel 10 5
Rock dump vessel 26 18
Guard vessel 10 5
Remotely operated vehicle 22 18

support vessel
Helicopters 1.96 -
Source: (Institute of Petroleum, 2000)
8-3
Table 8-4 Estimated Ancillary Emissions
VESSEL DURING DURING OPERATIONS (TONNES

MOBILISATION/DEMOBILISATION OF POLLUTANTS/DAY)
(TONNES OF POLLUTANTS/DAY)
CO2 NOx SO2 CO2 NOx SO2
Semisubmersible drilling rig 79.1 1.49 0.100 94.9 1.78 0.120
Anchor handling tug vessel 158 2.97 0.200 15.8 0.297 2.00x10-2
Standby vessel 31.6 0.594 4.00x10-2 15.8 0.297 2.00x10-2
Supply vessel 31.6 0.594 4.00x10-2 15.8 0.297 2.00x10-2
Floating, production, storage 22.2 0.416 2.80x10-2 - - -

and offloading vessel
Dynamic positioning 69.6 1.31 8.80x10-2 57.0 1.069 7.20x10-2

construction vessels
Trenching and backfill vessel 25.3 0.475 3.20x10-2 47.5 0.891 6.00x10-2
Dynamic positioning reel-lay 25.3 0.475 3.20x10-2 47.5 0.891 6.00x10-2

vessel
Dive support vessel 69.6 1.31 8.80x10-2 57.0 1.07 7.20x10-2
Survey vessel 31.6 0.594 4.00x10-2 15.8 0.297 2.00x10-2
Rock dump vessel 82.3 1.54 0.104 57.0 1.07 7.20x10-2
Guard vessel 31.6 0.594 4.00x10-2 15.8 0.297 2.00x10-2
Remotely operated vehicle 69.6 1.31 8.80x10-2 57.0 1.069 7.20x10-2

support vessel
Helicopters 6.20 0.116 7.84x10-3 - - -
Source: (Institute of Petroleum, 2000) (DECC and Oil and Gas UK, 2008)
8-4
Table 8-5 Diesel Use Emission Factors
PARAMETERS UNITS EMISSION FACTOR
Emission Factor for diesel engine(CO2) kg CO2/kg fuel used 3.16

Emission Factor for diesel engine (NOx) kg NOx/kg fuel used 5.94x10-2
Emission Factor for diesel engine(SO2) kg SO2/kg fuel used 4.00x10-3
Source: (DECC and Oil and Gas UK, 2008)
Table 8-6 details the expected first year emissions from FPSO power generation for gas only and Table 8-7
details emission on diesel use, which assumes that power generators will operate on diesel for four weeks
of the year during hook up and commissioning activities. Calculations have been based on the emission
factors contained within EEMS guidance for Atmospheric Emissions Calculations set out in Table 8-8.
Table 8-6 Installation and Commissioning Activities – Fuel Gas powered Equipment
HP COMPRESSOR GENERATOR GAS

PARAMETERS UNITS
TURBINE TURBINES
Power output kW 16,000 6,680
Runtime per annum hours 8,016 8,016*
Turbine efficiency % 35 33.9
Number of turbines - 1 3
Fuel Gas consumed per
mmscm 29.6 38.3
annum
CO2 emissions per annum tonnes 84,700 110,000
NOx emissions per annum tonnes 181 234
SO2 emissions per annum tonnes 0.379 0.490
*Three Generator Turbines are proposed. Power output and runtime data presented are for single turbines, with fuel
consumption and emissions data presented for all three Turbines.
8-5
Table 8-7 Installation and Commissioning Activities – Diesel powered Equipment
HP COMPRESSOR GENERATOR GAS

PARAMETERS UNITS
TURBINE TURBINES
Power output kW n/a 6,680
Runtime per annum hours n/a 672*
Diesel consumed per annum tonnes n/a 3,370
CO2 emissions per annum tonnes n/a 10,700
NOx emissions per annum tonnes n/a 45.5
SO2 emissions per annum tonnes n/a 13.5
Table 8-8 Power Generation Emission Factors
HP
GENERATOR GAS
PARAMETERS UNITS COMPRESSOR
TURBINE
TURBINE
Emission Factor for fuel gas (CO2) kg CO2/mmscm of fuel gas 2.86
Emission Factor for fuel gas (NOx) kg NOx/mmscm of fuel gas 6.10x10-3
Emission Factor for fuel gas (SO2) kg SO2/mmscm of fuel gas 1.28x10-5
Emission Factor for diesel turbine n/a 3.16
kg CO2/kg fuel used
(CO2)
Emission Factor for diesel turbine kg NOx/kg fuel used n/a 5.94x10-2
(NOx)
Emission Factor for diesel turbine kg SO2/kg fuel used n/a 4.00x10-3
(SO2)
Source: (Institute of Petroleum, 2000) (DECC and Oil and Gas UK, 2008)
8-6
8.3.1.3. FPSO Flaring

During normal steady state operation very little gas is expected to be flared. The flare pilots will be
continuously lit but their fuel gas consumption rates will be very small. There may be flaring during the
following operational scenarios:
 Start-up (prior to starting the low-pressure (LP) and high-pressure (HP) compressors);
 Shut down;
 Slugging events;
 Equipment depressurisation for maintenance purposes;
 Emergency depressurisation (EDP) in the event of a fire and gas initiated shutdown; and
 Equipment failure (compressors, passing valves).
The data in Table 8-9 details the expected emissions resulting from the likely flaring events. An average
daily flare rate of 0.5 mmscfd (1.42x10-2 mmscmd) has been assumed for the Project. This is slightly less
than the current best performing Shell FPSO asset (Curlew) and reflects the desire and commitment to
minimise flaring. The Penguins FPSO will be designed to the latest engineering standards and codes, and
so an improvement on the existing Shell operated FPSO is expected.
Table 8-9 Flaring Emissions
PARAMETER UNIT VALUE
Gas flared per annum mmscm 5.17

Gas flared per day (annual average) mmscmd 1.42x10-2
Emission Factor for fuel gas (CO2) kg CO2/mmscm of fuel gas 2.80
Emission Factor for fuel gas (NOx) kg NOx/ mmscm of fuel gas 1.20x10-3
Emission Factor for fuel gas (SO2) kg SO2/mmscm of fuel gas 1.28x10-5
CO2 emissions per annum tonnes 14,500
NOx emissions per annum tonnes 6.20
SO2 emissions per annum tonnes 6.61x10-2
Source: (Shell, 2015) (Institute of Petroleum, 2000) (DECC and Oil and Gas UK, 2008)
8.3.1.4. FPSO Power Generation

Fuel gas is to be consumed by the three main power generation gas turbines and the HP compressor gas
turbine. The HP compressor gas turbine and the main power generation gas turbines are likely to be the
largest emitters within the Penguins Redevelopment Project. The main power generation turbines are
designed to be operated on both fuel gas and diesel. During normal operation they will consume fuel gas.
However during shut-down and any upset events, they will switch to diesel. The HP compressor gas turbine
is fuelled on gas only.
Table 8-10 details the likely emissions from the operations of the 45.9MWth HP compressor gas turbine
and the three 19.7MWth main power generators, operating on gas only, with Table 8-11 detailing
emissions on diesel use. The summarised data and therefore emissions are based upon the maximum hours
of operation in a major year rather than a yearly average (or minor year) and therefore the data are
considered to be conservative. Calculations have been based on the emission factors contained within
EEMS guidance for Atmospheric Emissions Calculations, set out previously in Table 8-8.
8-7
Table 8-10 Maximum Power Generation Emissions - Fuel Gas Powered Plant
HP
GENERATOR GAS
PARAMETER UNIT COMPRESSOR
TURBINE*
TURBINE
Power output kW 16000 6680
a
Runtime per annum Hours 8520 8520b
Turbine efficiency % 35.0 33.9
Fuel Gas consumed per annum mmscm 31.5 40.7
CO2 emissions per annum tonnes 90,000 116,000
NOx emissions per annum tonnes 192 248
a and b – Year 2020 (minor turnaround) – Source: (Shell, 2015)
*Generator Turbines have been designed with dry low emission (DLE) burners. Overall NOx emissions should be less
than reported.
Table 8-11 Maximum Power Generation Emissions – Diesel Powered Plant
HP
GENERATOR GAS
PARAMETER UNIT COMPRESSOR
TURBINE*
TURBINE
Power output kW n/a 6680
Runtime per annum hours n/a 504
Diesel consumed per annum tonnes n/a 2530
CO2 emissions per annum tonnes n/a 8004
NOx emissions per annum tonnes n/a 34.1
SO2 emissions per annum tonnes n/a 10.1
Note – Worst-case runtime taken from Year 2022 (major turnaround) – Source: (Shell, 2015)
*Generator Turbines have been designed with dry low emission (DLE) burners, so overall NOx emissions should be less than reported.
*Three Generator Turbines are proposed. Power output and runtime data presented are for single turbines, with fuel consumption and
emissions data presented for all three Turbines
8.3.1.5. FPSO Diesel Engines

Internal combustion engines running on diesel fuel are expected to be used for the following services on the
Penguins Redevelopment Project:
 Emergency diesel generator;
 Three fire pump diesel generators; and
8-8
 Inert gas generator.

Table 8-12 details the expected usage of the additional diesel plant and their associated emissions.
Emissions related to the inert gas generator have not been included as the frequency of use is expected to
be very low (the base case is to blanket the cargo tanks with hydrocarbon gas which will be recovered to
the process via the VRU).
Table 8-12 Diesel Power Engine Emissions
EMERGENCY FIRE PUMP*

PARAMETER UNIT
GENERATOR
Thermal input kW 2,660 2,000
Runtime per annum hrs 150 104
Number of units - 1 3
Diesel used per annum tonnes 77.4 121
Emission Factor for diesel engine (CO2) kg CO2/kg fuel used 3.16
Emission Factor for diesel engine (NOx) kg NOx/kg fuel used 5.94x10-2
Emission Factor for diesel engine (SO2) kg SO2/kg fuel used 4.00x10-3
CO2 emissions per annum tonnes 245 383
NOx emissions per annum tonnes 4.60 7.19
* Three Fire Pumps are proposed. Rating and runtime data presented are for single Pump, with fuel consumption and
emissions data presented for all three pumps.
Source: (Shell,2015)
8.3.1.6. Cumulative Operational Emissions

The cumulative operational combustion emissions from the FPSO have been calculated 1 and are detailed in
Table 8-13. Comparison has been made between the total CO2, NOx and SO2 emissions and the
respective reported UKCS total offshore emissions in 2013 (OGUK, 2014).
The total emissions are estimated to represent 1.62%, 1.10% and 0.35% of the reported UKCS total CO2,
NOx and SO2 emissions respectively, from off-shore activities in 2013. Given the conservative operational
assumptions made, it is expected that the actual annual emissions for each pollutant will be lower.
Table 8-13 Cumulative Emissions from FPSO

NOx emissions per annum tonnes 496
SO2 emissions per annum tonnes 11.9
1Drilling emissions included in the total have been estimated using an average of the Previous Penguin Drilling Campaigns outlined in Table 8.2.
Ancillary emissions have not been included.
8-9

Total CO2 2013 emissions offshore tonnes 14,310,000
Total NOx 2013 emissions offshore tonnes 45,000
Total SO2 2013 emissions offshore tonnes 3,400
Annual CO2 emissions from proposed FPSO % 1.62

as a % of 2013 UKCS total
Annual NOx emissions from proposed FPSO % 1.10
Annual SO2 emissions from proposed FPSO % 0.35
8.3.1.7. Fugitive Emissions

All hydrocarbon plant will generate minor releases of fugitive emissions. Fugitive emissions are considered
to be emissions which cannot easily be quantified or attributed to a single source(s). Likely sources of
fugitive emissions on the Penguin Redevelopment Project are expected to include for example; pipe
connections, valves, flanges and pumps.
The status of the FPSO design data at this stage means it has not been possible to estimate the likely fugitive
emissions from the Project. However, in relative terms to the emissions assessed, these are considered to be
negligible.
8.3.2. Emission Management Incorporated into the Project Design

The FPSO is a new build vessel. Therefore, the equipment items which generate CO2 as a by-product of
generating power will be of a modern design and aligned with the latest Design Engineering Principles.
The new machines will be more efficient and less polluting than those used in previous campaigns.
The following CO2 and pollution preventive measures have been incorporated into the design and are
reflected in the emission values provided in Section 8.4:
 There will be no continuous flaring and venting during normal steady state operation of a well
maintained installation in accordance with Shell HSSE & SP Control Framework;
 All the gas turbines (three power generation turbines and one HP compressor service) have been
designed with DLE burners. This will reduce the quantity of NOX. It will not affect the CO2 or SO2
emission levels as these are not influenced by temperature;
 The fuel used during the Project will have a sulphur content of no more than 1.5% in line with EU
Directive 2005/33/EC;
 A vapour recovery package will be used to recover vapours which are displaced as cargo tanks
are filled and other minor streams which are normally flared (i.e. compressor seal purges). These
recovered vapours will then be routed back to the process (LP compressor suction) for further
processing. The package will also be used to recover hydrocarbon vapours from the produced
water degasser;
 Facility heat load for Topsides/Hull processing operations will be recovered from turbine exhaust
gas using waste heat recovery units (WHRU). Three WHRU on the 3 gas turbines (used for power
generation) will be provided. The use of a WHRU slightly reduces the efficiency of a turbine but
increases the overall efficiency of the system by reducing the amount of fuel required to generate
steam for heating by other systems. It is estimated that use of WHRUs will result in significant
reduction in fuel use and CO2 emissions;
8-10
 The HP compressor gas turbine is likely to be fitted with high efficiency particulate air (HEPA)
filters, which will significantly reduce and perhaps even remove the requirement for regular
cleaning of the turbines. Therefore, there will be less compressor shutdowns required for this work
and less flaring during the shutdown / start-up process;
 All fuel gas and diesel streams will be measured / monitored. This should identify when excessive
use is occurring;
 The LP & HP flare gas streams will be continuously measured / monitored. This should help identify
good and bad start-up / operating practice. Abnormal rates can be investigated further and may
indicate passing valves to flare. Measurement of these streams will also be used to confirm
compliance or otherwise with the assigned flare constraints; and
 Depressurisation of the subsea pipelines will generally be to the installation processing systems
rather than to the flare system. This will therefore recover those gases that might normally be flared
and wasted.
8.3.3. Atmospheric Dispersion Modelling and Impact Assessment

An assessment of effects using dispersion modelling was undertaken for the operational stages of the
project to quantify the predicted concentrations of NO2 and SO2.
Whilst the Penguin FPSO unit site is located off-shore, as it is located within the Scottish exclusive economic
zone (EEZ), it is therefore still bound to European Union (EU) and Scottish Legislation.
Within Scotland the majority of the air quality standards relating to ambient air quality are based upon the
EU directives (European Parliament, 2008), with the relevant Scottish Legislation being The Air Quality
Standards (Scotland) Regulations 2010. The comprehensive Air Quality Impact Assessment for the
Penguins Redevelopment Project is available as Appendix C. The following emissions were scoped out of
the modelling and EIA:
 Volatile Organic Compounds (VOC) emissions (such as benzene) as the annual mean averaging
period within the Scottish Air Quality Standards (AQS) does not reflect the likely short-term time
period when VOC emissions are likely to occur;
 Particulates (PM10 and PM2.5) and carbon monoxide (CO) from combustion exhausts are not
generally considered to be significant emissions for gas-fired sources;
 PM10, PM2.5 and CO emissions from diesel generators and flaring activities, as their respective
averaging periods within the AQS are not considered appropriate for the assessment of
intermittent upset conditions and flaring events; and
 CO2, methane (CH4) and nitrous oxide (N2O) as they are not considered within the AQS for the
protection of human health. CO2 (and equivalents) have been considered further with regards
their effects to global greenhouse gas emissions.
8.3.3.1. Ambient Air Quality Standards

The EU and Scottish air quality standards include nitrogen oxides (NOX) - which includes NO2 and NO -
and SO2, as the primary pollutants of concern within this study.
The air quality standards for the protection of human health used in this assessment are set out in Table
8-14.
8-11
Table 8-14 Air Quality Standards (AQS) for the Protection of Human Health
POLLUTANT AVERAGING PERIOD AND UNITS VALUE SOURCE

STATISTIC
NO2 Annual mean µg/m3 40 Scottish AQS / EU
1 hour mean, not to be
NO2 exceeded more than 18 times a µg/m3 200 Scottish AQS / EU
year (99.79th percentile)
SO2 exceeded more than 3times a µg/m3 125 Scottish AQS / EU
SO2 exceeded more than 24 times a µg/m3 350 Scottish AQS / EU
year (99.72nd percentile)
15-minute mean, not to be
SO2 exceeded more than 35 times a µg/m3 266 Scottish AQS
Horizontal Guidance H1 (SEPA, 2003), prepared jointly by Scottish Environment Protection Agency (SEPA),
2
Environment Agency and Environment and Heritage Service, has also been used within the assessment .
8.3.3.2. Assessment Methodology

The operational effects from the FPSO unit were assessed using the ADMS-5 (Atmospheric Dispersion
Modelling System) model. Five years of prognostic hourly sequential meteorological data for 2010-2014
(inclusive) were used in the assessment, in the absence of local measurement data, to take into account
meteorological variability.
The three production operational scenarios included in the assessment were:
 Normal operations operating on gas;
 Normal operations operating on gas with emergency flaring; and
 Upset conditions in which turbine generator is operating with diesel and emergency flaring (worst
case).
Operational activities for the normal operational scenario were assumed to occur continuously over a full
year i.e. 8760 hours, to provide a worst-case assessment of both short-term and long-term air quality
effects.
Effects of emissions on air quality were quantified by comparison of the predicted maximum concentrations
(inclusive of baseline conditions) with the relevant air quality standards.
8.3.3.3. Assessment Conclusions

Slight adverse effects for both 1-hour NO2 and SO2 concentrations, together with 15-minute SO2
concentrations, were predicted under Scenario 3 (upset conditions) through the use of the three gas
turbines generators operating on diesel fuel, together with an emergency flaring event occurring
simultaneously. However, none of the Air Quality Standards were exceeded.
2 The Environment Agency for England have updated H1, with the most up to date version (v2.2) issued in 2012. In some circumstances SEPA advised
that v2.2 may be more relevant. Where v2.2 has been cited, this is stated.
8-12
This scenario is considered to be highly unlikely, but was presented as a worst-case scenario in terms of the
potential non-routine emissions from the FPSO unit.
A summary of the maximum short-term NO2 and SO2 concentrations arising anywhere is presented in
Table 8-15 below, together with the overall significance of the predicted effects when compared to the
relevant air quality standards.
The significance of effects used in the EIA process is determined based on guidance developed jointly by
Environmental Protection UK (EPUK) and the UK Institute of Air Quality Management (IAQM)
(Environmental Protection (UK), 2010). The significance is determined in terms of Process Contribution (PC)
– this is the effect associated with emissions from the project only, and Predicted Environmental
Concentration (PEC) – this is the effect associated with PC added to the existing background conditions.
Table 8-15 Maximum Predicted Pollutant Concentrations - Scenario 3 (Upset Conditions)
POLLUTANT AVERAGING AQS BACKGROUND PC PC/AQS PEC PEC/AQS SIGNIFICANCE

PERIOD (µg/ (µg/m3) (µg/ (%) (µg/ (%)
m3) 3
m) 3
m)
Nitrogen 1 hour 200 2.88 69.6 34.8% 72.5 36.2% Minor adverse
dioxide (NO2) (99.79th
percentile)
Sulphur 1 hour 350 19.2 155 44.2% 174 49.7% Minor adverse
dioxide (SO2) (99.72nd
percentile)
15-minute 266 19.2 204 76.6% 223 83.8% Minor adverse
(99.9th
percentile)
Predicted pollutant contours have also been prepared and are illustrated in Figure 8-1, Figure 8-2 and
Figure 8-3.
8-13
(Coordinate reference system - European Datum 50, 0 degrees - Grid square scale 2 km x 2km)
Figure 8-1 Maximum Predicted 1-Hour NO2 Concentrations - Scenario 3 - Upset Conditions
8-14
Figure 8-2 Maximum Predicted 1-Hour SO2 Concentrations - Scenario 3 - Upset Conditions
8-15
Figure 8-3 Maximum Predicted 15-Minute SO2 Concentrations - Scenario 3 - Upset Conditions
8-16
8.4. MITIGATION MEASURES

Mitigation commitments to minimise and reduce emissions have been integrated and embedded within the
project design and management approach.
No specific additional mitigation measures are identified following this Assessment. The project will
however implement the following emission reducing measures:
 Vessels will be audited as part of selection and pre-mobilisation and management system
requirements;
 Fuel consumption will be minimised by operational practices and power management systems for
engines, generators and other combustion plant and maintenance systems;
 Removal of separator essential systems generator;
 Optimised sizing of power turbines to ensure turbines are operating as efficiently as possible
 A VOC Monitoring Programme will be applied to manage emissions of VOCs and identify
opportunities to further reduce VOC emissions;
 Contractor’s management plan will be in place to ensure no exceedance of air quality emissions
during vessels mobilisation and demobilisation;
 Quarterly or annual audit of emissions resulting from flaring and turbine generators to ensure
compliance with Shell HSSE & SP CF; and
 Regular check-ups to ensure efficient maintenance of equipment to avoid upset conditions resulting
in increased emissions.
Table 8-16 below provides the significance of the residual effects resulting from atmospheric emissions
from the project.
SENSITIVITY/ PROJECT ASPECT MAGNITUDE SIGNIFICANCE

IMPORTANCE
Local air quality Drilling Small – short term Negligible
Low – due to the temporary impact localised
absence of existing to the points of discharge.
pollution sources in the Installation and Small – short term Negligible
Penguins area, existing commissioning temporary impact localised
baseline pollutant to the points of discharge.
8-17
SENSITIVITY/ PROJECT ASPECT MAGNITUDE SIGNIFICANCE

IMPORTANCE
concentrations are likely Production - operational Small – during normal Minor significance
to be very low. This, combustion emissions operations short term
together with the temporary impact localised
absence of sensitive to the points of discharge.
receptors, means that However combustion
the area surrounding emissions as a result of the
Penguins is considered worst-case upset modelling
to be of low sensitivity to scenario (diesel power
atmospheric emissions. generation combined with
flaring) have the potential
to result in temporary,
localised adverse effects.
In the worse-case scenario assessed, slight adverse effects are predicted for NO2 and SO2. This process
Upset scenario is considered to be highly unlikely, but was presented as a worst-case scenario in terms of
the potential non-routine emissions from the FPSO unit. The conclusion is based upon the potential
maximum pollutant concentrations, relative to the relevant Air Quality Standards. No Air Quality
Standards are however predicted to be exceeded and the sensitivity of the FPSO is considered to be low.
NOx and SO2 emissions respectively, from off-shore activities in 2013.

The site is located in the UK Continental Shelf (UKCS), adjacent to the UK/Norway marine border,
approximately 150 km off the coast of the Shetland Islands.
Given the distance to the nearest landfall and the negligible predicted air quality effects under normal
operational conditions, the potential for any cumulative effects will be negligible.
Due to the close proximity of the Project to the UKCS boundary, transboundary air quality effects are of
greater concern. However as the predicted effects under normal operational conditions are considered to
be negligible immediately surrounding the Penguins FPSO, the transboundary effects will be negligible.
Upset conditions are associated with the greatest potential emissions, however these emissions are also not
considered to be significant.
NOx and SO2 emissions respectively, from off-shore activities in 2013. Given the conservative operational
assumptions made it is expected that the actual annual emissions for each pollutant will be lower.
8-18
UNDERWATER NOISE
9. UNDERWATER NOISE
9.1. INTRODUCTION
This chapter discusses the underwater noise propagated during installation and production activities for the
Project and the effects of that noise to fish and marine mammals. The assessment is supported by
Appendix D – Underwater Noise Modelling Report.
Marine fauna including whales, dolphins, seals and fish use sound for navigation, communication, and the
identification and capture of prey. High levels of sound introduced by offshore installation and production
activities can affect the behaviour of marine fauna and cause auditory injury in some cases.
Underwater noise is considered in this Environmental Statement (ES) on the basis that marine fauna may
experience these effects. In addition, the amended Conservation (Natural Habitats &c.) Regulations 1994
(i.e. the Habitats Regulations) (for England and Wales) and the Offshore Marine Conservation (Natural
Habitats, &c.) Regulations 2007 (the Offshore Marine Regulations) makes it an offense to cause deliberate
disturbance or injury of European Protected Species (EPS), species in Annex IV of the Habitats Directive.
The management procedures that will be implemented to minimise noise impacts on marine fauna are also
described.
9.2. BASIS OF THE ASSESSMENT

To predict and assess the behavioural or physiological responses of marine fauna to underwater noise
resulting from Project activities, it is necessary to determine the expected sound levels and sound
characteristics (Section 9.3) and to relate these to auditory thresholds that are known to elicit a response in
those species present in the vicinity of the Project. The thresholds found in literature vary according to the
hearing mechanisms of the species concerned and to the type of sound being received. The faunal groups
identified in Chapter 4 are therefore categorised where similarities in hearing sensitivity can be drawn, and
their auditory thresholds are defined. The sensitivity of the various faunal groups to noise, together with
their ecological importance, is described in Section 9.4.
Quantitative modelling has been undertaken to define the likely area of effect within which the various
thresholds for different animal groups might be reached. The modelling data has been used to create
contour plots of the attenuating sound to graphically represent the marine space where fauna may be
exposed during underwater noise events (Section 9.5).
The impact magnitude of underwater noise is assessed with consideration of factors such as the duration
and frequency of the noise event, the spatial extent of the noise propagation, and the nature of the impact
in terms of the response exhibited by receptors. For this assessment, this may range from no noticeable
response (negligible magnitude), various levels of behavioural response (small to medium), hearing
damage, loss, death (large).
For animals that range over a large area and/or have a large geographic distribution, the importance of
the area of effect (as predicted for each type of response and each animal group) is a key consideration.
This can be related to the likely proportion of a local or regional population that could be affected and may
be qualified by the ecological use of the area affected such as for feeding, breeding or in the case of
migration corridors.
Where available, population distribution data has been compared against the noise contours to give an
indication of the number of individuals that may be present within those areas or alternatively the
percentage of an animal’s range that is within a defined area of effect. This allows the assessment to
determine how important the area of effect is to a particular group of animals, particularly of a marine
EPS.
9-1
UNDERWATER NOISE
9.3. KEY PROJECT ACTIVITIES

The key activities that will create sound in the underwater environment are:
 Drilling of Wells: Drilling of 7 new wells (Tranche 1) and potentially an additional four depending
on productivity including the operation of drilling vessel and support vessels;
 Installation Phase: Piling during the installation of new manifolds, subsea infrastructure, and the
FPSO moorings; and
 Production Phase: Operation of the FPSO during production including vessel movements and
cargo offloading.
Two metrics are used in characterising the sound sources from these activities. Drilling and the operation
of the FPSO will generate non-pulsed or continuous sound, which is defined as root-mean-squared (rms).
Piling generates a pulsed sound, which can be defined in terms of rms, but the peak sound levels are also
important. Sound exposure level (SEL) is a measure of the total energy received over a period of time. The
characteristics of the project activity noise sources and the units used are described in detail in Appendix D
- Noise Modelling Report, and summarised in Table 9.1.
Table 9.1 Underwater Noise Source Levels
SOUND SOURCE SOURCE LEVELS (SL)

SL(peak) dB re 1μPa at 1m SL(rms) dB re 1μPa at 1m SEL dB re 1μPa2 at 1m
Drilling (continuous) - 170 -
Piling (pulsed) 231 216 206
FPSO operation - 192 -
(continuous)
NB: The only value shown for drilling and FPSO operation is shown as root-mean squared (rms) as this is valid for
continuous signals.
9.3.1. Drilling
Drilling is considered to be a medium term impact as it will continue over a 27 month period, which is
more than one breeding season for the species considered in this assessment, but for less than the full
lifecycle of individual animals. The drilling of all 11 wells is considered to be the worst case scenario in
terms of noise propagation from drilling, although only one well will be drilled at any one time. Drilling
will not be continuous but will recur so the frequency of impact is considered to be occasional.
9.3.2. Piling
Piling is considered to be an impact of short-term duration within the context of the life cycles of the species
concerned. The frequency of piling within the context of the overall Project installation phase and the wider
production/operational phase is considered to be occasional as it will not be repeated at any given
location once the piles have been driven. This assessment takes a conservative approach and assumes that
all piles will be of 2.4 m diameter. However, in reality only the piles for the mooring anchors will be this
size. The piles for other subsea infrastructure such as the Drill Centre manifolds will be smaller and require
less force to install into the seabed, generating less noise.
9.3.3. FPSO Operation

The underwater noise from FPSO operation referred to in this assessment refers to the use of offloading
tankers dynamic positioning thrusters only as this activity creates the highest levels of sound propagation.
Offloading is therefore the worst case scenario during the Production Phase and lower sound levels
propagated between offloading operations are not assessed. The duration of operational noise impacts
9-2
UNDERWATER NOISE
from offloading is considered to be long-term as the FPSO is intended to be operational over an

approximately 20 year period, which extends beyond the complete life cycle of some of the species
concerned. The frequency of noise impacts from offloading is considered to be occasional. However in the
first year of production offloading will take place approximately once every eight days but this frequency
will reduce over the first couple of years to offloading approximately once every month. The estimated
duration of an offload is less than 24 hours.
9.4. RECEPTORS TO UNDERWATER NOISE

This section categorises the marine fauna described in Chapter 4, according to their hearing capability.
The sensitivity of the key faunal groups to underwater noise is then described in qualitative terms of
tolerance, adaptability, and recoverability. The ecological importance of the faunal groups is also defined
with reference to particularly sensitive life cycle periods where appropriate.
9.4.1. Fish
9.4.1.1. General Importance of Fish Species

The fish assemblage of the open northern North Sea environment (that contains the project area) includes
ecologically sensitive pelagic species. They are considered in these terms because their stocks are
considered to be outside ‘safe biological limits’ in the North Sea (EEA, 2011) and because they have
commercial importance.
The most vulnerable periods for fish species in relation to impacts from underwater noise are the spawning
and juvenile stages. The project area is located close to or within spawning areas for cod, haddock,
Norway pout, saithe and whiting, and close to or within nursery areas for blue whiting, ling, mackerel,
spurdog and herring. Additional detail on fish spawning is presented in Chapter 4.
All commercially exploited fish species and those previously mentioned as being outside ‘safe biological
limits’ in the North Sea are considered to be high importance receptors.
The only elasmobranch considered (spurdog) is commercially exploited on a small scale and is not
protected under UK or European law. It is widespread throughout the northern North Sea and as such,
spurdog is considered to be a low importance receptor.
9.4.1.2. Hearing Sensitivity of Fish

Behavioural responses in fish can range from exhibiting an awareness of sound, to small movements, or
escape responses. High levels of underwater noise have been shown to produce strong behavioural
responses and avoidance from a variety of fish species (Gotz. T, 2009) (Popper, 2009a) (Popper, 2009b).
Fish hear a narrow band of sound and sensitivity is higher at lower frequencies. Their hearing capability is
controlled by their anatomy and physiology, which falls into three categories described below.
1. Fish with Swim Bladder Connected to Inner Ear
Fish with gas filled swim bladders that are physically connected to the inner ear have the most
acute hearing. Examples of fish with this anatomy and hearing capability that may be found in the
project area are herring, whiting and sandeel (various species).
Fish with a swim bladder connected to the inner ear can be expected to exhibit strong avoidance
behaviour when exposed to high levels of underwater noise. The tolerance of herring, whiting and
sandeel to underwater noise is therefore assessed as being low. Their adaptability to high levels of
sound in the marine environment is considered to be high as they are highly mobile and are likely
to avoid high levels of noise. Their recoverability is assessed as high as they are likely to return to
the area once the noise source has ceased. Based on this consideration of tolerance, adaptability
9-3
UNDERWATER NOISE
and recoverability the sensitivity of fish that have a swim bladder connected to the inner ear to
underwater noise is considered to be medium.
2. Fish with Swim Bladder Not Connected to Inner Ear
The hearing function of fish that have a swim bladder that is not connected to the inner ear is
reduced relative to those that do have the connection (Gill, 2010) (Nedwell, 2004). Fish with this
anatomy that may be found in the project area are mackerel, cod, and haddock. These fish may
exhibit avoidance of a sound source but they are less responsive to sound stimuli than fish with a
swim bladder-inner ear connection so their tolerance of underwater noise is assessed as medium.
This hearing group is also highly mobile and therefore has a high level of adaptability and
recoverability to underwater noise. The overall sensitivity of this hearing group is assessed as
medium-low.
3. Fish with a Reduced or Absent Swim Bladder
Fish with a greatly reduced swim bladder (e.g. flatfish) or no swim bladder at all (e.g.
elasmobranchs) have been shown to be relatively insensitive to noise and their hearing ability is
thought to be poor (Lovell et al., 2005). Spurdog is an examples species that may be found in the
project area.
Flatfish and elasmobranchs are assessed as having a high tolerance since they are relatively
unresponsive to sound stimuli (Popper and Hastings, 2009b). They are highly adaptable to
underwater noise due to their ability to move away from the area of impact. Their recoverability is
assessed as being high, as once the noise source has ceased they are likely to return to an area
once the sound source has ceased. Based on this consideration of tolerance, adaptability and
recoverability the sensitivity of these species to underwater noise is considered to be low.
9.4.1.3. Auditory Thresholds for Fish

Underwater noise above certain thresholds can cause injury to the auditory mechanisms of fish. Less direct
effects can also occur including the masking of biologically important sounds, temporary loss of normal
hearing capacity and impacts on the stress levels and immune system of the organism (Popper and
Hastings, 2009a) as well as behavioural reactions such as avoidance. These may potentially cause
abandonment of the most favourable spawning, nursery or feeding grounds, negatively affecting the
population (Robinson, 2011). The potential effects of Project-related underwater noise considered in this
EIA are mortality and potential mortal injury, recoverable auditory injury, temporary threshold shift (TTS),
and risk of auditory masking and behavioural effects.
Published literature has been reviewed and used to define threshold criteria for fish grouped by their
hearing mechanism, over which auditory injury or behavioural effects may be reasonably expected.
Appendix D discusses the literature review, describes these criteria in detail, the terminology used to define
them, and uses them to model the distances from the sound source within which fish are likely to be
affected. The criteria used are summarised in Table 9.2.
9-4
UNDERWATER NOISE
Table 9.2 Injury and Behavioural Criteria for Fish - Piling
TYPE OF ANIMAL MORTALITY AND IMPAIRMENT BEHAVIOUR

POTENTIAL MORTAL
INJURY RECOVERABLE TTS
INJURY
dB re 1µPa at 1m (peak) / dB re 1µPa2 at 1m (SEL)
Reduced or absent swim >219 dB SELcum or >216 dB SELcum or >186 dB SELcum (N) High
bladder
>213 dB Peak >213 dB Peak (I) Moderate
(F) Low
Swim bladder not connected 210 SELcum or >203 dB SELcum or >186 dB SELcum (N) High
to inner ear
>207 dB Peak >207 dB Peak (I) Moderate
(F) Low
Swim bladder connected to 207 SELcum or >203 dB SELcum or >186 dB SELcum (N) High
inner ear
>207 dB Peak >207 dB Peak (I) High
(F) Moderate
Fish eggs and larvae >207 SLpeak or >210 - - -

SEL
NB: N = near (i.e. tens of metres), I = intermediate (i.e. hundreds of metres), F = low as defined (i.e. thousands of
metres).
9.4.2. Marine Mammals
9.4.2.1. General Importance of Marine Mammal Species

All the marine mammal species considered in this report are considered to be of high importance due to
their role in the ecosystem and international conservation status by virtue of their listing in the following
agreements, conventions, and directives:
 Berne Convention on the Conservation of European Wildlife and Natural Habitats;
 Bonn Convention on the Conservation of Migratory Species of Wild Animals;
 Oslo Paris Convention for the Protection of the Marine Environment of the North-East Atlantic
(OSPAR);
 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES);
 Agreement on the Conservation of Small Cetaceans in the Baltic and North Seas (ASCOBANS);
 Annexes II and IV of the European Council Directive 92/43/EEC of 21 May 1992 on the
Conservation of Natural Habitats and of Wild Fauna and Flora (the Habitats Directive);
 UK Biodiversity Action Plan list of UKBAP priority marine species; and
 In the UK, seals are also protected under the Conservation of Seals Act, 1970.
9-5
UNDERWATER NOISE
9.4.2.2. Hearing Sensitivity of Marine Mammals

The marine mammals known to occur in the open northern North Sea environment (that contains the
project area) include whales, dolphins, porpoises and seals. The species reported as present in Chapter 4
can be assigned to one of four hearing groups shown in Table 9.3.
Table 9.3 Marine Mammal Hearing Groups and Estimated Auditory Bandwidths
HEARING GROUP ESTIMATED AUDITORY SPECIES

BANDWIDTH
Low frequency cetaceans 7 Hz to 22 kHz minke whale
Mid frequency cetaceans 150 Hz to 160 kHz killer whale, Atlantic bottlenose dolphin, white-
beaked dolphin, Atlantic white-sided dolphin
High frequency cetaceans 200 Hz to 180 kHz Harbour porpoise
Pinnipeds in water 75 Hz to 75 kHz Common seal, grey seal
Source: (Southall, 2007)
Marine mammals use sound (including echolocation in the case of harbour porpoise and dolphins) for
navigation, communication and the identification and capture of prey. Harbour porpoise for example, is
sensitive to a very broad bandwidth of sound and is responsive to underwater noise at frequencies from
100 Hz to 170 kHz. Peak hearing sensitivity occurs over the frequency range from 20 kHz to 150 kHz. At
this frequency the harbour porpoise is thought to be capable of hearing narrowband sounds as low as 40
dB re 1 µPa (Kastelein, 2002). They vocalise using clicks and other sounds with a frequency of
approximately 2 Hz, and they echolocate with short intense pulses of 110-150 kHz and with source levels
of 135-177 dB re 1 µPa at 1 m (Richardson, 1995). Underwater noise above the ambient levels to which
they are habituated has the potential to interfere with or mask the auditory cues they use in undertaking
their normal behaviour. As a result, all cetacean species are considered to have a high sensitivity to
underwater noise. While pinnipeds use their sense of hearing in the underwater environment, they do not
echolocate or use sound for communication to the same extent as cetaceans. As a result, pinnipeds are
considered to have a medium level of sensitivity to underwater noise.
9.4.2.3. Auditory Thresholds for Marine Mammals

The criteria selected for the assessment of auditory injury to marine mammals are explained in detail in
Appendix D. The criteria define the sound levels that would have to be exceeded in order to cause
instantaneous injury resulting in a permanent loss in hearing ability in cetaceans and pinnipeds, which is
referred to as permanent threshold shift (PTS).
This EIA presents ’precautionary’ criteria (i.e. levels at the low end of the measured ranges found to result
in a response considered by JNCC guidance to be significant or when variable behavioural responses
were recorded) and less precautionary ’alternative’ criteria where necessary to describe the likely bounds
of the area over which behavioural response is possible. The behavioural responses considered in JNCC
guidance to be significant are defined (from Southall et al. 2007) as follows:
 Extensive or prolonged changes in locomotion speed, direction, and/or dive profile;
 Moderate shift in group distribution;
 Change in inter-animal distance and/or group size (aggregation or separation); and
 Prolonged cessation or modification of vocal behaviour.
9-6
UNDERWATER NOISE
Sufficient data exist for sound levels that cause a significant response in low frequency cetaceans and this
level has been used as the benchmark precautionary criteria for all cetaceans. The criteria for pinnipeds is
based on the lowest sound level found to result in responses ranging from severity ‘level 0’ to ‘level 6’ (as
defined in Southall et al. 2007) and is therefore considered to be precautionary. The criteria used in this
assessment are shown in Table 9.4.
Table 9.4 Auditory Thresholds for Marine Mammals
SPECIES GROUP CRITERIA FOR PILING CRITERIA FOR SHIPPING (FPSO

OPERATION) AND DRILLING
Behavioural effects Auditory injury Behavioural Auditory injury
(PTS) effects (PTS)
dB re 1 μµPa (RMS) dB re dB re 1 dB re 1 μµPa dB re dB re 1
1µPa μµPa2s (RMS) 1 μµPa µμPa2s
Precautionary Alternative (PEAK) (SEL) (PEAK) (SEL)
Low frequency 140 230 198 120 230 215

cetaceans
Mid frequency 140 170 230 198 120 230 215
cetaceans
High frequency 140 158 206 179 120 206 215
cetaceans
Pinnipeds in water 160 218 186 120 218 203
9.5. UNDERWATER NOISE MODELLING RESULTS

Quantitative modelling has been undertaken to quantify the likely distance over which underwater noise
from Project activities is likely to propagate. The modelling outputs can then be compared against the
criteria defined previously in Table 9.2 and Table 9.4. Appendix D presents a detailed modelling
methodology and key assumptions.
The modelled data have been graphically plotted to represent the distances from the sound sources that the
auditory thresholds are met. Key data in this regard are shown in Table 9.5 and presented graphically in
Figure 9.1, Figure 9.2, and Figure 9.3 for piling, drilling and FPSO operation respectively.
On the assumption that mobile marine fauna such as whales, dolphins, seals and fish will not remain within
an area containing activity that causes behavioural or physiological responses, the modelling also accounts
for any sound exposure individuals may experience as they swim away from the sound source. The
starting distance in all cases is assumed by the swim-away model to be 500 m from the source, with the
animal continuing to swim away from the source during the piling period. The 500 m ‘starting’ distance is
based on the application of standard mitigation measures for marine mammals.
The model used in this assessment produces outputs to a limit of 60 km from the sound source. Where a
precautionary criterion has been used or an upper range of sound levels is referred to, the area of effect
where threshold exceedances are predicted have largely been found to reach this limit. Since the model
cannot create an output beyond 60 km, it is not possible to specify the distance at which the criterion would
be met for these sounds based on the worst case generic propagation assumption.
Consultations with DECC confirmed that the study should focus on piling as a worst case activity, and as
such this assessment considers piling as the worst case. Shell also proposed to carry out high level
9-7
UNDERWATER NOISE
modelling of the FPSO and drilling operations for completeness, but the detailed modelling approach that
has been adopted for the key piling activity was not considered justified since the risks are expected to be
limited to temporary disturbance to marine species during drilling or short term disturbance during the
noisiest periods of operation. The operational noise predictions are based on FPSO offloading vessels
which use dynamic positioning systems. Whilst these are relatively noisy they are not dissimilar to large
ships underway, which is typically part of the baseline activity in the area. Shipping has been described as
the main contributor to the rise in ambient noise in European waters (Tasker, 2010). The shipping density
in the project area has a weekly average of 0.1-5.0 vessels (created from 42 days of AIS-A and AIS-B
data from MMO project 1066 (MMO, 2014).
Since the predictions are not-site specific, the noise levels have been presented as ranges based on the
upper and lower bounds of the likely noise propagation rate. This results in a wide range of predicted
noise levels, which inevitably introduces a degree of uncertainty in the numerical results.
9-8
UNDERWATER NOISE
Table 9.5 Modelling Results of Radius of Impact for Various Auditory and Behavioural Thresholds
PILING DRILLING FPSO OPERATION

Auditory Injurypeak Auditory InjurySEL Behaviour* Auditory Injury Behaviour** Auditory Behaviour**
(PTS) (PTS) Injury
Fish with reduced or 0.5 km 0.5 km (N) High (N) Low (N) Moderate (N) Low (N) Moderate
absent swim bladder (I) Moderate (I) Low (I) Low (I) Low (I) Low
(F) Low (F) Low (F) Low (F) Low (F) Low
Fish with swim bladder 0.5 km 0.5 km (N) High N) Low (N) Moderate N) Low (N) Moderate
not connected to inner (I) Moderate (I) Low (I) Low (I) Low (I) Low
ear
(F) Low (F) Low (F) Low (F) Low (F) Low
Fish with swim bladder 0.5 km 0.5 km (N) High N) Low (N) High N) Low (N) High
connected to inner ear (I) High (I) Low (I) Moderate (I) Low (I) Moderate
(F) Moderate (F) Low (F) Low (F) Low (F) Low
Fish eggs and larvae 0.5 km 0.5 km - - - - -
Low frequency cetaceans 0.5 km 0.5 km 60 km (P and A) Not exceeded 60 km (upper) Not exceeded 60 km (upper)
Not exceeded (lower) 0.5-5 km (lower)
Mid frequency cetaceans 0.5 km 0.5 km 60 km (P) Not exceeded 60 km (upper) Not exceeded 60 km (upper)
4.5 km (A) Not exceeded (lower) 0.5-5 km (lower)
High frequency cetaceans 0.5 km 0.5 km 60 km (P) Not exceeded 60 km (upper) Not exceeded 60 km (upper)
44.5 km (A) Not exceeded (lower) 0.5-5 km (lower)
Pinnipeds in water 0.5 km 0.5 km 30 km Not exceeded 60 km (upper) Not exceeded 60 km (upper)
Not exceeded (lower) 0.5-5 km (lower)
NB: * N = near (i.e tens of metres), I = intermediate (i.e. hundreds of metres), F = low as defined (i.e. thousands of metres). P = precautionary criteria, A = alternative criteria. **
Distances refer to threshold exceedance by the upper and lower bounds of sound levels predicted by the model. Hyphen (-) used where not applicable.
9-9
UNDERWATER NOISE
Figure 9.1 Modelled Radius of Behavioural Effects from Piling on Marine Mammals
9-10
UNDERWATER NOISE
Figure 9.2 Modelled Sound Contours for Drilling Showing Modelled Radius of Behavioural Effects in Marine Mammals
9-11
UNDERWATER NOISE
Figure 9.3 Modelled Sound Contours for FPSO Operation Showing Modelled Radius of Behavioural Effects in Marine Mammals
9-12
UNDERWATER NOISE
9.6.1. Effects of Piling
9.6.1.1. Fish
The SEL exposure identified by the swim-away model for fish shows that the proposed piling of subsea
infrastructure in the project area is likely to cause fish with swim bladder connected to inner ear (i.e.
herring, whiting and sandeel) to flee the area, but will not cause injury or death to adult individuals. Fish
that do not have a swim bladder-inner ear connection or that have a reduced/absent swim bladder and
that are located at near and intermediate distances to the sound source may exhibit some behavioural
responses. Those located further away (i.e. beyond 1 km) will not respond in this way, and no injury or
death to these species groups will result. This change in distribution is considered to be negligible within a
context of the overall regional population.
Previous studies have shown that displacement due to underwater noise is not permanent and fish will
repopulate an area rapidly following a cessation of the noise source (Thomsen et al., 2006). The species
present in the project area are widespread throughout the wider northern North Sea and the area of
influence is small relative to the context of their overall North Sea range and distribution. While the project
area is located close to or within spawning areas for some of the species described in Chapter 4, these
areas are not exclusively used and may be considered to have a low importance in terms of overall rates of
breeding success. Fish are anticipated to move out of the area of influence during piling, with no
significant impacts on behaviour or from auditory injury to fish populations and that any change to their
distribution as a result of piling noise is unlikely to be detectable on a regional level.
Considering the short term duration of the proposed piling activity, the occasional frequency, its site-specific
extent (i.e. 0.5 km radius for auditory injury, and low risk of behavioural effects beyond 1 km), the overall
magnitude of piling noise in relation to fish is considered to be small. Considering this small magnitude
impact, the low importance of the area of effect to fish, and the low sensitivity of the receptor, the impact
from piling noise on fish is assessed as Negligible.
9.6.1.2. Fish Eggs and Larvae

The modelled sound pressure from piling does not exceed the threshold for mortality and potential mortal
injury for fish eggs and larvae. However, the eggs of most of the fish known to spawn close to or within the
project area are planktonic and are therefore not able to swim away from the sound source if continued
exposure to this sound level should exceed the threshold for injury or mortality. While juvenile fish can be
actively mobile, their swimming speed is variable according to body size and water temperature (Peck,
2006) and is not expected to reach the swim speed assumed by the swim-away model. Fish eggs and
larvae are considered to have a low level of adaptability and tolerance to this impact due to their inability
to avoid the noise source, but a high level of recoverability due to the broadcast reproductive strategies (i.e.
spawning of large quantities of eggs in open water) employed and the existence of other spawning areas
in the wider northern North Sea; they therefore have an overall low sensitivity to piling noise.
Considering the short term duration of the proposed piling activity, the occasional frequency, its site-specific
extent (i.e. the locations of spawning and nursery areas relative to the project area and injury within
0.5 km radius of the sound source but not within the wider area), the overall magnitude of piling noise in
relation to fish eggs and larvae is considered to be small. Considering this small magnitude impact, the
low importance of the area of effect for spawning, and the low sensitivity of the receptor, the impact from
piling noise on fish eggs and larvae is assessed as Negligible. However, it should be noted that Marine
Scotland have placed restrictions on seismic activities (which can also apply to piling) for Blocks 211/13
and 211/14 from January to May due to the cod, haddock and Saithe spawning area (DECC, 2014). The
anchor piling operations, where possible, will be undertaken outwith of the restriction period and discussed
with the regulator prior to finalisation.
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UNDERWATER NOISE
9.6.1.3. Marine Mammals
9.6.1.3.1. Auditory Injury

The mitigation in place for piling activity is in line with the JNCC (2010) piling noise protocol, which is
considered to be industry best-practice and is described in Section 9.7. It has been developed to reduce
the potential risk of injury to marine mammals in close proximity to piling operations to negligible levels.
The SEL levels predicted by the swim-away model do not exceed the thresholds for auditory injury used in
this EIA. It should be noted that the swim-away model uses the worst case scenario, which is the depth
where the highest sound levels are likely to occur. In this case, this is a depth range of 80-90 m but it
should be noted that air-breathing cetaceans and pinnipeds are not capable of swimming at a depth range
of 80-90 m for the prolonged periods assumed by the model and would actually swim at variable depths
including time at the sea surface. The defined exposures are therefore considered to be precautionary.
Given the short-term duration of piling, the occasional frequency during the construction phase, the low
likelihood that the effect will be experienced due to the mitigation in place, the impact of auditory injury
from piling noise on cetaceans and pinnipeds is assessed as Negligible.
9.6.1.3.2. Behavioural Responses

This assessment considers the significance of underwater noise from piling in the context of the cetaceans
populations that are likely to be present in SCANS I (Hammond, 2002) ‘Block E’. The data is indicative
due to natural fluctuations in the distribution of populations throughout their wider geographical range.
The significance of effects presented is likely to be lower when considered in terms of the wider distribution
of the species concerned or their total populations.
The precautionary criteria for behavioural responses in all cetaceans are exceeded by the modelled piling
noise out to the 60 km limit of the model. The alternative criteria for mid and high frequency cetaceans
and the criteria for pinniped result in a smaller area of effect however, as shown in Table 9.5.
The mitigation in place (in line with JNCC 2010 piling noise protocol) will deter marine mammals from
being present in the project area during piling but they are unlikely to be able to transit over 60 km within
a ‘soft start’ period of 20 minutes. If marine mammals are present during piling works within the distances
from the source specified, then some behavioural responses can be expected.
The areas within which behavioural responses are expected (using both the precautionary and the
alternative criteria) are small within the context of the overall range and distribution of the species of
concern throughout the North Sea and north-east Atlantic and the number of animals likely to be affected is
low. The Atlas of Cetacean Distribution (Reid, 2003) and the SCANS I (Hammond, 2002) and SCANS II
(Hammond, 2006) project illustrate the abundance and distribution of the cetaceans known to be present in
the project area. Data from ‘Block E’ in the SCANS I study has been analysed in this EIA to provide
indicative estimates for the abundance of animals that may be exposed to underwater noise from the
Project. ‘Block E’ corresponds to an area of the Northern North Sea with a surface area of 109,026 km2
that is located between the Shetlands and Norway and includes the project area. The abundance data
presented below were estimated in the SCANS I study for this area and are not representative of the total
North Sea populations of the species described.
The majority of species are found in low local abundance, the exception being harbour porpoise with a
predicted animal density of 0.288 animals/km2 across ‘Block E’ (Hammond, 2002). By comparison, the
white-beaked dolphin had a predicted animal density of 0.0011 animals/km2 and minke whale had a
predicted animal density of 0.0078 animals/km2 within the same ‘Block E’ area of the northern North Sea.
Using the data as an indicator for the number of animals likely to experience behavioural effects and the
modelling results for the radius distances from the source within which these effects may occur (and
accepting that animal density data are not available for all species), the total number of animals likely to
experience behavioural effects during each piling event are shown in Table 9.6.
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UNDERWATER NOISE
It is important to note that the surveys conducted during the subsequent SCANS II study (Hammond, 2006)
identified a substantial change in harbour porpoise distribution throughout the North Sea since the SCANS
I surveys conducted in 2005. Numbers in part of ‘Block E’ that includes the project area were estimated to
have reduced over the eleven year period to <0.2 animals/km2, and for the estimated surface densities in
the southern North Sea to have increased from 0-0.4 animals/km2 to >1.2 animals/km2 over the same
period. The SCANS II report does not present data that can be directly compared with SCANS I within the
context of this study, but the two SCANS studies clearly demonstrate that the population distribution of
highly mobile and far-ranging animals such as cetaceans is not static. The data presented in Table 9.6 is
therefore intended to be a precautionary indication of the possible numbers of marine mammals
experiencing behavioural effects from piling noise from the Penguins project, accepting that these numbers
should be expected to fluctuate within natural annual variability and could vary significantly if a more
recent dataset was available.
The data shown in the column headed as “Percentage of predicted abundance in ‘Block E’ experiencing
behavioural effects (%)” reflect the percentage of animals ranging within ‘Block E’ that would experience
behavioural effects within the modelled area of influence. Abundance data from beyond the boundaries of
‘Block E’ is not considered in this assessment so the calculations presented in Table 9.6 do not account for
abundance variability in the small areas where the sound level contours extend beyond the limits of ‘Block
E’.
The overall rating of sensitivity and importance combined is weighted towards sensitivity to noise rather
than receptor importance. Although the majority of the species assessed are of high importance,
ecologically it is the population that is important and in most cases, only small proportions of their
populations will actually be affected by noise from the Project. Focusing on sensitivity to noise (or tolerance
of the impact) is a conservative approach since all the species concerned have the ability to avoid the
impact (high adaptability) and having avoided the impact all the species concerned would be expected to
return to the area/resume normal behaviour once the impact ceases (high recoverability).
Given the short-term duration of piling, the occasional frequency during the construction phase, and the
small extent of the impact from piling within a context of the range of the cetacean species concerned, the
overall magnitude of this impact is considered to be small.
Pinnipeds are anticipated in very low and occasional numbers in the project area due to its distance
offshore so any changes to pinniped distribution are considered to be negligible on a regional scale.
Therefore, the behavioural effect of piling noise on pinnipeds is assessed as Negligible.
The number of low frequency cetaceans predicted to be present within the project area and that have
potential to exhibit significant behavioural responses (i.e. disturbance within context of the Habitats
Directive, the Wildlife and Countryside Act 1981 as amended, and the Conservation of Habitats and
Species Regulations 2010) as a result of piling has been calculated as 10.34% of the local population
(based on the likely population size of the SCANS ‘Block E’). This is considered to be a significant
proportion of the local population and as a result, piling is assessed as having the potential to significantly
affect the local distribution of low frequency cetaceans. Given the high sensitivity of this receptor group in
ecological terms and in relation to their sensitivity to underwater noise and their use of sound for critical
behaviours (e.g. communication and hunting), the effect of piling noise on the behaviour of low frequency
cetaceans is assessed as Moderate.
The number of mid frequency cetaceans that have been predicted to experience behavioural responses
varies considerably depending on whether the precautionary or the alternative criteria area applied.
Assuming that the precautionary criterion is used and that 10.81% of the local population of SCANS ‘Block
E’ is affected, the same rationale as for low frequency cetaceans is applied and the effect of piling noise on
the behaviour of mid frequency cetaceans taking this conservative criterion is assessed as Moderate. The
application of the alternative criterion results in 0.06% of the local population in SCANS ‘Block E’
experiencing behavioural effects. A temporary change in the distribution of this lower proportion of the
local population is considered to be negligible in ecological terms and the effect of piling noise on the
behaviour of mid frequency cetaceans in this case would therefore be assessed as Negligible.
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UNDERWATER NOISE
Table 9.6 Number of Marine Mammals Experiencing Behavioural Effects from Piling Noise
FUNCTIONAL SPECIES CRITERIA MODELLED AREA OF PREDICTED NO. OF ANIMALS ESTIMATED PERCENTAGE
HEARING EXAMPLE RADIUS OF EFFECT (km2) ANIMAL DENSITY WITHIN AREA OF ABUNDANCE OF PREDICTED
CATEGORY EFFECT (km) IN ‘BLOCK E’ EFFECT WITHIN SCANS ABUNDANCE
(ANIMALS/km2) I ‘BLOCK E’ IN ‘BLOCK E’
(HAMMOND, (ANIMALS) EXPERIENCING
2002) (HAMMOND, BEHAVIOURAL
2002) EFFECTS (%)
Low frequency Minke whale Precautionary and >60 11,309.73 0.0078 88.21 853 10.34
cetaceans alternative
Mid frequency White-beaked Precautionary >60 11,309.73 0.0011 12.44 115 10.81
cetaceans dolphin
Mid frequency White-beaked Alternative 4.5 63.62 0.0011 0.069 115 0.06
cetaceans dolphin
High frequency Harbour Precautionary >60 11,309.73 0.288 3,257.20 31,419 10.37
cetaceans porpoise
High frequency Harbour Alternative 44.5 6,221.14 0.288 1,791.69 31,419 5.70
cetaceans porpoise
9-16
UNDERWATER NOISE
The number of high frequency cetaceans that have been predicted to be experience behavioural responses
also varies depending on whether the precautionary or the alternative criteria area applied. Assuming that
the precautionary criterion is used and that 10.37% of the local population in SCANS ‘Block E’ is affected,
the same rationale as for low and mid frequency cetaceans is applied and the effect of piling noise on the
behaviour of high frequency cetaceans is assessed as Moderate. The application of the alternative criterion
results in 5.70% of the local population in SCANS ‘Block E’ experiencing behavioural effects. A temporary
change in the distribution of this proportion of the local population is considered to be significant, albeit to
a lesser extent than that predicted using the precautionary criterion and the significance of the impact of
piling noise on the behaviour of mid frequency cetaceans in this case is therefore assessed as Minor.
9.6.2. Effects of Drilling and FPSO Operation
9.6.2.1. Fish
Popper et al. (2014) specifies a threshold for recoverable injury to fish with a swim bladder connected to
the inner ear of 170 dB rms for 48 hours and a threshold of 158 dB rms for 12 hours for TSS. Table 5.3 of
Appendix D shows the rms levels predicted for drilling and FPSO operations at distance intervals ranging
from 500 m to the 60 km limit of the model from the source. The modelled data predict that the threshold
for recoverable injury to fish with a swim bladder connected to the inner ear, such as herring and whiting,
will not be exceeded by drilling or FPSO operation at any distance from the source. Therefore, the impact
of auditory injury to all fish species is assessed as Negligible.
The risk of behavioural effects on fish with a swim bladder connected to the inner ear is high within tens of
metres of the sound source but is moderate-low at further distances. This is reduced to a moderate risk
within tens of metres from the drilling and FPSO noise sound source for fish with no swim bladder-inner ear
connection or a reduced/absent swim bladder, but low risk at further distances. Given the previous
discussion of the overall magnitude of impact in terms of its duration, frequency, spatial extent, and the
context of wider regional distribution of fish in the project area, the behavioural impact of drilling and
FPSO noise on all fish species is assessed as Negligible.
9.6.2.2. Marine Mammals
9.6.2.2.1. Auditory Injury

The upper bounds of the predicted noise level ranges do not exceed the threshold criteria for auditory
injury for any of the cetacean and pinniped species considered in this EIA. Given the medium-term
duration of drilling operations but the long-term duration of FPSO operation (used here as the worst-case),
the occasional frequency of the sound source (for both drilling and FPSO operation), , the effect of auditory
injury from drilling and FPSO operation noise on cetaceans and pinnipeds is assessed as Negligible.
9.6.2.2.2. Behavioural Responses

The upper bounds of the predicted sound level ranges for drilling exceed the behavioural response criterion
for all marine mammals at all distances modelled up to 60 km. The lower bounds of the predicted sound
level ranges for drilling do not exceed the criteria for behavioural responses however.
The upper bounds of the predicted sound level ranges for FPSO operation also exceed the behavioural
response criterion for all marine mammals at all distances modelled up to 60 km. The lower bounds of the
levels predicted during FPSO operation exceed the behavioural response criterion up to approximately 5
km from the sound source (i.e. the dynamic positioning thruster location).
Using the same rationale as that applied to the assessment of behavioural responses from piling noise, the
percentage of the local cetaceans populations affected may be significant in ecological terms where effects
are predicted up to the 60 km limit of the model. However, using the lower bounds of the sound levels
predicted for FPSO operation, the percentage of the affected population of low and high frequency
9-17
UNDERWATER NOISE
cetaceans would be 0.0028% (Table 9.7).The upper bounds are highly precautionary and given that
marine mammals will not swim constantly within the zone of highest sound levels due to their need to
surface for air, the potential for this effect to be experienced to the highest degree is considered unlikely. A
temporary change in the lowest percentage of the local population predicted is considered to be negligible
in ecological terms, and the actual change is expected to be between the upper and lower bounds of the
predicted range for both drilling and FPSO operation.
The area of effect is not of particular ecological importance for marine mammals in terms of feeding areas
or other activities and given the occasional frequency of the sound source and the brief duration of each
drilling or offloading event, the impact of noise from drilling and FPSO operation on the behaviour of
marine mammals is assessed as Minor. This effect has been considered within a context of existing
shipping noise from large commercial vessels, which are expected to pass through the project area
between 1-5 times per week.
9.7. MITIGATION
The project will adhere to the JNCC piling noise protocol (JNCC, 2010). This JNCC protocol is considered
as ‘best practice’ for piling operations and includes the use of JNCC trained Marine Mammal Observers
(MMO) during piling works, the implementation of mitigation zones, the use of pre-piling searches, soft-
starts and other methods as prescribed by the JNCC. The JNCC piling protocol is intended to provide a
mechanism for reducing any potential risk of injury or death to marine mammals in close proximity to
piling operations. However, it has not been developed to mitigate disturbance effects.

Table 9.8 below provides the significance of the residual effects resulting from discharges to sea from the
project.
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UNDERWATER NOISE
Table 9.7 Number of marine mammals experiencing behavioural effects from FPSO operation
FUNCTIONAL SPECIES CRITERIA MODELLED AREA OF PREDICTED NO. OF ESTIMATED PREDICTED

HEARING EXAMPLE RADIUS OF EFFECT (km2) ANIMAL ANIMALS ABUNDANCE ANIMAL
CATEGORY EFFECT (km) DENSITY EXPERIENCING WITHIN DENSITY
(ANIMALS/km2) BEHAVIOURAL SCANS I (ANIMALS/KM2)
(HAMMOND, EFFECTS PER ‘Block E’ (HAMMOND,
2002) NOISE EVENT (ANIMALS) 2002)
(HAMMOND,
2002)
Low Minke whale Upper bounds 60 11,309.73 0.0078 88.21 853 10.34
frequency
cetaceans Lower bounds 5 78.54 0.0078 0.61 853 0.117
Mid White-beaked Upper bounds 60 11,309.73 0.0011 12.44 115 10.81

frequency dolphin
cetaceans Lower bounds 5 78.54 0.0011 0.08 115 0.07
High Harbour Upper bounds 60 11,309.73 0.288 3257.20 31,419 10.36

frequency porpoise
cetaceans Lower bounds 5 78.54 0.288 22.62 31,419 0.07
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UNDERWATER NOISE
Table 9.8 Significance of Residual Effects
SENSITIVITY/IMPORTANCE PROJECT MAGNITUDE RESIDUAL

ASPECT SIGNIFICANCE
Fish Piling Low risk of behavioural effects beyond 1 km. No auditory Negligible
injury >0.5 km
Low – Fish have varying sensitivity to noise that largely
depends on whether they have a swim bladder and whether the
swim bladder is connected to the inner ear. Their importance
can be from low to high. The species expected to be present
within the Penguins area are considered of low sensitivity.
Fish Eggs and Larvae No auditory injury >0.5 km. Negligible

Low – Fish eggs and larvae have a low sensitivity to noise.
Low Frequency Cetaceans Behaviour response 60 km from source using precautionary Moderate
and alternative criteria. No auditory injury >0.5 km.
High – Low frequency cetaceans have a high sensitivity to
noise. The species group is of high importance.
Mid Frequency Cetaceans Behaviour response 60 km from source using precautionary Moderate
criteria and 4.5 km from source using alternative criteria. No (precautionary),
High – Mid frequency cetaceans have a high sensitivity to
auditory injury >0.5 km. Negligible
(alternative)
High Frequency Cetaceans Behaviour response 60 km from source using precautionary Moderate
criteria and 44.5 km from source using alternative criteria. (precautionary),
High – High frequency cetaceans have a high sensitivity to
No auditory injury >0.5 km. Minor
(alternative)
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UNDERWATER NOISE

ASPECT SIGNIFICANCE
Pinnipeds Behaviour response 30 km from source. No auditory injury Negligible

>0.5 km.
Medium – Seals have a medium sensitivity to noise. The species
group is of high importance.
Fish with reduced or absent swim bladder Drilling Low to moderate risk of Behavioural response. Low risk of Negligible
auditory injury.
Very low –Not sensitive to noise. The species group of low to
high importance.
Fish with swim bladder not connected to inner ear Low to moderate risk of Behavioural response. Low risk of Negligible
auditory injury.
Low – Low sensitivity to noise but species group is of high
importance.
Fish with swim bladder connected to inner ear Moderate to high risk of Behavioural response. Low risk of Negligible
auditory injury.
Medium to high –Medium sensitivity to noise and species group
is of high importance.
Cetaceans Behaviour response 60 km (upper bound) and 1 km (lower Minor

bound). Auditory injury not exceeded.
High – Cetaceans have a high sensitivity to underwater noise.
All cetacean species groups are of high importance.
Pinnipeds Behaviour response 60 km (upper bound) and 1 km (lower Negligible

9-21
UNDERWATER NOISE

ASPECT SIGNIFICANCE
Fish with reduced or absent swim bladder FPSO Low to moderate chance of Behavioural response. Low chance Negligible
operation of auditory injury.
Very low –Not sensitive to noise. The species group of low to
high importance.
Fish with swim bladder not connected to inner ear Low to moderate chance of Behavioural response. Low chance Negligible
of auditory injury.
Low – Low sensitivity to noise but species group is of high
importance.
Fish with swim bladder connected to inner ear Moderate to high chance of Behavioural response. Low Negligible
chance of auditory injury.
Medium to high –Medium sensitivity to noise and species
Cetaceans Behaviour response 60 km (upper bound) and 0.5-5 km Minor

(lower bound) from the source. Auditory injury not exceeded.
All cetacean species group is of high importance.
Pinnipeds Behaviour response 60 km (upper bound) and 0.5-5 km Negligible

(lower bound). Auditory injury not exceeded.
9-22
UNDERWATER NOISE

Marine species will have some tolerance to anthropogenic noise in an area well-developed by the oil and
gas industry, particularly with respect to vessel traffic and operating facilities, and therefore these are not
considered further.
Although the project has no significant effects on fish and seals, piling activities may cause minor to
moderate significant effects on cetaceans. The project may also contribute to significant regional effects on
sensitive ecological receptors by acting cumulatively with other activities, particularly piling and seismic
surveys planned to take place in vicinity of the project area. If the timing of these activities overlap with the
piling at Penguins, noise sensitive species may experience noise effects within an area several times larger
than that resulting from the project alone. In addition, sensitive species may be cumulatively affected by
piling or seismic survey activities taking place consecutively, resulting in noise effects occurring over a
longer period of time. The cumulative effect on sensitive species in the wider area may therefore have a
greater significance, depending on the number, timing and scale of the noise generating activities
undertaken. There are no known plans for other noise generating activities taking place in the immediate
vicinity of the project area (or within 60 km). It is therefore unlikely that any significant cumulative effects
will arise. If cumulative effects were to occur, the project would be one of several contributing activities,
and its individual contribution would likely be short term, likely limited to the duration of piling.
The Penguins FPSO is located 4 km from the UK/Norway median line. Behavioural effects are expected at
distances greater than 60 km for cetaceans and 30 km for pinnipeds. These effects will therefore be
transboundary. Cetaceans are highly mobile and travel over large ranges, so may be affected in UK
and/or Norwegian waters. Pinnipeds are more restricted, preferring coastal waters in range of haul-out
sites and are therefore only likely to present in very low numbers within 30 km of the Project area.
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WASTE MANAGEMENT
10. WASTE MANAGEMENT

10.1. INTRODUCTION
This chapter discusses the types of wastes likely to be generated as a result of the Penguins Redevelopment
Project and the management procedures that will be implemented to minimise and monitor the volumes
produced and disposed onshore.
Waste management has been included in this Environmental Statement (ES) on the basis that it is a
regulatory control aspect of the Project which will require management. It has not been assessed using the
Environmental Impact Assessment (EIA) methodology.
Waste will be generated during all phases of the Project and Shell is committed to reducing waste
production and managing all produced waste by applying approved and practical methods such as the
principles of the waste hierarchy (reduce, reuse, recycle, recover and disposal). Waste should only be
disposed of if it cannot be prevented, reclaimed or recovered. All waste will be managed in line with
existing management plans for the asset and vessels. In addition, a project specific Waste Management
Plan (WMP) 1 will be developed for the Project and will identify:
 The types of waste generated; and

 Management procedures for each waste stream.
10.2. REGULATORY CONTROL

Waste generated from the Project will be managed in accordance with the legislation and standards
summarised below and detailed within Appendix A.
 The Merchant Shipping (Prevention of Pollution by Sewage and Garbage from Ships) Regulations
2008 prohibit the disposal of garbage and galley waste (excluding ground food wastes)
overboard. Offshore waste is therefore collected for disposal or recycling onshore. All waste must
have accurate descriptions and appropriate segregation measures in place to ensure legal
disposal at licenced sites by licensed disposal contractors. The Environmental Protection Act 1990
governs onshore disposal of waste in the UK and is implemented by the Scottish Environmental
Protection Agency (SEPA) in Scotland. Although it does not directly apply to offshore wastes, its
requirements for onshore waste disposal indirectly make provisions for the handling of offshore
wastes prior to shipping to shore for disposal (e.g. segregation). The Act introduced ‘Duty of Care’
to ensure all reasonable and applicable measures were taken with waste to:
• Ensure that waste is stored and transported appropriately and securely so it does not escape;
• Ensure that waste is transferred to people or businesses that have the appropriate
authorisations; and
• Ensure waste transfer notes (WTNs) are completed to document transfers.
 The European Union (EU) Waste Framework Directive (2006/12/EC) establishes the requirements
for management of wastes across the EU. Waste is classed as ‘controlled waste’ if it has controls
1
Under the HSSE & SP Control Framework, the Project Waste Management Plan (WMPs) is implemented. Annex V of the MARPOL
Regulations (International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 (MARPOL)
and its technical annexes) indicates the requirement for a ‘Garbage Management Plan’ for all vessels.
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WASTE MANAGEMENT
placed over its handling and disposal. Controlled waste includes both non-hazardous and
hazardous or special waste 2.
 The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (as
amended) addresses the discharge of hydrocarbons from offshore installations.
 The Radioactive Substances Act 1993 (as amended) (Scotland) regulates the keeping and use of
radioactive material and makes provision for the disposal and accumulation of radioactive waste.
The Act prohibits disposal or accumulation of radioactive waste except as authorised by SEPA. The
Act also enables the Secretary of State to provide facilities for the disposal and accumulation of
radioactive waste.
 International Convention for the Prevention of Pollution from Ships, 1973, as modified by the
Protocol of 1978 (MARPOL) and its technical annexes, notably:
• Annex I: Discharge requirements for the prevention of pollution from oil and oily materials;
• Annex IV: Discharge requirements to control pollution of the sea by sewage from ships; and
• Annex V: Specifies distances from land in which materials may be disposal of and subdivides
types of garbage.
10.3. WASTE MANAGEMENT POLICY

Shell’s waste policy commits to all wastes being disposed of in compliance with legal regulations and Shell
Group Policy and Standards (Shell UK Ltd, 2014). Shell’s requirements for waste management are set out
in the Shell Health Safety Security and Environment and Social Performance (HSSE & SP) Control
Framework (Environment Manual) as follows:
 To incorporate controls to reduce waste generation into procedures and working practices;
 To identify opportunities to reuse waste for the same or alternative applications, including in other
industries, or return unused materials to suppliers;
 To identify recycling and recovery opportunities for waste material;
 To identify, segregate and store waste;
 To transport and dispose of waste:
• Verify that trans-national movement of waste meets the requirements of the Basel Convention;
• Verify that all other transport of waste meets internationally recognised standards;
• When disposing of waste use where appropriate, government-approved disposal sites,
methods and contractors;
• When disposing of special waste maintain segregation from other waste and use disposal sites
that also meet internationally recognised standards; and
• Conduct land farming only after considering the risks of leaching or build-up of hazardous
substances, and implement appropriate mitigation measures to manage the risks.
 Retain Waste tracking records for periods defined by local legal requirements and the Group
Records Management System.
2
Three pieces of legislation implement the European Hazardous Waste Directive 91/689/EEC in the UK: The Hazardous Waste
(England and Wales) Regulations 2005, The Hazardous Waste (Northern Ireland) Regulations 2005 and the Special Waste
Regulations 1996. In England, Wales and Northern Ireland, the term ‘Hazardous Waste’ is used. In Scotland, the term ‘Special
Waste’ is used. As the Penguins field is located in Scottish waters, the term ‘Special Waste’ will be used for the remainder of this
report.
10-2
WASTE MANAGEMENT
10.4. WASTE GENERATION

A summary of waste generation from all Shell UK Upstream operations from 2013 to 2014 is set out in
Table 10-1.
Table 10-1 Annual Waste Generation by Shell UK Upstream Operations (2013-2014)
AMOUNT (TONNES)
TYPE
2013 2014
Special Waste (t) 38,490 23,354
Non-Hazardous Waste (t) 53,456 29,992
Total Waste (t) 91,946 53,346
Overall, the waste generated (special and non-hazardous) in 2014 was 39% lower than in 2013. The
main contributing factor was the reduction in the amount of produced water.
Waste will be generated during all development phases (drilling, sub-sea installation and commissioning
and production) and will include:
 Atmospheric emissions (see Chapter 8);
 Discharges to sea including produced water, chemicals, drainage water, sewage and grey water,
drill cuttings (water based mud, WBM) etc. (see Chapter 7);
 Waste lubrication oils;
 Drill cuttings (low toxicity oil based mud, LTOBM);
 Surplus chemicals;
 Special wastes (medical waste, paints and solvents, hydraulic oil and greases, sludge from tank
vessel washing, contaminated filters, LTOBM cuttings, contaminated oil based drilling fluids, oily
rags and electrical waste including batteries and light fittings);
 Non-hazardous waste (paper, no macerated food, tin and aluminium cans, packaging material,
glass and empty plastic containers; and
 Potential NORM contaminated waste
Segregation, disposal and consignment of offshore waste in the northern North Sea will be managed in
accordance with the Shell Offshore Waste Disposal Procedures Northern and Central North Sea (Shell UK
Ltd, 2014) and Radiation Local Rules (Shell UK Ltd, 2014).
Waste types addressed in this chapter are detailed in Table 10-2.
Table 10-2 Waste Types
PREFERRED DISPOSAL
WASTE TYPES DESCRIPTION OF WASTE
ROUTE
Paper Recycled
Macerated food Composted
Non-hazardous waste Tin and aluminium cans Recycled
Packaging material Recycled
Glass Recycled
10-3
WASTE MANAGEMENT
PREFERRED DISPOSAL
WASTE TYPES DESCRIPTION OF WASTE
ROUTE
Wood pellets Composted
Empty plastic containers Recycled
Scrap metal Recycled
OBM Cuttings and contaminated Oil based drilling Treatment and disposal
fluids
Paints and solvents Treatment and disposal
Hydraulic oil and greases Recycled
Sludge from tank and vessel washing Treatment and disposal
Contaminated filters Treatment and disposal

Special waste
Electrical waste, including batteries and light fittings Treatment and disposal
Oily rags Recycled
3
NORM contaminated waste Treatment and disposal
Medical/clinical waste Treatment and disposal
Waste chemicals Treatment and disposal
10.4.1. Drilling
The largest volumes of waste are expected to be generated during drilling operations.
Drilling waste includes cuttings from wellbore and oil-based drilling muds. The well top holes will be drilled
riserless using water based mud (mainly seawater with bentonite) which will be discharged at the seabed.
Following the installation of the marine riser between the MODU and well, the remaining well sections (16"
diameter and smaller) will be drilled using Low Toxicity Oil based mud (LTOBM). The LTOBM and cuttings
will be returned to the MODU for separation. The LTOBM will be reused whereas the cuttings will be stored
and transferred to shore for thermal treatment.
Following treatment, any separated oil may be recycled and reused. Any excess base oil will be stored on
site before being returned to the supplier. Any process water will be used to dampen the dry cuttings
before final disposal at a landfill site. Samples of oil, water and the dry cuttings will be taken following
thermal treatment. It is estimated that a total of 8,244 tonnes of LTOBM derived cuttings will be shipped to
shore during the drilling phase.
3
Radioactive waste is not classed as special waste (hazardous waste) due to its radioactivity (this is governed by Radioactive
Substances Act 1993). However where a radioactive waste has other properties (e.g. toxicity) it will also be classed as Special or
Hazardous Waste.
10-4
WASTE MANAGEMENT
10.4.2. Subsea Installation and Commissioning

Waste will be generated from a number of vessels associated with the project including anchor handling
vessels (AHVs), survey, supply, installation, pipelay, standby and diving support vessels (DSVs). Waste will
likely include scrap metal, waste oil, chemicals and domestic waste.
Non-hazardous wastes and special wastes generated on vessels will be categorised and segregated
onboard and then back-loaded for disposal onshore according to Duty of Care requirements. Sewage and
grey water will be treated on-board and managed as per MARPOL Annex IV requirements. All vessels will
have a waste management plan (WMP) in accordance with the requirements of MARPOL Annex V.
10.4.3. Production Operations

The main objective of the waste management system during operations is to manage waste generated in
accordance with the waste management hierarchy (Figure 10-1). Detailed waste management procedures
and plans will be developed prior to the operational stage. Solid waste on the FPSO unit will be classified
into special and non-hazardous as described in Table 10-2. All wastes will be segregated offshore and
selected wastes recycled onshore via waste management contracts established by Shell.
Figure 10-1 Waste Management Hierarchy
The volume of waste material will vary with the level of maintenance and production activities taking place.
However, it is likely that operational waste volumes on the FPSO would be comparable to that of other
FPSOs operated by Shell in the United Kingdom Continental Shelf (UKCS) (Pierce and Anasuria). Figure
10-2 shows the 2014 waste volumes for those.
10-5
WASTE MANAGEMENT
Figure 10-2 Waste Generated (tonnes) by FPSOs in Shell UK Operations (2014)
The annual average landed waste for Anasuria and Pierce was 207 Tonnes for non-hazardous waste and
60 tonnes for special waste. As of March 2016, Anasuria is no longer operated by Shell U.K. Limited.
10.5. WASTE MANAGEMENT

Shell procedures establish the controls required to manage the hazards associated with the transportation
and disposal of waste from offshore, and the processes necessary to ensure legal obligations are satisfied.
Relevant procedures provide practical guidance on the disposal of solid and liquid waste arising from
Shell’s Northern and Central North Sea operations and address key issues including, for example,
identification and management of special waste, site waste management plans, disposal of radioactive
wastes and steps for avoiding hydrogen sulphide (H2S) release from slops in tanks and pits. Waste
management within the Penguins Redevelopment Project will follow the principles presented below:
 Reduce at the source the volume and quantity of waste produced;
 Reuse the waste for the same or alternative applications, when applicable;
 Replace material and processes with more environmentally friendly alternatives;
 Recycle waste into raw materials; and
 Recover energy converting waste into resources (such as electricity, heat, compost and fuel)
through thermal and biological means.
10.5.1. Management Plans

In accordance with waste management philosophy, emphasis is placed on waste prevention and source
reduction measures. Waste will be managed in accordance with waste management plans and procedures
which the contractors will put in place to align with Shell’s requirements. These procedures will set out key
responsibilities, reporting requirements and method for the collection, storage, processing and disposal of
waste.
Additionally, the FPSO and project vessels will have Garbage Management Plans and a Garbage Record
Book in accordance with MARPOL 73/78 Annex V Regulation 9. The Garbage Management Plan will
include written procedures for collecting, storing, processing and disposing of garbage, including the use
of the equipment onboard.
10-6
WASTE MANAGEMENT
10.5.2. Training
Staff will undergo appropriate training and be notified of the separation and disposal requirements for
each category of waste. This will be reinforced to any new joiner via the Installation’s induction.
10.5.3. Auditing
Shell’s Compliance and Verification Group will undertake audits and third party checks. Project reviews
and installation audits and inspections will be conducted by Shell, the regulatory authorities and
verification bodies, to ensure standards are being maintained and corrective action is taken where
necessary.
Planned internal and third party audits will assess the effectiveness of, and conformity to waste
management procedures on a regular basis including, for example:
 Duty of Care Audits. An audit of compliance with the Duty of Care Regulations will include:
• roles and responsibilities throughout the waste management chain (waste
producer/carrier/manager);
• management systems controls, specifically record keeping and documentation of waste; and
• compliance with licensing and permit conditions and registration certificates.
 Waste Management Contractor Audits to include the following:

• checking that licence or permit conditions are appropriate for waste types being received;
• checking conformance with licence and permit conditions;
• checking that adequate and appropriate management system controls are in place; and
• checking compliance with appropriate transfer note system.
10-7
ACCIDENTAL HYDROCARBON RELEASES
11. ACCIDENTAL HYDROCARBON RELEASES
11.1. INTRODUCTION
The risk of an accidental hydrocarbon release/oil spill into the marine environment is inherent in all
offshore oil developments. The industry approach to dealing with potential oil spills is to develop
technology and operational procedures to reduce the likelihood of such events occurring, whilst at the same
time planning appropriate responses to oil spills to reduce the severity of impacts in the event of an
incident. The response procedures form part of the Oil Pollution Emergency Plan (OPEP).
This chapter provides the modelled outcomes of the potential worst-case hydrocarbon release scenarios.
11.2. SCENARIO IDENTIFICATION

Potential unplanned hydrocarbon releases associated with this Project were identified during the
environmental and social aspects identification (ENVID) workshop undertaken during the Front End
Engineering and Design (FEED) stage. Table 11-1 sets out the activities that were identified as potentially
having an impact on the environment following an unplanned event.
Table 11-1 Identified Activities
PHASE EVENT
Drilling Dropped objects impacting the existing pipelines
Leaks during drilling - oil spill or worst case blow out
Weather conditions causing rig to lose position and loss of containment for mud/oil
Collision risk/rig positioning failure resulting in oil spill
Bunkering accidents resulting in spillage
Installation & Dropped objects impacting the existing pipelines
commissioning
Leaks during installation and commissioning - oil spill to sea
Operation Offloading activities using shuttle tanker
Bunkering accidents resulting in spillage
Chemical use during production resulting in spillage
Hydrocarbon spills during operation - subsea pipeline/riser failure
Well blow out during production
FPSO Cargo tank loss of containment (Structural failure, ship collision)
Out of these scenarios, the following representative worse case oil spill scenarios were identified to inform
the oil spill modelling studies (see Appendix E) and this chapter:
 Well blowout; and
 Total loss of the crude inventory stored in the FPSO.
11-1
The well blow out scenario during drilling of the PAN-W well is considered the worst case oil release for
the Penguins Field. This well has the highest liquid flow rates. This scenario assumes an outflow without a
well completion (casing, tubular, packers, etc.).
The selection of total loss of the crude inventory, as opposed to the total loss of diesel inventory from the
MODU for example, was based on the Guidance Notes for preparing Oil Pollution Emergency Plans
(DECC, January 2015 and Draft revision May 2015) which states that ‘it is only the larger of the in-field
pipeline liquid hydrocarbon inventory, diesel inventory or crude inventory which should be modelled’ The
total loss of the crude inventory is the larger inventory and also the more persistent hydrocarbon. It is
therefore considered the worst case. The volume for this scenario is based on the total geometrical volume
for the 13 cargo tanks (88,006 m3). However due to stability and draft of the vessel the maximum
operational volume to be stored at any one time will be approximately 63,600 m3. The total geometrical
volume (88,006 m3) is considered the theoretical worst case volume and it is the basis for the model
undertaken.
The objective of the oil spill modelling is to identify the consequences of different spill scenarios, and in
particular identify the risk posed to the coastline or near shore resources and receptors.
11.3. LIKELIHOOD
The likelihood of unplanned events was determined during the ENVID. The likelihood of the two scenarios
is set out in Table 11-2.
Table 11-2 Likelihood of Unplanned Events Occurring
NAME CATEGORY DESCRIPTION
Well blowout Remote Heard of previously in the industry; occurring every 10-5 to 10-3 years.
Total loss of Extremely Never heard of in the industry; occurring every < 10-5 years.
FPSO stored remote
crude inventory
11.4. CONSEQUENCE
The consequence of oil spills is determined by a number of factors including the vulnerability of the
receptors to oiling and the degree of oiling. The degree of oiling is determined using oil spill modelling.
11.4.1. Oil Spill Modelling

The oil spill modelling studies for the Project were carried out by Oil Spill Response Limited (OSRL) using
the Oil Spill Contingency and Response (OSCAR) model. OSCAR is a multi-component three dimensional
(3D) model developed by SINTEF. It has been fully validated and calibrated using field observations and a
number of experimental controlled oil spills.
The full report is included in Appendix E – Oil Spill Modelling Report.
11.4.2. Scenarios
Four stochastic simulations were run for each of the scenarios to investigate seasonal impacts. The results
are presented over four separate seasons: winter (December to February), spring (March to May), summer
(June to August) and autumn (September to November). The modelling approach and results are discussed
in more detail in Appendix E – Oil Spill Modelling Report.
11-2
It is important to note that the modelling scenarios are run with the assumption that no oil spill response
measures (e.g. use of skimmers, booming etc.) were implemented and that no mitigating actions were taken
at the point of spillage (e.g. pumping out of ruptured oil tanks). Therefore the results of the modelling
present very much the ‘worst case’ that could result from any particular oil spill. In reality, were an oil spill
to occur Shell would initiate appropriate response measures to limit the extent and impact of the spill.
Additionally, the model does not take into account the likelihood of the spill occurring and assumes that the
cargo tanks of the FPSO are full at the time of the spill.
A summary of the scenarios is set out in Table 11-3. The PAN-W well and the Penguins FPSO site are both
approximately 150 km from the shore of Shetland.
Table 11-3 Summary of Scenarios
SCENARIO REFERENCE SCENARIO 1 (S01) SCENARIO 2 (S02)
Description PAN-W Well Blowout Total loss of FPSO crude inventory

a) Winter (Dec-Feb)
b) Spring (Mar-May)
Season
c) Summer (Jun-Aug)
d) Autumn (Sep-Nov)
Latitude (WGS84) 61° 37’ 43.428” N 61° 32’ 01.054” N
Longitude (WGS84) 001° 29’ 42.999” E 01° 36’ 17.993” E
Total oil volume / Mass released 413,367 m3 /352,003 Tonnes 88,006 m3 /74,935 Tonnes
Duration of release 120 days 3 hours
Depth of release Seabed (165 m) Surface (0 m)
Nearest shorelines Shetland Islands (UK) ~150 km
Nearest boundary lines UK-Norway ~7 km UK-Norway ~4
11.4.3. Hydrocarbon Characteristics

The hydrocarbon characteristics used for each the scenarios are set out in Table 11-4.
Table 11-4 Hydrocarbon Characteristics per Scenario
CHARACTERISTICS SCENARIO 1 SCENARIO 2

API Gravity 38.4 38.4
Viscosity 4.0 cP 4.0 cP
Pour Point 6 °C 6 °C
Wax Content 5.9 % 5.9 %
Asphaltenes 0.3 % 0.3 %
11-3
11.4.4. Results Summary

Summary results from the stochastic modelling are set out in Table 11-5 and Table 11-6, including quickest
arrival times.
Table 11-5 Summary of Stochastic Results by Country – Scenario 1
QUICKEST
QUICKEST TIME TO PROBABILITY OF
TIME TO MASS OF EMULSION
SCENARIO COUNTRY REACH SURFACE SHORELINE
REACH ONSHORE (MT)
WATERS IMPACT
SHORELINE
Oil released in
UK 25 days 79 %
UK
Scenario 1a Norway 15 days 6 hours 100 %

13,638
(Dec-Feb) Sweden N/A 94 days 0%
Denmark 35 days 31 days 34 %
Faroe Islands N/A 40 days 0%
Oil released in
UK 12 days 79 %
UK
Scenario 1b Norway 14 days 6 hours 100 %

14,264
(Mar-May) Sweden 91 days 84 days 21 %
Faroe Islands 116 days 49 days 3%
Oil released in
UK 111 days 48 %
UK
Norway 13 days 6 hours 100 %
Scenario 1c
7,418
(Jun-Aug) Sweden 111 days 99 days 3%
Denmark 110 days 76 days 9%
Oil released in
UK 13 days 83 %
UK
Scenario 1d Norway 13 days 6 hours 100 %

3,200
(Sep-Nov) Sweden N/A N/A 0%
Denmark N/A 146 days 0%
Note: MT = Metric Tonnes
11-4
Table 11-6 Summary of Stochastic Results by Country – Scenario 2
QUICKEST
QUICKEST TIME TO PROBABILITY MASS OF
TIME TO
SCENARIO COUNTRY REACH SURFACE OF SHORELINE EMULSION
REACH
WATERS IMPACT ONSHORE (MT)
SHORELINE
53 days and
UK Oil released in UK <1 %
16 hours
Scenario 2a
Norway 11 days 2 hours 96 % 3,860
(Dec-Feb)
53 days and 4
Denmark 39 days <1 %
hours
7 days and 4
UK Oil released in UK 44 %
hours
9 days and 2
Scenario 2b Norway 2 hours 53 %
hours 3,343
(Mar-May)
Denmark N/A 44 days and 4 hours N/A
27 days and 19
Faroe Islands N/A N/A
hours
6 days and 4
Scenario 2c UK Oil released in UK 16 %
hours 2,364
(Jun-Aug)
13 days and 7
UK Oil released in UK 2%
hours
Scenario 2d
8 days and 21 1,631
(Sep-Nov) Norway 2 hours 93 %
hours
54 days and 2 52 days and 19
Denmark 1%
hours hours
Note: MT = Metric Tonnes
Selected modelling outcomes are presented in this section. A complete set of figures is presented in
Appendix E.
11.4.5. Scenario 1 PAN-W Well Blowout

The probability of water surface oiling resulting from a blowout of the PAN-W well is illustrated on
Figure 11-1. The degree of shoreline oiling is presented on Figure 11-2.
The following observations are made from the oil spill modelling of a blowout from the PAN-W well:
Surface Water
 Oil would affect the waters of the UK, Norway, Denmark, Sweden and the Faroe Islands.
 Oil would cross the UK/Norway boundary in around 6 hours. Oil would not reach the waters of
Denmark, Sweden, and the Faroe Islands for at least 27 days.
11-5
 The emulsion thickness of oil during each scenario ranges from sheen (0.04 µm) to continuous true
colour (>200 µm).
Shoreline
 There is a 100% probability that oil would reach the shore under all seasonal conditions.
 Oil could reach the Shetland Islands in 6 days during worst case metocean conditions. Oil could
also reach the shorelines of mainland UK, Norway, Sweden Denmark and the Faroe Islands.
 Worst case conditions could see up to 14,264 tonnes of emulsion reaching nearby shorelines
(Figure 11-2).
Water Column
 Total hydrocarbon concentration (THC) levels greater than 500 ppb are present during each of the
four scenarios.
Seasonal Considerations
 Oil spilled during a well blowout at the PAN W well is likely to have a similar spatial extent
regardless of the season. Although shoreline oiling is expected during each season the impact of a
spill between September and November is likely to be smaller than spills in the other three
seasons. The high winds between September and November will assist with natural dispersion and
reduce shoreline oiling.
Plankton typically display extremely patchy spatial and temporal distribution but is generally present in the
offshore area. A blowout from PAN-W would have severe consequences on the planktonic community over
a regional scale. However, plankton is expected to recover quickly (typically weeks to months) due to high
productive rates and immigration from outside the affected area.
The egg and juvenile stages in fish lifecycles are particularly vulnerable to hydrocarbon spills; adult fish are
highly mobile and are generally able to avoid polluted areas. As detailed in Chapter 4, species such as
Cod, Haddock, Saithe and Norway Spout have high intensity spawning grounds at the Penguins area.
Spawning for most species in the North Sea occurs from January to June. Therefore an oil spill during this
time will have the most severe consequence to fish stocks in the area, as fish are less sensitive outside of
spawning periods. Although it should be noted that spawning occurs over large areas and not consistently
in the same areas year on year.
Seabird vulnerability in the Penguins area is derived from the JNCC OVI (see Chapter 4). The surrounding
area has a relatively low vulnerability throughout most of the year, with areas of moderate and high
vulnerability around Shetland and off the southwest coast of Norway. These areas would be severely
affected by a blowout at PAN-W, having a 75% to 95% probability of interaction.
Cetaceans have a lower vulnerability to oil and are generally able to avoid areas of heavy oiling.
Pinnipeds have a higher vulnerability particularly as pups (when they are furred) and when hauling-out at
coastal locations. Shetland and northeast Scotland are important to populations of European importance of
grey and common seal.
A blowout would result in light to moderate oiling along the Norwegian coastline and moderate to heavy
oiling along the coast of Shetland. Given the predominant coastal habitat types at these locations,
recovery would likely take up to 5 years. There a number of protected and sensitive areas along the
coastline of the UK and Norway. The accumulated and average oil mass (emulsion) predicted at these UK
designated sites and NOFO areas are set out in Table 11-7. The table also describes the sites and their
priority features. These sites are illustrated in Chapter 4 (Figure 4–15).
Fishing is one of the primary economic activities in the EU. The area surrounding the Penguins area
supports fishing of low to moderate intensity. A large blowout event would exclude fishermen from fishing
the affected areas and potentially taint catch. However, there is no evidence of long term effects of oil spills
on offshore fisheries.
11-6
Oil spills have detrimental effects on tourism in terms of perception, area avoidance and fouling of
recreational resources. Oil from a blowout event at PAN-W would reach the coast and depending on the
affected areas and resources could have a moderate impact on tourism in the UK and Norway.
Based on the above impacts the overall consequence of a well blowout event is rated as Massive.
11-7
Figure 11-1 Probability of Oil Reaching Surface Cells (Scenario 1 - Well Blowout).
11-8
Figure 11-2 Maximum Emulsion Mass on Shoreline Cells (Scenario 1 - Well Blowout).
11-9
Table 11-7 Interaction of Blowout Modelling with UK Protected Areas and Norwegian NOFO Areas
SITE DESCRIPTION PROBABILITY OF AVERAGE OIL MASS ACCUMULATED OIL

INTERACTION (Tonnes / 2 km2) MASS (Tonnes)
Fair Isle SPA The site has been designated as a SPA for supporting breeding populations and a seabird 20 45 90
assemblage of European importance and a SAC for the presence of Annex I habitat. Shoreline
comprises shingle beach, sea cliffs and islets. It is partly composed of Old Red Sandstone that
has weathered to produce a greatly indented coastline with many geos, stacks and crags. The
island is of major importance as a breeding area for seabirds, including skuas, terns, gulls and
auks. During the breeding season, the area regularly supports 180,000 individual seabirds.
Notable species include Arctic tern and guillemot.
Fetlar SPA The site has been designated as an SPA due to supporting breeding populations of European 28 368 4,786
importance of Annex I and migratory species, and a seabird assemblage of international
importance. The shoreline of this site comprises cliffs and rocky shores, with floristically rich
maritime grasses and heathlands around the coasts. The SPA is of importance for a number of
northern breeding waders and seabirds. During the breeding season, the area regularly
supports 22,000 individual seabirds. Notable species include: Arctic tern, red-necked
phalarope, dunlin, great skua, whimbrel, Arctic skua, fulmar.
Hermaness, Saxa The site has been designated as an SPA due to supporting breeding populations of European 28 328 5,904
Vord and Valla importance of Annex I and migratory species, and a seabird assemblage of international
Field SPA importance. The shoreline of the site comprises cliffs and off-lying stacks, mostly between 100
and 200 m high. A number of breeding seabird species nest on the cliffs. The seabirds feed
outside the SPA in nearby waters as well as more distantly in the North Sea. During the
breeding season, the area regularly supports 152,000 individual seabirds. Notable species
include: red-throated diver, gannet, great skua, puffin, guillemot, kittiwake, shag, fulmar.
Hoy SPA The site has been designated as an SPA due to supporting breeding populations of European 1 28 28
importance of Annex I species. On the west coast, Old Red Sandstone cliffs reach 339 m in
height and include a number of notable stacks and crags. These cliffs provide important
breeding sites for a number of seabird species, especially gulls and auks, whilst moorland areas
11-10

support large numbers of breeding birds, in particular Great Skua Catharacta skua. Red-
throated Diver Gavia stellata nest on the numerous small lochans found on the moorland. The
divers and seabirds feed in the rich waters around Hoy, outside the SPA.
Noss SPA The site has been designated as an SPA due to supporting breeding populations of European 29 222 666
importance of migratory species, and a seabird assemblage of international importance. The site
comprises high cliffs of Old Red Sandstone reaching to 180 m height. These sandstone cliffs
provide a high density of ledges suitable for nesting seabirds. The site supports the nesting of
large numbers of auks, gulls and gannet. Seabirds nesting on Noss feed outside the SPA in the
immediately surrounding waters, as well as further away in the North Sea. Notable species
include: gannet, great skua, guillemot, puffin, kittiwake and fulmar.
Sumburgh Head The site has been designated as an SPA due to supporting breeding populations of European 32 92 184
SPA importance of Annex I, and a seabird assemblage of international importance. The site
comprises boulder-strewn beaches and cliffs up to 100 m high along the east side of Sumburgh
Head. The site is of importance as a breeding area for several species of seabirds, including
terns, auks and gulls. These seabirds feed outside the SPA, both in the waters immediately
around Sumburgh Head, and further away. During the breeding season, the area regularly
supports 35,000 individual seabirds. Notable species include: Arctic tern, guillemot, kittiwake,
fulmar
Foula SPA The site has been designated as an SPA due to supporting breeding populations of European 7 35 35
importance of Annex I species. The island is formed of Old Red Sandstone with a low-lying
eastern side rising steeply to a central ridge and terminating on the western coast in sea-cliffs
The island is important for a wide range of breeding seabirds, with different species nesting in
different parts of the island. It is one of only seven known nesting localities in the EU for Leach's
Petrel Oceanodroma leucorhoa. The seabirds feed outside the SPA in nearby waters, as well as
more distantly in the North Atlantic.
11-11

Yell Sound Coast The site is designated for the presence of two Annex II species otter Lutra lutra and harbour seal 22 47 609
SAC Phoca vitulina. The site consists of a complex of islands and coastline.
Papa Stour SAC The site is designated for the presence of two Annex I habitats reefs and submerged or partially 1 7 7
submerged sea caves. The rocky coastline of Papa Stour is among the most exposed in the UK,
and the island and the adjacent mainland are fringed entirely by sublittoral bedrock and boulder
reefs reaching depths of more than 30 m. The underwater terrain is rugged, with rock walls,
slopes, gullies, ledges, ridges and boulder slopes, which support a diverse range of plant and
animal communities.
Sullom Voe SAC The primary reason for site designated is the presence of large shallow inlets and bays. The 4 20 121
boreal-arctic (northern) species-rich communities of Sullom Voe are restricted to Shetland voes
and are not represented elsewhere in the SAC series.
Caithness and The site supports one of the largest and most intact areas of blanket bog in the world. The site 1 13 13
Sutherland supports a number of rare species of wetland plants and animals. The plants include three
Peatlan Ramsar nationally rare mosses, eight nationally scarce vascular plants and four nationally scarce mosses.
The insect fauna includes several nationally scarce species and one nationally rare species. The
site supports nationally important breeding populations of ten waterfowl species.
Fetlar to Protected features include black guillemot; circalittoral sand and coarse sediment communities; 29 353 10,243
Haroldswick MPA horse mussel beds; kelp and seaweed communities on sublittoral sediment; maerl beds; shallow
tide-swept coarse sands with burrowing bivalves; Marine Geomorphology of the Scottish Shelf
Seabed.
Noss Head MPA The site is designated to protected horse mussel beds. 1 25 25
11-12

Ytre Sula NOFO Area including 2 protected sites, both of which are nature reserves. The NOFO area 10 41 41
includes a large number of small islands off the coast of Norway. The shorelines within the area
are predominantly composed of sloping rock. Specific information on bird species present at the
site is not available, but conservation plans are in place at the protected sites for seabirds.
Similar species are likely to be present at this site as at nearby island sites. The NOFO area
intersects with several coastal spawning areas.
Atløy/Værlandet NOFO Area including 12 protected sites, all of which are nature reserves. The NOFO area 55 38 230
includes a number of small islands off the coast of Norway. The shorelines within the area
comprise mainly rocky shore, with sections of cliff, boulder, stone / gravel beach and sand
beach. Specific information on bird species present at the site is not available, but conservation
plans are in place at the protected sites for seabirds. Similar species are likely to be present at
this site as at nearby island sites. The NOFO area intersects with several coastal spawning
areas.
Sverslingsosen/ NOFO Area including 3 protected sites, all of which are nature reserves. The NOFO area 45 40 242
Skorpa includes a number of islands off the coast of Norway. The shorelines within the area comprise
mainly rocky shore, with sections of cliff, boulder, stone / gravel beach and sand beach.
Specific information on bird species present at the site is not available, but conservation plans
are in place at the protected sites for seabirds. Similar species are likely to be present at this site
as at nearby island sites. The NOFO area intersects with two large coastal spawning areas.
Runde NOFO Area including 15 protected sites: these include nature reserves, animal conservation 93 46 969
areas and wildlife conservation areas. Runde NOFO Area includes a number of islands close to
the coast of Norway as well as sections of coast. A range of shoreline habitats are present: the
seaward islands comprise predominantly cliffs, sloping rock and stone/gravel beaches;
landward islands and the coast comprise mainly sloping rock, stone/gravel beaches and sand
beaches. Runde Island has a large seabird colony supporting over 500,000 individual seabirds
during the nesting season. Species include: puffin, fulmar, gannet, shag, kittiwake, guillemot,
11-13

razorbill, black guillemot, great skua, Arctic skua, and common eider. Several species of gull
and tern also occur. Specific conservation plans are in place at several sites for seabirds. A
coastal fish spawning area has been identified at the site.
Smøla NOFO Area including 11 protected sites: these include nature reserves and landscape 100 69 1654
conservation areas. The NOFO Area includes a large island off the coast of Norway, and a
large number of surrounding smaller islands. The shoreline in the area comprises mainly sloping
rock, with some sections of sand and gravel beaches in sheltered areas. Smøla has one of the
highest breeding densities of white-tailed sea eagle in the world. The sea areas are important for
wintering divers, grebes, various seaduck species and whooper swan. The area is important for
moulting greylag geese, breeding black guillemot, and red-throated and black-throated divers.
Several small coastal spawning areas fall within the NOFO Area.
Frøya og Froan NOFO Area including 16 protected sites: these include nature reserves, animal and wildlife 87 48 430
conservation areas, and a landscape conservation area. The NOFO Area includes a large
number of small islands off the coast of Norway. The shoreline in the area comprises mainly
sloping rock, with small stretches of sand and gravel beaches. The area also intersects with a
large area of marine habitat identified as an environmental priority. Internationally important
numbers of seabirds breed at the site, and large numbers of migrating, moulting, breeding and
wintering waterbirds of numerous species occur. Key species include: yellow-billed loon,
common eider, red-breasted merganser, red-throated diver, great cormorant, shag, white-tailed
sea eagle and black guillemot. The area provides habitat for approximately half of the
Norwegian population of harbour seal. Several coastal spawning areas fall within the NOFO
Area.
Austevoll NOFO Area including 7 protected sites, all of which are nature reserves. The NOFO area 10 30 121
includes a number of islands off the coast of Norway. The shoreline in the area comprises
almost entirely sloping rock. The area also includes marine habitat identified as an
environmental priority. Throughout the year the area supports the foraging, moulting and
breeding of seabirds including auks, ducks, gulls and cormorants. During summer the area
11-14

supports nesting cormorants, geese, gulls and storm petrels. There are several spawning
grounds present (cod and herring). Specific conservation plans are in place at several sites for
seabirds. Several small coastal spawning areas fall within the NOFO Area.
Nord-Jæren NOFO Area including 13 protected sites: these comprise nature reserves, animal, plant and 3 17 34
wildlife conservation areas, and a natural monument. The NOFO Area includes some islands off
the coast of Norway as well as sections of coastline. The shoreline in the area comprises mainly
sloping rock with sandy beaches, stone / gravel beaches and rocky shore / boulders. The area
also includes marine habitat identified as an environmental priority. The area supports
wintering, nesting and breeding populations of auks, ducks, geese, gulls, waders and terns year
round. Wetland species are present in the area. Specific conservation plans are in place at
several sites for seabirds. Notable species include grey seal and harbour seal. Several small
coastal spawning areas fall within the NOFO Area.
Bømlo NOFO Area including 6 protected sites, all of which are nature reserves. The NOFO Area 2 14 28
includes a number of islands close to the coast of Norway as well as a section of coast. The
shoreline in the area comprises almost entirely sloping rock. The area also includes marine
habitat identified as an environmental priority. Specific information on bird species present at
the site is not available, but conservation plans are in place at the protected sites for seabirds.
Similar species are likely to be present at this site as at nearby island sites. A coastal spawning
area falls within the NOFO Area.
Utsira NOFO Area including 1 protected site, a nature reserve. This NOFO area includes one larger 32 61 61
island off the coast of Norway, and a group of very small islands. The shoreline in the area
comprises almost entirely sloping rock. The remainder of the area is open water with a few
islands present. Specific conservation plan in place at the site for seabirds. The area supports
overwintering seabirds and marine mammals. Notable species: razorbill, kittiwake, guillemot,
Arctic tern, lesser black-backed gull, great black-backed gull and grey seal. The entire area falls
within a coastal spawning area.
11-15

Ognabukta NOFO Area including 5 protected sites, comprising animal and plant conservation areas. The 4 15 45
NOFO Area includes a section of the Norwegian coast and one very small island. The shoreline
in the area comprises a mix of sandy beach, sand dunes, stone / gravel beach, rocky shore and
boulders. The wider area is an important area for wetland related birds, and provides a staging
and wintering area for a number of species. The area overlaps with the edge of a large coastal
spawning area.
11-16
11.4.6. Scenario 2 Total Loss of Crude Oil Inventory Stored in FPSO

The following observations are made from the oil spill modelling of a total cargo oil inventory loss:
Surface Water
 Oil would affect the waters of the UK and Norway (Figure 11-3). Oil could cross the UK-
Norwegian maritime boundary in less than 1 hour.
 The emulsion thickness of oil during each scenario ranges from sheen (0.04 µm) to continuous true
colour (>200 µm).
Shoreline
 An instantaneous total loss of crude inventory has between a 92% and 97% chance of shoreline
impact depending on the season. Worst case conditions could see up to 3,860 MT of emulsion
reaching nearby shorelines (Figure 11-4).
 Oil could reach the Shetland Islands in just over six days during certain worst case metocean
conditions. Oil could also reach the Norwegian shorelines within 9 days during worst case
metocean conditions.
Water Column
 UK and Norwegian waters could both have THC levels greater than 500 ppb during all four
seasons.
An oil spill from a loss of stored crude oil inventory will cover a similar area as the blowout described
above, albeit with a lower probability of impacting coastal resources and a lesser degree of oiling. This is
because the FPSO crude inventory is a finite volume, whereas the blowout scenario is in effect a much
longer duration event. The impacts on specific environmental resources are therefore generally expected to
be less severe than those of a blowout and persist for less time.
Similar to the blowout, oil from a loss of crude oil inventory is expected to have localised to sub-regional
effects on plankton and fish spawning. Oil is still expected to reach areas of high seabird vulnerability and
coastal seal pupping locations around Shetland, although the probability (<50%) and degree of oiling is
reduced.
There is at least a 92% probability that the total loss of the crude inventory will reach the shore under all
seasonal conditions. The spill is predicted to cross international boundary into Norwegian waters. The
Norwegian coastline is likely to be the most heavily affected both in terms of emulsion mass and in terms of
the length of time for oil to reach the coastline. The coastline generally comprises habitat which has a
lower vulnerability to oiling. However, wetlands and areas used for recreation are common. Oiling of these
locations would cause widespread degradation to the quality and availability of habitats (particularly
wetland birds) requiring extensive long term restoration effort to restore beneficial uses.
Oil reaching the coast will have minor to moderate impacts to the conservation objectives of internationally
and nationally designated sites, although to a lesser degree when compared with a blowout event. The UK
coastline has a number of sites designated for their conservation importance (SACs, SPAs) in addition to
Ramsar areas, which are also present and would likely be affected along the Norwegian coastline.
Fishing would still be affected but the area which fishermen would need to avoid is smaller.
The consequence of a losing the entire stored volume of crude oil is rated as Major.
11-17
Figure 11-3 Probability of Oil Reaching Surface Cells (Scenario 2 – Total Loss of Crude Inventory).
11-18
Figure 11-4 Maximum Emulsion Mass on Shoreline Cells (Scenario 2 – Total Loss of Crude Inventory).
11-19
11.4.7. Summary of Consequences

The consequence of each scenario is presented in Table 11-8.
Table 11-8 Consequence
NAME CATEGORY DESCRIPTION
Well blowout Massive Wide spread long-term degradation to the quality or availability of
habitats and/or wildlife with recovery not expected for an extended
period (>5 years) or that cannot be readily rectified.
Major impact on the conservation objective(s) of internationally/
nationally protected sites, habitats and populations.
Major transboundary effects expected.
Persistent severe environmental and socioeconomic damage that will
lead to loss of commercial, recreational use or loss of natural
resources over a wide area of open water and coastline.
Total loss of Major Widespread degradation to the quality or availability of habitats

crude inventory and/or wildlife requiring significant long-term restoration effort.
from the FPSO Recovery likely within 2-5 years following clean up
Moderate-minor impact on the conservation objectives of
internationally/nationally protected sites, habitats or populations.
Transboundary effects that require a response.
Coastal and open water impacts on areas of social, economic,
recreational and aesthetic value.
11.5. MITIGATION MEASURES

Figures 11-6 and 11-7 details the Control and Barriers implemented to prevent a well control incident
(blowouts) from occurring and measures to mitigate the consequences if such an event occurs (e.g. OPEP
response). Shell’s philosophy for preventing and dealing with oil spills, particularly those resulting from
well blowout scenarios are focus on prevention. In regards to the spill response philosophy remains the
same (i.e. following a tiered response procedure).
Measures for reducing the risk of an oil spill from the FPSO are related to navigational risk, i.e. collisions.
As described previously, the FPSO will be subject to a 500 m exclusion zone enforced by a guard vessel
and marked on nautical charts.
These measures have not been considered in the assessment but would assist in reducing the likelihood of
spills occurring and reduce the consequences should they occur.
The total loss of crude inventory from the FPSO scenario is based on the total geometrical volume for the 13
cargo tanks (88,006 m3). However the maximum operational volume to be stored at any one time will be
approximately 63,600 m3. Potential impacts of this scenario under normal operational conditions will be
lower than the one anticipated by the current model.
11-20
11.6. ENVIRONMENTAL RISK

As described above, environmental risk is a combination of the probability of an oil spill event occurring
multiplied by the consequence should that event occur, with consideration given to the vulnerability and
importance of the resources and receptors.
A risk matrix is used to map likelihood and consequence of the three scenarios considered. Figure 11-7
shows that the lowest risks are located in the top left of the matrix (i.e. very unlikely with a low severity)
while the highest risks are located in the bottom right (i.e. very likely with a much greater severity).
Scenarios which fall within the green zone are considered Acceptable, where remedial action is
discretionary and procedures are put in place to ensure the risk level is maintained; those in the yellow
zone are considered Tolerable if it can be demonstrated that the risks are ALARP; finally scenarios in the
red zone are considered Unacceptable, where immediate action, further review, consultation and further
risk assessment is required.
The assessment of the two scenarios assessed in this chapter is presented in Figure 11-7.
 An unplanned event resulting in a well blowout is expected to have Massive consequences to the
marine and coastal environment. The remote likelihood means that the risk is rated as ALARP.
 A total loss of crude inventory is expected to have Major consequences to the marine and coastal
environment. The remote likelihood means the risk is rated as ALARP.
Likelihood of Event
A – Extremely B - Remote C - Unlikely D - Possible E - Likely
remote
0 – No effect
1 – Slight effect
Consequence of Event
2 – Minor effect
3 – Moderate effect
4 – Major effect Scenario 2
5 – Massive effect Scenario 1
Figure 11-5 Environmental Risk
11-21
Figure 11-6 Well Control Figure - Part 1 (Control and Barriers).
11-23
Figure 11-7 Well Control Figure - Part 2 (Response and Recovery).
11-24
11.7. CONCLUSIONS
It is important to consider that the scenarios that have been assessed as part of this chapter assume that no
intervention measures will be implemented to stop oil from reaching the UK and Norwegian coastlines. The
mitigation of oil spill incidents is addressed through the implementation of oil spill prevention and oil spill
preparedness measures. As set out above, the primary mitigation measure for avoiding the impacts of an
oil spill is to prevent any such spill taking place in the first instance. This is achieved through both
technology applications as well as operational controls.
Specific risk management and oil spill preparedness measures for the Project will be developed and
incorporated into the project’s Oil Pollution Emergency Plan (OPEP). Shell will implement the OPEP to
effectively respond to any oil spill event, remove as much of the oil volume as possible and protect and
divert oil away from environmentally sensitive sites. The response system described in the OPEP is
designed on the tiered approach with the capacity to handle the worst case credible scenario.
11-25
CONCLUSIONS
12. CONCLUSIONS
12.1. INTRODUCTION
A detailed assessment of the environmental effects associated with the Penguins Redevelopment Project has
been carried out, and the environmental assessment and management process will continue throughout the
life of the project. The commitments made in this ES will be incorporated into environmental management
plans for the detailed design, drilling, installation and commissioning, and production/operations and
decommissioning phases of the project.
12.2. ENVIRONMENTAL EFFECTS

The project area is considered to be of typical northern North Sea offshore environments in an area which
has been used for Oil and Gas Production for a number of years.
The potential effects to the environment from all phases of the project were identified and assessed; this was
done for both planned activities and unplanned/accidental hydrocarbon releases. The significance of the
effects of the project were assessed in terms of:
 Magnitude based on the size, extent and duration of the impact;
 The sensitivity, importance and value of the receiving resources or receptors; and
 The likelihood of an accidental hydrocarbon release occurring and its consequence.
Effect significance was classified, in ascending order, as presenting a positive, negligible, minor, moderate
or major effect. Similarly accidental hydrocarbon releases were classified as presenting an unacceptable,
As Low As Reasonably Practical (ALARP) or acceptable environmental risk. Throughout the assessment
embedded management and design measures aimed at reducing the magnitude of impacts were
incorporated into the assessment. These measures are set out in the Table 12.1 - Commitments Register.
Where significant effects persisted, suitable mitigation measures, safeguards and controls where identified
and additional assessment was undertaken for all impacts to determine their residual impact (or risk for
accidental hydrocarbon releases).
The assessment did not identify any major environmental effects. The assessment showed that the majority
of the planned activities have negligible effects with some minor and moderate effects on the environment.
Table 12.2 presents a summary of the residual significance of impacts from planned activities. The
environmental risk of accidental hydrocarbon releases from the project were assessed as ALARP, this is
shown in Table 12.3.
Waste management has been included in this ES as a potential ongoing source of environmental impacts
and risk throughout the life of the project. Waste generation will occur during all phases of the project and
will include special (hazardous), non-hazardous and recyclable wastes. Drilling waste and operational
waste associated with processing, maintenance and utilities will account for the majority of waste
generated during the Project. A project-specific waste management plan will be developed and
implemented.
In conclusion, the execution of the proposed Penguins Redevelopment Project, incorporating the mitigation
measures, safeguards and control measures identified and committed to within this ES, is not expected to
have a significant effect on the environment.
12-1
CONCLUSIONS
Table 12.1 Commitments Register

REQUIREMENTS
Atmospheric Well testing Contribution to Climate Well test programme and procedures Use of clean burn heads to maximise
Emissions change combustion;
Acidification No planned extended well test (>96 hours).
Vessel Contribution to Climate Contractor selection and audit for compliance with MARPOL Shell integrated activity planning
operations change Annex VI requirements
Shuttle tankers will always be dynamically
Reduction in air quality Contractor management audits and performance reviews positioned. Dynamic Positioning thrusters will
be used for keeping the accuracy and control of
position which will have an influence on
emissions.
Cooling systems Ozone depletion and Contractor selection to ensure used of certified contractors
contribution to climate
No use of Halons or HCFCs in accordance with MARPOL and
change
Shell HSSE & SP Control Framework
Flaring and Contribution to Climate Flare management strategy The hydrocarbon Vapour recovery unit to
venting change recover gas vented from the Cargo Tanks
Flare metering and allocation philosophy
Blanketing and other smaller sources.
Acidification
No routine flaring (continuous gas pilot will be provided)
Nitrogen purge to reduce CO2 Hydrocarbon gas
blanketing
12-2
PENGUINS REDEVELOPMENT ES
CONCLUSIONS

REQUIREMENTS
Power Contribution to Climate Compliance with EU Emissions Trading Scheme and Pollution Waste heat recovery system
generation change Prevention Control requirements Use of dry low emissions (DLE) burners
Acidification Externally verified energy efficiency improvement plan (including the HP compressor with DLE)
Reduction in air quality Programmed maintenance as per manufacturer’s
recommendations
Spare parts philosophy
Atmospheric emissions monitoring and reporting procedure
Discharges to Sea Chemical use Reduction in water Use of CEFAS registered chemicals Slimming of wellbore diameters where feasible
and discharge – quality Monitoring and reporting of use and discharge via EEMS to reduce mud and cuttings
all project Toxic impact on species Review of chemicals identified for substitution
phases and habitats (e.g. study on replacement of the existing
Chemical awareness training for personnel
Seabed disturbance corrosion inhibitor)
Drilling – Reduction in water Treatment of oil contaminated reservoir fluids to < 30 mg/l prior
discharge of quality to discharge
reservoir Toxic impact on species Well test programme and procedures
hydrocarbons – and habitats
well testing
Ballasting Introduction of non- Ballast water management procedures in accordance with
during transit native species MARPOL
Produced water Reduction in water Routine sampling and analysis of produced water and slops Drains/slops treatment system is designed to
quality discharges meet oil content < 15 mg/l for discharge
overboard
Toxic impacts to biota Compliance with Oil Discharge Permit requirements
and water column Produced water treatment system (hydrocyclone
and degasser) designed to meet < 30 mg/l
dispersed oil in water concentration
Provisions within the design to allow for the
future inclusion of injection points for chemical
treatment if required.
12-3
CONCLUSIONS

REQUIREMENTS
Drainage, Reduction in water FPSO and vessels designed as per MARPOL requirements for
foodwaste and quality drainage and blackwater.
blackwater Toxic impacts to biota
discharges and water column Drains/slops treatment system is designed to
DECC UK limit of monthly average 40mg/l oil discharge
meet oil content < 15 mg/l for discharge
overboard
Noise Drilling Disturbance to fish and Use of JNCC guidelines for piling activities Optimization of number of Drilling Centre
operations marine mammals Manifolds which will reduce scope of piling
Installation operations.
operations
Piling activities
Production
operations
Physical Presence Installation of Loss of access to other Notifications to Mariners circulated Snagfree (not overtrawlable) structures (see
new FPSO and sea users Locations of structures provided on admiralty charts/kingfisher Section 3.3.1.3)
seabed Benthic species and 500 m safety zone surrounding FPSO and Drill Centres
infrastructure habitat disturbance
Consent to locate will be obtained Additional area to be identified and notified to
mariners to cover FPSO mooring line area
Compliance with International Association of Lighthouse
beyond 500m safety zone
Authorities requirements
Guard and/or ERRV to cover additional area.
Emergency Response Rescue Vessel (ERRV) / Guard vessel
coverage
Disruption of Benthic species and Cuttings piles should not be impacted as subsea
cuttings piles habitat disturbance installation and drilling activities are not in the
area of historic cuttings piles at penguins.
Surface lay of the Brent area pipe section which
minimises disturbance to historic cuttings in this
area.
12-4
CONCLUSIONS

REQUIREMENTS
Unplanned Events Lifting activities Effects on other sea Certification for lifting equipment Dropped Objects Study
(Dropped Objects) users Lifting Procedures Pipe-in-pipe design for subsea pipelines – offer
Disturbance of benthic Permit to Work better protection from dropped objects
Dropped object reporting and recovery
and habitats
Oil Pollution Emergency Plan
Unplanned Events Vessel Effects on other sea Notifications to Mariners circulated Additional area to be identified and notified to
movement users 500 m safety zone enforced mariners to cover FPSO mooring line area
(Collision Risk)
Emergency Response Rescue Vessel (ERRV) / Guard vessel beyond 500m safety zone
coverage
Safety Case
Consent to locate will be obtained including vessel traffic survey
and collision risk assessment
Certified vessels (positioning systems, radar, communications
etc.)
Compliance with International Association of Lighthouse
Authorities requirements
Establishment of temporary safety zone Navigation risk
assessment
Marine operations manual
Adverse weather policy
Compliance with IALA requirements
SIMOPS Planning and Procedures
12-5
CONCLUSIONS

REQUIREMENTS
Unplanned Events Loss of Reduction in water Emergency Response Plan
containment – quality Oil Pollution Emergency Plan
(Chemical spill)
chemicals Bunkering procedures
and habitats Equipment maintenance and inspection
Tertiary containment e.g. bunds, drip trays
Trained personnel
Chemical Awareness Training
Monitoring and reporting of use and discharge
Subsea ROV inspection of umbilicals
Spill kits
Continuous flow and pressure monitoring on hydraulic systems
12-6
CONCLUSIONS

REQUIREMENTS
containment – Emergency Response Plan
well blowout Well design and management
(drilling /
Blow-out preventer when drilling
production) Toxic impact on species
Well cap containment system
and habitats
Well designs robust against cap and contain
Impact on offshore and Relief well planning
Adverse weather policy (stop drilling / disconnect)
areas
Well control procedures (including well examination scheme,
well integrity management system, over balance drilling, two
barrier policy)
Contractor selection to ensure certified contractors and
performance monitoring by procedure
Continuous flow monitoring of wells
Emergency Response Rescue Vessel (ERRV) / Guard vessel
coverage
SSSV and downhole safety valves
Pressure monitoring at wellheads
Well completion design optimised to prevent blowout during
production phase
12-7
CONCLUSIONS

REQUIREMENTS
containment – Ship Oil Pollution Emergency Plan (transit)
FPSO Cargo species and habitats Fire and explosion risk assessment
Tanks / cargo Emergency shutdown procedures
offloading Toxic impact on species
Gas monitoring
and habitats
Fire detection systems
Impact on offshore and Inert gas in tanks and wet to prevent pyrophoric scale
Cargo Oil Tanks (COTs) procedures
areas
Double skinned vessels
No bulkhead penetrations between COTs
Equipment maintenance
Hose testing and certification
Supply and tanker vessel specification
Marine breakaway coupling and emergency shutdown system
Contractor selection to ensure certified contractors and management
audits
Spill kits
Bunding containment
Leak detection system including communications between FPSO and
shuttle tanker during offloading
Waste Generation of Soil and ground water Waste Management Plan Environmental awareness training
hazardous and contamination Garbage management plan(s) and waste management and Shell UK wide programme to minimise
non-hazardous Use of space minimisation plan(s) will be developed.
packaging waste
waste Consignment waste and waste manifesting Contractor selection to
Climate change
ensure certified contractors
Reduction in air quality Waste segregation
Duty of care audit
12-8
CONCLUSIONS
Table 12.2 Planned Activities
PROJECT MAGNITUDE OF IMPACT ENVIRONMENTAL ASPECT AND SENSITIVITY RESIDUAL

ASPECT SIGNIFICANCE
Physical Presence
Presence of Small – limited to those from anchor handling, impacts Seabed (Features and Sediments) Negligible
installations, localised, and seabed and associated communities predicted
Low – The seabed in terms of its features and sediments are
vessels and to recover.
considered to have low sensitivity to impacts from the project
Anchoring footprint. The seabed shows isolated areas of contamination
Subsea Small – seabed disturbance impacts will be common to those but is largely representative of the wider area which is subject to Negligible
Infrastructure described above, the seabed infrastructure footprint will be historic and ongoing oil and gas development. The seabed
‘lost’ for at least the project lifetime, but this affected a small sediments are at a relatively remote deep water location and
part of the wider comparable seabed environment. support species of low to high conservation value in low
abundance. No habitats of conservation value have been
identified.
Presence of Small – limited to those from anchor handling, impacts Marine Habitats and Species Negligible
installations, localised, and seabed and associated communities predicted
Low – Most of the interaction between the Project and marine
vessels and to recover.
habitats and species will be at the seabed. The area does
Anchoring
support species of fish, seabird and marine mammals of low to
high importance but these are not expected to be affected by
Subsea Small – disturbance of the seabed and associated marine Negligible
vessel presence. The benthic species in the area are considered
Infrastructure habitats will be common to those described above, the seabed
of low to high importance and are characteristic of the wider
infrastructure footprint will be ‘lost’ for at least the project
area. They are found in low abundance. The supported species
lifetime, but this affected a small part of the wider comparable
are also subject to existing disturbance from existing oil and gas
seabed environment. Benthic communities in the wider
development and fishing activity.
disturbed area would be expected to recover within the
lifetime of the project.
12-9
CONCLUSIONS

ASPECT SIGNIFICANCE
Presence of Small - vessels and their associated activities or safety Other Marine Users Minor
installations, exclusion zones and the area influences by the mooring lines
Medium – The area is considered of low to moderate value to
vessels and will affect other marine users over a relatively small area
commercial fishing and is located within a wider area
Anchoring within the context of the wider marine environment. In
characterised by oil and gas development and moderate
addition the mitigation proposed to identify the risk presented
shipping activity. The sensitivity of other marine users and the
by the mooring lines should reduce the risk of negative effects.
commercial fishery to impacts from physical presence is
considered medium.
Subsea Small – the long term presence of seabed infrastructure will Minor
Infrastructure present an additional sea bed hazard, but will affect other
marine users over a small area within the context of the wider
marine environment and exiting oil and gas development.
The seabed infrastructure will be designed to minimise
snagging.
Discharges to Sea
Drilling Small – short term impact localised to the point of discharge. Water Quality Negligible
discharges Localised discharges and inert components of muds, cuttings
Low – The existing water quality in the Penguins area is
and cement.
expected to be good given its offshore location, away from
point source pollution. The area supports species of low to high
Installation & Small – relatively low toxicity effluent will disperse rapidly. Negligible
sensitivity in low abundance. The highly sensitive species are
commissioning Larger volumes leading to at most temporary, small, localised
transient within the project and surrounding area
Discharges effects.
Production Small to medium – produced water discharge near continuous Minor

discharges for the lifetime of the project but small scale with only small
change to baseline. Small discharges of other low toxicity
production chemicals will have localised effects to fauna within
a few tens of metres from the discharge point.
12-10
CONCLUSIONS

ASPECT SIGNIFICANCE
Drilling Small – localised smothering of sessile organisms from cuttings Marine habitats and Species Negligible
Discharges deposition, no toxic effects expected. Affected communities
Low – Most of the interaction between the Project and marine
expected to recover in 3-10 years.
habitats and species will be at the seabed. The area does
support species of fish, seabird and marine mammals of low to
high importance but these are not expected to be affected by
vessel presence on the surface. The benthic species in the area
are considered of low to high importance found in low
abundance. These species present are characteristic of the
wider area and are not unique. The area and supported
species are also subject to existing disturbance from other
development and fishing activity.
Atmospheric Emissions
Drilling Small – short term temporary impact localised to the points of Local air quality Negligible
discharge. Low – due to the absence of existing pollution sources in the
Installation & Small – short term temporary impact localised to the points of Penguins area, existing baseline pollutant concentrations are
Negligible
commissioning discharge. likely to be very low. This, together with the absence of sensitive
receptors, means that the area surrounding Penguins is
Production - Small – under normal operational conditions. However, considered to be of low sensitivity to atmospheric emissions. Negligible
operational combustion emissions as a result of the worst-case upset
combustion modelling scenario (diesel power generation combined with
emissions flaring) have the potential to result in temporary, localised
adverse effects.
12-11
CONCLUSIONS

ASPECT SIGNIFICANCE
Underwater Noise
Piling Low risk of behavioural effects beyond 1 km. No auditory Fish Negligible
injury >0.5 km
Low – Fish have varying sensitivity to noise that largely depends on
whether they have a swim bladder and whether the swim bladder is
connected to the inner ear. Their importance can be from low to high.
The species expected to be present within the Penguins area are
considered of low sensitivity.
No auditory injury >0.5 km. Fish Eggs and Larvae Negligible

Low – Fish eggs and larvae have a low sensitivity to noise.
Behaviour response 60 km from source using precautionary Low Frequency Cetaceans Moderate
and alternative criteria. No auditory injury >0.5 km.
High – Low frequency cetaceans have a high sensitivity to noise.
The species group is of high importance.
Behaviour response 60 km from source using precautionary Mid Frequency Cetaceans Moderate
criteria and 4.5 km from source using alternative criteria. No (precautionary),
High – Mid frequency cetaceans have a high sensitivity to noise. Negligible (alternative)
auditory injury >0.5 km.
The species group is of high importance.
Behaviour response 60 km from source using precautionary High Frequency Cetaceans Moderate
criteria and 44.5 km from source using alternative criteria. (precautionary), Minor
High – High frequency cetaceans have a high sensitivity to (alternative)
No auditory injury >0.5 km.
Behaviour response 30 km from source. No auditory injury Pinnipeds Negligible

>0.5 km.
12-12
CONCLUSIONS

ASPECT SIGNIFICANCE
Drilling Low to moderate risk of Behavioural response. Low risk of Fish with reduced or absent swim bladder Negligible
auditory injury.
Very low –Not sensitive to noise. The species group of low to high
importance.
Low to moderate risk of Behavioural response. Low risk of Fish with swim bladder not connected to inner ear Negligible
auditory injury.
Low – Low sensitivity to noise but species group is of high importance.
Moderate to high risk of Behavioural response. Low risk of Fish with swim bladder connected to inner ear Negligible
auditory injury.
Medium to high –Medium sensitivity to noise and species group is of
high importance.
Behaviour response 60 km (upper bound) and 1 km (lower Cetaceans Minor

High – Cetaceans have a high sensitivity to underwater noise. All
cetacean species groups are of high importance.
Behaviour response 60 km (upper bound) and 1 km (lower Pinnipeds Negligible

Medium – Seals have a medium sensitivity to noise. The species group
FPSO Low to moderate chance of Behavioural response. Low chance Fish with reduced or absent swim bladder Negligible
operation of auditory injury.
Very low –Not sensitive to noise. The species group of low to high
importance.
Low to moderate chance of Behavioural response. Low chance Fish with swim bladder not connected to inner ear Negligible
of auditory injury.
Low – Low sensitivity to noise but species group is of high importance.
12-13
CONCLUSIONS

ASPECT SIGNIFICANCE
Moderate to high chance of Behavioural response. Low Fish with swim bladder connected to inner ear Negligible
FPSO chance of auditory injury.
Medium to high –Medium sensitivity to noise and species group
operation
Behaviour response60 km (upper bound) and 0.5-5 km (lower Cetaceans Minor

bound) from the source. Auditory injury not exceeded.
All cetacean species group is of high importance.
Behaviour response 60 km (upper bound) and 0.5-5 km Pinnipeds Negligible

(lower bound). Auditory injury not exceeded.
12-14
CONCLUSIONS
Table 12.3 Accidental Hydrocarbon Releases
EVENT LIKELIHOOD CONSEQUENCE ENVIRONMENTAL

RISK
Well blowout Remote – Heard of previously Massive – Wide spread long-term degradation to the quality or availability of habitats and/or ALARP
in the industry; occurring every wildlife with recovery not expected for an extended period (>5 years) or that cannot be readily
10-5 to 10-3 years. rectified.
Major impact on the conservation objective(s) of internationally/ nationally protected sites,
habitats and populations.
Major transboundary effects expected.
Persistent severe environmental and socioeconomic damage that will lead to loss of
commercial, recreational use or loss of natural resources over a wide area of open water and
coastline.
Loss of stored Extremely Remote – Never Major – Widespread degradation to the quality or availability of habitats and/or wildlife ALARP
cargo oil heard of in the industry; requiring significant long-term restoration effort. Recovery likely within 2-5 years following
inventory occurring every < 10-5 years. clean up
Moderate-minor impact on the conservation objectives of internationally/nationally protected
sites, habitats or populations.
Transboundary effects expected.
Coastal and open water impacts on areas of social, economic, recreational and aesthetic
value.
12-15
ACRONYMS
ACRONYMS
AHV Anchor Handling Vessel
ALARP As Low As Reasonably Practicable
API American Petroleum Institute
ASCOBANS Agreement on Conservation of Small Cetaceans of the Baltic and North Seas
BAT Best Available Technique
BC Brent Charlie
BOP Blowout Preventer
BWMP Ballast Water Management Plan
CAPEX Capital Expenditure
CCS Carbon Capture and Storage
CEFAS Centre for Environment, Fisheries and Aquaculture Science
CHARM Chemical Hazard Assessment and Risk Management
CHIP Chemical (Hazard Information and Packaging for Supply)
CO Carbon Monoxide
CoP Cessation of Production
CO2 Carbon Dioxide
COLREGS International Regulations for Preventing Collisions at Sea
DC Drilling Centre
DECC Department of Energy and Climate Change
DEFRA Department for Environment, Food and Rural Affairs
DG Decision Gate
DLE Dry Low Emissions
DNV Det Norske Veritas – a certification body and classification society
DP Dynamically Positioned
DPN Disused Pipeline Notification
DRB Decision Review Board
i
ACRONYMS
DSV Diving Support Vessel
DTI Department of Trade and Industry
EC European Commission
EEC European Economic Community
EEMS Environmental Emissions Monitoring System
EEZ Exclusive Economic Zone
EGCS Exhaust Gas Cleaning Systems
EHS Environment, Health, Safety
EIA Environmental Impact Assessment
EMS Environmental Management System
ENVID Environmental Impact Identification
EPC Engineering and Procurement Contractor
EPS European Protected Species
ERP Emergency Response Plan
ERRV Emergency Response and Rescue Vessel
ES Environmental Statement
EU European Union
EU ETS European Union Emissions Trading Scheme
EUNIS European Natural Information System
FCG Flooding, Cleaning and Gauging
FDP Field Development Plan
FEED Front End Engineering Design
FEPA Food and Environmental Protection Act
FFLB Free Fall Life Boat
FLAGS Far North Liquids and Associated Gas System
FPSO Floating, Production Storage and Offloading
GC Gas Chromatography
ii
ACRONYMS
GHG Greenhouse Gas
HC Hydrocarbon
H2S Hydrogen Sulphide
HASS High Activity Sealed Source
HLV Heavy Lift Vessel
HP High Pressure
HSE Health, Safety and Environment
HSSE Health, Safety, Security and Environment
HSSE & SP Health, Safety, Security, Environment and Social Performance
IA Impact Assessment
ICES International Council for the Exploration of the Sea
IFC International Finance Corporation
IG Inert Gas
IMO International Maritime Organisation
IOPP International Oil Pollution Prevention
IPPC Integrated Pollution Prevention Control
IPR Interim Pipeline Regime
ISO International Organisation for Standardisation
ITOPF International Tanker Owners Pollution Federation
IUCN International Union for Conservation of Nature
JNCC Joint Nature Conservation Committee
JV Joint Venture
KO Knock-Out
LAT Lower Astronomical Tide
LP Low Pressure
LQ Living Quarters
LSA Low Specific Activity
iii
ACRONYMS
LTOBM Low Toxicity Oil Based Mud
MARPOL International Convention for the Prevention of Pollution from Ships
MAT Master Application Template
MCA Maritime Coastguard Agency
MCAA Marine and Coastal Access Act
MDAC Methane-derived authigenic carbonate
MEG Monoethylene Glycol
MODU Mobile Offshore Drilling Unit
MPA Marine Protected Area
MT Metric Tonnes
MW Megawatts
NB North Brent
NIMR Norwegian Institute of Marine Research
NOFO Norsk Oljevernforening for Operatørselskap (Norwegian Clean Seas

Association for Operating Companies)
NORM Naturally Occurring Radioactive Materials
NOx Oxides of Nitrogen
NPD Naphthalene, Phenanthrene, Anthracene and Dibenziothene
O&G UK Oil and Gas United Kingdom
OBF Oil Based Fluids
OBM Oil Based Mud
OCNS Offshore Chemical Notification Scheme
OESEA Offshore Energy Strategic Environmental Assessment
OIM Offshore Installation Manager
OIW Oil In Water
OPEP Oil Pollution Emergency Plan
OPEX Operational Expenditure
iv
ACRONYMS
OPF Organic-Phase Drilling Fluid
OPPC The Offshore Petroleum Activities (Oil Pollution Prevention and Control)
Regulations 2005
OPRC The Merchant Shipping (Oil Pollution Preparedness, Response Co-operation

Convention) Regulations 1998
OSCAR Oil Spill Contingency and Response – Oil spill modelling tool
OSPAR Oslo and Paris Convention for the Protection of the Marine Environment of the
North East Atlantic
OSRL Oil Spill Response Limited
PAH Polycyclic Aromatic Hydrocarbons
PBR Polished Bore Receptacle
PETS Portal Environmental Tracking System
PLEM Pipeline End Manifold
PLET Pipeline End Terminus
PMF Priority Marine Features
PON Petroleum Operations Notices
POPA Prevention of Oil Pollution Act
PPC Pollution Prevention Control
PPD Public Participation Directive
PSV Platform Supply Vessel
PW Produced Water
PWA Pipeline Works Authorisation
PWRI Produced Water Reinjection
RAM Risk Assessment Matrix
RBM Riser Base Manifold
REACH Registration, Evaluation, Authorisation & Restriction of Chemicals Regulations
ROV Remotely Operated Vehicle
RSA Radioactive Substances Act
v
ACRONYMS
SAC Special Areas of Conservation
SAHFOS Sir Alistair Hardy Foundation for Ocean Science
SATS Subsidiary Application Templates
SCM Subsea Control Modules
SCSSV Surface Controlled Subsurface Safety Valve
SD Sustainable Development
SEPA Scottish Environmental Protection Agency
SFF Scottish Fishermen’s Federation
SMRU Sea Mammals Research Unit
SNH Scottish National Heritage
SOPEP Shipboard Oil Pollution Emergency Plan
SOSREP Secretary of State Representative
SOx Oxides of Sulphur
SSIV Subsea Isolation Valve
TBT Tributylin
UHC Unburned Hydrocarbon
UK United Kingdom
UKCS United Kingdom Continental Shelf
UKOPP United Kingdom Oil Pollution Prevention
UNESCO United Nations Educational, Scientific and Cultural Organisation
UPS Un-interruptible Power Source
UTA Umbilical Termination Assembly
UTI Utility Area
UTS Umbilical Terminal Server
VOC Volatile Organic Compounds
VRU Vapour Recovery Unit
WBM Water Based Mud
vi
ACRONYMS
WEEE Waste Electrical and Electronic Equipment
WHR Waste Heat Recovery
WTN Waste Transfer Notes
vii
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iv
APPENDIX A
SUMMARY OF ENVIRONMENTAL
LEGISLATION
APPENDIX A SUMMARY OF ENVIRONMENTAL LEGISLATION
A. SUMMARY OF ENVIRONMENTAL LEGISLATION (UK AND INTERNATIONAL)

Table A-1 Summary of Environmental Legislation
REGULATORY
LEGISLATION SUMMARY OF REQUIREMENTS AND PROJECT IMPLICATIONS
BODY
GENERAL
The MARPOL Convention is the main international convention covering prevention of pollution of the marine
environment by ships from operational or accidental causes and covers pollution by oil, chemicals, and harmful
substances in packaged form, sewage and garbage.
The Convention currently includes six technical Annexes:
 Annex I Regulations for the Prevention of Pollution by Oil (entered into force 2 October 1983);
Maritime and
 Annex II Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk (entered into force 2
Coastguard MARPOL 73/78
October 1983);
Agency
 Annex III Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form (entered into force 1 July
1992);
 Annex IV Prevention of Pollution by Sewage from Ships (entered into force 27 September 2003);
 Annex V Prevention of Pollution by Garbage from Ships (entered into force 31 December 1988); and
 Annex VI Prevention of Air Pollution from Ships (entered into force 19 May 2005).
Part 1 of the Energy Act 2008 introduces two new licensing regimes for the storage and unloading of
combustible gas and the permanent storage of carbon dioxide. These regulations amend the following pieces of
legislation to include carbon capture and storage (CCS):
The Energy Act 2008
 Offshore Petroleum Production and Pipe-lines (Assessment of Environmental Effects) Regulations 1999;
(Consequential
 Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001;
DECC Modifications) (Offshore
 Offshore Marine Conservation (Natural Habitats, &c.) Regulations 2007;
Environmental
 Offshore Combustion Installations (Prevention and Control of Pollution) Regulations 2001;
Protection) Order 2010
 Offshore Chemicals Regulations 2002;
 Offshore Installations (Emergency Pollution Control) Regulations 2002;
 Greenhouse Gases Emissions Trading Scheme Regulations 2005;
A-1
REGULATORY
BODY
 Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005;
 REACH Enforcement Regulations 2008; and
 Fluorinated Greenhouse Gases Regulations 2009.
Annex VI is concerned with the control of emissions of ozone depleting substances, NOx, SOx, and VOCs and
require ships (including platforms and drilling rigs) to be issued with an International Air Pollution Certificate
following survey.
This annex set limits on sulphur oxide and nitrogen oxide emissions from ship exhausts as well as particulate
Maritime and MARPOL 73/78 Annex VI the matter and prohibit deliberate emissions of ozone depleting substances.
Coastguard Prevention of Air Pollution from Emissions arising directly from the exploration, exploitation and associated offshore processing of seabed
Agency Ships mineral resources are exempt from Annex VI, including the following:
 Emissions resulting from flaring, burning of cuttings, muds, well clean-up emissions and well testing;
 Release of gases entrained in drilling fluids and cuttings;
 Emissions from treatment, handling and storage of reservoir hydrocarbons; and
 Emissions from diesel engines solely dedicated to the exploitation of seabed mineral resources.
Petroleum Act 1998 The objective of this Act is to conserve gas, as a finite energy resource, by avoiding unnecessary wastage during
The Petroleum (Current Model the production of hydrocarbons in the UKCS. The actual Model Clause may vary depending on when the Block
DECC
Clauses) Order 1999 Licence was granted, but in recent licences flaring is covered by Paragraph 3 of Model Clause 21, and this states
that the Licensee shall not flare any gas from the licensed area or use gas for gas lift except with written consent.
This Act is mostly used for issue of vent consents, although it also covers some flaring which has not been
DECC The Energy Act 1976
permitted under licence model clauses.
There regulations transpose EC Directive on national emission ceilings for certain atmospheric pollutants
2001/81/EC into UK law and set national ceilings and a requirement for the development of a reduction
The National Emission Ceilings
programme for SOx, NOx and VOCs and set out the UK government commitment for achieving a reduction of
Regulations 2002
atmospheric emissions by 2010 and thereafter not to exceed the amounts specified in the Schedule of that
pollutant.
A-2
REGULATORY
BODY
These regulations implement Annex VI of MARPOL (the International Convention for the Prevention of Pollution
The Merchant Shipping from Ships 73/78) in the UK.
(Prevention of Air Pollution
from Ships) Regulations 2008 The 2010 Amendments primarily implement provisions concerning the sulphur content of marine fuels contained
(as amended 2010) in Council Directive 1999/32/EC. The Directive sets maximum sulphur content for fuel including heavy fuel oil
and gas oil including marine fuel.
The Act sets up a framework for the UK to achieve its long-term goals of reducing greenhouse gas emissions and
to ensure actions are taken towards adapting to the impact of climate change. The Act enables a number of
Climate Change Act 2008 elements, including amongst others; setting medium and long-term emissions reduction targets in statute,
introduction of a system of carbon budgeting which constrains the total amount of emissions in a given time
Climate Change (Scotland) Act period, a new reporting framework for annual reporting of the UK’s greenhouse gas emissions, creation of an
2009 independent advisory body (the Committee on Climate Change). As a result of the Act and the 2009 Order, the
current legally-binding targets for the net UK carbon account are: 34% reduction by 2020 and 80% reduction by
2050, against a 1990 baseline.
Offshore Combustion
Installations (Prevention and
Control of Pollution) These regulations implement Council Directive 96/61/EC concerning integrated pollution prevention and control
Regulations 2001 as amended (IPPC) in the context of offshore oil and gas combustion installations. The aim of IPPC is to consider
by: environmental impacts holistically and to achieve a higher level of environmental protection. The Regulations
Energy Act 2008 apply only to combustion installations with a combined rated thermal input exceeding 50 MW(th) and a PPC
(Consequential Modifications) Permit will be required in order to operate a qualifying offshore installation. The permit will be granted with
DECC (Offshore Environmental conditions that include provisions based on best available techniques, emission limits, and monitoring
Protection) Order 2010) requirements.
EU Emissions Trading Scheme The 2007 Amendment Regulations implement the amendments made to EC Directive 96/61 by the Public
(EU Directive 2003/87/EC) Participation Directive 2003/35/EC and bring in tighter requirements for public consultation as part of the
UK Emissions Trading Scheme permit application process.
as amended
Offshore Combustion
Installations (Prevention and
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Control of Pollution)
(Amendment) Regulations 2007
The objective of these Regulations is to reduce the emissions of fluorinated gases including hydrofluorocarbons,
perfluorocarbons and sulphur hexafluoride as covered by the Kyoto Protocol. These gases have been developed
The Fluorinated Greenhouse to replace ozone depleting substances such as CFCs and HCFCs but are long-lived powerful greenhouse gases.
DECC
Gases Regulations 2009 The Regulations include requirements on the leakage detection and labelling requirements of systems such as
refrigeration systems, air-conditioning units and heat pumps that use these gases. Fluorinated gases are also
used for firefighting offshore
The Environmental Protection The 2011 regulations revoke and replace the previous regulations. These Regulations make provision in the UK
DECC (Controls on Ozone Depleting for EC Regulation 1005/2009 which controls the production, impact, export, placing on the market, recovery,
Substances) Regulations 2011 recycling, reclamation and destruction of substances that deplete the ozone layer.
Directive 2003/87/EC of the
European Parliament and the
Council of 13 October 2003
establishing a scheme for
greenhouse gas emission
allowance trading within the The European Union Emissions Trading Scheme (EU ETS) is one of the primary drivers for reducing carbon
Community and amending dioxide emissions within the EU by introducing a cost element.
Council Directive 96/61/EC. A permit to emit greenhouse gases (at present only carbon dioxide) must be obtained for qualifying installations
DECC – for the upstream oil & gas industry, this applies to stationary installations with a combined rated thermal input
The Greenhouse Gas Emissions of >20 MW(th) and flaring. In practice this generally means that production platforms will require a permit
Trading Scheme Regulations whereas mobile drilling units are at present exempt. The Regulations are being implemented in stages; Phase I
2005 (as amended 2007) has been implemented and Phase II is currently in operation. Phase III will be in force during 2013-2020.
The Carbon Accounting

Regulations 2009
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The Greenhouse Gas Emissions
Data and National
Implementation Measures
Regulations 2009
ENVIRONMENTAL IMPACT ASSESSMENT
Council Directive on the The EIA Directive (85/337/EEC) is in force since 1985 and applies to a wide range of defined public and
Assessment of the Effects of private projects, which are defined in Annexes I and II:
Certain Public and Private Annex 1: all projects listed in Annex I are considered as having significant effects on the environment and
Activities on the Environment - require a mandatory EIA. Typical projects include, for example:
85/337/EEC (the EIA Directive)  Extraction of petroleum and natural gas for commercial purposes where the amount extracted exceeds 500
as amended by Directives tonnes/day in the case of petroleum and 500 000 cubic metres/day in the case of gas.
97/11/EC, 2003/35/EC and
 Pipelines with a diameter of more than 800 mm and a length of more than 40 km:
2009/31/EC
o for the transport of gas, oil, chemicals; and
o for the transport of carbon dioxide (CO 2 ) streams for the purposes of geological storage, including
associated booster stations.
Installations for storage of petroleum, petrochemical, or chemical products with a capacity of 200 000 tonnes or
more.
Annex 2: EIA is discretionary with the national authorities decide whether an EIA is needed. This is done by the
"screening procedure", which determines the effects of projects on the basis of thresholds/criteria or a case by
case examination.
DECC The Offshore Petroleum These Regulations implement the EIA Directive with regard to the offshore oil and gas industry. The Regulations
Production and Pipe-lines require an environmental impact assessment (EIA) and the associated public consultation document
(Assessment of Environmental (Environmental Statement (ES)) to be submitted for certain projects, these are:
Effects) Regulations 1999 (as Developments which will produce 500 tonnes (approximately 3,750 barrels) or more per day of oil or 500,000
amended 2007) (as amended cubic metres or more per day of gas (not including well testing).
by the Energy Act
(Consequential Modifications) Pipelines of 800mm diameter and 40 kilometres or more in length.
(Offshore Environmental Other activities are subject to a discretionary process where either an ES or a PON15 (seeking a Direction that
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Protection) Order 2010) an ES is not required) needs to be submitted. Typically this discretionary approval covers:
The drilling of all wells
Developments, either stand-alone or incremental, producing less than 500 tonnes of oil per day or 500,000
cubic metres of gas per day
Construction of pipelines of less than 800mm diameter and 40 kilometres in length
Revised guidance relating to Environmental Submissions was issued by DECC on the 21st of July 2011
highlighted changes that have been made to relevant regulations following the Gulf of Mexico incident.
The guidance highlighted the fact that EIAs must include a detailed assessment of the potential environmental
impact of a hydrocarbon release, broadly based on OPEP (Oil Pollution Emergency Plan) requirements but
including significant additional information to the mitigation measures in place to prevent and the potential
environmental impacts of the release.
Following enactment of the Energy Act 2008 (Consequential Modifications) (Offshore Environmental Protection)
Order 2010, the provisions of the Offshore Petroleum Production and Pipe-lines (Assessment of Environmental
Effects) Regulations 1999 (as amended 2007) now also apply to gas unloading and storage as they do to oil
and gas activities
OSPAR Recommendation The purpose of this Recommendation is to support the protection and conservation of species and habitats on the
2010/5 on assessments of OSPAR List of threatened and/or declining species and habitats, through assessments of environmental impacts
environmental impact in of human activities. When assessments of environmental impacts of human activities that may affect the marine
relation to threatened and/or environment of the OSPAR (Oslo and Paris Conventions) maritime area are prepared, Contracting Parties should
declining species and habitats ensure they take account of the relevant species and habitats on the OSPAR List of threatened and/or declining
species and habitats (OSPAR Agreement 2008/6).
ACCESS TO ENVIRONMENTAL INFORMATION AND PUBLIC PARTICIPATION
Directive 2003/4/EC of the This Directive transposes the first pillar of the Aarhus convention on access to information into EU legislation.
European Parliament and of the This Directive requires all public authorities to provide members of the public with access to environmental
Council of 28 January 2003 on information, and to actively disseminate the environmental information they hold. The information must be
public access to environmental provided to any person at their request, without them having to prove an interest and at the latest within two
information and repealing months of the request being made. The Directive is implemented in Scotland by The Environmental Information
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Council Directive 90/313/EEC (Scotland) Regulations 2004.
The Environmental Information

(Scotland) Regulations 2004
Public Participation Directive Provides for public participation in the preparation of environmental plans, programmes and projects with
2003/35/EC significant environmental impacts
CONSERVATION AND BIODIVERSITY
DECC, JNCC, The Offshore Marine These Regulations make provision for implementing the Birds Directive and Habitats Directive in relation to
SNH, DEFRA Conservation (Natural Habitats, marine areas where the United Kingdom has jurisdiction beyond its territorial sea. The Regulations make
&c.) Regulations 2007 as provision for the selection, registration and notification of sites in the offshore marine area (European Offshore
amended (2010) Marine Sites) and for the management of these sites. Competent authorities are required to ensure that steps are
taken to avoid the disturbance of species and deterioration of habitat in respect of the offshore marine sites and
that any significant effects are considered before authorisation of certain plans or projects. Provisions are also in
place for issuing of licences for certain activities and for undertaking monitoring and surveillance of offshore
marine sites. The 2010 Amendment Regulations make various insertions for new enactments (e.g. new Birds
Directive) and also devolve certain powers to Scottish Ministers. Most recent amendments to the 2007 and 2010
regulations are:
The Conservation (Natural Habitats, &c.) Amendment (Scotland) Regulations 2011
The Conservation of Habitats and Species (Amendment) Regulations 2011.
The Offshore Petroleum Secretary of State set out these Regulations to consider whether a “Habitats Regulatory Assessment” should be
Activities (Conservation of undertaken prior to granting a licence under the Petroleum Act 1998. The 2007 amendments also extend this
Habitats) Regulations 2001 as requirement to all UK waters. These regulations implement European Directives for the protection of habitats and
amended 2007 species in relation to oil and gas activities carried out in whole or in part on the UKCS. In particular these are
the Council Directive 92/43 on the conservation of natural habitats, wild fauna and flora and Council Directive
79/409 on the conservation of wild birds. The 2007 amendments extend the requirements to all UK waters.
Marine and Coastal Access Act These two Acts introduce a framework for the development of a new planning system for the marine area and
2009 ensure greater protection for the marine environment and biodiversity. However, oil and gas activities are
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generally exempted from the Act(s) since an environmental regime/regulator is already in place under DECC.
Marine (Scotland) Act 2010 However the Act(s) will apply to a number of activities e.g: removal of materials from the seabed (including
structures), deposit of materials during decommissioning, disturbance of the seabed, use of explosives and
installation of certain types of cables. DECC will retain responsibility for offshore installation enforcement
activities, and the Marine Management Organisation & Devolved Authorities will take responsibility for "at sea"
enforcement of oil and gas activities.
EMERGENCY RESPONSE
DECC The Offshore Installations These Regulations entered into force in July 2002 and implement the recommendations from Lord Donaldson's
(Emergency Pollution Control) review of “Salvage and Intervention and their Command and Control” insofar as they relate to the oil and gas
Regulations 2002 industry. The Regulations give the Representative of the Secretary of State for Energy and Climate Change
(as amended by the Energy Act (SOSREP) powers to intervene in the event of an incident involving an offshore installation where there is, or may
(Consequential Modifications) be, a risk of significant pollution, or where an operator is failing or has failed to implement effective control and
(Offshore Environmental preventative operations.
Protection) Order 2010) The Energy Act (Consequential Modifications) (Offshore Environmental Protection) Order 2010 amend these
regulations to extend to accidents resulting from carbon capture and storage (CCS).
The Offshore Petroleum Under these Regulations, it is an offence to make an unlawful discharge of oil, i.e. a discharge of oil other than
Activities (Oil Pollution in accordance with the permit granted under these Regulations for oily discharges (e.g. produced water etc.).
Prevention and Control) However, it will be a defence to prove that the contravention arose because of something that could not have
Regulations 2005 (as amended been reasonably prevented, or that it was due to something done as a matter of urgency for the purposes of
2011) (as amended by the securing the safety of any person.
Energy Act (Consequential The Energy Act (Consequential Modifications) (Offshore Environmental Protection) Order 2010 amend these
Modifications) (Offshore regulations to extend to carbon sequestration activities.
Environmental Protection)
Order 2010)
OSPAR Recommendation This recommendation came into force in September 2010 and establishes a process for assessing the relevance
2010/18 on the prevention of of the results of the US and EC reviews of the Macondo well incident with a view to taking additional action by
significant acute oil pollution the OSPAR Commission if needed and within the scope of the Convention.
from offshore drilling activities
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Under the recommendation, contracting parties are required to:
 As a precaution continue or, as a matter of urgency, start reviewing existing frameworks, including the permitting of
drilling activities in extreme conditions; and continue to evaluate this on a case by case basis and prior to
permitting;
 Take extra care to apply all relevant learning from the Deepwater Horizon accident;
 Report on this ongoing activity to OSPAR; and
 Based on the reviews undertaken, contracting parties should individually and jointly, if needed, take further action
within the scope of the OSPAR Convention.
Merchant Shipping Act 1995 The Merchant Shipping Act 1995 implements in the UK the OPRC Convention. The aim of the OPRC Convention
is to increase the level of effective response to oil pollution incidents and to promote international co-operation to
this end. The Convention applies to ships and offshore installations and requires operators to have in place Oil
Pollution Emergency Plans (OPEP), which are approved by the body that is the National Competent Authority for
the Convention.
The Merchant Shipping (Oil The Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998
Pollution Preparedness, introduce into UK law the oil spill planning requirements and legal oil spill reporting requirements of the OPRC
Response and Co- Convention.
operation)Regulations 1998 (as
amended 2001)
ENVIRONMENTAL LIABILITY
Directive 2004/35/CE of the The Environmental Liability Directive enforces strict liability for prevention and remediation of environmental
European Parliament and the damage to ‘biodiversity’, water and land from specified activities and remediation of environmental damage for
Council of 21 April 2004 on all other activities through fault or negligence.
environmental liability with
regard to the prevention and
remedying of environmental
damage.
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SEPA, MS and The Environmental Liability These Regulations implement the EC Environmental Liability Directive in Scotland. The regulations oblige
SNH (Scotland) Regulations 2009 as operators of certain activities to take preventative measures where there is an imminent threat of environmental
amended 2011 damage, and to remediate any environmental damage caused by their activities.
CHEMICALS, DRAINAGE AND OILY DISCHARGES
DECC, Marine The Offshore Chemicals The Offshore Chemicals Regulations 2002 implement the OSPAR Decision (2000/2) and OSPAR
Scotland, Regulations 2002 (as amended Recommendations (2000/4 and 2000/5) introducing a Harmonised Mandatory Control System for the use and
CEFAS 2011) reduction of the discharge of offshore chemicals. The Regulations introduced a permit system for the use and
discharge of chemicals offshore and include a requirement for site specific risk assessment. Chemicals used
offshore must be notified through the Offshore Chemical Notification Scheme (OCNS) and chemicals are ranked
by hazard quotient, using the CHARM model. Applications for permits are made via the submission of the
relevant PON15 (i.e. chemicals for drilling: PON 15B; pipelines: PON 15C; production: PON 15D;
decommissioning: PON 15E; and workovers and well interventions: PON 15F).
Amendments in 2011 to the Offshore Chemicals Regulations and the Offshore Petroleum Activities (Oil Pollution
Prevention and Control) Regulations 2010. The principal aim is to make unlawful unintentional releases of
chemicals and oil that arise through accidents / non-operational discharges by broadening accordingly the
definitions of "offshore chemical" and "discharges" and incorporating a new concept of "release".
Convention for the Protection of The OSPAR Convention (in particular Annex III) is the main driver for reductions in oily discharges to the North
the Marine Environment of the Sea. The UK as a contracting party to the Convention is therefore obliged to implement any Decisions and
North East Atlantic 1992 Recommendations made by the Commissions. Certain decisions made under the earlier Paris Convention also
(OSPAR Convention) still stand.
OSPAR Decision 2000/3 on OSPAR Decision 2000/3 that came into effect on 16 January 2001 effectively eliminates the discharge of
the Use of Organic-Phase organic phase fluids (OPF) (oil based (OBM) or synthetic based (SBM) drilling fluids) or cuttings contaminated
Drilling Fluids (OPF) and the with these fluids. Use of OPF is still allowed provided total containment is operated. The use of diesel-oil-based
Discharge of OPF- drilling fluids is prohibited. The discharge of whole OPF to the sea is prohibited. The mixing of OPF with
Contaminated Cuttings cuttings for the purpose of disposal is not acceptable. The discharge of cuttings contaminated with oil based
fluids (OBF) (includes OBM and SBM) greater than 1% by weight on dry cuttings is prohibited. The use of OPF in
the upper part of the well is prohibited. Exemptions may be granted by the national competent authority for
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OSPAR Recommendation geological or safety reasons.
2006/5 on a Management The discharge into the sea of cuttings contaminated with synthetic fluids will only be authorised in exceptional
Regime for Offshore Cuttings circumstances. Authorisations to be based on the application of BAT/BEP. Best Available Techniques described
Piles. within the Decision include recycling, recovery and reuse of muds.
The OSPAR 2006/5 Recommendation sets out measures to reduce pollution from oil or other chemicals from
cuttings piles.
DECC, Marine The Merchant Shipping These Regulations give effect to Annex I of MARPOL 73/78 (prevention of oil pollution) in UK waters and have
Scotland, (Prevention of Oil Pollution) been amended by the Merchant Shipping (Implementation of Ship-Source Pollution Directive) Regulations 2009
CEFAS Regulations 1996 (as amended) described above. They address oily drainage from machinery spaces on vessels and installations. The North
Sea is designated a “Special Area”, within which the limit for oil in discharged water from these sources is
15ppm. Vessels and installations are required to hold a valid UKOPP (UK Oil Pollution Prevention) or IOPP
(International Oil Pollution Prevention Certificate). Vessels and drilling rigs are also required to hold a current,
approved Shipboard Oil Pollution Emergency Plan (SOPEP) which is in accordance with guidelines issued by the
Marine Environment Protection Committee of the International Maritime Organisation (IMO).
Merchant Shipping Act 1995 Arrangements for Survey and Certification Part VI of the Merchant Shipping Act, 1995 makes provision for the
prevention of pollution from ships. It implements in the UK the requirements of the International Convention for
the Prevention of Pollution from Ships (MARPOL) 73/78. MARPOL defines ships to include offshore installations
International Convention for the
and relevant provisions of MARPOL are applied to offshore installations. Annex 1 of MARPOL relates to
Prevention of Pollution from
prevention of oil pollution and has provisions for machinery space drainage that are applied to offshore
Ships (MARPOL) 73/78
platforms:
Vessels of 400 GT or above (which includes FPSO’s and MODU’s) are permitted to discharge processed water
(i.e. Oily Drainage Water) from Machinery Space Drainage as long as the oil content without dilution, does not
exceed 15 ppm of the oil in water.
PARCOM Recommendation The PARCOM Recommendation 86/1 provision of a 40 mg/l performance standard for platforms is applicable,
86/1 of a 40 mg/l Emission and remains in force for discharges of displacement water, drainage water and ballast water, which are not
Standard for Platforms covered under MARPOL. The maximum concentration of dispersed oil must not exceed 100 mg/l at any time.
The REACH Enforcement These enforce Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals which require chemical users to demonstrate
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Regulations 2008 the safe manufacture of chemicals and their safe use throughout the supply chain. Under REACH, the users of
chemicals as well as their manufacturers and importers have a responsibility to ensure that the risks to both
human health and the environment are adequately assessed.
DECC, Marine The Offshore Petroleum These Regulations replaced the Prevention of Oil Pollution Act 1971 (“POPA”) and are a mechanism to continue
Scotland, Activities (Oil Pollution implementation on the UKCS of OSPAR Recommendation 2001/1.
CEFAS Prevention and Control) Discharges of reservoir oil associated with drilling from a mobile offshore drilling unit (MODU) must be covered
Regulations 2005 (as amended by an OPPC Term Permit, whereas discharges from a production installation are covered by an OPPC Life Permit.
2011) Operators are required to regularly report actual oil discharge in order that adequate monitoring can be
achieved.
These regulations do not apply to those discharges regulated under the Offshore Chemicals Regulations 2002,
the Merchant Shipping (Prevention of Oil Pollution) Regulations 1996 (as amended) or the Merchant Shipping
(Prevention of Pollution by Sewage and Garbage from Ships) Regulations 2008.
Amendments in 2011, via the Offshore Chemicals Regulations and the Offshore Petroleum Activities (Oil
Pollution Prevention and Control) Regulations 2010 introducing new concept of “release “ and “ offshore
installation” which encompasses all pipelines .
The concentration of dispersed oil in produced water discharges as averaged over a monthly period must not
exceed 30mg/l, whereas the maximum permitted concentration must not exceed 100mg/l at any time. The
quantity of dispersed oil in produced water discharged must not exceed 1 tonne in any 12 hour period.
TERRITORIAL WATERS
Territorial Sea Act 1987
Defines the extent of the territorial sea adjacent to the British Islands.
Territorial Waters Order
BALLAST WATER
MCA International Convention for the Objective to prevent, minimise and ultimately eliminate the transfer of harmful aquatic organisms and pathogens
Control and Management of though control and management of ships’ ballast water and sediments. Helsinki and OSPAR Commissions
Ships' Ballast Water and General Guidance on the Voluntary Interim has set out an application of the D1 Ballast Water Exchange
Sediments (BWM) – adopted Standard.
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2004 Under this regulation, all tankers > 150 GRT and all ships > 400 GRT.in the UK are required to have in place
United Kingdom Oil Pollution Prevention Certificate (UKOPP) or IOPP Certificate and Ballast Water Exchange
Management plan. It is required all vessels entering the North East Atlantic to exchange the ballast water at least
200mn from the nearest land and at least 200 metres deep.
WASTE HANDLING AND DISPOSAL
International Convention for the Annex V: Prevention of pollution by garbage from ships (entered into force December 1998). Deals with the
Prevention of Pollution from different types of garbage and specifies the distances from land and the manner in which they may be disposed
Ships (MARPOL) 1973 Annex of. The Annex also designates Special Areas (including the North Sea) where the disposal of any garbage is
V, as amended prohibited except food wastes. The dumping of plastics at sea is also prohibited by this Annex.
SEPA Environmental Protection Act This Act, and associated regulations, introduces a “Duty of Care” for all controlled wastes. Waste producers are
1990 required to ensure that wastes are identified, described and labelled accurately, kept securely and safely during
storage, transferred only to authorised persons and that records of transfers (waste transfer notes) are maintained
for a minimum of two years. Carriers and waste handling sites require licensing. This Act and associated
Regulations brought into effect a system of regulation for “controlled waste”. Although the Act does not apply to
offshore installations, it requires operators to ensure that offshore waste is handled and disposed of onshore in
accordance with the “Duty of Care” introduced by the Act.
Directive 2008/98/EC of the
The European Parliament introduced a new Directive, 2008/98/EC, on waste and repealing certain Directives.
European Parliament and of the
The Directive lays down measures to protect the environment and human health by preventing or reducing the
Council of 19 November 2008
adverse impacts of the generation and management of waste and by reducing overall impacts of resource use
on waste and repealing certain
and improving efficiency of such use.
Directives.
The 2011 Scotland Regulations make a number of amendments to a variety of Scottish waste legislation to
transpose aspects of Directive 2008/98/EC on waste into Scottish law.
The Waste (Scotland)
Regulations 2011
The Environment Protection Under these Regulations any person who imports, produces, carries, keeps, treats or disposes of Controlled
(Duty of Care) Regulations Waste has a duty to take all reasonable steps to ensure that their waste is handled lawfully and safely.
1991 Special/Hazardous Waste is a sub-category of Controlled Waste (see also Special Waste Regulations)
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The Controlled Waste This legislation does not strictly apply offshore. However, because the offshore disposal of garbage is prohibited
Regulations 1992 (as amended) then all wastes must be transferred to shore for disposal. Once onshore, the wastes must meet the requirements
SEPA of onshore legislation when being disposed of. These regulations must therefore be considered offshore to allow
onshore requirements to be met, for example the identification and appropriate documentation of these wastes.
These regulations define household, industrial and commercial waste for waste management licensing purposes.
SEPA Food and Environment A licence is required under FEPA for any waste disposal in the sea or under the seabed. However, the Deposits
Protection Act 1985 in the Sea (Exemptions) Order 1985 exempts from FEPA licensing the deposit on site or under the seabed of any
chemicals and drill cuttings.
However, export of cuttings to another field for re-injection will require a licence under FEPA
The Merchant Shipping These Regulations implement Directive 2005/35/EC of the European Parliament and of the Council of 7th
(Implementation of Ship-Source September 2005 on ship-source pollution and on the introduction of penalties for infringements. The Directive
Pollution Directive) Regulations aims to achieve better enforcement of the requirements of the International Convention for the Prevention of
2009 Pollution from Ships, 1973 (MARPOL 73), as modified by the Protocol of 1978 (MARPOL 73/78).
The Merchant Shipping These Regulations implement the requirements of MARPOL 73/78 Annex IV in the UK
(Prevention of Pollution by These regulations apply to vessels including fixed or floating platforms which operate in the marine environment
Sewage and Garbage from and came into force on 01 February 2009. They lay out the requirements for sewage system surveys and
Ships) Regulations 2008 (as certification and the requirements of sewage systems with an exception for fixed installations at a distance of
amended 2010) more than 12 nautical miles from the nearest land. They also identify the requirements for a garbage
management plan, garbage record books and prohibit the disposal of various types of garbage into the marine
environment and define enforcement action. The 2010 Amendments correct drafting errors.
SEPA The Special Waste Regulations These Regulations make provision for handling special waste and for implementing Council Directive
1996 as amended 91/689/EEC of 12 December 1991 on hazardous waste. The Regulations require controlled wastes that are
also considered to be special wastes because of their hazardous properties, to be correctly documented,
recorded and disposed of at an appropriately licensed site. Whilst strictly speaking the Regulations do not apply
offshore, waste consignments must be compliant as soon as the waste is offloaded at an onshore facility. In
Scotland, The Special Waste Amendment (Scotland) Regulations 2004 amend the Special Waste Regulations
1996. They implement the revised European hazardous waste list, (incorporated into the European Waste
Catalogue). They introduced new consignment note, segregation, packaging and labelling requirements. In
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England and Wales the Special Waste Regulations 1996 were repealed by The Hazardous Waste (England and
Wales) Regulations 2005.
The Waste Electrical and These Regulations transpose the requirements of the Waste Electrical and Electronic Equipment Directive (WEEE
Electronic Equipment Directive 2002/96/EC) which came into force in January 2007. The Regulations define new responsibilities for
SEPA Regulations 2006 (as amended users and producers of Electrical and Electronic Equipment depending on whether the equipment was purchased
2010) before or after 13/08/05.
The 2010 Amendments modify various definitions and realign dates
NATURALLY OCCURRING RADIOATIVE MATERIAL (NORM) CONTAMINATED WASTE (SAND, SLUDGE AND SCALE) AND RADIOACTIVE WASTE
SEPA Radioactive Substances Act Onshore and offshore storage and disposal of naturally occurring radioactive materials (NORM) is regulated
1993 under the Radioactive Substances Act. Operators are required to hold, for each relevant installation, an
Authorisation to store and dispose of radioactive waste such as low specific activity scale (LSA) which may be
deposited in vessels and pipework. The authorisation specifies the route and methods of disposal. Records of
disposal are required.
The offshore use, storage and disposal of radioactive sources are regulated under the same legislation. A
Registration Certificate is required to keep; transport and use sources and records must be kept. Additionally,
different radionuclides have different activity thresholds over which the containing sources qualify as a High
Activity Sealed Source (HASS). As of January 2008, and if applicable, HASS records must be reported to SEPA
or the EA and maintenance of an inventory is required.
The Radioactive Substances Act 1993 has been superseded by the Environmental Permitting (England and
Whales) Regulations 2010 in England and Whales but it has remained in place in Scotland. However, in
Scotland there have also been consultations regarding a future exemptions regime under The Radioactive
Substances Act 1993. These consultations have resulted in the Radioactive Substance Exemption (Scotland)
Order 2011. This order will revoke and replace a series of exemption orders (in Scotland) made under the
Radioactive Substances Act 1993 (“the Act”) and its predecessor (the Radioactive Substances Act 1960) in order
to rationalise the current system of exemptions and bring it into line with the structure and terminology used in
the Basic Safety Standards Directive.
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LICENSING
DECC Petroleum Act, 1998 as These Regulations consolidate with amendments the provisions of the Petroleum (Production) Regulations 1982
amended (as amended) in relation to (a) applications to the Secretary of State for petroleum production licences in respect
of seaward areas and (b) applications to the Secretary of State for petroleum exploration licences in respect of
seaward areas and landward areas below the low water line.
The Petroleum Licensing
(Exploration and Production) This Act vests all rights to the nation's petroleum resources to the Crown and provides the basis for granting
(Seaward and Landward licences to explore for and produce oil and gas. Production licences grant exclusive rights to the holders to
Areas) Regulations 2004 (as “search and bore for and get petroleum” in specific blocks. Licences generally contain a number of
amended 2006) environmental restrictions and conditions.
Under the terms of a Licence, licence holders require the authorisation of the Secretary of State prior to
conducting activities such as installing equipment or drilling of wells in the licence area. Consent to flare or vent
The Petroleum Licensing
hydrocarbons is also required from DECC under the terms of the Model Clauses incorporated into Production
(Production) (Seaward Areas)
Licences.
Regulations 2008
Licence conditions will include environmental issues e.g. time constraints in sensitive areas. The model clauses of
the licence require the licensee to appoint a fisheries liaison officer.
TRANSBOUNDARY
DECC Convention on Environmental The 1991 UNECE Convention on Environmental Impact Assessment in a Transboundary Context (the Espoo
Impact Assessment in a Convention) requires any country that has ratified the convention to consider the transboundary environmental
Transboundary Context (Espoo, effects of industrial projects and activities, including offshore hydrocarbon exploration and productions activities.
1991) The Convention requires that if the activity is found to cause a significant adverse transboundary impact then the
party undertaking the activity shall, for the purpose of ensuring adequate and effective consultations, notify any
potentially affected as early as possible.
LOCATION OF STRUCTURES
DECC Coast Protection Act 1949 (as This Act provides that where an obstruction or danger to navigation is caused, or is likely to result, the prior
extended by the Continental written consent of the Secretary of State is required for the siting of the offshore installation - whether mobile or
Shelf Act 1964) permanent - in any part of the UK designated areas of the Continental Shelf. In practice, this means that consent
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must be obtained for each drilling operation and for all offshore production facilities.
The issuing of 'consent to locate' under the Coast Protection Act Regulations 1949 section 34, part II, to an
individual or organisation and provides an indication that impacts have been considered with respect to
navigation, the local habitat within the proposed area and that no significant impacts would occur as a
consequence of the proposed offshore installation
The 1949 Act was extended by Section 4 (1) of the Continental Shelf Act 1964 to all parts of the UK Continental
Shelf where oil and gas exploration and development is taking place.
Continental Shelf Act 1964 This act extends the UK government’s right to grant licences to explore and exploit the UKCS
The Continental Shelf This Order consolidates the various Orders made under the Continental Shelf Act 1964 which have designated
(Designation of Areas) the areas of the continental shelf within which the rights of the United Kingdom with respect to the sea bed and
(Consolidation) Order 2000 subsoil and their natural resources are exercisable
Marine and Coastal Access Act The Marine and Coastal Access Act (MCAA) and Marine (Scotland) Act will replace and merge the requirements
2009 and Marine (Scotland) of FEPA Part II (deposits to the sea) and the Coast Protection Act 1949 (navigation). The licensing provisions of
Act 2010 these Acts enter into force in April 2011.See also Marine & Coastal Access Act 2009 & The Marine (Scotland)
Act 2010.
ENVIRONMENTAL MANAGEMENT SYSTEM
DECC OSPAR Recommendation All Operators controlling the operation of offshore installations on the UKCS are required to have in place an
2003/5 to Promote the Use independently verified Environmental Management System designed to achieve: the environmental goals of the
and Implementation of prevention and elimination of pollution from offshore sources and of the protection and conservation of the
Environmental Management maritime area against other adverse effects of offshore activities and to demonstrate continual improvement in
Systems by the Offshore environmental performance. OSPAR recognises the ISO 14001: 2004 & EMAS international standards as
Industry containing the necessary elements to fulfil these requirements. All operators are also required to provide a public
statement of their environmental performance on an annual basis.
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REGULATORY
BODY
DECOMMISSIONING
DECC, MMO, Petroleum Act 1998 The Petroleum Act 1998 sets out requirements for undertaking decommissioning of offshore installations and
Marine pipelines including preparation and submission of a Decommissioning Programme.
Scotland
Energy Act 2008 Part III of the Energy Act 2008 amends Part 4 of the Petroleum Act 1998 and contains provisions to enable the
Secretary of State to make all relevant parties liable for the decommissioning of an installation or pipeline;
provide powers to require decommissioning security at any time during the life of the installation and powers to
protect the funds put aside for decommissioning in case of insolvency of the relevant party.
Food and Environment The Marine and Coastal Access Act (MCAA) and Marine (Scotland) Act will replace and merge the requirements
Protection Act 1985 of FEPA Part II (deposits to the sea) and the Coast Protection Act (navigation). FEPA Part II remains in force in
Marine (Scotland) Act 2010 Scottish territorial waters to cover reserved activities (within 3 nm).
Marine and Coastal Access Act Many offshore sector activities are exempt from the acts, however certain activities including deposits of
2009 substances or articles in the seabed during abandonment and decommissioning operations are covered.
OSPAR Decision 98/3 on the Decision that requires operators to remove the whole installation. However large structures are possible
Disposal of Disused Offshore exceptions from derogation.
Installations
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GENERAL
ISSUE LEGISLATION REGULATOR SUMMARY OF REQUIREMENTS AND PROJECT IMPLICATIONS
The MARPOL Convention is the main international convention covering prevention of

pollution of the marine environment by ships from operational or accidental causes and
covers pollution by oil, chemicals, harmful substances in packaged form, sewage and
General MARPOL 73/78 MCA garbage.
The Project is required to comply with the Annexes of MARPOL to which the UK is
signatory.
EU Directive 2003/35 providing for
public participation in respect of the
drawing up of certain plans and
programmes relating to the environment The Public Participation Directive (PPD) was issued by the European Commission in
Public and amending with regard to public order to provide members of the public with opportunities to participate in the permitting
Participation participation and access to justice and ongoing regulation of certain categories of activities within Member States,
Council Directives including EIA.
85/337/EEC and 96/61/EC - Statement

by the Commission on Public Participation
EU Directive 2004/35 on Environmental The Environmental Liability Directive enforces strict liability for prevention and
Liability with Regard to the Prevention and remediation of environmental damage to ‘biodiversity’, water and land from specified
Remedying of Environmental Damage activities and remediation of environmental damage for All other activities through fault
(Environmental Liability Directive) or negligence.
Environmental These regulations implement EC Directive 2004/35 on Environmental Liability, forcing
Liability Environmental Damage (Prevention and
Remediation) Regulations 2009 (as polluters to prevent and repair damage to water systems, land quality, species and their
Marine
amended 2010) habitats and protected sites. The polluter does not have to be prosecuted first, so
Scotland,
remedying the damage should be faster.
Environmental Liability (Scotland) SEPA
Regulations 2009 (as amended 2011) The regulations were amended in 2010 to provide for the devolution to the Scottish
Ministers of certain of the Secretary of State’s functions with respect to preventing and
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GENERAL

remedying damage to marine nature conservation in the Scottish offshore region.
However, the Secretary of State still enforces preventing and remedying damage caused
by oil, gas and carbon dioxide storage activities and marine transport activities.
The 2011 amendments amend the Regulations in accordance with EC Directive
2009/31.
The Directive came into force in July 2013.
The objectives of this Directive are to:
 Attain best industry practice throughout the EU based on primary duty of major accident
risk control with consequent leverage on global standards;
 Implement best regulatory practice for major accident prevention and mitigation via
independent expert regulators in every relevant member state;
EU Directive 2013/30/EU on safety of DECC and
 Implement fully joined up emergency preparedness and response procedures in all EU
Accidental offshore oil and gas operations and Health and
offshore regions; and
discharge amending Directive 2004/35/EC (The Safety
 Improve and clarify existing EU liability and compensation provisions.
Offshore Safety Directive) Executive
New environmental regulations will be required to implement some of the objectives,
specifically relating to Environmental Management Systems and Environmentally Critical
Elements (ECEs). DECC and HSE will jointly lead the transposition of the Directive as it
contains requirements relating to licensing, environmental protection, emergency
response and liability, in addition to safety. The Directive has to be implemented by
19th July 2015.
The Climate Change Act introduces powers to combat climate change by setting targets
to reduce CO2 emissions by at least 60 % by 2050 and an interim target of 26-32 % by
The Climate Change Act 2008 Scottish
2020, against a 1990 baseline.
Emissions Government
Climate Change (Scotland) Act, 2009 and Defra Similarly, the Climate Change (Scotland) Act targets for an 80 % reduction in CO2
emissions from 1990 levels by 2050 with an interim target of 42 % by 2020. The Act
also requires Scottish Ministers to set annual targets, in secondary legislation, for
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GENERAL

Scottish emissions from 2010 to 2050.
The aim of Phase III of the EU ETS is to reduce EU emissions by 21 % between 2005 and
2020. There will be no National Allocation Plans (NAPs) and allocations will be
DECC, managed centrally by the EU.
EU ETS Phase III (2013 – 2020) Environment
Agency EC Directive 2009/29 (which outlines Phase III) is being transposed into UK law Stage 1
was completed by the end of 2009 and Stage 2 was scheduled for the end of 2012.
Phase III started in 2013 and will run until 2020.
The Marine Strategy Regulations 2010 transpose the requirements of the Marine
Strategy Framework Directive into UK law. The Directive requires Member States to
implement measures to achieve or maintain good environmental status of their marine
environment by 2020. Specifically, the Directive requires Member States to create a
strategy for the following:
EU Directive 2008/56 establishing a  An initial assessment of the current environmental status of a Member State's marine
framework for community action in the waters by 2012;
field of marine environmental policy (the Marine
 Development of a set of characteristics which describe what “Good Environmental
Marine Strategy Framework Directive) Scotland
Status” means for those waters by 2012;
Marine The Marine Strategy Regulations 2010  Establishment of targets and indicators designed to show the achievement of Good
Management Environmental Status by 2012; and
 Establishment of a monitoring programme to measure progress toward achieving Good
Environmental Status by 2014.
Establishment of a programme of measures designed to achieve or maintain Good
Environmental Status (to be designed by 2015 and implemented by 2016).
The Marine and Coastal Access Act (MCAA) came into force in November 2009. The
Marine and Coastal Access Act DECC, Act covers all UK waters except Scottish internal and territorial waters which are
2009 (as amended 2011) Marine Marine covered by the Marine (Scotland) Act 2010 which mirrors the MCAA powers. The
(Scotland) Act 2010 Scotland licensing provisions in relation to MCAA came into force on 1st April 2011. MCAA
replaced and merged the requirements of FEPA Part II (environment) and the Coast
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GENERAL

Protection Act 1949 (navigation). The following activities are exempt from MCAA as
they are controlled under different legislation:
 Activities associated with exploration or production / storage operations that are
authorised under the Petroleum Act 1998 (as amended) and Energy Act 2008; or
 Additional activities authorised solely under the DECC environmental regime, such as
chemical and oil discharges.
The offshore oil and gas activities that will require an MCAA licence are as follows:
 Deposits of substances or articles in the sea or on the seabed, e.g. pipeline crossing
works prior to use of pipeline authorisation works (PWA) or related Direction, or deposit
of materials associated with abandonment operations;
 Removal of substances or articles from the seabed, e.g. pre-sweep dredging with
disposal of material at a remote location, or removal of seabed infrastructure during
abandonment operations;
 Disturbance of the seabed, e.g. pre-sweep dredging using a levelling device or by side-
casting material, or disturbance of sediments or cuttings pile by water jetting during
abandonment operations;
 Installation of certain types of cable that cannot be covered by a PWA e.g.
communication cables; and
 Deposit and use of explosives that cannot be covered under an application for a
Direction, e.g. during abandonment operations.
 Licences will be valid for a maximum period of one year however applications for
licence renewals can be made.
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CONSENTING
ISSUE LEGISLATION REGULATOR SUMMARY OF REQUIREMENTS
EC Directive 85/337 on the assessment

of the effects of certain public and private Under the EIA Directive all Annex I projects are considered to have an effect on the
EIA projects on the environment. (the EIA environment and require an EIA and, consequently, an ES. Annex I projects include oil
Directive) (as amended by Directives and gas exploration and production projects.
97/11, 2003/35 and 2009/31)
The Secretary of State for Energy and Climate Change will take into consideration
environmental information in making decisions regarding consents for offshore
developments and projects.
A statutory ES and public consultation is mandatory for:
 New field developments or increase in production where production is predicted to
exceed 500 tonnes of oil per day or 500,000 m3 or more per day of gas; and
 New or extension to a pipelines of 800 mm (31") diameter and 40 km or more in
length.
The Offshore Petroleum Production and
Pipelines (Assessment of Environmental A formal process has been established for the submission of an ES and public
consultation which involves:
Effects) Regulations 1999 and the
DECC  Submission of the ES to DECC and their advisors (Environmental Authorities);
Offshore Petroleum Production and
Pipelines (Assessment of Environmental  The ES must be advertised in the national and local press;
Effects) (Amendment) Regulations 2007  The ES must be available for public consultation for at least 28 days following the
advertisements (longer if this includes a public holiday);
 The public may request a copy of the ES;
 The public, Environmental Authorities, consultees and other organisations make their
comments to DECC;
 DECC may require more information/clarifications from the operator or may require
resubmission of the ES should they feel that they have insufficient information on which
to evaluate the environmental implications of the proposed project; and
 Following consideration, DECC may issue a project consent which is then advertised in
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CONSENTING

the Gazette, following which there is a six week period during which those who feel
‘aggrieved’ by this decision may challenge it.
Storage
Petroleum Act 1998 (as amended) DECC Operators are required to submit plans for storage activities to DECC for approval.
License
Construction of a pipeline is prohibited in, under or over controlled waters, except in
accordance with an authorization granted by the Secretary of State (known as the
Pipeline Works Authorisation – PWA).
 Application for authorisation is made under Section 14 of the Act, to the Secretary of
State;
 The Secretary of State decides whether applications are to be considered or not. If not
to be considered reasons will be given;
 If an application is being considered, the Secretary of State will give directions with
respect to the application;
 The applicant is to publish a notice giving such details as directed by the Secretary of
Pipeline State, allowing 28 days from first publication of the notice for public consultation;
Works Petroleum Act 1998 (as amended) DECC  Publication must provide a map and such other information as directed by the Secretary
Authorisation of State and must make these available for public view during the specified period;
 Notice must also be provided to any other parties as directed by the Secretary of State;
 The Secretary of State considers any representations and issues authorisation; and
 An EIA via either an ES or an EIA Direction is required. A MAT has to be submitted for
a proposed pipeline which will include SATs for an EIA Direction(s) (if required), for a
permit for the use and/or discharge of chemicals during the operation of a pipeline
and a permit for the discharge of oil during pipeline operation. The application
requires a description of the work carried out, a site specific EIA (if a Direction is
required) and a list of all the chemicals intended for use and/or discharge, along with
a risk assessment for the environmental effect of the discharge of chemicals into the sea.
The permit obtained may include conditions
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CONSENTING
Deposit of Materials Consent (DepCon) is required for the deposit of materials e.g. rock
dumping or mattresses. This forms part of the PWA application process.
Deposition of
A licence under the MCAA is required in cases where not covered by a PWA, for
Material
Petroleum Act 1998 (as amended) example:
Consent
(DepCon)  Pipeline crossing preparations or other works before a PWA or related Direction is in
place; and
 Installation of certain types of cable, e.g. communications cables.
Crown Estate
Seabed Lease Crown Estate Act 1961 Minute of agreement required for occupation of seabed.
Commissioners
Requires impacts to be considered with respect to (i) navigation and (ii) the local
habitat within the proposed area.
Marine and Coastal Access Act 2009 (as As of April 2011, the Coast Protection Act 1949 was no longer in force and all
amended 2011) DECC Consent to Locate requirements were transferred to the Marine & Coastal Access Act
2009 (MCAA). The majority of oil and gas related activities are exempt from the
The Energy Act 2008
MCAA. Consequently, a new Part 4A of the Energy Act (2008) was created,
Location of transferring Consent to Locate provisions to the Energy Act and resulting in DECC
Structures becoming the regulatory body.
The Continental Shelf Act extends the UK government’s right to grant licences to explore
Continental Shelf Act 1964 (as amended (and exploit) hydrocarbon resources to the United Kingdom Continental Shelf (UKCS).
1989) The Continental Shelf (Designation of Areas) (Consolidation) Order 2000 consolidates
DECC
The Continental Shelf (Designation of the various Orders made under the Continental Shelf Act 1964 which have designated
Areas) Order 2013 the areas of the continental shelf within which the rights of the UK with respect to the
seabed and subsoil and their natural resources are exercisable.
Petroleum Act 1998 (as amended) Application for consent to drill exploration, appraisal and development wells must be
Well Consent DECC
Petroleum Operations Notice No 4 submitted to DECC through the Well Operation and Notification System WONS.
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CONSENTING

(revised May 2012)
The Marine (Scotland) Act introduces a new statutory marine planning system to
sustainably manage the increasing, and often conflicting, demands on our seas.
The Marine and Coastal Access Act 2009 makes provision for the amendment of the
Environmental Damage (Prevention and Remediation) Regulations 2009 in order to
place responsibility for enforcement in the Scottish offshore region with the Scottish
Marine Coastal Access Act 2009 (as DECC and Ministers, when there is significant damage to species and habitats protected under the
Planning amended 2011) Marine EU Habitats and Wild Birds Directives. This responsibility will not include enforcement
Scotland of the prevention and remediation of damage caused by oil and gas activities or CO2
Marine (Scotland) Act 2010
storage activities which will remain with DECC. As the works are in relation to a
variation of an existing PWA DECC and Marine Scotland have advised that the
offshore element of the additional pipeline from the MLWS will be covered under the
DECC regime. Subsequent permit applications for works within 12 nm will be
discussed and agreed with the regulators at the time of application (e.g. chemical
discharges during pipeline tie in).
Offshore Installations and Pipeline Works
(Management and Administration) DECC states that the Maritime and Coastguard Agency (MCA) should be informed as
Regulations 1995 soon as possible of all rig movements as a condition of any consent to locate a rig at a
new location.
HSE Operations Notice 6 Reporting of
Rig Offshore Installation Movements DECC, MCA Under Operations Notice 6 a rig warning communication must be issued at least 48
Movements and HSE hours before any rig movements.
HSE Operations Notice 3 Liaison with
other bodies Rig movements must be reported to the HSE when an installation is due to enter or
leave UK waters as per regulation 5 of the Offshore Installations and Pipeline Works
HSE Operations Notice 14 on Coast (Management and Administration) Regulations 1995.
Protection Act
Muds, The Offshore Petroleum Activities (Oil DECC Under OPPC it is illegal to discharge reservoir hydrocarbons and cuttings to the marine
Cuttings and Pollution Prevention and Control) supported by environment without an exemption from the Secretary of State. The Paris Commission
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CONSENTING

Chemical Regulations 2005 (as amended 2011) Marine decision 92/2 established maximum oil on cuttings concentration of 1% by weight for
Use and Scotland and discharge of cuttings to sea.
Discharge CEFAS The contamination of cuttings by muds comes under the Offshore Chemical Regulations
2002 (as amended), but discharges/cuttings contaminated with reservoir oil fall under
the OPPC regulations.
A permit is required for discharge of oil to sea and is obtained from DECC via a SAT
on the PETS system.
The Offshore Petroleum Activities (Oil Pollution Prevention and Control) (Amendment)
Regulations 2011 came into force on March 30th 2011. These amendments include a
new definition of ’offshore installation’, which now includes pipelines. This ensures that
all discharges of oil from pipelines used for offshore oil and gas activities will now be
controlled under the OPPC regulations.
Under these Regulations, offshore drilling operators need to apply for permits to cover
both the use and/or discharge of chemicals. The permits are applied for through PETS
(UK Oil Portal). An EIA via either an ES or an
Offshore Chemicals Regulations 2002 (as EIA Direction is required. A MAT has to be submitted for the works which will include
amended 2011) SATs for an EIA Direction(s) (if required) and for a permit for the use and/or discharge
of chemicals during the operation of a pipeline. The application requires a description
OSPAR Decision 2000/2 on a of the work carried out, a site specific EIA (if a Direction is required) and a list of all the
Harmonised Mandatory Control System DECC chemicals intended for use and/or discharge, along with a risk assessment for the
for the Use and Reduction of the environmental effect of the discharge of chemicals into the sea. The permit obtained
Discharge of Offshore Chemicals (as may include conditions.
amended by OSPAR Decision 2005/1)
and associated Recommendations. These Regulations amend the Deposits to Sea (Exemptions) Order 1985 to make the
discharges of chemicals to sea exempt from requiring a licence under MCAA when the
discharge has a permit under the Offshore Chemicals Regulations 2002 (as amended
2011).
The Offshore Chemicals (Amendment) Regulations 2011 also came into force on March
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CONSENTING

30th 2011. The key change is to ensure that enforcement action can be taken in
respect to non-operational emissions of chemicals, such as accidental leaks or spills.
Under the 2002 regulations a permit can only be granted in respect of discharge of
chemicals which occur during day to day oil and gas production, as a discharge is
limited to “an operational release of offshore chemicals.” Therefore, it is not an offence
to emit chemicals other than in the course of normal operations, for example, as a
result of leaks or spills. The 2011 amendments remedy this. Under the regulations, a
“discharge” now covers any intentional emission of an offshore chemical and a new
definition of “release” has been inserted which catches all other emissions (regulation
4(a) and (h) of the amendments).
Under the 2011 amendments, well suspension and abandonment also require a formal
permitting process and will usually require approval under the MCAA licensing regime,
both of which are registered by DECC’s Environmental Management Team. These
requirements are in addition to the MAT/SAT required consent to abandon a well.
As with drilling, discharges contaminated with reservoir oil during installation require
an OPPC permit. These can be either term permits or life permits depending on the
duration of the discharge. An OPPC permit is not required if the discharge originated
The Offshore Petroleum Activities (Oil from a vessel covered by the Merchant Shipping (Prevention of Oil Pollution)
Pollution Prevention and Control) DECC Regulations.
Regulations 2005 (as amended 2011)
A permit is required for discharge of oil to sea and is obtained from DECC via a SAT
on PETS. Specific monitoring and reporting requirements will be included on each
permit. Reporting is via the Environmental Emissions Monitoring System (EEMS).
OSPAR Recommendation 2006/5 outlines the approach for the management of
OSPAR Recommendation 2006/5 on a cuttings piles offshore. The purpose of the Recommendation is to reduce to a level that
management regime for offshore cuttings is not significant, the impacts of pollution by oil and/or other substances from cuttings
piles piles.
The Cuttings Pile Management Regime (outlined by the Recommendation) is divided
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CONSENTING

into two stages:
 Stage 1 involves initial screening of all cuttings piles. This should be completed within 2
years of the Recommendation taking effect; and
 Stage 2 involves a BAT and/or BEP.
Offshore Petroleum Production and Deposits to sea for the purpose of rig stabilisation require a Consent to Locate. This is
Pipelines (Assessment of Environmental in addition to the Direction required for deposits associated with pipelines.
Effects) Regulations 1999 (as amended The deposit of stabilisation or protection materials, such as jack-up rig
Rig 2007) (Offshore Environmental stabilisation/anti-scour deposits, or pipeline protection/free-span correction deposits,
Protection) Order 2010) DECC
Stabilisation must be the subject of a direction under the Offshore Petroleum Production and
Offshore Petroleum (Conservation of Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended). A
Habitats) Regulations 2001 (as amended DepCon would also be required. This does not apply to decommissioning sediments,
2007) which will require an MCAA licence (see Decommissioning).
The Merchant Shipping (Dangerous The regulations require that dangerous goods and marine pollutants are labelled and
Dangerous
Goods and Marine Pollutants) MCA packed according to the International Maritime Dangerous Goods (IMDG) code and
Goods
Regulations 1997 (as amended 1999). that dangerous goods declarations are provided to vessel masters prior to loading.
The Chemicals (Hazard Information and The transport of chemicals to and from offshore fields is principally by road to shore
Packaging for Supply) Regulations 2002 base and then by sea. These regulations (commonly known as CHIP 3) specify safety
(as amended 2008) (revoked by the Health and data sheet format and contents and required packaging and labelling of chemicals for
Chemicals (Hazard Information and Safety supply.
Packaging for Supply) Regulations 2009) Executive
Chemical The 2009 regulations, CHIP4, consolidate all amendments made to the Chemicals
Data Sheets (Hazard Information and Packaging for Supply) Regulations since 2002.
and Labelling DECC (and
EC Regulation 1907/2006 (REACH) SEPA within
REACH deals with the registration, evaluation, authorisation and restriction of chemical
REACH Enforcement Regulations 2008 SI Scottish
substances.
2852 territorial
waters)
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VESSELS
UK Regulations apply to all vessels regardless of flag whilst in UK Territorial Waters (12
nm from coastline), and implement the requirements of MARPOL 73/78. Similarly,
MARPOL 73/78
MARPOL 73/78 requirements apply to all vessels whilst on the High Seas (outside
territorial waters).
General The IMO may designate areas of sea as ‘Special Areas’ for oceanographic reasons,
MARPOL: Annexes I (Prevention of ecological condition and in relation to character of shipping and other sea users. The
Pollution by Oil), V (Prevention of Pollution North West European Waters (including the North Sea) have been given ‘Special Area’
by Garbage) and VI (Prevention of Air status from August 1999. In these areas special mandatory methods for the prevention
Pollution from Ships). of sea pollution are required and these special areas are provided with a higher level of
protection than other areas of the sea.
The Petroleum (Current Model Clauses) From the 7th and 8th Licensing rounds onwards, operators have been required to
Order 1999. appoint a Fisheries Liaison Officer to liaise with the fishing industry and Government
Fisheries Departments on exploration and production activities. In addition to any
The Petroleum Licensing (Production)
Fisheries project specific engagement, Shell holds biannual Fisheries Forums which fulfil this
(Seaward Areas) Regulations 2008 DECC
Liaison requirement.
Model Clauses of Licence
HSE Offshore Safety Division Operations Notice 3, Liaison with Other Bodies, June
HSE Offshore Safety Division Operations 2008 outlines liaison routes to improve communication between operators and other
Notice 3 users of the sea and includes a requirement for a Fisheries Liaison.
These regulations implement MARPOL Annex I (Prevention of Pollution by Oil) into UK
The Merchant Shipping (Prevention of Oil legislation.
Machinery
Pollution) Regulations 1996 (as amended Within a ‘Special Area’ (which includes the North Sea), ships which are 400 GT or
Space
2005) (as amended by the Merchant MCA above can discharge water from machinery space drainage providing the oil content of
Drainage from
Shipping (Implementation of Ship-Source the water does not exceed 15 ppm. Vessels must be equipped with oil filtering systems;
Shipping
Pollution Directive) Regulations 2009) automatic cut offs and oil retention systems. All vessels must hold an approved
Shipboard Oil Pollution Emergency Plan (SOPEP) and must maintain a current Oil
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VESSELS

Record Book and the ship must be proceeding on its voyage.
All vessels must hold a UKOOP certificate or an IOPC certificate for foreign ships.
Installations can obtain a temporary exception from MCA under an informal agreement
between O&GUK and the MCA, however new installations need to demonstrate their
‘equivalence’ to other offshore installations where temporary installations are being
issued and they are unlikely to obtain a certificate unless they fully comply with the
requirements.
MARPOL 73/78 also defines a ship to include "floating craft and fixed or floating
platforms" and these are required where appropriate to comply with the requirements
similar to those set out for vessels. Note, if all machinery drainage is routed via the
hazardous or non-hazardous drainage systems this will fall under OPPC and not
require a UKOOP certificate.
The amendments made under the Merchant Shipping (Implementation of Ship-Source
Pollution Directive) Regulations 2009 close an existing loop hole, where some large oil
and chemical spills were not open to prosecution under MARPOL.
Annex V generally prohibits the discharge of all garbage into sea with the exception of
Waste from food waste (if comminuted for special areas and platforms), cargo residues, cleaning
MARPOL 73/78 Annex V Prevention of agents and additives and animal carcasses. The Annex also obliges Governments to
Vessels and
Pollution by Garbage ensure the provision of facilities at ports and terminals for the reception of garbage.
Construction
The special areas established under the Annex include the North Sea.
The Merchant Shipping (Prevention of Pollution by Sewage and Garbage) Regulations
2008 implements Annexes IV and V of MARPOL and supersedes The Merchant
The Merchant Shipping (Prevention of Shipping (Prevention of Pollution by Garbage) Regulations 1998)
Sewage from
Pollution by Sewage and Garbage) MCA
Vessels Under the regulations all wastes are to be segregated and stored and returned to shore
for disposal and no garbage can be dumped overboard in a ‘Special Area’, including
the North Sea for Annex V. Food waste can be discharged only if:
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VESSELS

 Greater than 12 miles from coastline; and
 Ground to less than 25 mm particle size.
Vessels must have a garbage management plan with suitable labelling and notices
displayed.
Requirement for ships to discharge sewage only under certain conditions:
 Comminuted and disinfected sewage may only be discharged more than 4 nm from the
coast;
 Non-comminuted or disinfected sewage may only be discharged 12 nm from the coast;
MARPOL 73/78 Annex IV Regulations for and
the Prevention of Pollution by Sewage MCA  Original international regulations entered into force in September 2003 and the revised
from Ships annex entered into force in 2005.
Note: MARPOL 73/78 also defines a ship to include "floating craft and fixed or floating
similar to those set out for vessels. Thus for sewage the basic equipment and
operational requirements set out for other vessels will apply to offshore installations.
Annex VI is concerned with the control of emissions of ozone depleting substances,
NOx, SOx, and VOCs and require ships (including platforms and drilling rigs) to be
issued with an International Air Pollution Certificate following survey.
The Annex sets limits on SOx and NOx emissions from ship exhausts and prohibits
Atmospheric deliberate emissions of ozone depleting substances. It caps 4.5 % m/m on the sulphur
MARPOL 73/78 Annex VI the Prevention content of fuel oil.
Emissions from MCA
of Air Pollution from Ships
Vessels The Annex sets special SOx emission control areas (SECAS) where sulphur emissions
are limited further and sulphur content in fuel oil must not exceed 1.5 % m/m or have
an exhaust gas cleaning system fitted. The North Sea is one such SECAS.
No new installations containing ozone-depleting substances are permitted, with the
exception of HCFCs which are permitted till 1 January 2020.
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VESSELS

NOx emissions from diesel engines are to be limited by the implementation of NOx
technical code.
No incineration of contaminated packing materials or PCBs onboard ships.
Annex VI only applies to diesel engines over 130 KW and does not apply to turbines.
Emissions arising directly from the exploration, exploitation and associated offshore
processing of seabed mineral resources are exempt from Annex VI, including the
following:
 Emissions resulting from flaring, burning of cuttings, muds, well clean-up emissions and
well testing;
 Release of gases entrained in drilling fluids and cuttings;
 Emissions from treatment, handling and storage of reservoir hydrocarbons;
 Emissions from diesel engines solely dedicated to the exploitation of seabed mineral
resources; and
 In addition, Regulation 13 concerning NOx does not apply to emergency diesel engines,
engines installed in lifeboats or equipment intended to be used solely in case of
emergency.
The Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2008
implements Annex VI of MARPOL into UK law.
The Regulations aim to reduce air pollution from shipping. This will be achieved
through controls on emissions of NOx, SOx, VOCs and Ozone Depleting Substances,
The Merchant Shipping (Prevention of Air which are not GHGs. Additionally, elements of the
MCA
Pollution from Ships) Regulations limit the sulphur content of marine fuels and require a register of local
marine fuel suppliers.
The 2010 amendments primarily implement provisions concerning the sulphur content of
marine fuels. The draft regulations require that:
 The sulphur content of fuel for ships operating within a designated SECA (including the
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VESSELS

North Sea/English Channel) must not exceed 0.1 % from 1 January 2015; and
 Outside of designated SECAs the sulphur content of fuel will be limited to 0.5 % in
European waters from 1 January 2000.
These limits can also be achieved using alternative fuels or the use of abatement systems
such as exhaust gas cleaning systems (EGCS), often referred to as “scrubbers”.
It was proposed by the International Convention on the Control of Harmful Antifouling
Systems on Ships that the use of tributyltin (TBT) would be banned on new vessels from
International Convention on the Control of 2003 with a total ban on all hulls from 2008. However, currently, in the UK, the use is
Harmful Antifouling Systems on Ships only restricted under the Surface Waters (Dangerous Substances) (Classification)
2001; EC Regulation 782/2003 on the Regulations, 1997. Additionally, it is listed as a priority hazard substance under the
Antifouling
Prohibition of Organotin Compounds on Water Framework Directive, for priority action under the OSPAR and Helsinki
Coating on MCA
Ships Conventions and its sale and use are restricted under the Control of Pesticides
Vessels
Regulations (as amended).
The Merchant Shipping (Anti-Fouling
Systems) Regulations 2009  EC Regulation 782/2003 prohibits ships from having organotin compound based anti-
fouling paints applied to their hulls or other external surfaces, and it establishes a survey
and certification regime in relation to anti-fouling systems. The Merchant Shipping
(Anti-Fouling Systems) Regulations 2009 implements the EC Regulation into UK law.
EC Directive 76/464 EC Directive 76/464 deals with pollution caused by certain dangerous substances
discharged into the aquatic environment. The Surface Waters (Dangerous Substances)
The Surface Waters (Dangerous Marine
(Classification) Regulations 1998 prescribe a system for classifying the quality of inland
Discharges Substances) (Classification) (Scotland) Scotland,
freshwaters, coastal waters and relevant territorial waters with a view to reducing the
(No.2) Regulations 1998 OSPAR and MCA
pollution of those waters by the dangerous substances within List II of EC Directive
Helsinki Conventions 76/464.
The COLREGs are designed to minimise the risk of vessel collision at sea and apply to
International Regulation for Preventing all vessels on the high seas. They include 38 rules divided into five sections:
Vessel
Collisions at Sea 1972 (COLREGS) (as IMO
Movements  Part A – General;
amended 2009)
 Part B - Steering and Sailing;
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VESSELS

 Part C - Lights and Shapes;
 Part D - Sound and Light Signals; and
 Part E - Exemptions.
There are also four Annexes containing technical requirements concerning lights and
shapes and their positioning; sound signalling appliances; additional signals for fishing
vessels when operating in close proximity, and international distress signals.
The Merchant Shipping (Distress Signals The Merchant Shipping (Distress Signals and Prevention of Collisions) Regulations 1996
and Prevention of Collisions) Regulations MCA implements the COLREGS into UK law. Vessels to which these regulation apply must
1996 comply with Rules 1-36 of Annexes I to III of the COLREGS
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COMMISSIONING AND OPERATIONS
Deposits in the sea, including liquid discharges, were regulated through the MCAA but,
as stated above, as a result of the Petroleum Act 1998 this does not apply to anything
done:
Discharges of
 For the purpose of constructing a pipeline as respects any part of which an authorisation
Linefill and (within the meaning of Part III of the Petroleum Act 1998) is in force; or
The Petroleum Act 1998 (as amended). DECC
Hydrotest
 For the purpose of establishing or maintaining an offshore installation within the
Fluids
meaning of Part IV of that Act.
Discharges of linefill and hydrotest fluids are permitted under the Petroleum Act 1998
and this is incorporated and permitted within a chemical permit submitted through PETS.
Under these Regulations, both offshore pipelines and installations need to apply for
permits to cover both the use and/or discharge of chemicals.
Chemical Use Offshore Chemicals Regulations 2002 (as The permits are applied for through PETS. The application requires will include a list of
DECC
and Discharge amended 2011) all the chemicals intended for use and/or discharge, along with a risk assessment for
the environmental effect of the discharge of chemicals into the sea. The permit obtained
may include conditions.
The Merchant Shipping (Dangerous The regulations require that dangerous goods and marine pollutants are labelled and
Dangerous
Goods and Marine Pollutants) Regulations MCA packed according to the IMDG code and that dangerous goods declarations are
Goods
1997 (as amended 1999). provided to vessel masters prior to loading.
The transport of chemicals to and from offshore fields is principally by road to shore
The Chemicals (Hazard Information and base and then by sea. These regulations (commonly known as CHIP 3) specify safety
Chemical Data Packaging for Supply) Regulations 2002 Health and data sheet format and contents and required packaging and labelling of chemicals for
Sheets and (as amended 2008) (revoked by the Safety supply.
Labelling Chemicals (Hazard Information and Executive
Packaging for Supply) Regulations 2009) The 2009 regulations (CHIP4) consolidate all amendments made to the Chemicals
(Hazard Information and Packaging for Supply) Regulations since 2002.
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The Merchant Shipping (Prevention of Oil Pollution) Regulations 1996 (as amended)
implement Annex I of MARPOL into UK legislation.
MARPOL 73/78 also defines a ship to include "floating craft and fixed or floating
similar to those set out for vessels.
Within a ‘Special Area’ which includes the North Sea, ships which are 400 GT or
above can discharge water from machinery space drainage providing the oil content of
the water does not exceed 15 ppm. Vessels must be equipped with oil filtering systems,
The Merchant Shipping (Prevention of Oil automatic cut offs and oil retention systems. All vessels must hold an approved SOPEP
Pollution) Regulations 1996 (as amended and must maintain a current Oil Record Book and the ship must be proceeding on its
Machinery
2000 and 2005) (as amended by the voyage.
Space MCA
Merchant Shipping (Implementation of All vessels must hold a UKOOP certificate or an IOPC certificate for foreign ships.
Drainage
Ship-Source Pollution Directive) Installations can obtain a temporary exception from MCA under an informal agreement
regulations 2009) between O&GUK and the MCA, however new installations need to demonstrate their
‘equivalence’ to other offshore installations where temporary installations are being
issued and they are unlikely to obtain a certificate unless they fully comply with the
requirements.
Note, if all machinery drainage is routed via the hazardous or non-hazardous drainage
systems this will fall under OPPC and not require a UKOOP certificate. The
amendments made under the Merchant Shipping (Implementation of Ship-Source
Pollution Directive) Regulations 2009 close an existing loop hole, where some large oil
and chemical spills were not open to prosecution under MARPOL.
A certificate issued by SEPA is required for any new sources brought onto installations.
Radioactive Substances Act 1993 (as The application must refer to all temporary or permanent radioactive sources taken
Radioactive
amended 2011 (Northern Ireland and SEPA offshore. The certificate must be displayed or be easily accessible to those whose work
Sources
Scotland only)) activity may be affected. Radioactive waste brought onshore requires a Certificate of
Authorisation for Onshore Disposal of Radioactive Waste which is required under
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Sections 13 and 14 of the Radioactive Substances Act (RSA) 1993. Registration is also
required for any offshore accumulation of waste prior to onshore disposal. Permitted
onshore disposal routes for solid radioactive waste will be detailed in the Certificate.
The Radioactive Substances Act 1993 Amendment (Scotland) Regulations 2011 came
into effect on 1st October 2011 and amended Sections 1 and 2, changing the
definitions of radioactive material and radioactive waste. These regulations apply to
Scotland only.
Produced Water discharge limits under OPPC are:
 A monthly average oil-in-water concentration of 30mg/l;
 A maximum oil-in-water concentration of 100mg/l; and
The Offshore Petroleum Activities (Oil  Each installation has a specific discharge limit expressed as cubic meters per day.
Produced
Pollution Prevention and Control) DECC In addition, each installation will have permit for re-injection of produced water.
Water
Monthly reporting of produced water discharges is via EEMS. Bi-annual sampling and
analysis is required for total aliphatics, total aromatics and total hydrocarbons (BTEX,
NPDs, PAHs, organic acids, phenols and heavy metals). Other specific monitoring
requirements are attached to each permit.
Hazardous
and Non-
Hazardous
Drainage
(excluding The Offshore Petroleum Activities (Oil Requires a permit for hazardous drainage and non-hazardous drainage discharges.
machinery Pollution Prevention and Control) DECC Specific monitoring and reporting requirements are required on each schedule permit.
space Regulations 2005 (as amended 2011) Reporting is via EEMS.
drainage)
A-38
The Offshore Petroleum Activities (Oil The OPPC regulations require a permit for well workover, intervention and service fluid
Well
Pollution Prevention and Control) discharges. Under these regulations a permit is not required for the discharge of
Workover,
Regulations 2005 (as amended 2011) OBM/OPF and SBMs as these are permitted under the Offshore Chemical Regulations
Intervention
Environmental Protection) Order 2010) DECC 2002 (as amended). However any material being discharged or reinjected that has
and Service
been contaminated by hydrocarbons from the reservoir will require a permit. Specific
Fluid Offshore Chemicals Regulations 2002 (as monitoring and reporting requirements are included on each schedule permit and
Discharges amended 2011) reporting is via EEMS.
The OPPC regulations require a permit for maintenance and cleaning discharges,
Maintenance The Offshore Petroleum Activities (Oil however it may be possible to include it in an existing permit. Permits extend to both
and Cleaning Pollution Prevention and Control) DECC installations and pipelines under the Offshore Petroleum Activities (Oil Pollution
Discharges Regulations 2005 (as amended 2011) Prevention and Control) (Amendment) 2011. Specific monitoring and reporting
requirements are included on each schedule permit and reporting is via EEMS.
The OPPC regulations require a permit for minor oily discharges such as those
The Offshore Petroleum Activities (Oil
associated with BOP actuation, subsea valve actuation, subsea production start-up and
Pollution Prevention and Control) DECC
pipeline disconnection. Specific monitoring and reporting requirements are included on
each schedule permit and reporting is via EEMS.
The Industrial Emissions Directive combines seven existing directives into one namely:
Other Minor  The Large Combustion Plant Directive (2001/80/EC);
Oily  The Integrated Pollution Prevention and Control Directive (2008/1/EC);
Discharges Directive 2010/75/EU on Industrial  The Waste Incineration Directive (2000/76/EC);
Emissions (integrated pollution prevention  The Solvent Emissions Directive (1999/13/EC); and
and control) (Industrial Emissions
 The three existing Directives on Titanium dioxide on (i) disposal (78/176/EEC), (ii)
Directive) monitoring and surveillance (82/883/EEC) and (iii) programs for the reduction of
pollution (92/112/EEC).
The Directive improves the interaction between the existing seven directives which it
replaces and strengthens, in several instances; some provisions in existing directives, for
A-39

example the Large Combustion Plant provisions.
The Pollution Prevention and Control Act 1999 implements the EC IPPC Directive into UK
law. More specifically Sections 1 and 2 of the Act confer on the Secretary of State
Pollution Prevention and Control Act 1999
power to make regulations providing for a new pollution control system to meet the
(applies to waters outside the 3 nm limit)
requirements of the IPPC Directive and for other measures to prevent and control
The Pollution Prevention and Control DECC pollution.
(Scotland) Regulations 2000 (as amended
The Pollution Prevention and Control (Scotland) Regulations 2000 enact the IPPC
2011)
Directive in Scotland and were made under the Pollution Prevention and Control Act
1999.
The Offshore Combustion Installations (Pollution Prevention and Control) Regulations
2013 (“the Offshore PPC Regulations 2013”) transpose the appropriate provisions of
Directive 2010/75/EU on industrial emissions (integrated pollution prevention and
control) (the Industrial Emissions Directive) into UK legislation.
The regulations replace previous IPPC 2001 and IPPC 2007 Regulations. However,
these regulations still apply for Permits granted before the 2013 Regulations came into
The Offshore Combustion Installations force.
(Pollution Prevention and Control) They apply to combustion installations located on offshore oil and gas platforms and
Regulations 2013 where an item of combustion plant on its own, or together with any other combustion
DECC
Offshore Combustion Installation plant installed on a platform, has a rated thermal input exceeding 50 MW(th).
(Prevention and Control of Pollution) Requirements included:
Regulations 2001 (as amended)  The operator to apply for a permit, in writing to Secretary of State with prescribed
information detailed in the Regulations;
 Secretary of State will publish applications in the Gazettes specifying where applications
can be obtained, and specifying a date not less than 4 weeks from the final Gazette
publication, by which public will be permitted to make representations;
 Public consultation period must be at least 28 days; and
 Permit will either be granted, along with conditions, or rejected (reasons for rejection will
A-40

be given).
Regular permit reviews are required to check whether the permit conditions are still
relevant. These will be carried out by DECC at least once every five years, following
which the Department may either request an application for a permit variation or
proceed to issue a revised permit.
The EU ETS Directive relates to six GHGs; however, to date only CO2 is covered. The
Directive applies to numerous installations, including those with combustion facilities
with a combined rated thermal input of >20 MW (th). The Directive has been amended
by three subsequent acts:
 EC Directive 2004/101;
 EC Directive 2008/101; and
EC Directive 2003/87 establishing a
 EC Directive 2009/29.
scheme for greenhouse gas emission
allowance trading with the community (as The revised Directive outlines Phase III of the EU ETS, which will take place between
amended by EC Directive 2009/29 2013 and 2020. Phase III includes:
CO2  Centralised, EU-wide cap which will decline annually by 1.74% delivering an overall
Combustions reduction of 21% below 2005 verified emissions by 2020;
Sources and  Adjustment of the EU ETS cap up to the 30% GHG reduction target when the EU ratifies
Emissions a future international climate agreement; and
 A significant increase in auctioning levels – at least 50% of allowances will be auctioned
from 2013; compared to around 3% in Phase II.
Greenhouse Gas Emissions Trading Scheme Regulations 2005 (as amended) provide a
Greenhouse Gas Emissions Trading framework for a GHG emissions trading scheme and implement Directive 2003/87/EC
Scheme Regulations 2005 (as amended establishing a scheme for GHG emission allowance trading. A permit is required to
2011) DECC emit GHG from combustion plants with an aggregate thermal rating of >20 MW(th) and
Greenhouse Gas Emissions Trading from flaring. The requirement must be registered and an application made from the UK
Scheme (Nitrous Oxide) Regulations 2011 allocation plan.
The purpose of the Greenhouse Gas Emissions Trading Scheme (Nitrous Oxide)
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Regulations 2011 is to enable the UK to take advantage of the option, accorded by
Article 24 of Directive 2003/87/EC, to apply the EU ETS to other greenhouse gases
and activities, in this case nitrous oxide (N2O) emissions from nitric acid production
(“the N2O opt-in”). For that purpose, the regulations detail an amended plan for the
allocation of allowances in line with the Greenhouse Gas Emissions Trading Scheme
Regulations 2005.
The Regulations give effect to two parts of the EU ETS Directive. Firstly, the Regulations
enable specified GHG emissions data to be collected. Secondly, the Regulations enable
The Greenhouse Gas Emissions Data and DECC and production and other data to be collected for the purpose of enabling the United
National Implementation Measures Environment Kingdom, as it is required to do so by the Directive, to publish and submit to the
Regulations 2009 Agency European Commission its national implementation measures for the third phase of the
GHG emission allowance trading scheme which commenced on 1st January 2013 (EU
ETS Phase III).
The Carbon Reduction Commitment (CRC) Energy Efficiency Scheme Order 2010 is a
CRC Energy Efficiency Scheme Order
DECC mandatory scheme designed to promote energy efficiency and reduce carbon
2010 (as amended 2013)
emissions.
Provisions relating to the control and prohibition of F-gas emissions including:
 Prevent and repair detected leakages of F-gases from all equipment covered by the EU
F-Gases Regulation;
 Undertake periodic leakage inspections to equipment that contains 3 kg or more of F-
Ozone EC Regulation 842/2006 DECC, gases;
Depleting Fluorinated Greenhouse Gases Defra and  Maintain records; and
Substances Regulations 2009 (as amended 2012) SEPA  Monitor and annually report (by 31 March each year) data to EEMS on all emissions of
HFCs / PFCs and SF6 from relevant equipment.
The Fluorinated Greenhouse Gases Regulations 2009 prescribe offences and penalties
applicable to infringements of EU Regulation 842/2006 on certain fluorinated
greenhouse gases (F-gases), amongst others, as well as dealing with other requirements
A-42

relating to leakage checking, reporting and labelling, together with proposed powers
for authorised persons to enforce these Regulations.
These Regulations also give effect to the following EC Regulations relating to certain
fluorinated GHGs:
 EC Regulation 1493/2007;
 EC Regulation 306/2008; and
 EC Regulation 307/2008.
These regulations consolidate and replace EC Regulation 2037/2000 as amended by

introducing tighter controls on the use/reuse of certain controlled substances.
EC Regulation No 1005/2009 on
DECC, UK Statutory Instruments providing for EC Regulation 2037/2000 will continue to be in
substances that deplete the ozone layer
Defra and force until updated/amended for the new consolidated Regulation (see pending
(as amended by EC Regulation No
SEPA legislation).
744/2010)
EC Regulation No 744/2010 extends the cut-off date for the use of certain essential
uses of halons in fire protection systems
The Environmental Protection (Controls on
Ozone Depleting Substances) Regulations The 2011 regulations revoke and replace the previous regulations. The regulations
2011 (revokes and replaces the enforce the provisions of EC Regulation 1005/2009 which controls the production,
DECC
Environmental Protection (Controls on impact, export, placing on the market, recovery, recycling, reclamation and destruction
Ozone Depleting Substances) Regulations of substances that deplete the ozone layer.
2002 (as amended 2008).
A-43
Energy Act 1976

Petroleum Act 1998 (as amended) Consent required for flaring or venting.
Pollution Prevention and Control Act The Model Clauses are incorporated into the Production Licences and require a flare
1999. and venting consent to be granted by DECC. Annual flare consents must be obtained
Flaring and
The Petroleum (Current Model Clauses) DECC from DECC. During commissioning and start up flare consents for short durations can
Venting
Order 1999 be issued until flaring levels have stabilised. Flaring requirements must not exceed
The Petroleum Licensing (Production) installations’ flare consent.
(Seaward Areas) Regulations 2008 All flaring and venting volumes must be reported to DECC.
Model Clauses of Licences
Food and Environment Protection Act DECC
1985 (as amended) supported by Discharges of sewage and grey and black water as part of routine operations are
CEFAS and
Deposits in the Sea (Exemptions) Order Marine
permitted discharges under the Deposits in the Sea (Exemptions) Order 1985.
1985 Scotland
Sewage from Requirement for ships to discharge sewage only under certain conditions:
Installations  Comminuted and disinfected sewage may only be discharged more than 4nm from the
MARPOL 73/78 Annex IV Regulations for coast;
the Prevention of Pollution by Sewage MCA  Non-comminuted or disinfected sewage may only be discharged 12nm from the coast;
from Ships and
 Original international regulations entered into force in September 2003 and the revised
annex entered into force in 2005.
The Waste Framework Directive establishes a legal framework for the treatment of waste
EC Directive 2006/12 (EU Waste
in the EU. It aims to protect the environment and human health through the prevention
Framework Directive) (repealed by EC
Waste SEPA of the harmful effects of waste generation and waste management. It does not apply to
Directive 2008/98) ( as amended by EC
the following (which are captured under various other regulations discussed):
Directive 2009/31
 Gaseous effluents;
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 Radioactive elements;
 Decommissioned explosives;
 Faecal matter;
 Waste waters;
 Animal by-products;
 Carcasses of animals that have died not from being slaughtered; and
 Elements resulting from mineral resources.
Commits the UK to a target of cutting landfill of biodegradable waste by two thirds by

2020.
National Waste Strategy 2000 (as SEPA and The Waste (Scotland) regulations 2012 apply onshore and transpose Articles 11(1) (re-
amended 2007) Local use and recycling) and 22 (bio-waste) of Directive 2008/98/EC on waste.
The Waste (Scotland) Regulations 2012 Authorities Waste transported onshore must be segregated and recycled and requires persons who
produce or manage controlled waste to take reasonable steps to ensure that high quality
waste is available for recycling.
There have been significant amendments to Annex V of MARPOL since it first entered
into force in 1998. The Merchant Shipping (Prevention of Pollution by Sewage and
Garbage from Ships) Regulations 2008 (as amended) supersedes Merchant Shipping
MARPOL Annex V: Prevention of pollution (Prevention of Pollution by Garbage from Ships) Regulations 1998 and brings the
by garbage from ships Maritime previous implementing regulations into line with the current version of Annex V.
The Merchant Shipping (Prevention of and Under the regulations:
Pollution by Sewage and Garbage from Coastguard  All wastes are to be segregated and stored and returned to shore for disposal;
Ships) Regulations 2008 (as amended Agency  No garbage is to be dumped overboard from an installation (including incinerator ashes
2010) from plastics as they may contain toxic or heavy metal residues);
 Food waste can be discharged only if ground to less than 25 mm particle size; and
 Installation must have a garbage management plan and suitable labelling and notices
displayed.
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Environmental Protection (Duty of Care)

SEPA Duty of Care requires correct segregation, identification and disposal of wastes.
Special Waste (Scotland) Regulations Under these Regulations Waste Transfer Notes (for general waste) and Waste
1997 (as amended) has been superseded Consignment Notes (for waste designated ‘Special’ in Scotland) are to be used for
SEPA
by the Special Waste Amendment hazardous wastes. In addition, the regulatory authorities need to be notified regarding
(Scotland) Regulations 2004. the disposal of hazardous or special waste.
The Waste Batteries (Scotland) Regulations 2009 amends the Pollution Prevention and
The Waste Batteries (Scotland) Control (Scotland) Regulations 2000/323 to ban incinerating waste industrial and
SEPA
Regulations 2009 automotive batteries and amends the Landfill (Scotland) Regulations 2003/235 to ban
waste industrial and vehicle batteries from landfills.
Deposits in the sea were regulated through the MCAA but, as a result of the Petroleum
Act 1998 (as amended) this does not apply to anything done:
 For the purpose of constructing a pipeline as respects any part of which an authorisation
Rock Dumping
(within the meaning of Part III of the Petroleum Act 1998 (as amended)) is in force; or
and Other
The Petroleum Act 1998 (as amended). DECC  For the purpose of establishing or maintaining an offshore installation within the
Deposits on
meaning of Part IV of that Act.
the Seabed
The application for consent to deposit items on the seabed required under the Petroleum
Act 1998 (as amended) for these activities is incorporated within the PWA and DepCon
process.
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DECOMMISSIONING
OSPAR Decision 98/3 concerns the decommissioning of installations. It requires that

decommissioning will normally remove the whole of an installation, although there are
some exceptions for large structures. Currently, there are no international guidelines
for the decommissioning of pipelines.
Under the terms of the OSPAR Decision 98/3 there is a prohibition on dumping and
leaving wholly or partly, in place of offshore installations. All installations installed
post 1999 should be removed entirely. For those installed pre 1999 the topsides must
be returned to shore and all installations with a jacket weight of less than 10,000
tonnes completely removed for re-use, recycling or final disposal on land with
Petroleum Act 1998 (as amended by the installations of greater than 10,000 tonnes being considered on an individual basis
Energy Act 2008 and in accordance with the base case being that they will be removed entirely.
with OSPAR Decision 98/3 )
Preliminary The Petroleum Act 1998 (as amended) sets out requirements for undertaking
Discussions IMO Guidelines and Standards for the decommissioning of offshore installations and pipelines including preparation and
removal of offshore installations and DECC submission of a Decommissioning Programme. Decommissioning proposals for
Decommissioning structures on the continental shelf 1989
Proposals pipelines should be contained with a separate Decommissioning Programme from that
DECC Guidance note for Industry of installations. However, programmes for both pipelines and installations in the same
Decommissioning of Offshore field may be submitted in one document.
Installations and Pipelines 2009 Part III of the Energy Act 2008 amends Part 4 of the Petroleum Act 1998 (as amended)
and contains provisions to enable the Secretary of State to make all relevant parties
liable for the decommissioning of an installation or pipeline; provide powers to require
decommissioning security at any time during the life of the installation and powers to
protect the funds put aside for decommissioning in case of insolvency of the relevant
party.
The Petroleum Act 1998 (as amended) stipulates that a decommissioning programme
needs to be prepared and agreed with DECC.
The main stages of the decommissioning process are:
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DECOMMISSIONING

Stage 1 - Preliminary discussions with DECC
Stage 2 – Detailed discussions submission and consideration of a draft programme
Stage 3 – Consultations with interested parties and the public
Stage 4 – Formal submission of a programme and approval under the Petroleum Act
(as amended)
Stage 5 – Commence main works and undertake site surveys
Stage 6 – Monitoring of site
Under the Petroleum Act, when a pipeline/umbilical is to be taken out of use the
Secretary of State has the option of immediately calling for a full decommissioning
programme. However, this is not always considered an appropriate option, e.g.
when the pipeline is out of use before EOFL, and so it has been agreed that
consideration will be given to handling suitable pipelines, under an informal
The Petroleum Act 1998 decommissioning regime, thereby deferring a formal programme until EOFL. This is
done by entering the pipeline into the Interim Pipeline Regime (IPR) via a Disused
Pipeline Notification (DPN). Where a pipeline/umbilical is to be left in situ consent,
via a DepCon, is required for any mattresses and/or rock dumping used to protect it.
Disused pipeline Where pipelines/umbilicals are removed/out of use, the PWA should be updated to
reflect this.
Marine and Coastal Access Act 2009 Pipeline/umbilical removal operations require a Marine Licence. Licences will be valid
(as amended 2011) for a maximum period of one year, however, applications for licence renewals can be
Marine (Scotland) Act 2010 made.
The use and/or discharge of any chemicals used to clean pipelines or umbilicals prior
Offshore Chemicals Regulations 2002 to recovery or abandonment should be permitted via PETS.
(as amended 2011) The discharge of residual chemicals in a pipeline during recovery is also subject to a
risk assessment however, this would require a Marine Licence.
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ACCIDENTAL EVENTS
In the event of an incident or accident involving an offshore installation where there may
be a risk of significant pollution of the marine environment or where the operator fails to
implement effective control and preventative operation the Government is given powers
to intervene.
Offshore Installations (Emergency Pollution
DECC DECC under agreement with MCA will notify the Secretary of State Representative
Control) Regulations 2002
(SOSREP) in the event of an incident if there is a threat of significant pollution into the
environment. The SOSREP’s role is to monitor and if necessary intervene to protect the
environment in the event of a threatened or actual pollution incident in connection with
an offshore installation.
The Oil Pollution Emergency Plan (OPEP) is a legally required emergency response
document which should aid the operator and any appropriate users to implement a
Oil Pollution
robust, effective and tested emergency response procedure. It should set out the
Emergency
“arrangements for responding to incidents which cause or may cause marine pollution
Planning The Merchant Shipping (Oil Pollution by oil, with a view to preventing such pollution or reducing or minimising its effect”.
(Installations) Preparedness, Response Co-operation DECC
Convention) Regulations 1998 All installations, infrastructure and activities that could give rise to an oil pollution event
on the UKCS must be covered by an OPEP. This requirement applies to fixed and
floating installations, including MoDUs (Mobile Offshore Drilling Units); gas, condensate
and oil pipelines; and subsea facilities, including any connected third party
infrastructure that is not the subject of a separate OPEP.
Offshore Chemical Regulations 2002 (as These Regulations require all use and/or discharge of chemicals at offshore oil and gas
amended 2011) installations to be covered under a permit system. Exceedance of discharge limits must
be reported.
Offshore Petroleum Activities (Oil Pollution DECC
Prevention and Control) Regulations 2005 Amendments to the Offshore Chemicals Regulations 2002 made under Schedule 2 of
(as amended 2011) the Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations
2005 (OPPC) increase the powers of DECC inspectors to investigate non-compliances
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ACCIDENTAL EVENTS

and risk of significant pollution from chemical discharges, including the issue of
prohibition or enforcement notices.
Under these Regulations it is an offence to make any discharge of oil other than in
accordance with the permit granted under these Regulations for oily discharges (e.g.
produced water). However, it will be a defence to prove that the breach of permit arose
from an event that could not be reasonably prevented.
OSPAR recommendation 2010/18 on the prevention of significant acute oil pollution
from offshore drilling activities came into force on 24th September 2010.
According to OSPAR recommendation 2010/18, contracting parties should:
OSPAR Recommendation 2010/18  Continue or, as a matter of urgency, start reviewing existing frameworks (i.e. the
regulatory mechanisms and associated guidance applied by the Contracting Parties in
the OSPAR area), including the permitting of drilling activities in extreme conditions.
Extreme conditions include, but are not limited to, depth, pressure and weather; and
 Evaluate activities on a case by case basis and prior to permitting.
EC Directive 2005/35 on ship-source pollution and on the introduction of penalties for

infringements states that ship-source polluting discharges constitute in principle a
criminal offence. According to the Directive this relates to discharges of oil or other
noxious substances from vessels. Minor discharges shall not automatically be
Oil Pollution considered as offences, except where their repetition leads to deterioration in the quality
The Merchant Shipping (Implementation of of the water, including in the case of repeated discharges.
Emergency
Ship-Source Pollution Directive) MCA The Directive applies to all vessels; polluting discharges are forbidden in:
Planning
Regulations 2009
(shipping)  Internal waters, including ports, of the EU;
 Territorial waters of an EU country;
 Straits used for international navigation subject to the regime of transit passage, as laid
down in the 1982 United Nations Convention on the Law of the Sea (UNCLOS);
 The exclusive economic zone (EEZ) of an EU country; and
A-50
ACCIDENTAL EVENTS

 The high seas.
The Merchant Shipping (Implementation of Ship-Source Pollution Directive) Regulations
2009 implement EU Directive 2005/35/EEC by making amendments to the following:
 The Merchant Shipping Act 1995;
 The Merchant Shipping (Prevention of Oil Pollution) Regulations 1996; and
 The Merchant Shipping (Dangerous or Noxious Liquid Substances in Bulk) Regulations
1996.
The Regulations limit the defences available to the master or owner of a ship involved in
an oil spill or chemical spill and extend liability for the discharge to others such as
charterers and classification societies. This closed a loop hole in the existing legislation
where some large spills were not open to prosecution under MARPOL.
Under the Pipeline Safety Regulations 1996 (as amended):
 Pipelines must be designated and constructed to ensure safe and effective shut-down in
Pipeline Health and
Pipelines Safety Regulations 1996 (as the event of an emergency;
Emergency Safety
amended 2003)  HSE must be notified of proposed pipeline construction; and
Prevention Executive
 Pipelines must have emergency shutdown valves and major accident prevention
documentation.
The Petroleum (Current Model Clauses)

Order 1999
All oil spills must be reported to DECC, the nearest HM coastguard and JNCC using a
Spill Reporting The Petroleum Licensing (Production) DECC
PON1.
(Seaward Areas) Regulations 2008
Model Clauses of Licence PON 1
A-51
WILDLIFE PROTECTION
The Directive establishes a framework for environmental liability based on the "polluter
pays" principle, with a view to preventing and remedying environmental damage.
EC Directive 2004/35 on Environmental Under the terms of the Directive, environmental damage is defined as:
Liability (as amended by EC Directive DEFRA  Direct or indirect damage to the aquatic environment covered by Community water management
legislation;
2009/31)
 Direct or indirect damage to species and natural habitats protected at Community level by the Birds
or Habitats Directives; and
 Direct or indirect contamination of the land which creates a significant risk to human health.
The Birds Directive aims to protect ranges of species, as well as population and
breeding, of certain populations of birds.
Birds and
Under the Birds Directive, Member States are to take measures to conserve certain
other Wildlife
EU Directive 2009/147/EC on the areas, including the establishment of Special Protection Areas (SPAs) both on land and
Protected Sites conservation of wild birds (the Birds within UK territorial waters.
and Species DEFRA
Directive) (as amended by EC Directive The Directive provides a framework for the conservation and management of, and
SACs and 2009/147) human interactions with, wild birds in Europe. It sets broad objectives for a wide range
SPAs of activities, although the precise legal mechanisms for their achievement are at the
discretion of each Member State (in the UK delivery is via several different statutes). The
Directive applies to the UK and to its overseas territory of Gibraltar.
The main aim of the Habitats Directive is to promote the maintenance of biodiversity by
EU Directive 92/43/EEC on the requiring Member States to take measures to maintain or restore natural habitats and
Conservation of natural habitats and of wild species listed on the Annexes to the Directive at a favourable conservation status,
wild fauna and flora (the Habitats introducing robust protection for those habitats and species of European importance.
Directive) (as amended by 97/62/EC and The regulations provide for the designation and protection of Special Areas of
2006/105/EC) Conservation (SACs). SACs and SPAs form the Natura 2000 European Network.
A-52
WILDLIFE PROTECTION
The Habitats Regulations 1994 (as amended in Scotland) provide the protection afforded to
European protected species (EPS) of animals and plants (those species listed on Annex IV of the
Habitats Directive whose natural range includes Great Britain).
EPS are listed on Schedules 2 (animals) and 4 (plants) of the Habitats Regulations 1994 (as
Habitats Regulations 1994
amended). These Regulations have been amended many times since 1994 including in 2007,
2008(a), 2008(b), 2009, 2011 and 2012. Only some of the species listed on Schedules 2 and 4
are found in Scotland. These include all species of cetacean, all marine turtles and sturgeon
(Acipenser sturio).
The Nature Conservation (Scotland) Act 2004 places duties on public bodies in relation to the
Marine conservation of biodiversity, increases protection for SSSIs, amends legislation on Nature
Nature Conservation (Scotland) Act 2004 Scotland, Conservation Orders, provides for Land Management Orders for Site of Special Scientific Interest
SNH, JNCC (SSSIs) and associated land, strengthens wildlife enforcement legislation, and requires the
preparation of a Scottish Fossil Code.
The Conservation (Natural Habitats &c.) Regulations 1994 (as amended) transpose the Habitats
and Birds Directives into UK law. They apply to land and to territorial waters out to 12 nm from
the coast and have been subsequently amended several times. In Scotland, the Habitats and Birds
Directives are transposed through a combination of the Conservation of Habitats and Species
Regulations 2010 (in relation to reserved matters) and the 1994 Regulations.
The Conservation (Natural Habitats &c.) The Conservation (Natural Habitats &c.) Amendment (Scotland) Regulations 2011 make
Regulations 1994 (as amended 2012) DECC, amendments to the 1994 regulations (in Scotland only). The amendments place a legislative
The Conservation of Species and Habitats Marine requirement on Scottish Ministers to classify SPAs in terrestrial and inshore environments. Since
Regulations 2010 (as amended 2012) Scotland, the Birds Directive first came into force in 1979, the UK government and Scottish Ministers (since
SNH, JNCC devolution) have actively delivered this responsibility without a legislative requirement (153 SPAs
The Conservation (Natural Habitats &c.) have been classified in Scotland to date). In recent years, SPAs have been identified in
Amendment (Scotland) Regulations 2011 accordance with agreed guidelines for the selection of SPAs which were published by the Joint
Nature Conservation Committee (JNCC) in 1999. The amendments came into force on 6th April
2011. The Conservation of Species and Habitats Regulations 2010 also implement aspects of the
Marine and Costal Access Act 2009.
A-53
WILDLIFE PROTECTION
These regulations transpose the Habitats Directive and the Birds Directive into UK law in
relation to oil and gas projects. The Regulations apply to the UK’s offshore marine area
The Offshore Marine Conservation (i.e. outside the 12 nm territorial limit) and English/Welsh territorial waters.
(Natural Habitats, &c) Regulations 2007 DECC
(as amended 2012) The 2012 Amended Regulations make various insertions for new enactments (e.g.
amendments to the Birds Directive by EC Directive 2009/147) and also devolve certain
powers to Scottish Ministers
The Ramsar convention aims to prevent encroachment or loss of wetlands on a
Convention on Wetland of International
worldwide scale, recognising the importance of a network of wetlands on waterfowl. It
Birds Importance Especially as Waterfowl DEFRA
is applicable to marine areas to a depth of 6m at low tide and other areas greater than
Habitats 1971 (The Ramsar Convention)
6m depth that are recognised as being important to waterfowl habitat.
Requires governments to undertake habitat management, conduct surveys and research
Agreement on the Conservation of Small and to enforce legislation to protect small cetaceans.
Marine
Cetaceans of the Baltic and North Seas
Cetaceans Scotland, Originally ASCOBANS only covered the North and Baltic Seas, as of February 2008
1991 (ASCOBANS) and 2008
Defra the ASCOBANS area has been extended to include the North East Atlantic and Irish
amendments
Sea.
In line with OSPAR Recommendation 2006/3, contracting Parties to OSPAR should
have phased out the discharge of offshore chemicals that are, or which contain
substances, identified as candidates for substitution, except for those chemicals where
OSPAR Recommendation 2006/3 on despite considerable efforts, it can be demonstrated that this is not feasible due to
Environmental Goals for the Discharge by technical or safety reasons. This should be done as soon as is practicable and not later
Chemical the Offshore Industry of Chemicals that than 1 January 2017.
DECC
Discharges are, or which Contain Substances
A UK National Plan for a phase out of chemicals to meet the requirements of the OSPAR
Identified as Candidates for Substitution –
Recommendation is being developed. This will involve continuation of the production
UK National Plan
permit review process and annual reporting to DECC, extending the scheme to term
permits and development of a prioritised National List of Candidates for Substitution.
A-54
WILDLIFE PROTECTION
The objectives of this Directive is to:

 Attain best industry practice throughout the EU based on primary duty of major accident
risk control with consequent leverage on global standards;
 Implement best regulatory practice for major accident prevention and mitigation via
General EU Offshore Safety Directive
independent expert regulators in every relevant member state;
 Implement fully joined up emergency preparedness and response procedures in all EU
offshore regions; and
 Improve and clarify existing EU liability and compensation provisions.
A-55
APPENDIX B
HABITAT ASSESSMENT DESK TOP STUDY

FUGRO EMU LIMITED
PENGUINS FPSO PROJECT,

UKCS BLOCK 211/14
Fugro Survey Report No: 140605-65V1.5

Fugro EMU Report No: J/3/25/2676
Volume 1 of 1: Habitat Assessment Desktop Study
Prepared for: Shell UK Limited

1 Altens Farm Road
Nigg
Aberdeen
AB12 3FY
United Kingdom
Client Reference Number: PRD-PT-GEN-00-D-HE-0702-00002 -

Habitat Assessment Desk Top Study
5 Final Report P. Collins P. Collins P. Collins 13 February 2015
4 FFA (4) P. Collins P. Collins P. Collins 12 February 2015
3 FFA (3) L. Molloy P. Collins P. Collins 22 September 2014
2 FFA (2) S. Archer A. Griffith A. Griffith 15 August 2014
1 FFA S. Archer A. Griffith A. Griffith 13 August 2014
0 Issued as Proof S. Archer P. Collins P. Collins 28 July 2014
Rev Description Prepared Checked Approved Date
Fugro EMU Limited

Morton Peto Road, Gapton Hall Industrial Estate, Great Yarmouth, Norfolk, NR31 0LT, United Kingdom
Tel: +44 (0)1493 414 423, Fax: +44 (0)1493 440 319, http://www.fugroemu.com
SHELL UK LIMITED
PENGUINS HABITAT ASSESSMENT DESKTOP STUDY, UKCS 211/14
FRONTISPIECE
FSLTD/Report No. 140605-65V1.5

SHELL UK LIMITED
DOCUMENT ARRANGEMENT
Volume 1: Habitat Assessment Desktop Study
CONTENTS
Page
1. INTRODUCTION AND SCOPE OF WORK 4

1.1 General 4
1.2 Scope of Work 6
1.2.1 Historical Geophysical Surveys of the Penguins site 6
1.3 Environmental Legislation and Background Information 8
1.3.1 Relevant Legislation 8
1.3.2 Background Information 9
1.4 Geodetic Parameters 11
2. METHODS 12
2.1 Hierarchical Habitat / Biotope Classification 12
2.2 Side Scan Sonar Data 12
2.3 Bathymetry 12
2.4 Video Data 12
2.5 Interpretation Methods 13
2.5.1 Seabed Habitats/Biotope Classification 13
3. RESULTS 14
3.1 Geophysical Data Review 14
3.1.1 Bathymetry 14
3.1.2 Side Scan Sonar and Interpreted Seabed Features 14
3.2 Video Data Analysis 18
3.2.1 EUNIS Classification 19
3.2.2 Epifauna 19
3.3 Comparison of ROV Video Data and Geophysical Data 21
3.4 Potentially Sensitive Habitats 25
3.4.1 Stony Reefs 25
3.4.2 Submarine Structures Made by Leaking Gas 26
3.4.3 Priority Marine Features 27
4. CONCLUSION 28
5. REFERENCES 29
FSLTD/Report No. 140605-65V1.5 Page i

SHELL UK LIMITED
APPENDICES
A. PERSONNEL
B. LOGS
B.1. VIDEO LOGS
C. SEABED PHOTOGRAPHS
D. SERVICE WARRANTY
TABLES
Table 1.1: Proposed FPSO Location 4

Table 1.2: Penguins FPF (proposed FPSO) Anchoring Location Survey Area (2011) Coordinates 6
Table 1.3: Proposed Penguins DC4 to Penguins DC5 Route (2011) Coordinates 7
Table 1.4: Proposed Penguins FPF to SALB Tee Route (2011) Coordinates 7
Table 1.5: Coordinates of the Centre of the Habitat Survey Area, UKCS Block 211/18 (2007) 8
Table 1.6: Coordinates of the Penguins ROV Video Transect (2005) 8
Table 1.7: Project Geodetic Parameters 11
Table 3.1: Habitat Classification Hierarchy 19
Table 3.2: Measures of Reefiness of the Stony Reef Habitat. 25
Table 3.3: Summary Results of the ‘Reefiness’ Assessment carried out on the ROV Transects 26
FIGURES
Figure 1.1: Coverage of historical and comparative survey data 5

Figure 3.1: Bathymetry data collected during the anchoring conditions survey, 2011 15
Figure 3.2: Overview of the data coverage of the site 16
Figure 3.3: Interpreted seabed features from the Penguins FPSO site anchoring survey 17
Figure 3.4: Example photographs for ‘slightly gravelly sand’ and ‘gravelly sand’ sediment types 18
Figure 3.5: Sediment boundaries from ROV video data overlain on interpreted seabed features 23
Figure 3.6: Terrain Ruggedness Index (TRI) across the site 24
FSLTD/Report No. 140605-65V1.5 Page ii

SHELL UK LIMITED
ABBREVIATIONS
3D Three Dimensional
CM Central Meridian
EC European Community
ED50 European Datum 1950
EUNIS European Natural Information System
FPF Floating Production Facility
FPSO Floating Production Storage and Offloading facility
FSLTD Fugro Survey Limited
Fugro EMU Fugro EMU Limited
JNCC Joint Nature Conservation Committee
km Kilometre
LAT Lowest Astronomical Tide
m Metre
MDAC Methane Derived Authigenic Carbonate
mm Millimetre
MPA Marine Protected Area
OSPAR Oslo-Paris Convention for the Protection of the Marine Environment of the North-East Atlantic
PMF Priority Marine Feature
ROV Remotely Operated Vehicle
SAC Special Area of Conservation
SPA Special Protected Area
SSS Side Scan Sonar
UKCS United Kingdom Continental Shelf
WGS84 World Geodetic System 1984
FSLTD/Report No. 140605-65V1.5 Page iii

SHELL UK LIMITED
EXECUTIVE SUMMARY
As part of the Penguins Redevelopment Project Fugro EMU Limited was contracted by Shell UK Limited to
perform a desk top study of data collected in the project area surrounding the proposed location of a new
Floating production, storage and offloading facility (FPSO) within the Penguins site. Historical geophysical and
video data was used to identify and map the habitats within the site with particular attention paid to the presence
of any potential sensitive habitats. The Penguins site falls within a region of the North Sea where there are
potential Annex I stony reef habitats. Specific attention was given to identifying any potential reef habitats, with
areas of coarse sediment identified on the video data assessed according to the JNCC guidelines which include
‘reefiness’ criteria (Irving, 2009).
Geophysical data used within this report was derived from surveys carried out in 2011 by Fugro Survey Limited
(FSLTD) in support of the placement of the Penguins floating production facility (FPF) and associated
infrastructure. Video data, used to validate the geophysical seabed features interpretation data, was collected
during the 2005 ROV pipeline survey between well 211/13aW and the Brent C platform. The video data covers
the north-east of the project area in one continuous line, split into separate contiguous transects. Interpretation
of the geophysical and video data was also compared to the results of the Don SW habitat and environmental
baseline survey carried out by FSLTD in 2007, located approximately 9 km south of the current survey.
The bathymetry and geophysical data were analysed to identify any differences in sediment type and any
distinct features which may be present within the site. Coverage was good (>100%) for bathymetry and low
resolution side scan sonar data. High resolution side scan sonar data was collected along four main lines
crossing the site, along with additional lines covering the area where the ROV video transects were taken.
Areas of sediment change were delineated and presented as a seabed features map. From the high resolution
side scan sonar data variations in sediment type were very subtle with only small changes in reflectivity,
indicating that sediment types across the site are likely to be very similar. Due to the subtlety of the changes in
reflectivity, sediment type changes could not be identified from the low resolution data. The two sediments types
were identified as areas of ‘Sand and gravel with cobbles, boulders and clay outcrops’ with patches of ‘Coarse
sediments – cobbles, boulders and clay outcrops’. Numerous boulders were identified across the site with the
majority showing heights of less than 1.0 m.
The ROV video data was reviewed noting changes in sediment/habitat type and epifaunal species. Two
sediment types were identified from the video data; ‘Slightly gravelly sand’ and ‘Gravelly sand’. The boundaries
between the two sediment types were often indistinct and generally transitioned between the two sediment
types over several metres of seabed. The areas of slightly gravelly sand and the patches of gravelly sand were
classified according to the EUNIS classification scheme as ‘Deep circalittoral coarse sediment’ (A5.14) and
‘Deep circalittoral mixed sediment’ (A5.45), respectively. The epifaunal community of both habitats was
characterised by an extremely sparse community of echinoderms and cnidarians. Similar epifaunal communities
were observed at the Don SW site survey with echinoderms being the prominent group. Sponges were also
observed at the Don SW survey, which were not recorded at the Penguins site. However, due to the very similar
depth and sediment types between the two sites, sponges are likely to be present but were not visible from the
ROV video data.
The similarities between the two sites also mean that the infaunal community is likely to be very similar. The
community at Don SW was dominated by annelids such as Spiophanes kroyeri, Galathowenia oculata and
FSLTD/Report No. 140605-65V1.5 Page 1

SHELL UK LIMITED
Glycera lapidum. Infaunal communities at the Don SW site, and likely at the Penguins site, were found to be
influenced by sediment size. Where higher proportions of coarse material were recorded, higher abundances of
epilithic taxa were also recorded.
The analysis of the ROV video data, in particular the changes in sediment type, were compared to the
geophysical data interpretation and seabed features interpretation. The video data was in general agreement
with the interpreted seabed features, in particular with the location of the areas of coarser sediment. However
some areas of coarser sediment identified on the video data were not identified from the geophysical data. The
areas interpreted as ‘Coarse sediments – cobbles, boulders and clay outcrops’ from the geophysical data were
actually found to have very low quantities of cobbles and boulders and differed from the surrounding seabed of
‘slightly gravelly sand’ by a marginally higher proportion of gravelly material.
Terrain modelling was used to analyse the ruggedness of the survey area and identify areas of potential stony
reef. Terrain ruggedness is a measure of the local variation in seabed terrain about a central pixel and is useful
in identifying local small scale variations in bathymetry which may indicate the presence of structures, such as
stony reefs. Areas surveyed by the camera and high resolution side scan sonar data were found to show very
low TRI values indicative of a level seabed. The low TRI values continued across the whole of the Penguins site
indicating that there are no features which are elevated above the ambient seabed. While the low resolution of
the available bathymetry data for the survey area means that this analysis cannot be used to give a definitive
assessment of the presence or absence of stony reef, it provides useful information to support the analysis of
geophysical and seabed video data.
The ROV video data was also assessed for ‘reefiness’ in accordance with the JNCC guidelines criteria (Irving,
2009). The criteria looks into the total cover of cobbles and boulders, the elevation above the ambient seabed
and the cover of epifaunal species scoring each as either having a high, medium or low ‘reefiness’, or as ‘not a
reef’. All the areas covered by the ROV video transect, for both cover of cobbles and boulders and cover of
epifaunal species were found to be classified as ‘not a reef’. No other potential sensitive habitats were identified
from the geophysical or video data.

SHELL UK LIMITED
SUMMARY OF SURVEY RESULTS
Geodetic Datum International Spheroid, ED50 - EPSG 1311, CM 0°E

Location: Location Latitude Longitude Easting [m] Northing [m]
Penguins FPSO 061° 32' 08.313" N 001° 36' 04.584" E 585 438 6 823 498
Project Area: The project area focused on a 3 km by 3 km grid centred on the location of the
Penguins FPSO and the pipeline routes running from the Penguins FPSO location to
DC4, DC5 and SALB Tee.
Study Strategy: Historical geophysical data, collected in 2011, was analysed in association with ROV
video data collected in 2005, to map and identify the habitats which occur in the
Penguins site. Particular attention was paid to potential sensitive habitats.
Bathymetry: The water depth across the Penguins site ranged from 158.3 m (LAT) to 165.1 m (LAT)
sloping gently from the east north-east to the west-south-west. Several small
depressions were identified in the centre and eastern parts of the survey.
Seabed Features: Numerous objects, interpreted as boulders, were identified across the site, with the
majority having heights of less than 1.0 m. Two sediment types were identified on the
areas of high resolution (410 kHz) side scan sonar data record; sand and areas of
coarse material.
General Analysis the video data confirmed the presence of two sediment types; ‘slightly gravelly
Habitats/Biotopes: sand’ and ‘gravelly sand with occasional cobbles and boulders’. These two sediment
types were classified under the EUNIS classification system as ‘Deep Circalittoral
Coarse Sediment (A5.14)’ and ‘Deep Circalittoral Mixed Sediment (A5.45)’. It is thought
that the two biotopes extend across the whole site in roughly equal proportions.
The visible epifaunal community was sparse with occasional echinoderms, such as sea
stars (Asteroidea) and urchins (Echinoidea), being identified from the video data.
Potential Sensitive No potential sensitive habitats were identified from the video or geophysical data.
Habitats:

SHELL UK LIMITED
1. INTRODUCTION AND SCOPE OF WORK
1.1 General
Fugro EMU Limited (Fugro EMU) was contracted by Shell UK Limited to perform a desktop habitat
study review of existing geophysical and camera data from the project area around the proposed
Penguins Floating Production, Storage and Offloading facility (FPSO) in UKCS Block 211/14 and
211/13a.The study was required prior to the emplacement of the FPSO on the site. The coordinates
for the proposed FPSO location are given in Table 1.1.
The Penguins fields are located in the northern North Sea within the Strategic Environmental
Assessment 2 extension area (SEA2 Extension). The SEA2 area has been highlighted as an area of
potential stony reef habitat which comes under Annex I of the habitats directive. If the area is deemed
to meet the Annex I descriptions, it may be afforded protection as a special area of conservation
(SAC).
Geophysical data acquired by FSLTD (2011) from three surveys within the Penguins project area,
together with ROV video data from a pipeline route survey conducted by Gardline Environmental
Limited, in 2005, were used to describe the character of the project area. Sections of the ROV video
data covering areas of differing acoustic facies on the geophysical data (FSLTD, 2011), were reviewed
and assessed for the presence of habitats of conservation importance.
The interpretation of the ROV video data collected in 2005 was considered to be appropriate for the
project area, because habitats such as stony reef are formed over geological timescales, when stable
boulders and cobbles arise from the seabed (Irving, 2009) and MDAC is accreted naturally over long
time periods (Tobin, Bower, Blasdale, & McLeod, 2013). Therefore, the presence/absence of such
features is unlikely to have change in the space of nine years between acquisition of the ROV video
data and the present time.
Table 1.1: Proposed FPSO Location

Location Easting [m] Northing [m] Latitude Longitude
Penguins FPSO 585 438 6 823 498 061° 32' 08.313" N 001° 36' 04.584" E
The Service Warranty in Appendix D outlines the limitations of this report.

SHELL UK LIMITED
Figure 1.1: Coverage of historical and comparative survey data

SHELL UK LIMITED
1.2 Scope of Work

The scope of this desktop study includes:
• Review of the historical geophysical data (multibeam echo sounder and side scan sonar) for the
Penguins sites, identifying and mapping habitats and any areas of potential protected habitats.
Data utilised during this report came from the following reports:
 Anchoring Conditions Survey (2011) - Penguins FPF, FSLTD Report No.

6500714.4aV1
 Pipeline Route Survey (2011) - Penguins DC4 to Penguins DC5, FSLTD Report No.
6500714.4bV1
 Pipeline Route Survey (2011) - Proposed Penguins FPF to SALB, FSLTD Report No.
6500714.4dV1
• Comparisons to environmental surveys carried out in the region which displays similar physical
characteristics to the Penguins site. Specifically the habitat assessment and environmental
baseline survey carried out for:
 Don South-West Site (2007) - UKCS Block 211/18, FSLTD Report No. 9320.1V2
• Interpretation of video data collected by ROV during a pipeline route survey carried out in the
Penguins project area in 2005
• Particular attention was paid to the areas identified during the geophysical anchoring conditions
survey, as ‘areas of coarse sediment – cobbles, boulders and clay outcrops’ and the
depressions recorded across the site, as these may constitute potential sensitive habitats.
1.2.1 Historical Geophysical Surveys of the Penguins site

The coverage of the historical geophysical data and the comparative habitat assessment data is
displayed in Figure 1.1. The geophysical data being used for the current desktop habitat study was
collected from three surveys, conducted during the Penguins survey cruise in 2011.
1.2.1.1 Anchoring Conditions Survey (Site Survey, 2011)

The anchoring conditions survey was completed between 3 and 17 September 2011 by FSLTD
(FSLTD Report No. 6500714.4a). The anchoring conditions survey (2011) was required to provide
information on shallow soils, anchoring conditions, seabed obstructions and bathymetry within a
3.5 km x 3.5 km project area around the proposed previously planned Penguins floating production
facility (FPF) location. The limits of the survey are detailed in Table 1.2.
Table 1.2: Penguins FPF (theFPSO) Anchoring Location Survey Area (2011) Coordinates
Corner Point Easting [m] Northing [m] Latitude Longitude
A 583 970.5 6 825 709.8 61° 33' 15.422"N 01° 34' 48.647"E
B 583 970.5 6 822 209.8 61° 31' 22.358"N 01° 34' 42.905"E
C 587 470.5 6 822 209.8 61° 31' 19.562"N 01° 38' 39.663"E
D 587 470.5 6 825 709.8 61° 33' 12.623"N 01° 38' 45.644"E

SHELL UK LIMITED
1.2.1.2 Pipeline Route Survey (2011), Penguins DC4 to Penguins DC5

The pipeline route survey between Penguins DC4 and Penguins DC5 was completed between 3 and
17 September 2011 by FSLTD (Report No. 00714.4bV1). The pipeline route survey (2011) was
required to provide information on bathymetry, seabed features, installation constraints, and shallow
soils along the 4.800 km route. The pipeline route coordinates are detailed in Table 1.3.
Table 1.3: Proposed Penguins DC4 to Penguins DC5 Route (2011) Coordinates
Penguins DC4 (offset) 585 400 6 826 947 61° 33' 54.259"N 01° 36' 27.512"E
Point 1 586 185 6 825 889 61° 33' 19.453"N 01° 37' 18.902"E
Point 2 586 997 6 825 052 61° 32' 51.759"N 01° 38' 12.463"E
Point 3 587 428 6 824 531 61° 32' 34.578"N 01° 38' 40.751"E
Point 4 587 799 6 824 075 61° 32' 19.545"N 01° 39' 05.081"E
Penguins DC5 (offset) 588 348 6 823 177 61° 31' 50.086"N 01° 39' 40.687"E
1.2.1.3 Pipeline Route Survey (2011), Proposed Penguins FPF to SALB

The pipeline route survey between the previously planned Penguins FPF and the Single Anchor
Loading Buoy (SALB) Tee was completed between 3 and 17 September 2011 by FSLTD (Report No.
00714.4dV1). The pipeline route survey (2011) was required to provide information on bathymetry,
seabed features, installation constraints, and shallow soils along a 15.248 km route between proposed
Penguins FPF and the SALB Tee. The pipeline route coordinates are detailed in Table 1.4.
Table 1.4: Proposed Penguins FPF to SALB Tee Route (2011) Coordinates
Proposed Penguins FPF 585 721 6 823 960 61° 32' 17.505"N 01° 36' 44.215"E
Proposed FPF Riser Base 585 982 6 823 698 61° 32' 08.836"N 01° 37' 01.459"E
Change of Direction 585 987 6 823 693 61° 32' 08.670"N 01° 37' 01.783"E
Point 1 586 221 6 822 978 61° 31' 45.398"N 01° 37' 16.422"E
Point 2 586 283 6 822 726 61° 31' 37.208"N 01° 37' 20.172"E
Point 3 586 781 6 819 712 61° 29' 59.444"N 01° 37' 48.790"E
Point 4 586 538 6 818 522 61° 29' 21.192"N 01° 37' 30.345"E
Point 5 584 406 6 815 173 61° 27' 34.704"N 01° 35' 00.781"E
Point 6 583 449 6 814 455 61° 27' 12.236"N 01° 33' 55.026"E
SALB Tee 579 256 6 813 227 61° 26' 35.760"N 01° 29' 10.091"E
1.2.1.4 Other Surveys

Reference will also be made to a previous habitat and environmental baseline survey carried out by
FSLTD, in 2007, for Petrofac Facilities (now Enquest) at the Don South-West site, in UKCS Block
211/18. This survey data has been utilised with the permission of Enquest. The habitat investigation
involved twenty camera and grab stations across a 3 km by 3 km site which was dominated by iceberg
ploughmarks within a seabed sediment of predominantly fine to medium sand. The coordinates of the
centre of the survey area are given in Table 1.5 along with the distance to the Penguin site.

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Table 1.5: Coordinates of the Centre of the Habitat Survey Area, UKCS Block 211/18 (2007)
Location Easting [m] Northing [m] Latitude: Longitude:
Centre of Site 581 738 6 815 797 61° 28' 02.178''N 1° 32' 02.201''E
Distance to Penguin Site: 8.9 km
ROV data acquired from a previous survey conducted in the Penguins field were reviewed. The ROV
data was collected as part of a pipeline route survey, by Gardline Environmental Limited in 2005. The
proposed pipeline ran between the Brent C platform in UKCS Block 211/29 and the Penguins Drill
Centre DC2 in UKCS Block 211/13aW Table 1.6. A stony reef assessment has been conducted on the
acquired video data as part of the current desktop habitat study.
Table 1.6: Coordinates of the Penguins ROV Video Transect (2005)

Location Easting [m] Northing [m]
Start of Transect 579 244 6 833 958
End of Transect 592 889 6 774 852
1.3 Environmental Legislation and Background Information
1.3.1 Relevant Legislation

Council Directive 92/43/EEC on the Conservation of natural habitats and of wild fauna and flora,
commonly known as the EC Habitats Directive, was adopted in 1992, with the main aim of promoting
maintenance of biodiversity at a European level. Member States are required to take measures to
ensure that protection is afforded to habitats and species of European importance, and that these
features are restored to a ‘favourable conservation status’. These species and habitats are listed
under Annexes of the Directive, and may be selected as features for which Natura 2000 protected
areas are designated; Special Areas of Conservation (SACs) and Special Protected Areas (SPAs).
The Annexes include species and habitats identified by the Oslo-Paris Convention for the Protection of
the Marine Environment of the North-East Atlantic (OSPAR), and detailed on the OSPAR list of
threatened and/or declining species and habitats. This habitat investigation was undertaken in part to
satisfy the Habitats Directive requirement of surveillance for Annex I habitats, on the basis of which
SACs may be designated.
Annex I habitats of relevance for the offshore industry include ‘reefs’, ‘sandbanks slightly covered by
seawater all the time’ and ‘submarine structures made by leaking gases’. This investigation will pay
particular attention to ‘stony reefs’ and ‘submarine structures made by leaking gases’ which are both
thought to occur in the wider region encompassing the Penguins project area.
The more recent implementation of marine conservation legislation by the United Kingdom, the Marine
and Coastal Access Act (2009) and the Marine (Scotland) Act (2010), has led to a further initiative to
designate marine protected areas, as part of a comprehensive reform of domestic marine and coastal
resource management. A network of marine protected areas are currently undergoing consideration

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for designation, and have been located to provide linkage with, and compliment the conservation
objectives of Natura 2000 sites. These areas provide increased protection for habitats and species
which are considered vulnerable on a regional or national level, in addition to representative examples
of broad habitats. In Scottish waters, this process is being led by Marine Scotland and the JNCC, who
have proposed a number of Marine Protected Areas (MPAs) for designation. MPAs are selected to
protect a range of Priority Marine Features (PMFs) which incorporate seabed habitats and large-scale
features of functional importance to Scotland’s seas, in addition to low or limited mobility species and
highly mobile species (Marine Scotland & JNCC, 2011). These features incorporate habitats and
species included on the OSPAR list of threatened and / or declining species and habitats, in addition
to those included in the UK Biodiversity Action Plan (UKBAP) Priority List, and the Scottish Biodiversity
List. This habitat investigation will assess the occurrence of relevant PMFs, which in the Penguins
project area are thought most likely to comprise the broad habitat ‘offshore subtidal sands and
gravels’, based on UK SeaMap 2010 predictive mapping of seabed habitats in UK waters (UKSeaMap,
2010).
1.3.2 Background Information

The predicted EUNIS habitats in the wider region around the Penguins project area, based on the are
either ‘Deep Circalittoral Sand’ (A5.27) or ‘Deep Circalittoral Coarse Sediment’ (A5.15), based on
predictive modelling undertaken by UK nature conservation agencies (UKSeaMap, 2010).
1.3.2.1 Stony Reefs

Stony reefs occur when hard compact substrata, specifically cobbles or boulders (>64 mm in
diameter), arise from the surrounding seabed thus creating a stable substrate for colonisation by
faunal and algal communities. The habitat may be extremely variable in structure, and a definitive
interpretation of the term ‘stony reef’ has been the subject of some debate. Patchiness and stability
are thought to be instrumental in the efficacy of stony reef habitat, however Annex I habitat status is
primarily conferred based on assessment of cobble and boulder composition, elevation from the
seabed and epifaunal cover (Irving, 2009).
Special Areas of Conservation (SACs) encompassing Annex I stony reef habitats have been
designated throughout the UK; at sites such as Flamborough Head, North Yorkshire, and Lundy,
Devon authority. However, the ‘offshore area of search’ for this habitat is concentrated predominantly
to the north and north-west of Scotland, in offshore waters where glacial deposition, glacial and late
glacial iceberg movement have influenced the distribution of stony reef sediments (Belderson, Kenyon,
& Wilson, 1973). Glacial till, or moraine, sediments exist within the northern North Sea as a result of
substantial glaciation during the early Weichselian period, when coarse material was disturbed and
deposited as a result of glacial action (Carr, 2004).
Communities associated with stony reefs vary in composition dependent on a host of environmental
variables and may incorporate a range of trophic levels. Stony reef faunal communities are usually
characterised by a diverse assemblage of sessile or sedentary epifauna which may include hermatypic
corals (i.e. Scleractinia), ahermatypic corals (i.e. Alcyonaria, Gorgonacea), bryozoans (Bryozoa),
hydroids (Hydroida), sponges (Porifera), anemones (Ascidiacea), faunal turfs or encrustations. The
structural complexity of the stony reef substrate is also associated with increased abundance and
richness of motile epifauna. Echinoderms are commonly encountered, including sea urchins

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(Echinoidea), sea stars (Asteroidea), sea cucumbers (Holothuroidea), brittlestars (Ophiuroidea) and
basketstars (Euryalina), in addition to crustracean fauna i.e. crabs (Brachyura), hermit crabs
(Paguridae) and squat lobsters (Galatheoidea). Rich benthic communities are in turn commonly
associated with increased fish abundance. In areas where stony reefs occur within the euphotic zone,
communities may be dominated by algal assemblages.
1.3.2.2 Submarine Structures Made by Leaking Gases

Submarine structures made by leaking gases are defined by the JNCC as ‘rocks, pavements and
pillars up to four metres high and composed of carbonate cement’. The cement is produced by
microbial oxidation of gases (mostly methane) that bubble up from below the sea floor. This biogenic
cement is referred to as MDAC (methane-derived authigenic carbonate). Within UK waters this habitat
is mainly (but not exclusively) associated with pockmarks in the northern North Sea as well as parts of
the Irish Sea (Jackson & McLeod, Revised 2002).
Carbonates provide a hard substratum for colonisation and refuge, and support a faunal assemblage
similar to that of stony reef (Judd, 2001), which is different from the surrounding soft sediment.
Epifaunal communities in the vicinity of MDAC typically show an increased number of anemones and
hydroids. Additionally if the seep is active, mat-forming sulphur oxidising bacteria may be evident
(Judd, 2001).

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1.4 Geodetic Parameters

All coordinates detailed in this report are referenced to the International 1924 Spheroid, the ED50
datum and Transverse Mercator projection (Table 1.7).
Table 1.7: Project Geodetic Parameters

(1)
Global Positioning System Geodetic Parameters
Datum: World Geodetic System 1984 (WGS84)
Spheroid: World Geodetic System 1984
Semi major axis: a = 6 378 137.000 m
1
Reciprocal Flattening: /f = 298.257 223 563
Local Geodetic Datum Parameters
Datum: European Datum 1950 (ED50)
Spheroid: International 1924
Semi major axis: a = 6 378 388.000 m
1
Reciprocal Flattening: /f = 297.000 000 000
(2)
Datum Transformation Parameters from WGS84 to ED50
Shift dX: +89.500 m Rotation rX: 0.000 arc sec Scale Factor: -1.200 ppm
Shift dY: +93.800 m Rotation rY: 0.000 arc sec
Shift dZ: +123.100 m Rotation rZ: -0.156 arc sec
Project Projection Parameters
Grid Projection: Transverse Mercator, Northern Hemisphere
Central Meridian: 0° 00′ 00″ East
Latitude of Origin: 00° 00′ 00″ North
False Easting: 500 000 m
False Northing: 0m
Scale factor on Central Meridian: 0.9996
Units: metre
Notes:
1) Fugro Starfix navigation software always uses WGS84 geodetic parameters as a primary datum for any geodetic
calculations.
2) This is the right-hand coordinate frame rotation used by the Fugro Starfix navigation software.

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2. METHODS
2.1 Hierarchical Habitat / Biotope Classification

A marine biotope classification system for British waters has been developed by Connor et al. (2004)
from data acquired during the Joint Nature Conservation Committee (JNCC) Marine Nature
Conservation Review (MNCR). This classification system is analogous with the European Nature
Information Service Habitat Classification (EUNIS, 2013), which has compiled habitat information from
across Europe into a single database. The two classification systems are both based around the same
hierarchical analysis. Initially abiotic habitats are defined at four levels; biological communities are then
linked to these (at two lower levels) to produce a biotope classification. For the purposes of this report
the EUNIS coding system was used for classification of biotopes.
2.2 Side Scan Sonar Data

The historical side scan sonar data were acquired during geophysical surveys completed by FSLTD
(FSLTD, 2011), provided as mosaicked digital GeoTiff files and imported into Surfer V10 for review.
The data were studied to identify and delineate any features indicative of potential submarine
structures made by leaking gas, stony reef structures or other potential protected habitat.
2.3 Bathymetry
Multibeam bathymetry data were acquired during the geophysical surveys completed by FSLTD
(FSLTD, 2011) and reviewed as light-illuminated colour shaded 3D surface and relief images; created
directly from multibeam bathymetry data. As with the side scan sonar data, bathymetry data were
reviewed to identify and delineate any features indicative of potential submarine structures made by
leaking gas, stony reef structures or any areas of other potential protected habitat.
Bathymetry data was also processed using the Terrain Ruggedness Index as described in Wilson et
al. (2007). Ruggedness is a measure of the local variation in the seabed terrain about a central pixel.
As variations in seabed terrain are often associated with changes in habitat this technique is especially
useful for identifying habitats associated with rugged terrain, such as stony reefs and MDAC habitats,
in areas of predominantly sandy sediments.
2.4 Video Data

Video data was acquired by Gardline Environmental Limited during an ROV pipeline route survey
(2005) from well 211/13aW to the Brent C platform. The ROV video data crosses the north-east corner
of the site allowing verification of the features identified from the geophysical data. This interpretation
was then extrapolated across the available geophysical data for the remainder of the Penguins site.
The interpretation of data collected in 2005 was considered to be representative in this case due to the
nature of the potential sensitive habitats; see Section 1.1 for more details.

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2.5 Interpretation Methods
2.5.1 Seabed Habitats/Biotope Classification

To assess habitats present within the Penguins project area, detailed analysis of video data was
undertaken by experienced Fugro marine biologists / taxonomists. Video data were reviewed noting
the locations of any observed changes in sediment type and/or associated faunal community.
Seabed sediments have been described based on the seabed video/photographic data. Descriptions
are based on the Folk classification (Folk, 1954) which uses the descriptive terms ‘mud’ ‘sand’ and
‘gravel’ in combinations depending on the estimated proportions of each component. For example, a
description of ‘muddy sand’ defines sediment which has sand as the principle component and a mud
proportion of between <50% and >10%. Further colloquial descriptive terms have also been used to
better describe the observations where necessary, for example terms such as ‘cobbles, boulders, or
pebbles’ may be referred to the EUNIS habitat coding system.

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3. RESULTS
3.1 Geophysical Data Review

Geophysical data was originally reviewed as part of the anchoring conditions survey and pipeline route
surveys carried out in 2011 by FSLTD (FSLTD Report No. 00714.4a, b and d).
3.1.1 Bathymetry
The seabed within the project area was recorded as being relatively flat and gently sloping down from
the east-north-east to the west-south-west (Figure 3.1). The water depth across the site ranged from
158.3 m LAT in the south-east to a maximum of 165.1 m LAT in the south-west.
Two shallow (0.2 – 0.3 m deep) relict iceberg ploughmarks run in a north to south direction across the
central part of the current project area and have been depicted on Figure 3.1 . Several small
depressions were recorded around the centre of the proposed FPSO project area, along with an
increased density of these depressions east of the project area. The depressions were found to range
in depth between 0.1 and 0.3 m.
No distinct bathymetric features, which may constitute a potential sensitive habitat, were identified
from the data in the area surrounding the proposed Penguins FPSO location.
3.1.2 Side Scan Sonar and Interpreted Seabed Features

The majority of the seabed was classified as ‘Sand and gravel with cobbles, boulders and clay
outcrops’ from the geophysical data, while numerous patches were delineated and classified as ‘Areas
of coarse sediment – cobbles boulders and clay outcrops’. The areas interpreted as comprising
‘cobbles, small boulders and clay outcrops’ were primarily mapped from the high resolution (410 kHz)
side scan sonar data as it was difficult to distinguish between the two sediment types from the lower
resolution (120 kHz) side scan sonar data that covers the remainder of the Penguins FPSO survey.
The high resolution SSS data covers the DC4 to DC5 pipeline route as well as 4 main lines which
cross at the Penguins FPSO location. The areas covered by high resolution SSS and lower resolution
SSS are displayed in Figure 3.2.
The areas delineated as ‘coarse sediment’ are displayed on Figure 3.3 and are thought to extend past
the limits of the high resolution data and across the entire site. Occurrences of the areas of coarse
sediment were fairly regular and were especially dense at the centre of the survey area, to the
north-east of the proposed FPSO location. Interpreted areas of delineated ‘cobbles and boulders’
covered 17.3% of the surface area covered by high resolution data. It is likely that a similar percentage
of the wider project area, surveyed by low resolution SSS, is characterised by the same seabed facies,
but this cannot be reliably quantified without high resolution data for the entire project area. Numerous
boulders have been identified in the survey area, with the majority found in areas identified as coarse
sediment. The majority of the boulders showed heights of less than 1.0 m.

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Figure 3.1: Bathymetry data collected during the anchoring conditions survey, 2011

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Figure 3.2: Overview of the data coverage of the site

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Figure 3.3: Interpreted seabed features from the Penguins FPSO site anchoring survey

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3.2 Video Data Analysis

ROV video data were selected for review, targeting transects showing transitions between the two
interpreted seabed features types (‘sand and gravel with cobbles, boulders and clay outcrops’ and
‘areas of coarse sediment-cobbles, boulders and clay outcrops’). Transects PL003 and PL004 were
reviewed (Figure 3.3), which crossed the north-east portion of the project area, including the area of
high resolution SSS data collected during the DC4 to DC5 route survey (FSLTD Report No.
00714.4bV1). The sediment types along the two transects were recorded and any observed
boundaries between different sediments/habitats were noted. Full analysis of the video data is detailed
in Appendix B.1.
Two sediment types were recorded along the ROV transects with the total area covered being evenly
spread between the two sediment types. The first sediment type can be described as ‘gravelly sand’
with occasional cobbles and boulders, while the other sediment type can be described as ‘slightly
gravelly sand’. Of the 7670 m of video transect covered by the ROV, 51% consists of the ‘gravelly
sand’ sediment while 49% consists of ‘slightly gravelly sand’. It should be noted that the ROV data
reviewed in the current study was selected to target areas of interest and, as such, the wider project
area is unlikely to show a similarly equitable distribution of the two sediment types. Example images of
the two sediment types are displayed in Figure 3.4 and Appendix C.
Boundaries between the two sediment types were often indistinct and generally transitioned between
the two sediment types over several metres of seabed. The similarities between the two sediment
types and the indistinct boundaries may make delineation from the geophysical data problematic and
any delineated boundary may vary from that recorded on the video data by several metres.
Sediment Type: Slightly gravelly sand Sediment Type: Gravelly sand
Figure 3.4: Example photographs for ‘slightly gravelly sand’ and ‘gravelly sand’ sediment types

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3.2.1 EUNIS Classification

Habitats were classified to biotope complex according to the EUNIS classification system. The
equivalent classification from ‘The Marine Habitat Classification for Britain and Ireland – Version 04.05’
(Connor et al. 2004) was also noted. The areas of gravelly sand were classified as ‘Deep circalittoral
coarse sediment’ (A5.14), while the areas of slightly gravelly sand were classified as ‘Deep circalittoral
mixed sediment’ (A5.45). However, due to the very similar nature of the two sediment types it is
possible that all the areas observed on the video transects will fall under one broad habitat type.
Particle size analysis of seabed samples would be required to ascertain which biotope the entire site
should be classified under.
Table 3.1: Habitat Classification Hierarchy

EUNIS Habitat Classification
Connor et al. (2004)
Environment Broad Habitat Habitat Complex Biotope Complex Classification
(Level 1) (Level 2) (Level 3) (Level 4)
Sublittoral Coarse Deep Circalittoral
Offshore circalittoral coarse
Sediment Coarse Sediment
Sublittoral sediment (SS.SCS.OCS)
(A5.1) (A5.14)
Marine (A) Sediment
(A5) Sublittoral Mixed Deep Circalittoral
Offshore Circalittoral Mixed
Sediment Mixed Sediment
Sediment (SS.Smx.Omx)
(A5.4) (A5.45)
3.2.2 Epifauna
The very similar nature of the two sediment types meant that the epifaunal communities recorded
along the transects were very similar with no noticeable difference in abundance or taxa. Echinoderms
made up the majority of the very sparse community with seastars (Asteroidea including Astropecten
irregularis), cushion stars (Asteroidea), sea cucumbers (Holothuroidea) and sea urchins (Echinoidea);
while the occasional anemone (Actiniaria) and sea pen (Pennatulacea) were also observed. Due to
the low resolution of the video data and the absence of any still photographs, identification of taxa to
species level was problematic and smaller epifaunal species may have been missed during the
analysis.
The epifaunal community was found to be similar to the community recorded during the environmental
survey of the Don SW site (UKCS Block 211/18, 2007) in the areas of coarse sediment. Echinoderms
were also prominent with sea stars (Astropecten irregularis, Asterias rubens, Luidia sp. and Henricia
sp.), cushion stars (probably Ceramaster sp. or Porania sp.) and sea urchins (probably Echinus sp.)
being recorded in many of the stills.
Higher abundances of both sessile and motile epifauna were found during the Don SW survey (2007)
in areas of cobbles and boulders which were not as prevalent in the Penguins site. Sponges were also
recorded across the majority of the Don SW site including in the habitats which were very similar to
those found during the survey of the Penguins (2011) site. It is likely that sponges were also present
within the Penguins site; however, due to the low resolution of the video data they may have not been
recorded during the analysis.

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The similarities in sediment type, depth and epifaunal community mean that it is likely that a similar
infaunal community is present within the Penguins site as was found at the nearby Don SW survey
(2007) site. The community at Don SW was dominated by annelids, making up 52.6% of the recorded
taxa and 57.5% of individuals with the most dominant taxon being the spionid polychaete Spiophanes
kroyeri, along with the polychaetes Galathowenia oculata and Glycera lapidum. The cockle
Parvicardium also occurred in very high abundances and was found to occur across all stations along
with the barnacle Verruca stroemia.
Infaunal communities were influenced by sediment size across the Don SW site. Where higher
proportions of coarse material were recorded, higher abundances of epilithic taxa were also recorded,
these taxa included the barnacle Verruca stroemia, the cup coral Caryophyllia smithii, anemones and
brachiopods such as Macandrevia cranium. Areas with high proportions of coarse material also tended
to have an increased diversity of colonial epifaunal taxa, these taxa included sponges, the hydroid
Clytia hemispherica and bryozoans such as Alderina imbellis, Ramphonotus minax and
Hemicyclopora polita.

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3.3 Comparison of Survey Data from Penguins and Don SW Fields

The Don SW survey, situated 8.9 km from the Penguins project area was interpreted to be
characterised by predominantly sandy sediments, being comparable to the Penguins project area and
thereby validating the use of Don SW survey data to aid description of the current survey area.
Sediments within the Penguins site were observed to be similar to the sediments recorded during the
habitat investigation of Don SW. The majority of sediments from the Don SW survey (2007) were
found to be mostly fine or medium sand with low proportions of coarse material, similar to the areas
identified as slightly gravelly sand within the Penguins site. Areas of gravelly sand were less prevalent
at the Don SW site, covered smaller areas and tended to be restricted to the edges or within the
iceberg ploughmarks which crossed all over the Don SW site. Iceberg ploughmarks were largely
absent from the Penguins site with only three indistinct marks running through the main site. No
increase in coarse sediment was identified from the geophysical data on the edges of the ploughmarks
within the Penguins site and the video data does not cover this area.
3.4 Comparison of ROV Video Data and Geophysical Data

Following review of the ROV video data, the delineated areas from the geophysical data were
compared to the sediment boundaries identified from the analysis of the video data. The ROV route
crossed the north-east corner of the current project area along the same route as the DC4 to DC5 high
resolution side scan sonar data.
In the 2011 geophysical datasets the areas of mixed reflectivity, recorded on the side scan sonar data,
were identified as areas of cobbles, boulders and clay outcrops. Review of the video data indicated
low numbers of cobbles and boulders in these areas, but an increase in the proportion of gravel
compared with the surrounding seabed. A more accurate description for the areas of coarser sediment
would be ‘Gravelly sand with occasional cobbles and boulders.’ Figure 3.5 compares the areas
delineated from the geophysical data with the sediment boundaries recorded from the video transects.
The video data was in general agreement with the interpreted seabed features with regards to the
locations of the areas of coarser sediment, although some areas identified from the video data were
not represented on the geophysical data indicating that there may be a general underestimation of the
areas of coarser material. Due to the similarity in the sediment types, some of the patches of gravelly
sand which were identified from the video data may not produce a sufficiently different signal on the
geophysical data from the surrounding seabed for confident delineation. The other patches delineated
across the site are likely to comprise gravelly sand with occasional cobbles and boulders.
Bathymetry data were analysed using the ‘Terrain Ruggedness Index’ (TRI) described in Wilson et al.
(2007). The TRI value is a measure of the local variation in seabed terrain about a central pixel. This is
not the same as elevation from the seabed but expresses the elevation difference between adjacent
map cells. Differences in the TRI can indicate a different substrate and this index is useful for picking
out areas of large coarse sediment (i.e. cobbles and boulders) which may be associated with
potentially sensitive habitats such as reefs. Bathymetry data was mapped with a point every 2 m,
therefore any object or feature smaller than 2 m may not be individually represented on the TRI data,
however, general areas of coarse substrate, including boulders smaller than 2 m, will have been
identified. While the low resolution of the available bathymetry data for the survey area means that this

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analysis cannot be used to give a definitive assessment of the presence or absence of stony reef, it
provides useful information to support the analysis of geophysical and seabed video data.
The results of the TRI analysis are displayed in Figure 3.6. The majority of the site exhibited a very low
score on the index indicating a level seabed throughout. The two shallow iceberg ploughmarks can
clearly be seen in both the overall image and in the close up of the FPSO location trending north to
south. The patches delineated as coarser sediment from the SSS data do not show any increase in
TRI, indicating that they do not display any significant changes in height over the resolution size (2 m).
Outside of the areas covered by the high resolution SSS, where sediment patches have not been
delineated, there is no evidence of any patches of increased ruggedness which may be associated
with an area of cobbles and boulders. This analysis indicates that there are no areas of significantly
rugose seabed, such as would be expected areas in areas of boulder-sized stony reef.

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Figure 3.5: Sediment boundaries from ROV video data overlain on interpreted seabed features

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Figure 3.6: Terrain Ruggedness Index (TRI) across the site

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3.5 Potentially Sensitive Habitats
3.5.1 Stony Reefs

Stony reefs are defined by the Habitats Directive as comprising areas of boulders (>256 mm diameter)
or cobbles (64 mm – 256 mm diameter) which arise from the seafloor and provide suitable substratum
for the attachment of algae and/or animal species (Irving, 2009).
Video data was assessed using the criteria described in Section 3.5.1.1. The ROV transects were split
into habitat type and all areas classified as being areas of ‘Deep circalittoral coarse sediment’ were
assessed. A summary of the results is given in Table 3.3 while the full assessment is displayed in
Appendix B.1.
3.5.1.1 Stony Reef Assessment Criteria

Areas which supported cobbles or boulders were to be analysed in detail for potential classification as
stony reef. Video data was reviewed according to JNCC guidelines which include ‘reefiness’ criteria
(Irving, 2009).
When considering the potential of an area as stony reef, the composition of the substrate is an
important characteristic. Stony reefs are defined as comprising coarse sediments with a diameter
greater than 64 mm (cobbles and boulders) that provide a hard substratum. The relationship between
the coarse material and sediment in which it lies is integral in determining ‘reefiness’. Matrix (soft
sediment) supported material is likely to have a more patchy distribution than clast (coarse sediment)
supported and so have lower ‘reefiness’. Additionally, matrix supported material is likely to have a
larger infaunal component which again reduces its ‘reefiness’ (Irving, 2009). Reefs are also defined as
having relief from the seafloor, and as such relief is used as another criterion for assessment. The
epifaunal community of potential reef habitat is also a key determinant of its ‘reefiness’ and percentage
cover of fauna is therefore included as an assessment criterion. Within the Irving (2009) scheme,
areas of potential stony reef habitat must have an area of at least 25 m² to be considered as reef and
this report also adopts this minimum area. These criteria have been summarised in Table 3.2.
Table 3.2: Measures of Reefiness of the Stony Reef Habitat.

Characteristic Not a reef Low Medium High
Cover of cobbles and boulders** <10% 10-40% >40-95% >95%
Elevation above seabed Flat seabed <64 mm 64 mm – 5 m >5 m
Cover of visible epifauna Predominantly infaunal species n/a >80%
Colour coding
Note: Stony reef assessment criteria (Irving, 2009).

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3.5.1.2 Stony Reef Assessment Results

Table 3.3: Summary Results of the ‘Reefiness’ Assessment carried out on the ROV Transects
Criteria Not a Reef [m] Low [m] Medium [m] High [m]
Cover of cobbles
4041.7 (100%) 0.0 (0%) 0.0 (0%) 0.0 (0%)
and boulders [%]
Elevation above
123.26 (3.05%) 3288.29 (81.4%) 630.11 (15.6%) 0.0 (0%)
seabed [cm]
Cover of visible
4041.7 (100%) N/A 0.0 (0%)
epifauna [%]
Note: Bracket contains percentage of total length of transect over habitat.
The minimum cover required to be classified as a reef formation is 10% coverage of cobbles and
boulders. During the review of the video data the percentage cover by cobbles and boulders was
consistently lower than 10%. No areas were classified as having low, medium or high ‘reefiness
potential with all areas being classified as ‘not a reef’. Cover of visible epifauna was also extremely low
along the entire length of the transect, with only one or two individuals being recorded in each section.
All areas assess for epifaunal coverage were classified as ‘not a reef’.
Elevation across the site was generally low with the majority of the sections showing no elevation
above the ambient seabed. In the areas classified as ‘Deep circalittoral coarse sediment’ 3.05% was
classified as ‘not a reef’, 81.4% was classified as having low reefiness and 15.6% was classified as
having medium reefiness. The areas which displayed medium reefiness potential for height contained
several large boulders with a maximum height of 20 cm above the ambient seabed. However, these
tended to be lone matrix supported boulders and not part of a larger clast supported reef structure.
Due to the very low cover of cobbles and boulders and of epifaunal coverage, all areas along the ROV
video transect can be classified as ‘not a Reef’ according to the ‘Reefiness’ classification system
(Irving, 2009). No other areas, which were not interpreted, were found to have a higher reflectivity,
from the side scan sonar data or a higher ruggedness index indicating that there are unlikely to be any
areas with a higher cover of cobbles and boulders or higher elevation above the ambient seabed and
therefore a higher potential of ‘reefiness’.
3.5.2 Submarine Structures Made by Leaking Gas

Within the North Sea, ‘structures made by leaking gases’ (i.e. MDAC), tend to occur in the base of
pockmarks. Though pockmark characteristics including size, shape and density have been
documented (for example, Judd, 2001) there is currently no published classification for assessing the
quality of MDAC itself which can vary substantially between pockmarks.
Any area which has been identified as MDAC will be recorded with details of its overall area, height
above the surrounding seabed and the coverage of epifauna.
Depressions were identified from the geophysical data across much of the site, ranging from 0.1 m to
0.3 m deep and from 10 m to 20 m in diameter. These depressions were thought likely to be created
by seabed scouring due to their shallow depth and small diameter. Several of these depressions were
found to contain hard contacts, which have been identified on the interpreted seabed features chart
(see Figure 3.3). The heights of these contacts, between 0.4 m and 1.0 m, were more consistent with

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boulders than MDAC, which tends to be encountered as low-level, slab-like structures. The contacts
also displayed more distinct rounded shapes, which would typically be evident for boulders, whereas
MDAC often displays more indistinct and irregular edges on the side scan sonar record.
None of the identified depressions were covered by the ROV transects, so no video interpretation
could be carried out. However, the photographic data did confirm the presence of isolated boulders
across the site, such as those thought to be present within several of the delineated seabed
depressions; isolated boulders are an expected feature of the underlying Tampen Formation.
3.5.3 Priority Marine Features

No priority marine features were identified from the geophysical or video data for the project area. The
closest available infaunal data was from the Don SW survey (2007), located 8.9 km to the south-west
of the Penguins project area. Review of this infaunal dataset showed the presence of Glycera lapidum
in the areas of gravelly sand which can form part of the PMF ‘Offshore subtidal sands and gravel’.
However, the other species required for the component biotope, Thyasira spp. and Amythasides
macroglossus, were only present in very low numbers. The similarity in sediment type between the
Don SW and Penguins areas means that the Penguins field is likely to support a similar macrofaunal
community.

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4. CONCLUSION
Historical geophysical and video data were reviewed as part of the desktop study into the placement of
an FPSO at the Penguins site.
The historical bathymetry and side scan sonar data were evaluated for sediment and habitat types as
well as for the presence of features which may constitute potential sensitive habitats. The majority of
the seabed was interpreted as ‘sand and gravel with cobbles and boulders’ while a significant number
of patches were interpreted as ‘areas of cobbles and boulders’.
The historical video data was then reviewed in conjunction with the interpreted seabed features to
validate their accuracy. The video data indicates that the seabed was dominated by two habitats,
Deep Circalittoral Coarse Sediment (A5.14) and Deep Circalittoral Mixed Sediment (A5.45) which are
both characterised by a very sparse visible community of echinoderms. The areas interpreted from the
geophysical data as ‘areas of cobbles and boulders’ were actually found to be made up of ‘gravelly
sand with occasional cobbles and boulders’.
Terrain modelling was used to analyse the areas which were not covered by the high resolution side
scan sonar data. The bathymetry data was analysed using the terrain ruggedness index, which
measures differences in seabed height surrounding each pixel and is especially useful for identifying
2
small features (<100 m ), such as stony reefs, which are raised above the surrounding seabed. No
significant features were identified with this technique indicating that the area surrounding the
proposed FPSO location is likely to be similar to the video interpreted seabed of slightly gravelly sand
and gravelly sand.
A ‘reefiness’ assessment was carried out on the ROV video data using the criteria set out by the JNCC
(Irving, 2009); the results of which can be found in Appendix B.1. Along the entire length of the camera
transect two of the criteria, cover of cobbles and boulders and cover of epifaunal species, were found
to be classified as ‘not a reef’ (less than 10% cover of cobbles and boulders and predominantly
infaunal species). As no other significant features or areas of with a higher density of coarse material
were identified it is very unlikely that any potential reef structures exist in the site surrounding the
FSPO.
No other potential sensitive habitats were identified from the geophysical or video data.

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5. REFERENCES
1. Belderson, R. H., Kenyon, N. H. & Wilson, J. B., 1973. Iceberg Ploughmarks in the Northeast
Atlantic. Palaeogeography, Palaeoclimatology, Palaeoecology, Volume 13, pp. 215-224.
2. Carr, S., 2004. The North Sea basin. In: J. Ehlers & P. L. Gibbard, eds. Quaternary
Glaciations—Extent and Chronology, Part I. Amsterdam: Elsevier, pp. pp. 261-270.
3. Connor, D.W., Allen, J.H., Golding, N., Howell, K.L., Lieberknecht, L.M., Northen, K.O. and
Reker, J.B. 2004. The Marine Habitat Classification for Britain and Ireland Version 04.05. JNCC,
Peterborough.
4. Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild
fauna and flora. OJ L 206.
5. Folk, R. L., 1954. The distinction between grain size and mineral composition in sedimentary
rock nomenclature. Journal of Geology, 65(4), pp. 344-359.
6. FSLTD 2011a. Anchoring Conditions Survey - Penguins FPF, FSLTD Report No. 6500714.4aV1
7. FSLTD 2011b. Geophysical Pipeline Route Survey - Penguins DC4 to Penguins DC5, FSLTD
Report No. 6500714.4bV1
8. FSLTD 2011c. Geophysical Pipeline Route Survey - Proposed Penguins FPF to SALB, FSLTD
Report No. 6500714.4dV1
9. FSLTD 2007. Environmental Baseline Study and Habitat Assessment, Don South-West Site -
UKCS Block 211/18, FSLTD Report No. 9320.1V2
10. Irving, R., 2009. The identification of the main characteristics of stony reef habitats under the
Habitats Directive. Summary report of an inter-agency workshop. JNCC, Volume 432.
11. Jackson, D. L. & McLeod, C. R., Revised 2002. Handbook on the UK status of EC Habitats
Directive interest features; provisional data on the UK distribution and extent of Annex I habitats
and the UK distribution and population size of Annex ii species, UK: JNCC Report No. 312.
12. Judd, A. G., 2001. Pockmarks in the UK Sector of the North Sea, Technical Report TR_002,
Technical report produced for Strategic Environmental Assessment – SEA2, London: DTI.
13. Wilson, M.F. et al., 2007. Multiscale Terrain Analysis of Multibeam Bathymetry Data for Habitat
Mapping on the Continental Slope. Earth, (3), 3-35.

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A. PERSONNEL
FSLTD/Report No. 140605-65V1.5 Appendix A - Personnel Page 1of 2

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PERSONNEL
Environmental Reporting
Position Name
Environmental Science Manager Richard Walters
Report Project Manager Paul Collins
Interpretation / Report Author Simeon Archer
FSLTD/Report No. 140605-65V1.5 Appendix A - Personnel Page 2of 2

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B. LOGS
FSLTD/Report No. 140605-65V1.5 Appendix B – Logs Page 1of 1

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B.1. VIDEO LOGS
FSLTD/Report No. 140605-65V1.5 Appendix B.1 – Video Logs Page 1 of 9

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Reefiness Assessment
Distance Cover of
Easting Northing Epifauna / Bioturbation / Other Elevation Cover of
Transect Date Time Sediment over Habitat cobbles
[mE] [mN] info above visible
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
18/11/2005 10:42:51 584246 6828325 Gravelly sand with occasional
PL003 Sea stars (Asteroidea) 100.2 1 20 1
18/11/2005 10:56:34 584299 6828240 cobbles and boulders
18/11/2005 10:56:34 584299 6828240

PL003 Sand with occasional gravel 20.1 0 0 0
18/11/2005 10:57:37 584308 6828222
PL003 64.7 1 0 0
18/11/2005 11:00:10 584342 6828167

PL003 Sand with occasional gravel Sea Urchin (Echinoidea) 289.1 0 0 1
18/11/2005 11:12:30 584509 6827931
PL003 35.2 2 4 0
18/11/2005 11:14:06 584529 6827902

PL003 Sand with occasional gravel Sea stars (Asteroidea) 62.2 0 0 1
18/11/2005 11:16:46 584566 6827852
PL003 24.4 1 2 0
18/11/2005 11:17:41 584580 6827832

18/11/2005 11:18:55 584598 6827809
18/11/2005 11:18:55 584598 6827809 Sea stars (Asteroidea), Sea
Gravelly sand with occasional
PL003 urchin (Echinoidea), Hermit crab 455.4 3 3 1
(Paguridae)
18/11/2005 11:38:50 584869 6827443
18/11/2005 11:42:17 584918 6827375
PL003 135.0 2 5 0
PL003 18/11/2005 11:48:03 584999 6827267 Sand with occasional gravel Sea stars (Asteroidea) 39.4 0 0 1
FSLTD/Report No. 140605-65V1.5 Appendix B.1 - Video Logs Page 2 of 10

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Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
18/11/2005 11:49:46 585022 6827235
18/11/2005 11:56:48 585119 6827103

18/11/2005 11:58:16 585137 6827077
18/11/2005 11:58:16 585137 6827077 Gravelly sand with occasional Sea stars (Asteroidea), Sea
PL003 65.8 4 10 1
18/11/2005 12:01:13 585176 6827024 cobbles and boulders urchin (Echinoidea)
18/11/2005 12:01:13 585176 6827024

18/11/2005 12:02:59 585200 6826993
PL003 97.4 2 5 0
18/11/2005 12:07:02 585257 6826914

18/11/2005 12:09:16 585289 6826871
PL003 43.6 1 0 0
18/11/2005 13:20:03 585315 6826836

18/11/2005 13:24:10 585327 6826820
PL003 55.2 2 5 0
18/11/2005 13:28:01 585359 6826775

18/11/2005 13:33:55 585436 6826671
PL003 Sea Urchin (Echinoidea) 15.0 0 0 1

SHELL UK LIMITED
Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
18/11/2005 13:34:30 585445 6826659
18/11/2005 13:35:10 585456 6826645
PL003 12.5 4 5 1
18/11/2005 13:35:40 585462 6826634

18/11/2005 13:36:06 585470 6826625
PL003 Sea star (Asteroidea) 65.2 5 5 1
18/11/2005 13:38:46 585508 6826572

18/11/2005 13:42:22 585556 6826505
PL003 23.4 9 20 0
18/11/2005 13:43:17 585571 6826487

18/11/2005 13:48:11 585642 6826390
18/11/2005 13:48:11 585642 6826390 Gravelly sand with occasional Sea Urchin (Echinoidea), Sea
PL003 75.8 5 5 1
18/11/2005 13:51:14 585687 6826329 cobbles and boulders star (Asteroidea)
18/11/2005 13:51:14 585687 6826329

18/11/2005 13:55:44 585752 6826241
PL003 10.8 1 5 0
18/11/2005 13:56:08 585758 6826232

18/11/2005 13:58:41 585797 6826178
PL003 18/11/2005 13:58:41 585797 6826178 Gravelly sand with occasional 42.8 2 5 0

SHELL UK LIMITED
Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
18/11/2005 14:00:23 585823 6826144
18/11/2005 14:01:47 585844 6826117
18/11/2005 14:01:47 585844 6826117 Gravelly sand with occasional Sea Urchin (Echinoidea), Sea
PL003 201.8 2 4 1
18/11/2005 14:10:56 585963 6825954 cobbles and boulders star (Asteroidea)
18/11/2005 14:10:56 585963 6825954

18/11/2005 14:12:34 585984 6825924
18/11/2005 14:12:34 585984 6825924 Gravelly sand with occasional Sea Urchin (Echinoidea), Hermit
PL003 318.5 2 4 1
18/11/2005 14:28:37 586191 6825682 cobbles and boulders crab (Paguridae)
18/11/2005 14:28:37 586191 6825682 Sea cucumber (Holothuroidea),

PL003 Sand with occasional gravel Sea star (Asteroidea), possible 123.1 0 0 1
18/11/2005 14:34:43 586281 6825598 sea pen (Pennatulacea)
PL003 15.6 2 3 0
18/11/2005 14:35:28 586292 6825587

18/11/2005 14:36:19 586305 6825574
18/11/2005 14:37:44 586329 6825552

18/11/2005 14:39:00 586349 6825535
18/11/2005 14:42:59 586409 6825481

18/11/2005 14:44:47 586436 6825455

SHELL UK LIMITED
Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
PL003 Sea urchin (Echinoidea) 67.2 7 5 1
18/11/2005 14:48:01 586485 6825409

18/11/2005 14:49:50 586492 6825402
PL004 22.0 2 5 0
18/11/2005 15:01:26 586492 6825404

18/11/2005 15:01:51 586497 6825399
PL004 24.8 2 3 0
18/11/2005 15:03:13 586516 6825383 Sea star (Astropecten

18/11/2005 15:03:54 586523 6825376 irregularis),

PL004 13.5 1 5 0
18/11/2005 15:04:38 586533 6825367

18/11/2005 15:04:11 586542 6825360
PL004 Sea cucumber (Holothuroidea) 34.0 2 3 1
18/11/2005 15:06:48 586567 6825337

18/11/2005 15:09:29 586607 6825299
PL004 18/11/2005 15:10:38 586624 6825284 Sand with occasional gravel 47.4 0 0 0

SHELL UK LIMITED
Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
18/11/2005 15:12:49 586659 6825252
PL004 5.7 6 5 0
18/11/2005 15:13:06 586663 6825248

18/11/2005 15:16:51 586720 6825197
PL004 Sea Star (Asteroidea) 68.6 3 5 1
18/11/2005 15:19:52 586770 6825150

18/11/2005 15:24:29 586849 6825077
PL004 14.9 6 10 0
18/11/2005 15:25:08 586860 6825067 Sea star (Asteroidea), Hermit

18/11/2005 15:34:04 587008 6824925 crab (Paguridae),

PL004 12.0 5 10 0
18/11/2005 15:34:35 587016 6824916

18/11/2005 15:35:43 587033 6824899
PL004 41.8 2 3 0
18/11/2005 15:37:31 587061 6824868

PL004 Sand with occasional gravel Sea star (Asteroidea), 0 0 1
18/11/2005 15:39:49 587096 6824825
18/11/2005 15:39:49 587096 6824825 Sea star (Asteroidea), Cushion
PL004 star (possibly Ceramaster 80.3 3 5 1
granularis), Sea Urchin

SHELL UK LIMITED
Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
(Echinoidea)
18/11/2005 15:43:18 587147 6824763
18/11/2005 15:56:09 587255 6824615
PL004 220.1 4 5 0
18/11/2005 16:05:28 587383 6824436

18/11/2005 16:08:09 587421 6824384
18/11/2005 16:13:55 587500 6824275

PL004 Sand with occasional gravel Ray (Raja undulata) 177.1 0 0 1
18/11/2005 16:21:20 587603 6824131
PL004 Sea Star (Asteroidea) 50.0 3 3 1
18/11/2005 16:23:29 587633 6824091

18/11/2005 16:27:08 587682 6824022
PL004 46.6 5 10 0
18/11/2005 16:29:07 587709 6823984

18/11/2005 16:32:12 587751 6823925
PL004 109.6 5 10 0
18/11/2005 16:36:53 587812 6823834 Sea Cucumber (Parastichopus

18/11/2005 16:40:26 587853 6823764 tremulus)

SHELL UK LIMITED
Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
PL004 42.5 2 5 0
18/11/2005 16:42:23 587874 6823727

18/11/2005 16:45:52 587904 6823657
18/11/2005 16:45:52 587904 6823657 Sea Cucumber (Holothuroidae),
PL004 Sea urchins (Echinoidea), sea 121.8 2 3 1
stars (Asteroidea)
18/11/2005 16:50:57 587972 6823556
18/11/2005 16:53:34 588002 6823503
PL004 Hermit crab (Paguridae) 134.5 4 10 1
18/11/2005 16:59:18 588070 6823387

PL004 Sand with occasional gravel Sea star (Asteroidea) 34.5 0 0 1
18/11/2005 17:00:51 588087 6823357
PL004 25.6 2 3 0
18/11/2005 17:01:56 588100 6823335

18/11/2005 17:04:56 588134 6823276
18/11/2005 17:04:56 588134 6823276 Shrimp (Caridea), anemone
PL004 (Cnidaria), sea urchin 148.7 3 5 1
(Echinoidea)
18/11/2005 17:11:15 588208 6823147
18/11/2005 17:24:45 588366 6822877
PL004 123.2 8 15 0

SHELL UK LIMITED
Distance Cover of
[m] and
seabed epifauna
boulders
[cm] [%]
[%]
18/11/2005 17:30:00 588427 6822770
18/11/2005 17:38:52 588530 6822593
18/11/2005 17:40:20 588547 6822562

18/11/2005 17:41:41 588562 6822534
PL004 34.0 2 3 0
18/11/2005 17:43:09 588578 6822504

18/11/2005 17:44:08 588589 6822484
18/11/2005 17:44:08 588589 6822484 Gravelly sand with occasional Sea star (Asteroidea), sea
PL004 237.9 2 3 1
18/11/2005 17:54:21 588682 6822265 cobbles and boulders urchin (Echinoidea)
18/11/2005 17:54:21 588682 6822265

18/11/2005 17:56:24 588696 6822224
PL004 34.5 2 3 0
18/11/2005 17:58:00 588706 6822191

18/11/2005 17:59:41 588714 6822167

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C. SEABED PHOTOGRAPHS
FSLTD/Report No. 140605-65V1.5 Appendix C –Seabed Photographs Page 1 of 9

SHELL UK LIMITED
Transect PL003
Photograph:
Easting:584 574 mE
Northing:6 827 841 mN
Depth: 161.3 m
Sediment Type:
Gravelly Sand with
occasional cobbles and
boulders
Fauna:
Photograph:
Easting:584 811 mE
Northing: 6 827 520 mN
Depth: 161.1 m
Sediment Type:
Gravelly sand
Fauna:

SHELL UK LIMITED
Transect PL003
Photograph:
Easting:584 851 mE
Depth: 161.1 m
Sediment Type:
Slightly gravelly sand
Fauna:
A
A: Sea urchin (Echinoidea)
Photograph:
Easting:585 212 mE
Depth: 160.8 m
Sediment Type:
Gravelly sand
Fauna:
A: Sea star (Asteroidea)

SHELL UK LIMITED
Transect PL003
Photograph:
Easting:585 513 mE
Depth: 160.5 m
Sediment Type:
Fauna:
Photograph:
Easting:585 875 mE
Depth: 160.2 m
Sediment Type:
Gravelly sand with cobbles
and boulders
Fauna:
A: Sea urchin (Echinoidea)

SHELL UK LIMITED
Transect PL003
Photograph:
Easting:586 238 mE
Depth: 159.8 m
Sediment Type:
Fauna:
Photograph:
Easting:586 475 mE
Depth: 158.9 m
Sediment Type:
with cobbles and boulders
Fauna:

SHELL UK LIMITED
Transect PL004
Photograph:
Easting:586 568 mE
Depth: 159.4 m
Sediment Type:
Fauna:
Photograph:
Easting:586 930 mE
Depth: 158.8 m
Sediment Type:
Gravelly sand occasional
cobbles and boulders
Fauna:

SHELL UK LIMITED
Transect PL004
Photograph:
Easting:587 221 mE
Depth: 158.4 m
Sediment Type:
Slightly gravelly sand with
boulders
Rope debris
Fauna:
Photograph:
Easting:587 351 mE
Depth: 157.7 m
Sediment Type:
Gravelly sand
Fauna:

SHELL UK LIMITED
Transect PL004
Photograph:
Easting:587 713 mE
Depth: 157.6 m
Sediment Type:
Fauna:
Photograph:
Easting:588 002 mE
Depth: 157.1 m
Sediment Type:
Gravelly sand
Fauna:

SHELL UK LIMITED
Transect PL004
Photograph:
Easting:588 220 mE
Depth: 156.8 m
Sediment Type:
Gravelly sand
Fauna:
A: Sea star (Asteroidea)
Photograph:
Easting:588 504 mE
Depth: 156.5 m
Sediment Type:
Fauna:

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D. SERVICE WARRANTY
FSLTD/Report No. 140605-65V1.5 Appendix D – Service Warranty Page 1 of 2

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FUGRO EMU LIMITED

SERVICE WARRANTY
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discovery of which inaccuracies required the doing of any act including the gathering of any information which was not reasonably
available to Fugro EMU Limited and including the doing of any independent investigation of the information provided to Fugro
EMU Limited save as otherwise provided in terms of the contract between the Client and Fugro EMU Limited.
FSLTD/Report No. 140605-65V1.5 Appendix D – Service Warranty Page 2 of 2

APPENDIX C
AIR QUALITY MODELLING REPORT

CONTENTS
1. Introduction ................................................................................................................................. 1
2. Assessment Criteria ..................................................................................................................... 2
2.1. Overview ............................................................................................................................ 2
2.2. Regulatory Framework ......................................................................................................... 2
2.3. Regulatory Guidelines .......................................................................................................... 2
3. Existing Environment .................................................................................................................... 4
4. Assessment Methodology ............................................................................................................. 6
4.1. Dispersion Modelling Inputs and Method ............................................................................... 6
4.1.1. Consideration of Building Downwash ............................................................................ 6
4.2. Operational Scenarios ......................................................................................................... 7
4.3. Emissions Inventory .............................................................................................................. 8
4.4. Meteorology ...................................................................................................................... 10
4.5. Receptors .......................................................................................................................... 12
5. Significance Criteria .................................................................................................................. 13
6. Assessment Results ..................................................................................................................... 15
6.1. Scenario 1 – Normal Operations ........................................................................................ 15
6.1.1. Scenario 1 Findings.................................................................................................... 16
6.2. Scenario 2 – Normal Operations with Emergency Flaring ..................................................... 19
6.3. Scenario 3 – Upset Conditions (Diesel Gas Turbine Generator use and Emergency Flaring) ..... 20
6.4. Discussion of Uncertainties.................................................................................................. 25
7. Conclusions ............................................................................................................................... 27
8. References ................................................................................................................................ 28
TABLES
Table 2-1 Air Quality Standards for the Protection of Human Health ................................................... 2
Table 3-1 Strathvaich Rural Background Monitoring Data 1990 – 1997 (µg/m3) ................................. 4
Table 3-2 Background Data used in Assessment (µg/m3) ................................................................... 5
Table 4-1 ADMS 5 Model Set up Parameters .................................................................................... 6
Table 4-2 Emission Parameters......................................................................................................... 8
Table 5-1 Significance Criteria for Assessing Impacts at Human Sensitive Receptors (EPUK, 2010) ...... 13
Table 6-1 Maximum Predicted Pollutant Concentrations (µg/m3) – Scenario 1 (Normal Operations).... 15
Table 6-2 Maximum Predicted Pollutant Concentrations (µg/m3) - Scenario 2 (Normal Operations
Including Flaring) .............................................................................................................................. 19
Table 6-3 Maximum Predicted Pollutant Concentrations (µg/m3) - Scenario 3 (Upset conditions) ........ 20
Table 6.4 Cumulative Combustion Emissions ....................................................................................... 26
FIGURES
Figure 4-1 Wind Roses for Penguin FPSO (2010-2014) ................................................................ 11
Figure 6-1 Maximum Predicted 1-hour NO2 Concentrations - Scenario 1 - Normal Operations ....... 17
Figure 6-2 Maximum Predicted Annual Mean NO2 Concentrations - Scenario 1 - Normal Operations .
................................................................................................................................. 18
Figure 6-3 Maximum Predicted 1-hour NO2 Concentrations - Scenario 3 - Upset Conditions ........... 22
Figure 6-4 Maximum Predicted 1-hour SO2 Concentrations - Scenario 3 - Upset Conditions ............ 23
Figure 6-5 Maximum Predicted 15-minute SO2 Concentrations - Scenario 3 - Upset Conditions ....... 24
ACRONYMS
ADMS Atmospheric Dispersion Modelling System
AQIA Air Quality Impact Assessment
EEZ Exclusive Economic Zone
EU European Union
FPSO Floating Production Storage and Offloading unit
IAQM Institute of Air Quality Management
PC Process contribution
PEC Predicted Environmental Concentration
SEPA Scottish Environment Protection Agency
UKCS UK Continental Shelf
VOCs Volatile Organic Compounds

1. INTRODUCTION
The Air Quality Impact Assessment (AQIA) has been undertaken for the operation of the Shell Penguin
Floating Production, Storage and Offloading unit (FPSO), in the northern North Sea (Easting, 585438,
Northing, 6823498) 1.
The site is located in the UK Continental Shelf (UKCS), adjacent to the UK/Norway marine border,
approximately 160 km off the coast of the Shetland Islands.
The primary sources of emissions considered in the assessment are the continuous operation of combustion
sources on the FPSO; namely the three gas turbine generators (19.7 MWth combined) and the high
pressure (HP) compressor (45.9 MWth). Emergency flaring events have also been considered, in addition
to other intermittent auxiliary combustion appliances, which use diesel as fuel. These operational FPSO
sources were considered to represent a worst-case assessment of the potential impact to air. Potential
emissions from the drilling, commissioning and decommissioning phases, together with activities associated
with shipping vessels and helicopters have been scoped out as they are not considered to be significant in
air quality terms.
Due to the remote nature of the FPSO unit location, impacts on air quality have only been assessed in the
context of human receptors, as there are no sensitive ecological sites in the vicinity.
The AQIA has been undertaken in a number of stages as follows.
 The legal framework was examined, focusing on the identification of applicable emissions limits
and air quality standards;
 The receiving environment was characterised, including derivation of the existing baseline and
meteorological conditions;
 An emissions inventory was built to quantify the emissions to air and characterise emission sources
from the FPSO unit;
 Dispersion modelling using the ADMS 5 atmospheric dispersion model was used to quantify the
maximum concentrations of pollutants of interest under three worst case operational scenarios; and
 Impacts of emissions on air quality were quantified by comparison of the predicted maximum
concentrations with the relevant air quality standards, with reference to the existing baseline
conditions.
The three operational scenarios included in the assessment are namely; normal operations operating on
gas; normal operations operating on gas with emergency flaring; and upset conditions operating with
diesel gas turbine generator use and emergency flaring (as a worst-case potential scenario).
Total emissions of carbon dioxide (CO2) have also been calculated for the proposed FPSO operations to
show the cumulative greenhouse gases contribution of the Project.
The remainder of this section sets out the detailed approach to this process, the results of the AQIA, the
identification of impacts and mitigation measures required, where appropriate.
1 European Datum 50, 0 degrees
1
2. ASSESSMENT CRITERIA
2.1. OVERVIEW
The potential effects on human health of the emissions from the FPSO unit are assessed by comparison of
the predicted pollutant concentrations arising around the FPSO to air quality standards and guidelines,
taking into account the existing background.
2.2. REGULATORY FRAMEWORK

Whilst the Penguin FPSO unit site is located off-shore (160 km from the Shetland Islands), as it is located
within the Scottish exclusive economic zone (EEZ), it is therefore still bound to European Union (EU) and
Scottish Legislation.
Within Scotland the majority of the air quality standards relating to ambient air quality are based upon the
EU directives (European Parliament, 2008). The relevant Scottish Legislation is The Air Quality Standards
(Scotland) Regulations 2010. Scottish Statutory Instrument No. 204.
The EU and Scottish air quality standards include nitrogen oxides (NOX) (which includes nitrogen dioxide
(NO2) and nitrogen oxide (NO)) and sulphur dioxide (SO2), which are the primary pollutants of concern
within this study. There will be emissions of other pollutants such as volatile organic compounds (VOCs);
however, there is only one VOC with a mandatory standard in the EU and Scotland which is benzene.
Predicted VOC concentrations have not been compared to the annual mean benzene standard as this is not
considered appropriate for the assessment of short-term, emergency flaring emissions or VOCs emitted
during intermittent upset conditions, neither of which is expected to involve significant quantities of
benzene. VOC emissions from the gas-turbine generators and HP gas compressor have also been scoped
out.
In addition, emissions of particulates (PM10 and PM2.5) and carbon monoxide (CO) from combustion
exhausts are not generally considered to be significant emissions for gas-fired sources and are therefore
not included within the modelling assessment. PM10, PM2.5 and CO emissions from diesel generators and
flaring activities have also not been included as their respective averaging periods within the Scottish air
quality standards are not considered appropriate for the assessment of intermittent upset conditions and
flaring events.
Total emissions of carbon dioxide (CO2),have also been included in the assessment to show the cumulative
greenhouse gas (GHG) contribution of the FPSO, in relation to the UK Continental Shelf (UKCS) annual
CO2 emissions. Further detail on the summary GHG calculations has been captured within the inventory for
the Atmospheric Emissions chapter within the EIA.
2.3. REGULATORY GUIDELINES

The air quality standards for the protection of human health used in this assessment are set out in Table
2-1.
Table 2-1 Air Quality Standards for the Protection of Human Health
POLLUTANT AVERAGING PERIOD UNITS VALUE SOURCE

AND STATISTIC
Scottish AQS /
NO2 Annual mean µg/m3 40
EU
2
POLLUTANT AVERAGING PERIOD UNITS VALUE SOURCE

AND STATISTIC

exceeded more than 18 Scottish AQS /
NO2 µg/m3 200
times a year (99.79th EU
percentile)

exceeded more than Scottish AQS /
SO2 µg/m3 125
3times a year (99.9th EU
percentile)

exceeded more than 24 Scottish AQS /
SO2 µg/m3 350
times a year (99.72nd EU
percentile)
15-minute mean, not to be

exceeded more than 35
SO2 µg/m3 266 Scottish AQS
times a year (99.9th
percentile)
Horizontal Guidance H1 (SEPA, 2003), prepared jointly by Scottish Environment Protection Agency
(SEPA), Environment Agency and Environment and Heritage Service, has also been used within the
assessment 1.
1 The Environment Agency for England have updated H1, with the most up to date version (v2.2) issued in 2012. In some circumstances SEPA advised
3
3. EXISTING ENVIRONMENT
The impacts on air quality arising from the FPSO unit are considered in the context of the existing
environmental baseline conditions, in order to determine the overall significance.
Given the remote nature of the FPSO unit, site-specific ambient air quality data are not available. The most
appropriate data source for off-shore applications is a representative ’rural‘ site from Defra’s Automatic
and Rural Network. Continuous background monitoring data from Defra’s Strathvaich rural site has
therefore been used in the assessment. The Strathvaich monitoring site was operated in a remote area of
the Scottish Highlands and is considered to be the site which is most representative of the likely ambient
concentrations at the FPSO unit and in the open North Sea.
It is acknowledged that Defra also operate a continuous monitoring site as part of the Automatic and Rural
Network, at Lerwick, Shetland. The Lerwick site is also classified by Defra as ‘Rural Background’, however
as the site is located with 150 m of a main road and on the outskirts of Lerwick town, it was considered
that the Strathvaich site data was more closely matched to the proposed FPSO unit’s location in terms of air
quality.
For the pollutants of concern within this study, pollutant concentrations of NOx, NO2 and SO2 were
monitored at Strathvaich between 1990-1997. A summary of the monitored data over these periods is
provided in Table 3-1 below.
It is acknowledged that the use of data from the historic closed site may not be considered to be ideal;
however, as trends in the UK suggest a gradual improvement in background air quality concentrations
since the 1990s, the use of the data in the assessment is considered to be robust.
Table 3-1 Strathvaich Rural Background Monitoring Data 1990 – 1997 (µg/m3)
POLLUTANT 1990 1991 1992 1993 1994 1995 1996 1997

Nitrogen dioxide (NO2)
Annual 1.81 3.53 1.30 1.89 2.02 0.92 1.44 1.02
mean
1 hour max 24.7 41.4 19.9 22.6 25.5 11.2 27.0 14.9
(99.79th
percentile)
Data 16.6% 44.1% 85.3% 41.6% 68.1% 86.3% 84.6% 17.1%
capture
Sulphur dioxide (SO2)
24hour 6.82 26.6 9.17 10.4 11.1 6.01 7.37 6.57
max
(99.19th
percentile)
1 hour max 13.3 45.3 15.2 19.2 19.4 11.9 16.5 13.1
(99.72nd
percentile)
Data 18.8% 56.1% 69.7% 77.4% 61.6% 94.4% 92.8% 17.2%
capture (%)
The data used in the assessment are also detailed in Table 3-2. Only recorded background concentrations,
where data capture exceeded 75%, were considered in the assessment, in line with guidance (Defra,
2009).
4
.
Table 3-2 Background Data used in Assessment (µg/m3)
POLLUTANT AVERAGING PERIOD VALUE SOURCE
Nitrogen dioxide (NO2) Annual mean 1.44 Strathvaich 1996
1-hour 2.88 2 x annual mean
Sulphur dioxide (SO2) 1-hour 19.2 Strathvaich 1993
15-minute 19.2 Assumed as 1-hour
5
4. ASSESSMENT METHODOLOGY
The scope of the assessment is summarised as follows
 Understand and quantify the potential sources of emissions on the FPSO unit;
 Identify potential operational emission scenarios;
 Identify sensitive receptors;
 Assess the potential impacts associated with the operational scenarios; and,
 Consider the magnitude and significance of the potential impacts.
4.1. DISPERSION MODELLING INPUTS AND METHOD

The operational impacts from the FPSO unit are assessed using the ADMS (Atmospheric Dispersion
Modelling System) model. Its use is advocated by SEPA (SEPA, 2003) and the Environment Agency for
industrial applications.
ADMS allows for the modelling of dispersion under convective meteorological conditions using a skewed
Gaussian concentration distribution. It is able to simulate the effects of terrain and building downwash
simultaneously. It can also calculate concentrations for direct comparison with air quality standards or
guidelines.
A summary of the initial ADMS set up parameters are detailed in Table 4-1 below.
Table 4-1 ADMS 5 Model Set up Parameters
Location of FPSO unit (easting, northing) m, m 585438, 6823498
Coordinate reference system - European Datum 50, 0 degrees
Latitude degrees 61.5
Surface Roughness m 0.0001
Surface albedo - 0.23
Minimum Monin-Obukhov length m 1
Height of recorded wind m 14
Assumed height of FPSO above sea level m 30
4.1.1. Consideration of Building Downwash

When air flow passes over buildings, a phenomenon known as building downwash occurs where the air is
entrained in the lee of the building and drawn down to ground level. This effect can bring the plume from
the stack down to ground level quicker than would otherwise be the case, and therefore increase the
ground level concentration relative to a case where there are no buildings or less tall buildings.
Building effects are typically a consideration where the buildings are greater than one third the height of
the stacks. As detailed building information was not available at the time of reporting, the inclusion of
buildings within the modelling has not been carried out. In addition, given the likely close proximity of
buildings on the FPSO unit, the ADMS model used is also not considered to be appropriate to assess the
6
complex interactions of air flow in such near-field applications which typically require dedicated
Computational Fluid Dynamics modelling and is beyond the scope of most environmental assessments.
4.1.1.1. Conversion of NOx to NO2

Oxides of nitrogen (NOx) are formed in the combustion process. In the exhaust gases from the stack, these
are in the ratio of approximately 95% nitric oxide (NO) to 5% nitrogen dioxide (NO2). With regard to the
assessment of effect on human health, NO2 is the pollutant of interest, as NO has far less pronounced
health effects at ambient-type concentrations. In the atmosphere, various processes will oxidise NO to
NO2, but the process will not occur quickly or completely before the plume reaches ground level. It is
therefore necessary to use a factor to estimate ground level concentrations of NO2 based upon total NOx
emitted, because assuming 100% conversion is overly pessimistic. Based upon Environment Agency
guidance (EA, 2005), it is assumed that, when assessing short term average concentrations, 35% of NOx
occurs as NO2 and, for long term average concentrations, 70% of NOx occurs as NO2.
4.1.1.2. Operational Hours

Operational activities for the normal operational scenario are assumed to occur continuously over a full
year i.e. 8760 hours, to provide a worst-case assessment of both short-term and long-term air quality
impacts.
Operational activities for Scenarios 2 and 3, assessing the impacts of an emergency flaring event and
potential upset conditions respectively, have been assessed against short-term air quality standards only,
given the temporary nature of such emissions.
4.1.1.3. Assumptions and Limitations

 It is acknowledged that the absence of building data within the model is a limitation of the study as
it may underestimate the maximum predicted impacts.
 The use of on-site plant operating on diesel will be minimised in line with industry best practice.
 Emergency flaring events will be minimised. A total of 12 events per year have been assumed for
the assessment.
4.2. OPERATIONAL SCENARIOS

In order to provide a representative assessment of the likely operational conditions at the FPSO unit, the
following scenarios have been considered in the study:
1. Normal operations (operating on gas)

 Emission sources:
o Three gas turbine generators (19.7MWth combined)
o HP gas compressor (45.6MWth)
 Pollutant Assessment:
o Annual mean NO2 concentrations
o 1-hour NO2 concentrations (99.79th percentile)
2. Normal operations (operating on gas) with emergency flaring
o Three gas turbine generators (19.7MWth combined)
o HP gas compressor (45.6MWth)
o HP emergency flare
7
o 1-hour SO2 concentrations (99.72nd percentile)
o 15-minute SO2 concentration (99.9th percentile)
3. Upset conditions (diesel gas turbine generator use and emergency flaring)
o Three gas turbine generators using diesel (19.7MWth combined)
o HP emergency flare
o 1-hour SO2 concentrations (99.72nd percentile)
o 15-minute SO2 concentration (99.9th percentile)
4.3. EMISSIONS INVENTORY

An inventory of data for the proposed operational plant on the FPSO unit was provided directly by Shell for
the assessment. At the time of writing, due to on-going project developments, the exact model of the gas
compressor and power generators to be utilised onsite were unknown. Multiple options were however
provided by Shell and therefore the worst-case options, in terms of emissions, were selected for the
assessment. Full details of the emissions parameters are provided in Table 4-2 below.
Additional auxiliary plant will also be utilised on-site (emergency generator and three fire pumps), however
the potential impact of their emissions was not considered to be significant due to their non-continuous
operational nature. Whilst the likely size of the auxiliary plant and hours of operation were provided by
Shell, the exact models were unknown and therefore emissions parameters were reviewed from auxiliary
plant considered to be representative to those likely to be installed at the FPSO.
Table 4-2 Emission Parameters
PARAMETER UNITS VALUE
GAS COMPRESSOR POWER GENERATOR FLARE (HP)

W. WHRU
Assumed Model General Electric Solar Taurus 70 N/A

PGT20
Location of flues 585400, 6823511 585398, 6823510 585460,

(easting, 6823568
585400, 6823511
northing)a
585402, 6823512
Number of units 1 3 1
Number of 1 3 1
stacks
Number of flues 1 1 1
per stack
8
PARAMETER UNITS VALUE
GAS COMPRESSOR POWER GENERATOR FLARE (HP)

W. WHRU
Flue diameter m 2.15 2.15 (x3) 1.65
Stack height m 64.0 60 113
Flue gas Celsius 475 413 1000

temperature
Exit Velocity m/s 15.5 7.04 200
Volumetric Flow Nm3/s 18.5 9.17 119

Rate (per stack)
Volumetric Flow Am3/s 56.4 25.6 426

Rate (per stack)
Emission rates
NOx g/s 0.95 0.47 143
SOx g/s n/a n/a 3.27
VOCs g/s n/a n/a 294
Emission rates (alternative fuel use – Diesel)
NOx controlled g/s n/a 14.7 n/a
*SOx g/s n/a 13.7 n/a
VOCs g/s n/a 0.80 n/a
a Coordinate system - European Datum 50, 0 degrees

*Assumed max sulphur content in fuel in north sea (EU Directive 2005/33/EC) = 1.5%
9
4.4. METEOROLOGY
The meteorological data used in the model need to reflect local conditions. Given the off-shore location, in
the absence of measurement station data in the area, prognostic MM5 data were used for the FPSO unit
location (61.534108O N, 1.606761O E). The use of prognostic data is advocated for use particularly
where measurement data are not readily available, such as remote locations and for off-shore applications.
MM5 data are however ultimately based upon measured empirical data.
To ensure that meteorological variability was taking into account in the study, five years of hourly
sequential data for 2010-2014 inclusive were used in the assessment. The wind roses for these data are
illustrated in Figure 4-1.
10
Figure 4-1 Wind Roses for Penguin FPSO (2010-2014)
11
4.5. RECEPTORS
Due to the remote location of the FPSO unit, there are no specific human receptors within 10 km of the
FPSO and therefore discrete receptors have not been included within the modelling exercise. In order to
ascertain the maximum potential impacts off-site, a receptor grid has been used in the assessment. A grid
of receptors measuring 20 km by 20 km centred on the FPSO unit site (i.e. a 10 km radius), is defined in
the model in line with UK guidance (SEPA, 2003) 1.
This grid is considered to be appropriate to assess the worst-case impacts at all potential sensitive human
receptors in the vicinity of the Penguin FPSO unit location.
(1)The Environment Agency for England have updated H1, with the most up to date version (v2.2) issued in 2012. In some circumstances SEPA advised
12
5. SIGNIFICANCE CRITERIA
In relation to effects on sensitive human receptors, the significance of effects used in the EIA process is
determined based on guidance developed jointly by Environmental Protection UK (EPUK) and the UK
Institute of Air Quality Management (IAQM) (Environmental Protection (UK), 2010). The significance is
determined in terms of:
 Process Contribution (PC), this is the impact associated with emissions from the Project only; and
 Predicted Environmental Concentration (PEC), this is the impact associated with PC added to the
existing background conditions.
The criteria presented in Table 5-1 have been used to assess the significance of effects on sensitive human
receptors. The process is in two stages:
 Screening stage, to determine the magnitude of impacts of the PC as a percentage of the air
quality standard or guideline; and
 Second stage, to determine the significance of effects in terms of the magnitude of impacts
identified from the screening stage, considered alongside the PEC.
Table 5-1 Significance Criteria for Assessing Impacts at Human Sensitive Receptors (EPUK, 2010)
DETERMINATION OF MAGNITUDE
Magnitude of impact PC as a percentage of air quality standard or guideline
Large PC >10%of AQS
Medium PC 5% - 10% of AQS
Small PC 1% - 5% of AQS
Negligible PC <1% of AQS
DETERMINATION OF SIGNIFICANCE
Magnitude of Impact Negligible Small Medium Large
PEC above air quality Not Minor adverse Moderate Major

standard or guideline with significant adverse adverse
or without scheme
PEC below air quality Not Minor adverse Moderate Moderate

standard or guideline significant adverse adverse
without scheme and PEC
above air quality standard
with scheme
13
DETERMINATION OF MAGNITUDE
PEC below air quality Not Not significant Minor Minor adverse
standard or guideline with significant adverse
scheme (75%-90% of air
quality standard or
guideline)
PEC well below air quality Not Not significant Not Minor adverse
standard or guideline with significant significant
scheme (<75% of air
quality standard or
guideline)
14
6. ASSESSMENT RESULTS
The PC and PEC for NO2 and SO2 have been calculated for comparison with the relevant Scottish Air
Quality Standards, based on the emissions inventory detailed in Section 4.3. The results for each of the
investigated scenarios identify the maximum concentrations (as relevant percentiles) predicted over a
period of five years 2010 – 2014 on a sea level receptor grid, as discussed in Section 4. This approach
therefore presents the worst case impact for the pollutants of interest anywhere in the study area at sea
level. The overall significance for each Scenario is then determined on the basis of the approach outlined
in Section 5.
The modelling has also been undertaken based on historic background monitoring data from Strathvaich,
given the remote locations of the FPSO unit, as these were the data considered to be most appropriate at
the time of writing. It is not expected however that the conclusions of the assessment would be substantially
different should site specific ambient air quality data for the vicinity of the FPSO unit ever be available for
use.
The predicted impact of FPSO operations on CO2 emissions are also detailed in Section 5.5.
6.1. SCENARIO 1 – NORMAL OPERATIONS

This scenario has been modelled based on the operation and associated emissions from the HP gas
compressor and three gas turbine generators for NO2. The modelling has been based on the source
parameters and emissions inventory detailed in Section 4.3.
A summary of the maximum short-term and long-term NO2 concentrations arising anywhere on the
modelled receptor grid is presented in Table 6-1 below, together with the overall significance of the
predicted impacts when compared to the relevant air quality standards
Table 6-1 Maximum Predicted Pollutant Concentrations (µg/m3) – Scenario 1 (Normal Operations)

PERIOD
Nitrogen Annual mean 40 1.44 7.28x 0.18% 1.51 3.78% Not significant
dioxide (NO2) 10-2
1 hour 200 2.88 2.66 1.33% 5.54 2.77% Not significant

(99.79th
percentile)
KEY
Major adverse impacts
Moderate adverse impacts
Minor adverse impacts
Not significant
15
6.1.1. Scenario 1 Findings

When considering the PC and PEC for the normal operation of the Penguin FPSO unit, not significant
impacts are predicted at all locations for both annual mean and 1-hour NO2 concentrations against the
Scottish Air Quality Standards.
Predicted pollutant contours have also been prepared and are illustrated in Figure 6-1 and Figure 6-2.
16
Figure 6-1 Maximum Predicted 1-hour NO2 Concentrations - Scenario 1 - Normal Operations
17
Figure 6-2 Maximum Predicted Annual Mean NO2 Concentrations - Scenario 1 - Normal Operations
18
6.2. SCENARIO 2 – NORMAL OPERATIONS WITH EMERGENCY FLARING

This scenario has been modelled based on the operation and associated emissions from the gas
compressor and three gas turbine generators, in addition to an emergency flaring event for the pollutants
of concern from the FPSO unit. The modelling has been based on the source parameters and emissions
inventory detailed in Section 4.3.
A summary of the maximum short-term NO2 and SO2 concentrations arising anywhere on the modelled
receptor grid is presented in Table 6-2 below, together with the overall significance of the predicted
impacts when compared to the relevant air quality standards.
Table 6-2 Maximum Predicted Pollutant Concentrations (µg/m3) - Scenario 2 (Normal Operations
Including Flaring)

PERIOD
Nitrogen 1 hour 200 2.88 2.66 1.33% 5.54 2.77% Not significant
th
dioxide (NO2) (99.79
percentile)
Sulphur 1 hour 350 19.2 1.94 0.001% 19.2 5.49% Not significant
dioxide (SO2) (99.72nd x10-
03
percentile)
15-minute 266 19.2 3.49 0.001% 19.2 7.22% Not significant

(99.9th x10-3
percentile)
KEY
Not significant

When considering the PC and PEC for the normal operation (including emergency flaring) of the Penguin
FPSO unit, not significant impacts are predicted at all locations for 1-hour NO2 concentrations, together
with 1-hour and 15-minute SO2 concentrations against the Scottish Air Quality Standards. Due to the low
predicted pollutant concentrations, the preparation of contour plots for Scenario 2 has not been considered
necessary.
19
6.3. SCENARIO 3 – UPSET CONDITIONS (DIESEL GAS TURBINE GENERATOR USE AND EMERGENCY
FLARING)
This scenario has been modelled based on the operation and associated emissions from the three gas
turbine generators operating on diesel, in addition to an emergency flaring event, for the principal
pollutants of concern on the FPSO unit. The modelling has been based on the source parameters and
emissions inventory detailed in Section 4.3.
A summary of the maximum short-term NO2 and SO2 concentrations arising anywhere on the modelled
receptor grid is presented in Table 6-3 below, together with the overall significance of the predicted
impacts when compared to the relevant air quality standards.
Table 6-3 Maximum Predicted Pollutant Concentrations (µg/m3) - Scenario 3 (Upset conditions)

PERIOD
Nitrogen 1 hour 200 2.88 69.6 34.8% 72.5 36.2% Minor adverse
dioxide (NO2) (99.79th
percentile)
Sulphur 1 hour 350 19.2 155 44.2% 174 49.7% Minor adverse
dioxide (SO2) (99.72nd
percentile)
15-minute 266 19.2 204 76.6% 223 83.8% Minor adverse

(99.9th
percentile)
KEY
Not significant
20

When considering the PC and PEC for the Upset conditions (gas turbine generators using diesel) and an
emergency flaring event) of the Penguin FPSO unit, minor adverse impacts are predicted with regards to
both 1-hour NO2 and SO2 averaging periods, as well as 15-minute SO2 concentrations. Predicted PCs are
all considered to be Large (>10% of the relevant Scottish Air Quality Standard), however the PEC is not
predicted to exceed any of the relevant criteria.
The use of all three gas turbine generators on 100% load using diesel is considered to be highly unlikely, in
addition to an emergency flaring event occurring simultaneously, however it has been presented as a
worst-case scenario in terms of the potential non-routine emissions from the FPSO unit.
Predicted pollutant contours have also been prepared and are illustrated in Figure 6-3, Figure 6-4 and
Figure 6-5.
21
Figure 6-3 Maximum Predicted 1-hour NO2 Concentrations - Scenario 3 - Upset Conditions
22
Figure 6-4 Maximum Predicted 1-hour SO2 Concentrations - Scenario 3 - Upset Conditions
23
Figure 6-5 Maximum Predicted 15-minute SO2 Concentrations - Scenario 3 - Upset Conditions
24
6.4. DISCUSSION OF UNCERTAINTIES

It is acknowledged that uncertainties exist within dispersion modelling, in terms of both of data input and
subsequently the results output.
The following points have been discussed to acknowledge the potential effect of any modelling limitations
and the effect these may have on the overall assessment conclusions.
The omission of building downwash from the modelling assessment was noted as a limitation in the study,
in terms of identifying the maximum potential impact. Were the PCs for each pollutant in each scenario to
be conservatively doubled (allowing for any underestimation), overall the significance of impacts for both
Scenarios 1 and 2 - Normal operations on gas; and, normal operations on gas, with an emergency flaring
event, respectively, would not change from those concluded in the assessment i.e. not significant impacts.
Theoretically also doubling the PCs for Scenario 3 (upset conditions) however, would result in an increased
significance rating for both SO2 averaging periods (1-hour and 15-minute), increasing impacts to
moderate and major adverse, respectively. It is considered however that the likelihood of this very much
worst-case upset scenario occurring is low.
The remote location of the FPSO unit also presents uncertainty with regards to understanding the existing
baseline concentrations. Defra’s rural site at Strathvaich in the Scottish Highlands was selected as the most
representative of conditions in the North Sea. It is likely however that ambient air quality conditions at sea
would be lower than even a remote onshore environment for both NO2 and SO2 and therefore the
assessment approach is considered to be robust.
Five sequential years of meteorological data were also included in the modelling to present a robust
assessment. Using the ‘best-case’ meteorological year, only the significance of the 1-hour NO2 impacts is
reduced from minor adverse impacts to not significant. The significance of all pollutants in all other
scenarios would remain the same as reported, albeit with lesser concentrations.
With regards to potential uncertainties associated with the meteorological data used in the assessment,
whilst the data used was that of prognostic MM5 data (due to the absence of a meteorological station in
the remote study area), it is considered that the environment surrounding the FPSO site is relatively
straightforward to simulate, and therefore the meteorological data used are likely to be representative of
the site conditions.
6.5. CUMULATIVE FPSO GREENHOUSE GAS EMISSIONS

The cumulative operational combustion emissions from the FPSO have been calculated and are detailed in
Table 6.4. .Comparison has been made between the total greenhouse gas (CO2 emissions and the reported
2013 UKCS total CO2 emissions from offshore fixed installations (ie platforms and FPSOs) 1.
The total cumulative CO2 emissions from FPSO combustion sources are calculated to represent 0.17%,
which is not considered to be significant in relation to the reported 2013 UKCS total CO2 emissions from
fixed installations.
1Total CO2 2013 emissions from fixed installations (EEMS, 2014) tonnes 137,000,680
25
Table 6.4 Cumulative Combustion Emissions
NOx emissions per annum tonnes 489
SO2 emissions per annum tonnes 11.6
26
7. CONCLUSIONS
An assessment of impacts using dispersion modelling was undertaken for the operational stages of the
Project to quantify the predicted concentrations of NO2 and SO2. VOC emissions (such as benzene) were
not included in the modelling, as the annual mean averaging period within the Air Quality Standards does
not reflect the likely short-term time period when VOC emissions are likely to occur. Overall, there were no
predicted exceedances of any of the relevant Air Quality Standards for the pollutants of concern, for any of
the modelled scenarios at any location.
Slight adverse impacts for both 1-hour NO2 and SO2 concentrations, together with 15-minute SO2
concentrations, were predicted under Scenario 3 (upset conditions) through the use of the three gas
turbines generators operating on diesel, together with an emergency flaring event occurring
simultaneously. However, none of the Air Quality Standards were exceeded. This scenario is considered
to be highly unlikely, but was presented as a worst-case scenario in terms of the potential non-routine
emissions from the FPSO unit.
The total cumulative CO2 emissions from FPSO combustion sources are calculated to represent 0.17%, of
the reported 2013 UKCS total CO2 emissions from fixed installations, which is not considered to be
significant.
On the basis of the impact assessment, mitigation measures for reducing emissions and reducing impacts
are not considered necessary. However, in line with industry best practice, flaring events and the use of
plant operating on diesel will be minimised, with an overall focus on energy efficiency.
27
8. REFERENCES
Defra. (2009, February ). Local Air Quality Management Technical Guidance Note LAQM TG(09).
EA. (2005). Conversion rations for NOX and NO2. Retrieved from http://www.environment-
agency.gov.uk/static/documents/Business/noxno2conv2005_1233043.pdf
Environmental Protection (UK). (2010). Development Control: Planning for Air Quality (2010 update).
European Parliament. (2008). Directive 2008/50/EC of the European Parliament and of the Council of 21
May 2008 on ambient air quality and cleaner air for Europe.
SEPA. (2003). The Scottish Environmental Protection Agency (2003) v6 Horizontal Guidance Note H1.
28
APPENDIX D
UNDERWATER NOISE MODELLING REPORT

GLOSSARY
Peak Sound Pressure The maximum absolute value of the instantaneous sound
pressure recorded over a given time interval.
Peak to Peak Pressure The algebraic difference between the highest (positive) point to
the lowest (negative) point of a sound pressure signal. The peak
to peak value is higher for a given signal than the peak value.
Mean Square Sound Pressure The mean square pressure level measured over a given time
and represents a measure of the average sound pressure over
that time.
Root Mean Square Pressure The square root of the mean square pressure over a given time.
Sound Pressure Level The pressure values above expressed as decibel (dB) values
relative to stated reference pressure values.
Sound Exposure Level The time integral of the square pressure over a time window
long enough to include 90% of the energy of a sound pulse
expressed as a decibel relative to a standard reference. For a
single sound pulse the
Cumulative Sound Exposure The value calculated for multiple pulses which is used to
Level represent the logarithmic sum of received sounds from events
which individually quantified
Source Level The apparent strength of a sound source at a reference

distance, usually 1m, from the source.
Received Level The strength of the acoustic field at a given depth and range
relative to the source. As the sound varies with range, it is
important to state the range at which the measurement has
been taken or the estimate has been made.
ACRONYMS
p-p Peak to Peak
RMS Root Mean Square
SEL Sound Exposure Level
SELcum Cumulative SEL
RL Sound level experienced at receptor position

CONTENTS
1. Introduction ................................................................................................................................. 1
1.1. Introduction ......................................................................................................................... 1
2. Baseline ...................................................................................................................................... 3
2.1. Introduction ......................................................................................................................... 3
2.2. Marine Mammals ................................................................................................................ 3
2.2.1. Cetaceans.................................................................................................................... 3
2.2.2. Pinnipeds ..................................................................................................................... 3
2.3. Fish..................................................................................................................................... 3
3. Criteria ....................................................................................................................................... 4
3.1. Introduction ......................................................................................................................... 4
3.2. Marine Mammals ................................................................................................................ 4
3.3. Fish..................................................................................................................................... 8
4. Methodology ............................................................................................................................. 10
4.1. Introduction ....................................................................................................................... 10
4.2. Noise Sources ................................................................................................................... 10
4.2.1. Pilling ........................................................................................................................ 10
4.2.2. Drilling ...................................................................................................................... 12
4.2.3. FPSO Operation ........................................................................................................ 12
4.3. Site Specific Noise Transmission Loss Modelling of Piling ...................................................... 13
4.3.1. Transmission Loss Modelling Method ........................................................................... 13
4.3.2. Cumulative SEL Calculation Method ............................................................................. 13
4.3.3. Sound Speed Profile Data ........................................................................................... 15
4.3.4. Depth Data ................................................................................................................ 16
4.4. Generic Modelling (Drilling and FPSO Operation) ................................................................ 17
5. Modelling Results ....................................................................................................................... 18
5.1. Noise Propagation with Distance from Source ...................................................................... 18
5.2. SEL Calculations for Swim Away Model ............................................................................... 19
5.3. Summary of Distances at Which Criteria are Met for Piling ................................................... 19
5.4. Summary of Distances at Which Criteria are Met for Drilling and FPSO Operation ................. 21
TABLES
Table 3-1 Adopted Criteria for Piling ................................................................................................ 6
Table 3-2 Adopted Criteria for Shipping and Drilling ........................................................................ 7
Table 3-3 Injury and Behavioural Criteria for Fish - Pilling .................................................................. 8
Table 3-4 Injury and Behavioural Criteria for Fish – Shipping and Other Continuous Sources ............... 9
Table 4-1 Pilling Source Levels (Mooring Piles) ................................................................................ 12
Table 4-2 Piling Stages .................................................................................................................. 12
Table 4-3 The Low and High Frequency cut-off Parameters of the M-weighting Functions.................... 14
Table 5.1 Predicted SELcum Level due Piling.................................................................................... 19
Table 5-2 Calculated Distances for the Adopted Criteria .................................................................. 20
Table 5-3 RMS Sound Levels vs Range – Drilling & FPSO Operation ................................................. 21
FIGURES
Figure 1-1 Proposed FPSO Location ............................................................................................... 1
Figure 4-1 Example of on Impulsive Signal ................................................................................... 11
Figure 4-2 M-Weighting Functions for the Underwater Marine Mammal Hearing Groups ................ 15
Figure 4-3 Sound Speed Profile - July .......................................................................................... 16
Figure 4-4 Depth vs Range Used in Noise Modelling ..................................................................... 17
Figure 5-1 Sound Levels vs Range ................................................................................................ 18
1. INTRODUCTION
1.1. INTRODUCTION
The primary purpose of this study is to identify and assess the potential underwater noise impacts of the
proposed Shell UK Ltd Penguins Redevelopment Project (the Project) on marine fauna. There is the potential
for disturbance and injury to occur as a result of noise from certain activities in the marine environment.
Potential impacts from the Shell Penguin Project will arise from subsea piling during installation of anchor
piles for the FPSO and foundation piles for the manifolds. The installation (drilling) of wells will also
produce lower levels of continuous sound. Installation of pipelines will result in relative short term low level
noise levels and has not been considered further in this assessment.
During operation the most prominent source of underwater noise from the Project is likely to be the
offloading vessels, during the use of dynamic positioning thrusters.
The Project will take place in North Sea, with the FPSO 150 km north east from Shetland Islands coastal
area Figure 1-1.
Figure 1-1 Proposed FPSO Location
1
The report considers the following:

 The baseline noise environment;
 The appropriate noise assessment criterion for marine mammals and fish;
 The methodology used to quantify the noise emissions; and
 The results of the Noise modelling.
The assessment of the significance of the underwater noise is assessed in Chapter 9 of the Environmental
Statement (ES).
2
2. BASELINE
2.1. INTRODUCTION
A detailed baseline environment for marine mammal and fish as receptors to underwater noise is presented
in Chapter 4 of the Environmental Statement. This includes information on the wider distribution and range
of those species known to be present in the Penguins area and their use of the Penguins area and
surrounding environment for important life-stage events such as pupping / spawning or nursery areas. The
sections below list the key marine mammal and fish species referred to in Chapter 4 of the Environmental
Statement.
2.2. MARINE MAMMALS
2.2.1. Cetaceans
The main cetacean species known to occur in the northern North Sea are:
 harbour porpoise (Phocoena phocoena);
 minke whale (Balaenoptera acutorostrata);
 killer whale (Orcinus orca);
 Atlantic bottlenose dolphin (Tursiops truncatus);
 white-beaked dolphin (Lagenorhynchus albirostris);
 Atlantic white-sided dolphin (Lagenorhynchus acutus); and
2.2.2. Pinnipeds
Pinniped species known to occur in the northern North Sea including the Penguins area are as follows;
 Common seal (Phoca vitulina); and
 Grey seal (Halichoerus grypus).
2.3. FISH
The fish spawning and nursey grounds known to occur in the Penguins project area are as follows;
 whiting (Merlangius merlangus);
 cod (Gadus morhua);
 haddock (Melanogrammus aeglefinus);
 saithe (Pollachius virens);
 Norway pout (Trisopterus esmarkii);
 herring (Clupea harengus);
 sandeel (various species); and
 mackerel (Scomber scombrus).
A full description of the baseline situation and the distribution of species is contained in Chapter 4 of
the Environmental Statement.
3
3. CRITERIA
3.1. INTRODUCTION
The two broad categories of effects considered in this assessment are as follows:
 Injury – Commonly described in terms of permanent threshold shift (PTS) in an individual’s hearing
ability(1); and
 Behavioural Response: This can involve moving away or avoidance, or other notable changes to
behaviour which are outside of an animal’s normal range of behaviour. It is noted that responses
to sound of this kind are highly variable and context specific.
It should be noted that PTS has not been measured in marine mammals, and the thresholds are based on
TTS thresholds with an extrapolation based on the difference between PTS and TTS that has been observed
in other mammals. Exceedances of PTS thresholds do not necessarily mean that permanent hearing
damage would occur. A precautionary approach has therefore been taken by using these thresholds in
this assessment. For fish criteria are based on “mortality and Potential Mortal Injury” and “recoverable
injury”.
3.2. MARINE MAMMALS

The work of Southall et al (2007) (2) of the Marine Mammal Criteria Group sets out criteria for damage and
behavioural reactions of marine mammals to noise and has been used to derive criteria for the assessment
of potential noise impacts from the Project on marine mammals. The study reviews data for activities
involving multiple noise pulses (such as piling) separately from more continuous, non-pulsed, noise (such as
from vessel noise and operation of the FPSO).
In line with the guidance (JNCC, NE and CCW 2010), the point at which Permanent Threshold Shift (PTS)
will occur has been identified based on the work in (Southall et al 2007). The study suggests that in order
to cause instantaneous injury to cetaceans resulting in PTS, the sound level must exceed 230 decibels (dB)
re 1 micropascal (μPa) (peak). For pinnipeds, Southall et al (2007) suggest a level of 218 dB re
1 μPa (peak).
Southall et al (2007) includes criteria for cumulative Sound Exposure Level (SEL) which assesses the
potential for marine mammals to experience PTS as a result of accumulated noise exposure over a 24 hour
period. It provides criteria for three of the four different functional categories of marine mammals in water
(low/mid frequency cetaceans, and seals), but identifies the need for more information on high-frequency
cetaceans. Calculations are based on assumptions regarding the location of animals in relation to the
noise source and worst case scenarios have been adopted in this assessment for each group of species.
The criteria are described in Table 3-1.
Lucke et al (2009) have suggested a level of 200 dB re 1 μPa (p-p) at which Temporary Threshold Shift
(TTS) may occur based on a study of a single captive harbour porpoise (a high frequency cetacean)
exposed to noise from an airgun. This would equate to a level which is 6 dB higher for PTS (using the
procedures described in Southall et al which enable extrapolation to PTS from TTS data (ie a criterion of
206 dB re 1 μPa (p-p)), or which would be equivalent to 190 dB re 1 μPa (RMS) (3).
(1) Temporary Threshold Shift (TTS) is also an effect of sound, but is considered to be auditory fatigue rather than an injury.
(2) Southall, B. A. B. W. E. J. F. R. G. C. G. J. D. K. D. K. J. M. P. N. W. R. J. T. a. P. T., 2007. Marine mammal noise exposure criteria: initial scientific
recommendations. Aquatic Mammals, Volume 33(4), pp. 411-522.
(3) Based on subtracting approximately 6 dB to convert to peak and then converting to rms by subtracting a further 10 dB which is appropriate for a
seismic test source that was used in the Lucke et al study.
4
A second SEL criterion of 164 dB re 1 μPa2s is also proposed in Lucke et al (2009) for TTS which would be
equivalent to 179 dB re 1 μPa2s for PTS using the conversion factor of 15 dB which is discussed in Southall
et al. These criteria have been adopted in this assessment for high-frequency cetaceans.
Southall et al includes a database of studies on behavioural responses to sounds, for five different
functional hearing categories of marine mammals (low/mid/high frequency cetaceans, and pinnipeds in
air/water). The documented responses to certain types of sound have been logged using a unique severity
scoring system which ranks the sound level at which behavioural responses start from a zero for ‘no
response’ to a 9 for ‘outright panic, flight, stampede, attack of conspecifics or stranding events’. However,
it is recognised that there is not enough data to be able to specify sound levels corresponding to all of the
severity rating levels.
The species referred to in the study are limited as research has not been conducted into the responses of all
possible species, including some of those known to occur in northern North Sea. It is therefore necessary to
infer the responses of known species onto others within the same functional hearing category.
JNCC guidance (JNCC, 2010) (1) recommends a severity rating level of ‘5’ as a significant threshold and
has therefore been identified as the relevant level for this assessment, and where there are no direct data
for this severity rating level data for other reaction levels has had to be used to estimate a suitable level ’5’
reaction level. The adopted criteria and the behavioural severity scores on which they are based are
summarised at the end of this section in Table 3-1.
During the literature research it was noted that there were limited data on which to establish the level at
which these behavioural responses of severity rating level of ‘5’ are likely to occur. Whilst it would have
been possible to adopt a precautionary approach and base the criteria on data for a less significant
reaction, this would be extremely precautionary in some cases. This is particularly obvious when much
higher sound levels are needed to result in a reaction that would be classed as just above level ‘5’.
Therefore, the approach that has been taken in this report is to present “precautionary” and less
precautionary “alternative” criteria where necessary to describe the likely bounds of the area over which
behavioural response is possible.
The criteria in Table 3-1 have been adopted in this assessment for the assessment of piling.
(1)The Protection of Marine European Protected Species from Injury and Disturbance, Guidance for the marine area in England and Wales and the UK
offshore marine area – Draft (in Preparation), JNCC, NE and Council for Wales, October 2010.
5
Table 3-1 Adopted Criteria for Piling
SPECIES ADOPTED CRITERIA, ADOPTED ADOPTED FREQUENCY

CRITERIA, CRITERIA, WEIGHTING
dB re 1 μPa (RMS)
dB re 1 μPa dB re 1 μPa2s
PRECAUTIONARY ALTERNATIVE (PEAK) (SEL)
Behavioural Effects
Low Frequency 140 None

Cetaceans
Mid Frequency 140 170 None

Cetaceans
High Frequency 140 158 None

Cetaceans
Pinnipeds 160 None
Auditory Injury

Cetaceans
Low Frequency 198 Mlf

Cetaceans
Mid Frequency 230 None

Cetaceans
Mid Frequency 198 Mmf

Cetaceans
High Frequency 200 None

Cetaceans

Cetaceans
Pinnipeds 218 None
Pinnipeds 186 Mpw
The criteria in Table 3-2 have been adopted in this assessment for the assessment of shipping and drilling.
6
Table 3-2 Adopted Criteria for Shipping and Drilling
SPECIES ADOPTED ADOPTED ADOPTED FREQUENCY

CRITERIA, CRITERIA, CRITERIA, WEIGHTING
dB re 1 μPa dB re 1 μPa dB re 1 μPa2s
(RMS) (peak) (SEL)
Behavioural Effects

Cetaceans

Cetaceans

Cetaceans
Pinnipeds 120 None
Auditory Injury

Cetaceans
Low Frequency 215 Mlf

Cetaceans

Cetaceans
Mid Frequency 215 Mmf

Cetaceans

Cetaceans
High Frequency 215 Mhf

Cetaceans
Pinnipeds 218 None
Pinnipeds 203 Mpw
7
3.3. FISH
Research into both injury and possible avoidance response for fish has been carried out by various
researchers. A review of studies by Popper, Hawkings et al, 2014(1) reviews the current data and previous
assessment practice and sets out interim standards for sound threshold criteria.
For pulsed noise sources (e.g. piling), numerical criteria apply to the potential for mortality and potential
mortal injury, recoverable injury and TTS. There is a lack of direct observations of the effect of piling on
the potential for masking effects and behaviour so these aspects are dealt with in a qualitative manner. For
behaviour and masking the relative risk of an effect taking place is indicated as being “low”, “moderate”
or “high” at three distances from the source that are termed “near”, “intermediate” and “far”. Since there
are many variables that will influence the distances at which these events occur, specific distances are not
assigned to these terms. However, “near” might be considered to be tens of metres from the source,
“intermediate” might be hundreds of metres and “far” could be thousands of metres.
The interim criterion developed for the three categories of fish that have been adopted by the Popper,
Hawkins et al are presented in Table 3-3.
Table 3-3 Injury and Behavioural Criteria for Fish - Pilling

POTENTIAL
MORTAL INJURY RECOVERABLE TTS MASKING
INJURY
Fish: no swim >219 dB SELcum or >216 dB SELcum or >186 dB SELcum (N) Moderate (N) High
bladder (particle
>213 dB Peak >213 dB Peak (I) Low (I) Moderate
motion detection)
(F) Low (F) Low
Fish: swim 210 SELcum or >203 dB SELcum or >186 dB SELcum (N) Moderate (N) High
bladder is not
>207 dB Peak >207 dB Peak (I) Low (I) Moderate
involved in
hearing (particle (F) Low (F) Low
motion)
Fish: swim 207 SELcum or >203 dB SELcum or >186 dB SELcum (N) High (N) High
bladder involved
>207 dB Peak >207 dB Peak (I) High (I) High
in hearing
(primary pressure (F) Moderate (F) Moderate
detection)
Fish eggs and >207 dB Peak or - - - -

larvae
>210 SELcum
Peak sound pressure levels dB re 1 μPa; SEL dB re 1 μPa2s. NB: N = near (i.e. tens of metres), I = intermediate (i.e.
hundreds of metres), F = low as defined (i.e. thousands of metres).
(1) Sound Exposure Guidelines for Fishes and Sea Turtles: A Technical Report Prepared by ANSI-Accredited Committee S3/SC1 and Registered with
ANSI ASA S3/SC1.4 TR-2014: Popper Hawkings et al, 2014
8
There is no direct evidence of mortality or potential mortal injury to fish from ship noise. Some evidence for
auditory tissue effects or TTS caused by continuous sound comes from data on goldfish (Carassius auratus),
an otophysan species that has specializations for enhanced sensitivity to sound pressure. Some recoverable
loss of sensory hair cells occurred in the ear after 48 hours of exposure to white noise at 170 dB re 1 μPa
RMS (1). A maximum TTS of about 16 dB accompanied this loss. Recovery of TTS took seven days and full
replacement of the sensory cells took eight days. Exposure to 158 dB re 1 μPa RMS in another study also
resulted in TTS in goldfish (26 dB TTS) and another pressure sensitive fish that hears well, the catfish
(Pimelodus pictus) (32 dB TTS) (2). Full recovery occurred after three days for the goldfish and after
fourteen days for catfish.
The interim criterion developed for the three categories of fish that have been adopted by the Popper,
Hawkins et al are presented in Table 3-4.
Table 3-4 Injury and Behavioural Criteria for Fish – Shipping and Other Continuous Sources

POTENTIAL
MORTAL INJURY RECOVERABLE TTS MASKING
INJURY
Fish: no swim (N) Low (N) Low (N) Moderate (N) High (N) Moderate
bladder (particle
(I) Low (I) Low (I) Low (I) High (I) Moderate
motion detection)
(F) Low (F) Low (F) Low (F) Moderate (F) Low
Fish: swim (N) Low (N) Low (N) Moderate (N) High (N) Moderate
bladder is not
(I) Low (I) Low (I) Low (I) High (I) Moderate
involved in
hearing (particle (F) Low (F) Low (F) Low (F) Moderate (F) Low
motion)
Fish: swim (N) Low 170 dB RMS for 158 dB RMS for (N) High (N) High
bladder involved 48h 12 h
(I) Low (I) High (I) Moderate
in hearing
(primary pressure (F) Low (F) High (F)Low
detection)
RMS sound pressure levels dB re 1 μPa.

NB: N = near (i.e. tens of metres), I = intermediate (i.e. hundreds of metres),
F = low as defined (i.e. thousands of metres).
(1) Smith ME, Coffi n AB, Miller DL, Popper AN (2006) Anatomical and functional recovery of the goldfish ( Carassius auratus ) ear following noise
exposure. J Exp Biol 209:4193–4202
(2) Amoser S, Ladich F (2003) Diversity in noise-induced temporary hearing loss in otophysine fishes. J Acoust Soc Am 113:2170–2179
9
4. METHODOLOGY
4.1. INTRODUCTION
In order to predict the levels of underwater noise two approaches have been taken. Firstly for major noise
sources such as driven piling site-specific modelling has been carried out to ensure that a realistic estimate
of noise propagation has been derived. For the other less noisy sources a simplified approach has been
taken using the upper and lower bounds of typical spreading losses that are encountered in underwater
noise environments.
In both of these approaches the predictions have been based on a quantitative assessment, which has
required a noise source level to be quantified based on published data. Section 4.2 summarises the
assumptions made for the modelled noise sources. Section 4.3 summarises the inputs that have been used
to carry out the site-specific modelling and the calculation methodologies and Section 4.4 summarises the
simplified modelling approach.
4.2. NOISE SOURCES
4.2.1. Pilling
Pilling activities will be associated with the FPSO’s mooring Anchor installation and the installation of
foundation piles for the subsea manifolds onto the seabed. Pile driving generates sound as the driving
hammer strikes the pile, the sound then propagates into the water column and seabed through the pile
itself. The peak to peak source level for pile-driving can be calculated using the equation below.
𝑆𝑆 (𝑝𝑝𝑝𝑝 − 𝑝𝑝𝑝𝑝) = 24.3𝐷 + 179 (8)
Where D is the pile diameter in metres.

The largest diameter piles which will be used have a diameter of 2.4 m. Thus the SL(peak-peak) is
predicted to be 237 dB re 1 μPa at 1 m. The IHC S800 impact hammer’s maximum blow rate is 38 bl/min
which results in a gap of approximately 1.6 sec between blows.
The peak source level (SL(peak) ) represents the peak pressure in an acoustic wave over a given time
expressed as a decibel level with respect to 1 µ Pascal of pressure. Where the wave is symmetrically
distributed in positive and negative pressure (see Figure 4-1) which is the case for piling the SL(peak) will be
given by the equation below (9).
𝑆𝑆 (𝑝𝑝𝑝𝑝) = 𝑆𝑆(𝑝𝑝𝑝𝑝 − 𝑝𝑝𝑝𝑝) − 6
(8) Nedwell, J.R., Workman, R., Parvin, S.J., 2005. The assessment of likely levels of piling noise at Greater Gabbard and its comparison with
background noise, including piling noise measurements made at Kentish Flats. Subacoustech Report, 633R0115, Southampton.
(9) Richardson, W.J., Green Jr, C.R., Malme, C.I. & Thomson, D.H. (1995). Marine Mammalsand Noise. Academic Press, New York.
10
Figure 4-1 Example of on Impulsive Signal
Since the criteria for assessment of underwater effects on marine mammals relies on not only on peak
pressure levels but also root-mean-square (RMS) levels and SEL levels, factors have been derived to convert
peak levels into these metrics. Illiniworth and Rodkin (2007) (10) estimated the difference between SL(peak)
and SL(RMS) due to piling noise. Based on a number (25) of different measurements, in shallow waters, of
different diameter (0.3-2.4 meter) piles, they found that the average difference between SL(peak) and SL(RMS)
was approximately 15 dB re 1 μPa. Therefore, the SL(RMS) was estimated by subtracting 15 dB from the
SL(peak).
The SEL is given by the equation below,
2
𝑝𝑟𝑟𝑟 𝑇
𝑆𝑆𝑆 = 10𝑙𝑙𝑙10 2
𝑝𝑟𝑟𝑟
where pref is 1 μPa (RMS) sound pressure and pRMS presents the RMS levels over the duration (T) of the
pulse. Given that,
𝑝𝑟𝑟𝑟
𝑆𝑆(𝑟𝑟𝑟) = 20𝑙𝑙𝑙10
𝑝𝑟𝑟𝑟
then,
𝑆𝑆𝑆 = 𝑆𝑆(𝑟𝑟𝑟) + 10log10 (𝑇)
Then assuming a typical pulse duration equal to 0.1 s(11), then the SEL per pulse is equal to,
𝑆𝑆𝑆 = 𝑆𝑆(𝑟𝑟𝑟) − 10
(10) Illinworth and Rodkin, Inc. (2007). Compendium of Pile Driving Sound Data, prepared for the California Department of Transportation.
(11)De Jong and Ailslie, Underwater radiated noise due to the piling for the Q7 Offshore Wind Park. Acoustics 08 Paris, 2008.
11
The calculated source levels are shown in Table 4-1. It is noted that the factors are likely to vary from one
situation to another, and for that reason a conservative factors have been used to convert between the
different indices.
Table 4-1 Pilling Source Levels (Mooring Piles)
SL(peak) dB re 1 μPa at 1 m SL(RMS) dB re 1 μPa at 1 m SEL dB re 1 μPa2 at 1 m
231 216 206
The installation stages for each pile are shown in Table 4-2. It has been assumed that only one anchor per
day will be installed, thus the piling duration will be 3 hours in the 24 hours assessment period.
Table 4-2 Piling Stages
Stage Duration (min) Blow rate (blow/min)
1-Soft/slow start 30 1
2-Main piling period 140 20
3-Driving pile to refusal 10 38
Piling will also take place at the manifolds. The piling locations are show in the Project Description
(Environmental Statement, Chapter 3). A smaller pile will be required for this activity, but he same source
noise levels have been used as for the mooring piles, which is a conservative approach.
4.2.2. Drilling
Drilling will be carried out at seven well locations using a semi-submersible rig. Semi-submersibles are
floating platform type drilling rigs which use pontoons that are partially submerged in the water. They give
rise to continuous noise, but typically are less noisy than drill ships. An anchored semi-submersible rig
generates sounds in the range of 0.016 to 0.2 kHz, and during drilling the sound pressure level (SPL) can
reach the 170 dB re 1 μPa at 1 m (RMS) (12).
4.2.3. FPSO Operation

The FPSO will be reliant on support and supply vessels and offloading tankers. These vessels will be
equipped with dynamic positioning thrusters which will increase the underwater noise levels compared to
normal operation of the FPSO. Thrusters on vessels that are manoeuvring during offloading of the product
will also result in high underwater noise levels. No noise data have been provided for the specific FPSO
vessels that will be used and so the predictions of impacts have been based on published measurements of
similar vessels. The underwater noise levels are highest in the frequency range of 25 to 50 Hz during the
use of thrusters. Vessels associated with the FPSO were assumed to generate noise levels of
(12)Richardson, W.J., Greene Jr., C.R., Malme, C.I., Thomson, D.H., 1995. Marine Mammals and Noise. Academic, San Diego, CA.
12
192 dB re 1 μPa at 1 m (RMS) (based on Wyatt 2008) (13) during their worst-case operational mode which
is offloading during the use of dynamic positioning thrusters.
4.3. SITE SPECIFIC NOISE TRANSMISSION LOSS MODELLING OF PILING
4.3.1. Transmission Loss Modelling Method

For the piling noise assessment a model has been used which can take into account site-specific factors that
affect propagation such as bathymetry, seabed type and acoustic properties of the water column. Noise
modelling has been carried out using well established noise modelling algorithms to predict noise
propagation as it spreads out from the sound sources in relevant marine environment. A number of
available prediction codes such as RAMGEO, RAMSGEO and Bellhop & Bounce can be used in order to
reflect the intricacies of real-life environments, in range-dependent conditions such as sloping or irregular
seabed areas, range-varying sound speed profiles and elastic sea-beds, over a large frequency range.
Underwater noise propagation has been modelled using the RAMSGEO prediction code up to frequencies
of 1000 Hz. This calculation method assumes that shear waves would propagate in elastic sea beds as
well as compressive waves, which allows for the sea bed type in this situation to be represented robustly.
For frequencies above 1000 Hz the Bellhop noise prediction code has been used to calculate the noise
propagation due to its faster calculation time. These propagation codes are well established methods for
accurately predicting underwater noise and have been used as part of ERM’s Marine Mammals Noise
Exposure Tool (MMNET) in house software. The MMNET model has been used on a series of successful
projects to predict noise levels and aid the efficient assessment of impacts and specification of mitigation to
meet international and local regulatory requirements.
4.3.2. Cumulative SEL Calculation Method

Cumulative Sound exposure levels (SELcum) for an animal moving away from the survey have also been
calculated using ERM’s MMNET software, which effectively moves the animal through the sound field
accumulating the SEL taking into account the distances at which pulses of sound from piling are received by
the moving animal. The model assumes the animal starts outside the 500 m exclusion zone, as required by
the mitigation guidelines (14), and travels to a distance of 60 km from the survey (which is the limit of the
area which was modelled). Whilst the assumption regarding the 500 m starting point can be relied upon
for marine mammals due to the pre-start exclusion zone, it cannot be said with certainty that no fish will be
within this area. However, it has been adopted as a reasonable scenario. The assumption is also that the
animal swims away at a depth of 80 to 90 m (in the noisiest part of the sound field) at a speed of 12
km/h.
The calculation is carried out over 24 hours as defined by the noise criteria discussed in Section 3.2. This
SELcum calculation has taken the soft start procedure into account, which allows animals to move away
from the noise source before the maximum blow rate is reached. This calculation has only been applied to
piling which is the most significant noise source. For continuous noise sources (e.g. Drill and FPSO
operation)it has been assumed that animals do not remain close enough to the source to result in auditory
damage. Therefore, the SEL approach has not been adopted.
The methodology in Southall et al requires M-weightings filters to be used to predict the SEL noise levels,
more specifically:
 Mlf – weighting for low frequency cetaceans;
 Mmf – weighting for mid frequency cetaceans;
(13) Wyatt, R. (2008). Joint Industry Programme on Sound and Marine Life - Review of Existing Data on Underwater Sounds Produced by the Oil and
Gas Industry.
(14) The Marine Mammal Observer should make a visual assessment to determine if any marine mammals are within 500 metres of the centre of the
airgun array, JNCC, 2010.
13
 Mhf – weighting for high frequency cetaceans; and

 Mpw – weighting for pinnipeds in water.
The general expression for M-weighting uses lower and upper frequency limits for each of the four
functional marine mammals hearing groups. The expression is given as follows:
𝑅(𝑓) (15)
𝑀(𝑓) = 20𝑙𝑙𝑙10
max{|𝑅(𝑓)|}
where
2
𝑓ℎ𝑖𝑖ℎ 𝑓
𝑅(𝑓) = 2 2 )
(𝑓 2 +𝑓ℎ𝑖𝑖ℎ )(𝑓 2 +𝑓𝑙𝑙𝑙
The four functional marine mammal hearing groups and given in Table 4-3.
Table 4-3 The Low and High Frequency cut-off Parameters of the M-weighting Functions
MARINE MAMMAL HEARING flow (Hz) fhigh (Hz)

GROUP
Low – frequency cetaceans (lf) 7 22000
Mid – frequency cetaceans (mf) 150 160000
High – frequency cetaceans (hf) 200 180000
Pinnipeds in water(pw) 75 75000
(15) Southall, B. L., Bowles, A. E., Ellison, W. T., Finneran, J. J., Gentry, R. L., Greene Jr., C. R., Kastak, D., Ketten, D. R., Miller, J. H., Nachtigall, P. E.,
Richardson, W. J., Thomas, J. A. and Tyack, P. L. (2007). Marine mammals noise exposure criteria: initial scientific recommendations. Aquatic
Mammals. 33: 411-521.
14
Figure 4-2 M-Weighting Functions for the Underwater Marine Mammal Hearing Groups
4.3.3. Sound Speed Profile Data

Sound speed profile data are taken from ESME Workbench 2012 software, which uses the Generalised
Digital Environment Model (GDEM), a four-dimensional steady-state digital model data base of ocean
temperature, salinity and sound speed. The speed of sound in the sea varies with changing values of
temperature, salinity and pressure (depth). Close to the surface the sound speed dependence on
temperature is much stronger than its dependence on the other variables (Duncan and McCauley) (16). At
larger depths (larger that in this study area) the pressure effect dominates and the sound speed increases
with increasing the depth. However, in this case the temperature reductions with depth result in general
reduction in sound speed throughout the water column. Figure 4-3 shows sound speed profile for July,
when the anchor pile installation will take place.
(16) Environmental Impact Assessment of Underwater Sound: Progress and Pitfalls. AAS 2008.
15
Figure 4-3 Sound Speed Profile - July
4.3.4. Depth Data

Depth data have been taken from EMODnet (17). The EMODnet-Bathymetry portal is being developed in the
framework of the European Marine Observation and Data Network (EMODnet) as initiated by the
European Commission. It provides services for discovery and requesting access to bathymetric data survey
data sets and composite Digital Terrain Models (DTMs) as managed by an increasing number of data
providers from government and the research community. The portal also provides a service for viewing and
downloading a harmonised Digital Terrain Model (DTM) for the European sea regions that is generated by
the EMODnet Bathymetry partnership on the basis of the gathered data sources.
The modelling transect chosen for the underwater noise model is shown in Figure 4-4. This was chosen
based on a review of the source locations form the FPSO anchor and manifold piling to represent a typical
down-slope transect from any of the sources. Down-slope transects are likely to represent a worst-case
situation since there are fewer interactions between the sound wave and the sea bed when compared to
propagation into shallower water. The transect extends from the source in a north-easterly direction
following the increasing depth in this direction.
(17) http://www.emodnet-hydrography.eu/
16
Figure 4-4 Depth vs Range Used in Noise Modelling
4.4. GENERIC MODELLING (DRILLING AND FPSO OPERATION)

A generic approach has been taken to modelling sources that are likely to give rise to a lower potential for
auditory injury than piling (eg the drilling rig and the FPSO during offloading activities). Typically,
attenuation of underwater noise with distance (r) from the source varies based on site specific factors, but
the propagation tends to attenuate at a rate which falls between upper and lower bounds. These bounds
can typically be described as spreading at a rate of 10 x log (r) and 20 x log (r). In these equations r is
the distance in meters from the noise source.
Since site specific modelling has not be carried out specifically for these sources and the characteristics
such as the frequency content and the depth of the source in the water may result in different attenuation
rates to the site specific values that were calculated for piling at the sea bed, predictions for both upper and
lower bound propagation estimates have been presented. The approach of focusing modelling detailed
modelling effort on the major noise sources, and in particular piling, was discussed with DECC.
17
5. MODELLING RESULTS
5.1. NOISE PROPAGATION WITH DISTANCE FROM SOURCE
Figure 5-1 shows the “maximum over depth” values for Peak, RMS and SEL(single pulse) levels along the
northwest transect. These values are obtained by modelling noise at intervals covering all available depths
in the water column for a given ranged from the noise source. The highest sound level for each range is
then reported so that the worst-case is adopted. Note that a conservative assumption has been made that
the relationship between these values is constant, which is reflected in the propagation rates being a
constant distance apart on the Figure.
The SEL(single pulse) value does not include the M-weighting discussed in this report, and cannot be compared
to the criteria in Southall et al. The propagation curves show that the propagation rate falls within the
expected upper and lower bound values for underwater noise.
Figure 5-1 Sound Levels vs Range
The extent of likely behavioural effects has been derived for each type of marine mammal and is discussed
in Section 5.3 of this modelling report and is shown in Chapter 9 in the main ES in Figure 9.1, 9.2 and
9.3.
18
5.2. SEL CALCULATIONS FOR SWIM AWAY MODEL

Table 5.1 shows the predicted SELcum level for the each hearing group, due to exposure to the pilling
noise, based on the swim away scenario which was described in Section 4.3.2. The starting distance in all
cases is assumed to be 500 m from the source, with the animal continuing to swim away from the source
during the piling period.
Table 5.1 Predicted SELcum Level due Piling
SPECIES SELcum dB re 1 μPa2
Low Frequency Cetaceans 162
Mid Frequency Cetaceans 160
High Frequency Cetaceans 159
Pinnipeds 161
Fish: no swim bladder (particle motion detection) 162
Fish : swim bladder not involved in hearing (particle 162

motion detection)
Fish : swim bladder involved in hearing (primarily 162

pressure detection)
5.3. SUMMARY OF DISTANCES AT WHICH CRITERIA ARE MET FOR PILING

A summary of calculated distances for the adopted criteria for behavioural effects is presented in Table 5-2
below. Both a precautionary and alternative criterion have been adopted where the noise level at which a
significant behavioural change may be expected cannot be determined exactly due to gaps in the available
data.For some marine mammals the criteria were not met at the limits of the modelling (60 km from the
source). The behavioural zones are shown graphically in Figure 10.1, Figure 10.2 and Figure 10.3 of
Chapter 9 of the main ES.
For all cases the auditory injury distances are presented as 500 m. This is the minimum distance from the
source at which the animal was assumed to start swimming in the SELcum calculation. Since there will be
no marine mammals within 500 m of the piling due to the adoption of the pre-start procedures including a
500 m safety zone based on the JNCC guidance (2010) (18), the results show that the criteria will not be
exceeded for any marine mammals. The model has not been run to calculate start distances closer to the
source than this and it possible that animals even closer to the source would not be at risk of auditory
damage.
For fish species the “recoverable injury” and “mortality and potential mortal injury” distances are also
presented as 500 m. The model has not been run to calculate start distances closer to the source than this
and it possible that animals even closer to the source would not be at risk of recoverable injury or mortality
and potential mortal injury. The distances are shown for functional hearing groups which would represent
a range of species. The species that are likely to be affected in this study are discussed in Chapter 9 of the
main Environmental Statement and tabulated in Table 9.6.
(18) JNCC (2010) Statutory Nature Conservation Agency Protocol for Minimising the Risk of Injury to Marine Mammals from Piling Noise.
19
Table 5-2 Calculated Distances for the Adopted Criteria
SPECIES CALCULATED DISTANCE FOR CALCULATED CALCULATED FREQUENCY

ADOPTED RMS CRITERIA – for DISTANCE DISTANCE WEIGHTING
Behavioural Effects FOR FOR
ADOPTED ADOPTED
(km)
PEAK SEL
CRITERIA, for CRITERIA, for
PRECAUTIONARY ALTERNATIVE
Auditory Auditory
Injury Injury
(m) (m)
Behavioural effects
Low Frequency Cetaceans >60 None
Mid Frequency Cetaceans >60 4.5 None
High Frequency Cetaceans >60 44.5 None
Pinnipeds 30 None
Auditory injury
Low Frequency Cetaceans 0500 m None
Low Frequency Cetaceans 500 m Mlf
Mid Frequency Cetaceans 500 m None
Mid Frequency Cetaceans 500 m Mmf
High Frequency Cetaceans 500 m None
High Frequency Cetaceans 500 m None
Pinnipeds 500 m None
Pinnipeds 500 m Mpw
Recoverable Injury
Fish: no swim bladder 500 m 500 m None

(particle motion detection)
Fish : swim bladder not 500 m 500 m None

involved in hearing
20
SPECIES CALCULATED DISTANCE FOR CALCULATED CALCULATED FREQUENCY

ADOPTED RMS CRITERIA – for DISTANCE DISTANCE WEIGHTING
Behavioural Effects FOR FOR
ADOPTED ADOPTED
(km)
PEAK SEL
CRITERIA, for CRITERIA, for
PRECAUTIONARY ALTERNATIVE
Auditory Auditory
Injury Injury
(m) (m)
Fish : swim bladder 500 m None

involved in hearing
(primarily pressure
detection)
Mortality and potential mortal injury
Fish: no swim bladder 500 m 500 m None

Fish : swim bladder not 500 m 500 m None

involved in hearing
Fish : swim bladder 500 m 500 m None

involved in hearing
(primarily pressure
detection)
Fish eggs and larvae 500 m 500 m None
5.4. SUMMARY OF DISTANCES AT WHICH CRITERIA ARE MET FOR DRILLING AND FPSO OPERATION
The calculated noise levels from drilling and FPSO are shown in Table 5-3. The noise levels have been
presented as ranges based on the upper and lower bounds of the likely noise propagation rate. It should
be noted that although the noise levels are much higher for the FPSO this is based on the off-loading
scenario which will only occur over relatively short periods. The noise levels during these periods are
elevated as a result of dynamic positioning systems of offloading vessels, and during steady operation of
the FPSO noise levels are expected to be significantly lower.
Table 5-3 RMS Sound Levels vs Range – Drilling & FPSO Operation
DISTANCE (m) DRILLING FPSO OPERATION
RMS (dB re 1 μPa)
500 143 – 116 165 – 138
1000 140 – 110 162 – 132
21
DISTANCE (m) DRILLING FPSO OPERATION
RMS (dB re 1 μPa)
5000 133 – 96 155 – 118
10000 130 - 90 152 – 112
20000 127 – 84 149 – 106
30000 125 – 80 147 – 102
40000 124 – 78 146 – 100
50000 123 – 76 145 – 98
60000 122 - 74 144 - 96
The adopted criteria for these non-pulse sounds are show in

Table 3-2 (120 dB dB re 1 μPa for all species). The predicted noise levels due to drilling meet the adopted
behavioral criterion between 1 km and (greater than) 60 km. Since 60 km is the limit of the modelling
adopted for this project it is not possible to indicate the distance at which the criterion would be met for
these sounds based on the worst case generic propagation assumption. It can be seen that the distance at
which behavioral reactions could occur is subject to a high degree of uncertainty based on this modelling.
The predicted noise levels due to FPSO operation meet the adopted behavioral criterion between
approximately 5 km and (greater than) 60 km. It can be seen that the distance at which behavioral
reactions could occur is also subject to a high degree of uncertainty based on this modelling.
For fish, the distances at which behavioral effects are likely to occur are given approximately in Table 3-3
and Table 3-4.
Hearing damage or other physiological injuries are not expected to occur as a result of these lower level
sound sources for either fish or marine mammals. The significance of these effects is discussed in Chapter
9 of the Environmental Statement.
22
APPENDIX E
OIL SPILL MODELLING REPORT

Oil Spill Modelling Report:
North Sea Penguins Redevelopment
Project, UK
Shell U.K. Limited
Document Number: GEOM0027 R02
Issued: 19 April 2016
Oil Spill Response Limited

Lower William Street
Southampton
SO14 5QE
United Kingdom
Tel: +44 (0)23 8033 1551
Fax: +44 (0)23 8022 1972
Oil Spill Modelling Report: North Sea Penguins Redevelopment Project
Shell U.K. Limited
EXECUTIVE SUMMARY
This document summarises the oil spill modelling work carried out by Oil Spill Response Ltd. (OSRL)
for Shell U.K. Limited (Shell). This report evaluates the impact of a well blowout at the PAN-W well
and a total loss of crude inventory at the Penguins FPSO, offshore UK, during winter, spring, summer
and autumn:
Scenario 1. PAN-W well head blowout
a. Winter (Dec-Feb).
b. Spring (Mar-May).
c. Summer (Jun-Aug).
d. Autumn (Sep-Nov).
Scenario 2. Total loss of crude inventory

a. Winter (Dec-Feb).
b. Spring (Mar-May).
c. Summer (Jun-Aug).
d. Autumn (Sep-Nov).
The two scenarios were simulated using SINTEF’s Oil Spill Contingency and Response (OSCAR) 3D
modelling tool. OSCAR, Matlab and ArcGIS were used to post-process the results.
A well blowout of 413,367 m3 of crude oil over 120 days at the PAN-W well is likely to result in
shoreline impact regardless of season. All of the well blowout simulations modelled result in
shoreline oiling. Worst case conditions could see up to 14,264 MT (12,148 m3) of emulsion reaching
nearby shorelines. The Shetland Islands, mainland UK, Norway, Sweden, Denmark and the Faroe
Islands could all be affected by this spill scenario.
An instantaneous total loss of crude inventory (88,006 m³) at the Penguins FPSO is also likely to
result in shoreline impact regardless of season. Worst case conditions could see up to 3,860 MT
(4,634 m3) of emulsion reach nearby shorelines. First impact could occur in just over 6 days following
the release during worst case conditions.
Document No: GEOM0027 R02 Page 2 of 57 Oil Spill Response Ltd

Date Issued: 19-Apr-16
Shell U.K. Limited
DOCUMENT HISTORY
Document Technical Format Date of
Revision Document Type Author
Number Review Review Issue
Draft Modelling
GEOM0027 R00 JKD JLG LES 6 April 2016
Report
Final Modelling
GEOM0027 R01 JKD PGH/LHM LES 14 April 2016
Report
Revised Modelling
Report – Format
GEOM0027 R02 changes in JKD n/a PGH 19-April-2016
response to client
comments
JKD Jenny Kirsty Dumas JLG Jonathan Lee Griffiths LES Lucy Elizabeth Sanders
PGH Polly Georgiana Hill LHM Liam Harrington-Missin
DISCLAIMERS
 Modelling results are to be used for guidance purposes only and response strategies should not be based on these
results alone.
 The resolution / quality of wind and current data vary between regions and models. As with any model, the quality
and reliability of the results are dependent on the quality of the input data.
Giving consideration to the above, all advice, modelling, and other information provided is generic and illustrative only and
not intended to be relied upon in any specific instance. The recipient of any advice, modelling or other information from, or
on behalf of, OSRL acknowledges and agrees that any number of variables may impact on an oil spill and, as such, should
be addressed on an individual basis. OSRL has no liability in relation to such advice, modelling or other information and the
recipient of such information hereby fully indemnifies and holds harmless OSRL its officers, employees, shareholders,
agents, contractors and sub-contractors against any costs, losses, claims or liabilities arising in connection with such advice,
modelling, training or other information.

Shell U.K. Limited
TABLE OF CONTENTS
1 INTRODUCTION.................................................................................................................... 6
1.1 BACKGROUND .................................................................................................................. 6
1.2 AIMS .............................................................................................................................. 7
2 SCENARIO SETUP ................................................................................................................. 8

2.1 GENERAL SETUP ................................................................................................................ 8
2.2 THRESHOLDS .................................................................................................................... 9
3 RESULTS ............................................................................................................................. 10
3.1 SUMMARY OF STOCHASTIC RESULTS .................................................................................... 10
3.2 SCENARIO 1 (BLOWOUT OF 413,367 M³ OVER 120 DAYS AT THE PAN-W WELL) RESULTS.............. 13
3.2.1 Stochastic Results ........................................................................................... 13
3.3 SCENARIO 2 (TOTAL LOSS OF CRUDE INVENTORY, 88,006 M³) RESULTS ...................................... 23
3.3.1 Stochastic Results ........................................................................................... 23
4 CONCLUSION...................................................................................................................... 33
4.1 SCENARIO 1 (WELL BLOWOUT OF 413,367 M3 OVER 120 DAYS AT THE PAN-W WELL).................. 33
4.2 SCENARIO 2 (CRUDE INVENTORY LOSS OF 88,006 M³) ............................................................ 34
APPENDIX A. MODEL SETUP ...............................................................................................35

APPENDIX B. METOCEAN DATA ..........................................................................................38
APPENDIX C. OIL CHARACTERISTICS AND BEHAVIOUR .......................................................41
APPENDIX D. OIL SPILL MODELLING SOFTWARE.................................................................44
APPENDIX E. MODELLING METHODOLOGY ........................................................................45
APPENDIX F. GLOSSARY OF TERMS, ACRONYMS AND ABBREVIATIONS .............................46
APPENDIX G. REFERENCES ..................................................................................................48
APPENDIX H. OPEP SUBMISSION - PAN-W WELL BLOWOUT ..............................................49
4.3 SCENARIO SETUP ............................................................................................................. 49
4.4 RESULTS ........................................................................................................................ 50
APPENDIX I. OPEP SUBMISSION – LOSS OF CRUDE INVENTORY 88,006 M³ ........................54

4.5 SCENARIO SETUP ............................................................................................................. 54
4.6 RESULTS ........................................................................................................................ 55

Shell U.K. Limited
Figure 1: Map of spill location - PAN-W well and Penguins FPSO

Shell U.K. Limited
1 INTRODUCTION
1.1 Background
Oil Spill Response Ltd (OSRL) has produced this modelling report on behalf of Shell U.K.
Limited (Shell) for the UK North Sea Penguins Redevelopment Project (Figure 1). The
modelling is being used to support an Environmental Impact Assessment (EIA) and to feed
into the Oil Pollution Emergency Plan (OPEP).
As this work will feed into an OPEP, it has been completed in line with the Department of
Energy and Climate Change (DECC) ‘Guidance Notes for Preparing Oil Pollution Emergency
Plans’, dated August 20151. However, supplementary tables and figures have been
presented to support the EIA.
The modelling information required by DECC for an OPEP submission can be easily extracted
from this document by going to APPENDIX H and APPENDIX I.
A well blowout at the Penguins A North well (PAN-W) and a total loss of crude inventory at
the Penguins FPSO, offshore UK, were modelled during winter, spring, summer and autumn.
The modelled scenarios are summarised in Section 2.
PAN-W well head blowout
a. Winter (Dec-Feb)
b. Spring (Mar-May)
c. Summer (Jun-Aug)
d. Autumn (Sep-Nov)
Total loss of crude inventory
a. Winter (Dec-Feb)
b. Spring (Mar-May)
c. Summer (Jun-Aug)
d. Autumn (Sep-Nov)
The modelling was carried out using SINTEF’s Oil Spill Contingency and Response (OSCAR)
model. OSCAR is a 3D modelling tool used to predict the movement and fate of oil on the sea
surface and throughout the water column (see APPENDIX D for further details).
1
Department of Energy and Climate Change (DECC), 2015, Guidance Notes for Preparing Oil Pollution Emergency Plans For Offshore Oil &
Gas Installations and Relevant Oil Handling Facilities. http://www.hse.gov.uk/osdr/guidance-regulations.htm

Shell U.K. Limited
1.2 Aims
The aim of this report is to present the risk to the:
By:
1. Creating spatial maps of probability that help us to
understand how likely an area is to be impacted.
Ocean Surface 2. Creating spatial maps of arrival time that help us to
understand how quickly an area could be impacted.
3. Creating spatial maps of emulsion thickness that help us
to understand how severely an area is impacted.
By:
understand how likely an area is to be impacted.
Water Column 2. Creating spatial maps of arrival time that help us to

understand how quickly an area could be impacted.
3. Creating spatial maps of total hydrocarbon
concentrations that help us to understand how severely
an area could be impacted.
By:
understand how likely a shoreline is to be impacted.
Shoreline 2. Creating spatial maps of arrival time that help us to
understand how quickly a shoreline could be impacted.
3. Creating spatial maps of emulsion thickness that help us
to understand how severely an area could be impacted.
The data behind these maps allow us to answer the following questions:
1. How quickly oil could reach nearby shorelines?
2. What mass of oil could reach nearby shorelines?
3. Which countries are more likely to be affected by an oil spill at the North Sea
Penguins Project?

Shell U.K. Limited
2 SCENARIO SETUP
2.1 General Setup
Four stochastic simulations were run for each scenario to investigate seasonal impacts on a
well blowout at the PAN-W well and a total loss of crude inventory at the Penguins FPSO. To
create the stochastic results 508 and 879 individual trajectories were post-processed for
Scenarios 1 and 2 respectively2. In each scenario a minimum of 100 individual trajectories
has been run for each season, as recommended by DECC’s OPEP regulations. Each trajectory
began on a different start date, so that each oil spill was simulated using a range of wind and
current conditions. The results are presented over four separate seasons in accordance with
DECC regulations – winter (Dec-Feb), spring (Mar-May), summer (Jun-Aug) and autumn (Sep-
Nov).
Two years of hydrodynamic data (sourced from Oil and Gas UK) were used as model inputs.
See APPENDIX A, APPENDIX B and APPENDIX C E for more information on the model setup.
Table 1: Summary of scenarios
Scenario 1 Scenario 2
Scenario Reference (S02)
(S01)
Latitude 61° 37’ 43.428” N 61° 32’ 01.054” N
Longitude 001° 29’ 42.999” E 001° 36’ 17.993” E
Description PAN-W Well Blowout Total Loss of Crude Inventory
a. Winter (Dec-Feb)
b. Spring (Mar-May)
Season
c. Summer (Jun-Aug)
d. Autumn (Sep-Nov)
Total Oil Volume/ 413,367 m³ 88,006 m³
Mass Released 352,003 MT 74,949 MT
Duration of Release 120 days 3 hours
Depth of Release 165 m Surface (0 m)
Nearest Shorelines Shetland Islands (UK), ~150 km Shetland Islands (UK), ~150 km
Nearest Boundary Lines UK-Norway, ~7 km UK-Norway, ~4 km
Total Number of
508 879
Trajectories
Time Between
19 hours 19 hours
Trajectories
2
The number of trajectories run per scenario is dependent upon the model run duration and the number of years of metocean data. If
the model run duration extends beyond the extent of the metocean dataset, simulations are cut off and discarded by the model. As a
result, more short trajectories can be completed than long trajectories, particularly towards the end of the dataset.

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2.2 Thresholds
Thresholds define when oil is no longer relevant. For example, when the surface emulsion
thickness is less than 0.04 µm, the oil is no longer considered relevant (as it is not visible to
the naked eye) and is ignored. The thresholds below have been applied to this study.
Threshold Value Description

The Bonn Agreement Oil Appearance Code defines five oil layer
thicknesses based on their optic effects and true colours. A thickness of
Surface 0.04 µm
0.04 µm is the minimum thickness that can be seen with the naked eye
(Code 1 – Silver/Grey Sheen).
The threshold at which the most sensitive marine life will begin to be
Water affected. It is based on guidelines from the Norwegian Oil Industry
25 ppb
Column Association concerning the effects of acute oil pollution on fish eggs and
larvae.
2 0.1 l/m2 is the lower limit of the threshold for light oiling from the
Shoreline 0.1 l/m
“Recognition of oil on shorelines” document by ITOPF.
The surface oil thickness key below is used in the surface maps throughout this document
and is derived from the Bonn Oil Appearance Code.
Appearance Layer Thickness Interval Colour

Sheen 0.04 µm - 0.3 µm
Rainbow 0.3 µm -5.0 µm

Metallic 5 µm - 50 µm
Discontinuous True Colour 50 µm - 200 µm
Continuous True Colour >200 µm
The shoreline oil thickness key below is used in the shoreline maps throughout this
document and is derived from the ITOPF Technical Information Paper No. 6 “Recognition of
oil on shorelines”.
Shoreline oiling
Concentration Thickness Colour
classification
Light Oiling 0.1 – 1 litres /m2 0.1 mm – 1.0 mm
Moderate Oiling 1 – 10 litres /m2 1 mm – 10 mm

Heavy Oiling > 10 litres /m2 > 10 mm

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3 RESULTS
3.1 Summary of Stochastic Results
Table 2 summarises the results of the stochastic simulations for Scenarios 1 and 2. See
Section 2.2 for more information on the thresholds used when post-processing data. Tables
3 and 4 present the minimum arrival time and probability of oil reaching territorial waters of
nearby countries in Scenarios 1 and 2, respectively.
Table 2: Summary of stochastic results
Number of Probability Worst case
Scenario Description Simulations of Shoreline Mass/Volume of
Reaching the Shore Impact Emulsion Onshore
PAN-W Well Blowout – 13,638 MT
1a 104 out of 104 100 %
Winter (Dec-Feb) (11,615 m3 )
1b 160 out of 160 100 % 3
Spring (Mar-May) (12,148 m )
1c 135 out of 135 100 %
Summer (Jun-Aug) (6,319 m3 )
1d 109 out of 109 100 %
Autumn (Sep-Nov) (2,725 m3 )
Total Loss of Crude Inventory – 3,860 MT

2a 189 out of 195 97 %
Winter (Dec-Feb) (4,634 m3 )
2b 225 out of 242 93 % 3
Spring (Mar-May) (4,013 m )

2c 222 out of 242 92 %
Summer (Jun-Aug) (2,838 m3 )
2d 188 out of 200 94 %
Autumn (Sep-Nov) (1,959 m3 )

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Table 3: Minimum arrival time and probability of impact by country (Scenario 1)

Quickest Time to
Quickest Time to Probability of
Scenario Country Reach Surface
Reach Shoreline Shoreline Impact
Waters
UK 25 days Oil released in UK 79 %
Scenario 1a
Sweden N/A 94 days 0%
(Dec-Feb)
Scenario 1b
Sweden 91 days 84 days 21 %
(Mar-May)
Faroe Islands 116 days 49 days 3%
Scenario 1c
Sweden 111 days 99 days 3%
(Jun-Aug)
Denmark 110 days 76 days 9%
Scenario 1d
Sweden N/A N/A 0%
(Sep-Nov)
Denmark N/A 146 days 0%

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Table 4: Minimum arrival time and probability of impact by country (Scenario 2)

Quickest Time to
Quickest Time to Probability of
Scenario Country Reach Surface
Reach Shoreline Shoreline Impact
Waters
53 days and 16
UK Oil released in UK <1 %
hours
Scenario 2a
(Dec-Feb)
53 days and 4
Denmark 39 days <1 %
hours
7 days and 4
UK Oil released in UK 44 %
hours
9 days and 2
Norway 2 hours 53 %
Scenario 2b hours
(Mar-May) 44 days and 4
Denmark N/A N/A
hours
27 days and 19
Faroe Islands N/A N/A
hours
6 days and 4
Scenario 2c UK Oil released in UK 16 %
hours
(Jun-Aug)
13 days and 7
UK Oil released in UK 2%
hours
Scenario 2d 8 days and 21
Norway 2 hours 93 %
(Sep-Nov) hours
54 days and 2 52 days and 19
Denmark 1%
hours hours

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3.2 Scenario 1 (Blowout of 413,367 m³ over 120 days at the PAN-W well) results
3.2.1 Stochastic Results
The stochastic results for Scenario 1 were calculated from a total of 508 trajectories. The
well blowout scenario involves the release of 413,367 m³ over a 120 day period. The model
is simulated for an additional 30 days following cessation of the blowout.
The following maps are presented using the WGS84 coordinate system:
Sea Surface
 Figure 2: Probability of oil reaching surface cells (Scenario 1 - Well Blowout)

 Figure 3: Minimum arrival time of oil to surface cells (Scenario 1 - Well Blowout)
 Figure 4: Maximum surface emulsion thickness (Scenario 1 - Well Blowout)
Water Column
 Figure 5: Probability that a water column cell could be impacted (Scenario 1 - Well
Blowout)
 Figure 6: Minimum arrival time of oil to water column cells (Scenario 1 - Well
Blowout)
 Figure 7: Maximum total water column oil concentration (Scenario 1- Well Blowout)
Shoreline
 Figure 8: Probability that a shoreline cell could be impacted (Scenario 1 - Well

Blowout)
 Figure 9: Minimum arrival time of oil to shoreline cells (Scenario 1 - Well Blowout)
 Figure 10: Maximum emulsion mass on shoreline (Scenario 1 - Well Blowout)

Figure 2: Probability of oil reaching surface cells (Scenario 1 - Well Blowout)
Figure 3: Minimum arrival time of oil to surface cells (Scenario 1 - Well Blowout)
Figure 4: Maximum surface emulsion thickness (Scenario 1 - Well Blowout)
Figure 5: Probability that a water column cell could be impacted (Scenario 1 - Well Blowout)
Figure 6: Minimum arrival time of oil to water column cells (Scenario 1 - Well Blowout)
Figure 7: Maximum total water column oil concentration (Scenario 1- Well Blowout)
Figure 8: Probability that a shoreline cell could be impacted (Scenario 1 - Well Blowout)
Figure 9: Minimum arrival time of oil to shoreline cells (Scenario 1 - Well Blowout)
Figure 10: Maximum emulsion mass on shoreline (Scenario 1 - Well Blowout)
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3.3 Scenario 2 (Total Loss of Crude Inventory, 88,006 m³) results

3.3.1 Stochastic Results
The stochastic results for Scenario 2 were calculated from a total of 879 trajectories across
the four seasons. The total loss of crude inventory scenario involves the release of 88,006 m3
over a 3 hour period. The simulation is tracked for 60 days.
The following maps are presented using the WGS84 co-ordinate system:
Sea Surface
 Figure 11: Probability of oil reaching surface cells (Scenario 2 - Crude Inventory Loss)
 Figure 12: Minimum arrival time of oil to surface cells (Scenario 2 - Crude Inventory)
 Figure 13: Maximum surface emulsion thickness (Scenario 2 - Crude Inventory Loss)
Water Column
 Figure 14: Probability that a water column cell could be impacted (Scenario 2 - Crude
Inventory Loss)
 Figure 15: Maximum total water column oil concentration (Scenario 2 - Crude
Inventory Loss)
 Figure 16: Minimum arrival time of oil to water column cells (Scenario 2 - Crude
Inventory Loss)
Shoreline
 Figure 17: Probability that a shoreline cell could be impacted (Scenario 2 - Crude
Inventory Loss)
 Figure 18: Minimum arrival time of oil to shoreline cells (Scenario 2 - Crude
Inventory Loss)
 Figure 19: Maximum emulsion mass on shoreline (Scenario 2 - Crude Inventory Loss)

Figure 11: Probability of oil reaching surface cells (Scenario 2 - Crude Inventory Loss)
Figure 12: Minimum arrival time of oil to surface cells (Scenario 2 - Crude Inventory)
Figure 13: Maximum surface emulsion thickness (Scenario 2 - Crude Inventory Loss)
Figure 14: Probability that a water column cell could be impacted (Scenario 2 - Crude Inventory Loss)
Figure 15: Maximum total water column oil concentration (Scenario 2 - Crude Inventory Loss)
Figure 16: Minimum arrival time of oil to water column cells (Scenario 2 - Crude Inventory Loss)
Figure 17: Probability that a shoreline cell could be impacted (Scenario 2 - Crude Inventory Loss)
Figure 18: Minimum arrival time of oil to shoreline cells (Scenario 2 - Crude Inventory Loss)
Figure 19: Maximum emulsion mass on shoreline (Scenario 2 - Crude Inventory Loss)
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4 Conclusion
Two oil spill scenarios were modelled for the Penguins Redevelopment Project, North Sea,
UK, during four seasons: winter (Dec-Feb), spring (Mar-May), summer (Jun-Aug) and autumn
(Sep-Nov). The scenarios modelled were:
 Scenario 1: Worst case PAN-W well head blowout - 413,367 m³ of crude oil over 120
days at PAN-W well
 Scenario 2: Total loss of crude inventory – 88,006 m³ of crude oil spilled

instantaneously at the Penguins FPSO
This section interprets the results of these model runs with a focus on the far-field impact.
4.1 Scenario 1 (Well blowout of 413,367 m3 over 120 days at the PAN-W well)
Shoreline Impact
A well blowout of 413,367 m3 of crude oil over 120 days at the PAN-W well is likely to result
in shoreline impact regardless of season. All of the well blowout simulations modelled result
in shoreline oiling.
Worst case conditions could see up to 14,264 MT (12,148 m3) of emulsion reach nearby
shorelines.
Oil could reach the Shetland Islands in 6 days during certain worst case metocean conditions
(Table 12). Oil could also reach the shorelines of mainland UK, Norway, Sweden, Denmark
and the Faroe Islands.
Surface Water Impact
UK, Norwegian, Danish, Swedish and Faroe Islands waters could all be affected by a well
blowout at the PAN-W well. Oil could cross the UK-Norwegian maritime boundary in around
six hours. It is likely that the remaining countries (Denmark, Sweden and Faroe Islands)
would have at least 31 days before oil crosses into their waters.
The emulsion thickness of oil during each scenario ranges from sheen (0.04 µm) to
continuous true colour (>200 µm). Surface waters covered by metallic and true colour oil
could be suitable for mechanical response and dispersant application with approval. Areas
containing sheens will need to be monitored and evaluated regularly.
Water Column Impact
Total hydrocarbon concentration (THC) levels greater than 500 ppb are present during each
of the four scenarios. This is significant as literature reviews suggest that acute toxicity
occurs to over 50% of the marine life in areas with THC levels greater than 500 ppb.
UK and Norwegian waters could both have THC levels greater than 500 ppb during all four
seasons.
Seasonal Comparison
Oil spilled during a well blowout at the PAN W well is likely to have a similar spatial extent
regardless of the season. Although shoreline oiling is expected during each season the

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impact of a spill between September and November is likely to be smaller than spills in the
other three seasons. The high winds between September and November will assist with
natural dispersion and reduce shoreline oiling.
4.2 Scenario 2 (Crude Inventory Loss of 88,006 m³)

Shoreline Impact
An instantaneous total loss of crude inventory (88,006 m³) at the Penguins FPSO is likely to
result in shoreline impact regardless of season. 94 % of the loss of crude inventory
simulations modelled result in shoreline oiling.
Worst case conditions could see up to up to 3,860 MT (4,634 m3 of emulsion reach nearby
shorelines.
Oil could reach the Shetland Islands in just over 6 days during certain worst case metocean
conditions (Table 14). Oil could also reach Norwegian shorelines within 9 days, and in some
seasons, also reach Danish shorelines within 53 days.
Surface Water Impact
UK and Norwegian waters could both be affected by a crude loss of 88,006 m³ at the
Penguins FPSO. Oil could cross the UK-Norwegian maritime boundary in less than 1 hour.
The emulsion thickness of oil during each scenario ranges from sheen (0.04 µm) to
continuous true colour (>200 µm). Surface waters covered by metallic and true colour oil
could be suitable for mechanical response and dispersant application with approval. Areas
containing sheens will need to be monitored and evaluated regularly.
Water Column Impact
Total hydrocarbon concentration (THC) levels greater than 500 ppb are present during each
of the four scenarios. This is significant as literature reviews suggest that acute toxicity
occurs to over 50% of the marine life in areas with THC levels greater than 500 ppb.
UK and Norwegian waters could both have THC levels greater than 500 ppb during all four
seasons. Other countries are not likely to see their water columns affected.

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APPENDIX A. MODEL SETUP

Scenario 1 Scenario 2
Basic Information
Scenario Reference S01 S02
Description PAN-W Well Blowout Total Loss of Crude Inventory
Latitude 61° 37' 43.428" N 61° 32' 01.054" N
Longitude 001° 29' 42.999" E 001° 36' 17.993" E

Dec-Feb (a) Dec-Feb (a)
Mar-May (b) Mar-May (b)
Time of Year
Jun-Aug (c) Jun-Aug (c)
Sep-Nov (d) Sep-Nov (d)
Model Parameters
Release Depth 165 m Surface (0 m)
Release Rate 3,444.7 m³/day 88,006 m³
Release Duration 120 days 3 hour
Duration After Cessation 30 days 60 days
Total Model Duration 150 days 60 days
Oil Characteristics
API Gravity 38.4 38.4
Viscosity 4.0 cP 4.0 cP
Pour Point 6 °C 6 °C
Wax Content 5.9 % 5.9 %
Asphaltenes 0.3 % 0.3 %
Subsea Release Information
Diameter of Release Hole 0.22 m N/A

3 3
Gas to Oil Ratio (GOR) 304 Sm /m N/A
Gas Density 1.1 kg/Sm3 N/A
Oil Temperature 118 °C N/A

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Table 5: Habitat domain details

Name Domain Extent
Bottom Top Left Right
53° 06' 47’’ N 69° 20' 52’’ N 008° 54' 10’’ W 016° 23' 06’’ E
Number of Cells Cell Resolution
C1037-Hab06 East to West North to South East to West North to South

(Scenario 1) 675 900 2 km 2 km
Domain Distance
East to West North to South
1,350 km 1,800 km
Name Domain Extent
Bottom Top Left Right
56° 07' 30’’ N 66° 47' 26’’ N 007° 17' 50’’ W 013° 56' 34’’ E
Number of Cells Cell Resolution
G0027-Hab02 East to West North to South East to West North to South

(Scenario 2) 563 592 2 km 2 km
Domain Distance
East to West North to South

1,126 km 1,184 km

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Figure 20: Habitat grids used for the modelling study

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APPENDIX B. METOCEAN DATA

Table 6: Current data – general description
Name Description
This dataset is sourced from UK Oil and Gas.
Start Time End Time
Jan 2012 Dec 2013
Resolution Resolution
C1037-Curr03
~9 km 1 hour
Depth Levels [m]
0, 10, 20, 30, 50, 75, 100 , 125, 150, 200, 250, 300, 400, 500, 600, 700, 800, 900, 1000,
1100, 1200, 1300, 1400, 1500, 1750, 2000, 2500, 3000, 3500, 4000, 4500, 5000, 5500
Table 7: Wind data – general description

Name Description
This dataset is sourced from UK Oil and Gas.
Start Time End Time
Jan 2012 Dec 2013
C1037-Wind03 Resolution Resolution
~35 km 3 hours
Depth Levels
10 m

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Table 8: Temperature plot for the release location.

Name Description
TEMPC1037
Source: NOAA

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Table 9: Salinity plot for the release location.
Name Description
SALIC1037
Source: NOAA

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APPENDIX C. OIL CHARACTERISTICS AND BEHAVIOUR

The components found in crude oil are classified into two main groups: hydrocarbons and non-
hydrocarbons (see Figure 21). If oil is rich in C1-12 alkanes, it is particularly light, as these are lighter
components than the C25+ alkanes. Conversely, if oil contains high quantities of C25+ alkanes, resins
and asphaltenes, it is heavy.
Figure 21: The chemical composition of crude oil

The chemical composition of oil is important when predicting how it will break down or weather. For
example, oil containing mostly light components is likely to lose a greater volume to evaporation
than heavy oil. Oils with carbon chains exceeding 15 (C15+) cannot evaporate, even during large
storms. Long chains (for example, C25+ alkanes) take a long time to degrade in the water column.
Asphaltenes can increase the stability of oil, allowing it to take up water but preventing the oil and
water emulsion from breaking down.
As crude oil is a complicated mixture of organic compounds, its components must be analysed to
characterise it successfully (LECO Corporation, 2012). The components of oil can be ‘identified’ and
plotted using gas chromatography instruments which are coupled with mass spectrometers (see
Bacher, 2014, for further information). The results of gas chromatography and mass spectrometry
are converted into a list of 25 sub-components, as broken down in the OSCAR oil database. Each of
the 25 sub-components is characterised by molecular weight, density, viscosity, boiling point,
solubility in water, vapour pressure, and partition coefficient between oil and water.
The OSCAR Oil Database
A strength of the OSCAR model is its foundation on an observational database of oil weathering
properties (maximum water content, viscosity, droplet size distribution, evaporation, emulsification
and dispersion, which are measured in a wide range of conditions). The oil database contains
complete weathering information for 340 crude oils and petroleum products. It also contains crude
assay data for approximately 170 other crude oils (derived from the HPI database - HPI, 1987). But
these oils have not been lab-tested so model estimates of the weathering process are used in place
of observational data. This reduces the reliability of the model.

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Oil Matching
A lab tested oil was selected for this modelling study based on the information provided by Shell.
The similarities between the Penguins A North oil and the modelled oil are shown in Table 10. Figure
22 presents the chemical components of the modelled oil. The Penguins A North oil and the oil
modelled are an excellent match.
Table 10: Properties of Penguins A North oil and the modelled oil.
Specific
Name API Viscosity Pour Point Wax Content Asphaltenes
Gravity
Penguins A North oil - 38.9 4.7 cP - 7.5 % Low
Modelled oil 0.833 38.4 4.0 cP 6.0 °C 5.9 % 0.3 %

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50
Sub-component Name % in Oil Sub-component Name % in Oil
C1 – C4 gasses 2.6503 Phenols 0.0098
45
C5-saturates 4.2290 Naphthalenes (C0-C1 alkylated) 0.3334
C6-saturates 2.7864 C13-C14 (total saturates + aromatics) 5.4527
Benzene 0.4644 Naphthalenes 2 (C2-C3 alkylated) 0.3687
40
C7-saturates 2.4326 C15-C16 (total saturates + aromatics) 5.1339
C1-benzene 0.8140 C17-C18 (total saturates + aromatics) 5 0654
35 C8-saturates 3.2086 C19-C20 (total saturates + aromatics) 3 2813
C2-benzene 0.8766 Unresolved chromatographic material 0 0713
C9-saturates 3.5721 C21-C25 (total saturates + aromatics) 5 9412
of Componment in Oil
30 PAH 1 (low soluble polyaromatic

C3-benzene 5.8232 0 2224
hydrocarbons)
PAH 2 (low soluble polyaromatic
Percent
C10-saturates 3.3027 0 0733

25 hydrocarbons)
C4-benzene 0.1139 C25+ (total) 37.5828
C11-C12 (total saturates + aromatics) 6.1809
20
15
10
Oil Component
Figure 22: Chemical composition of modelled oil

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APPENDIX D. OIL SPILL MODELLING SOFTWARE

Oil Spill Contingency and Response (OSCAR) software is used to carry out 3D oil spill modelling of
sub-sea and surface release scenarios. This software is developed and maintained by SINTEF.
This project was completed using the version of OSCAR contained within the Marine Environmental
Modelling Workbench (MEMW) 6.5.1, a model that has been fully validated and calibrated using
various field observations from a number of experimental oil spills (Reed et al., 1995, 1996).
OSCAR is able to predict the movement of oil, both at the water’s surface and throughout the water
column. OSCAR consists of a number of interlocking modules that are activated when required.
Figure 23 illustrates how these modules interact.
Figure 23: Schematic diagram of the modules that make up OSCAR (Source: SINTEF)

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APPENDIX E. MODELLING METHODOLOGY

Stochastic results are created by combining the results of a large number of individual trajectories.
Stochastic results are an excellent tool for assessing risk as they examine how an oil spill could
behave under many different types of weather conditions. By running many hundreds of
trajectories, trends will appear that allow key personnel to make informed decisions.
Figure 24 shows how a simple probability map is created. In this example, four trajectories are run
to create the final probability map.
Trajectory 1 Trajectory 2 Trajectory 3 Trajectory 4
X X X X
Stochastic X Spill Location

100%
75%
66%
50%
33%
25%
X X X X
Trajectory 1 Trajectory 1 & 2 Trajectory 1,2 & 3 Trajectory 1,2,3 and 4
Figure 24: Diagram to show how stochastic maps are made

Stochastic results are composed of many hundreds of trajectories which provide the decision maker
with a range and an associated likelihood.
The more trajectories that are run, the more confident we are in the results but the longer it takes to
finish. In turn, the better the metocean data that drives the oil, the more confident we are in the
results.
OSCAR has two types of trajectory simulations. The first are those that are run to obtain stochastic
results, known as stocSims. stocSims are more basic than the second type, known as trajSims that
are run when doing a more detailed trajectory simulation. stocSims do not include some of the more
complex process such as sedimentation and shoreline remobilisation.

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APPENDIX F. GLOSSARY OF TERMS, ACRONYMS AND ABBREVIATIONS

μm Micrometers
Degrees Celsius
°C
(1.0°C = 33.8° Fahrenheit)
API American Petroleum Institute
API Gravity, like specific gravity, is a ratio between the densities of oil and water.
Unlike specific gravity, API gravity is only used to describe oil and has been used to
categorise an oil as follows:
 Light – API > 31.1
 Medium – API between 22.3 and 31.1
 Heavy – API < 22.3
API Gravity  Extra Heavy – API < 10.0
You can convert between API Gravity and Specific Gravity using the following formula:
API gravity = (141.5/Specific Gravity) – 131.5
An API of 10 is equivalent to water, which means any oil with an API above 10 will
float on water while any with an API below 10 will sink.
See also: Specific Gravity, API
The asphaltenes present the crude oil components that are (1) insoluble in n-heptane
Asphaltene at a dilution ratio of 40 parts alkane to 1 part crude oil and (2) re-dissolves in toluene.
Content The asphaltenes include the crude oil material highest in molecular weight, polarity
and aromaticity.
The BONN Agreement is an international standard and agreement on how to
BONN Agreement characterise and respond to pollution. Although aimed at pollution in the North Sea
(Europe) many of the characterisation standards are internationally recognised.
DECC Department of Energy and Climate Change

Gas to Oil Ratio. GOR is the ratio of volumetric flow of produced gas to the volumetric
flow of oil. Although GOR is a ratio, the volume units still need to be known since the
GOR volume of gas and oil are measured in different ways. Further, the pressure and
temperature conditions under which the GOR was calculated must be known since
GOR will change with temperature and pressure.
ITOPF International Tanker Owners Pollution Federation Ltd
Kilometres (1.0 km = 1,000 m)
km
See also: m
Metres (1.0 km = 1,000 m)
m
See also: km
Marine Environmental Modelling Workbench - the modelling software package
developed by SINTEF. The MEMW consists of three models:
 DREAM (Dose, Risk and Effects Assessment Model)
 OSCAR (Oil Spill Contingency and Response Model)
MEMW
 ParTrack Model
When combined, these three models quantify the environmental effect of most
chemical pollution activities.
See also: OSCAR, SINTEF

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Metric Tonnes (This is a unit of oil mass)

(1.0 MT = 1,000 kg)
The conversion between mass and volume requires knowledge of the oil’s API or
MT Specific Gravity as follows:
Barrels per metric ton = 1/[(141.5/(API + 131.5) x 0.159]
See also: bbls, API Gravity, Specific Gravity
OPEP Oil Pollution Emergency Plan
Oil Spill Contingency And Response
The name of an advanced 3D oil spill model developed by SINTEF sitting within the
OSCAR
larger MEMW application
See also: SINTEF, MEMW
OSRL Oil Spill Response Limited
The pour point of a liquid is the lowest temperature at which it shows flow
Pour Point characteristics. If ambient temperature is less than the liquid’s pour point it will begin
to solidify.
SINTEF SINTEF is the largest independent research organisation in Scandinavia
Specific gravity is a ratio of the density of one substance to the density of a reference
substance, usually water. Specific gravity of oil is a ratio of the density of oil to the
Specific Gravity
density of water.
See also: API Gravity, bbls, MT
Stochastic (or probabilistic) results show the probability or likelihood of an event
occurring. They provide statistical data that can be used to assess risk and identify
Stochastic worst-case scenarios. Stochastic results are achieved by combining many different
trajectory simulations.
See also: Trajectory
THC Total hydrocarbon concentration
Trajectory or deterministic results show the impact of a single spill event over
Trajectory time. They are also useful in their ability to simply assess different mitigation
measures such as booms, skimmers and dispersant.
See also: Stochastic
The waxes present the crude oil components that are soluble in higher
Wax Content molecular weight normal alkanes (n-heptane) but are insoluble in lower
molecular weight alkanes (n-pentane).

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APPENDIX G. REFERENCES
Bacher, A.D. (2014) ‘Gas Chromatography Theory’, accessible online via:
http://www.chem.ucla.edu/~bacher/General/30BL/gc/theory.html, last accessed 27th
June 2014.
HPI Consultants Inc. (1987) HPI Crude Oil Assay Handbook, First Edition, California: USA.
The International Tanker Owners Pollution Federation Limited (ITOPF) (n.d.) ‘Technical Information
Paper 02: Fate of marine oil spills’, accessible online via:
http://www.itopf.com/knowledge-resources/documents-guides/document/tip-2-fate-of-
marine-oil-spills/, last accessed 9th July 2014.
The International Tanker Owners Pollution Federation Limited (ITOPF) (n.d.) ‘Technical Information
Paper 06: Recognition of oil on shorelines’, accessible online via:
http://www.itopf.com/knowledge-resources/documents-guides/document/tip-6-
recognition-of-oil-on-shorelines/, last accessed 29th October 2014.
LECO Corporation (2012) ‘Analysis of Light Crude Oil Using Gas Chromatography – High Resolution
Time-of-Flight Mass Spectrometry’, Form No. 203-821-410 Rev0, accessible online via:
http://www.leco.com/index.php/component/edocman/?task=document.download&id=4
04&Itemid=404, last accessed 27th June 2014.
National Oceanic and Atmospheric Administration (NOAA, 2014) National Oceanographic Data
Center (NODC), World Ocean Atlas Select (WOAselect), accessible via:
http://www.nodc.noaa.gov/OC5/SELECT/woaselect/woaselect.html, last accessed 14th
April 2014.
Oil Spill Response Ltd. (OSRL) ‘Shoreline Cleanup and Assessment Technique (SCAT) Field Guide’
accessible online via: http://www.oilspillresponse.com/technical-development/technical-
field-guides, last accessed 29th October 2014.
Reed, M., French, D., Rines, G. and Rye, H. (1995) ‘A three-dimensional oil and chemical spill model
for environmental impact assessment’, paper presented at 1995 International Oil Spill
Conference, pp.61-66.
Reed, M., Aamo, O.M. and Downing, K. (1996) ‘Calibration and Testing of IKU’s Oil Spill Contingency
and Response (OSCAR) Model System’, paper presented at 1996 AMOP Oil Spill
Conference.
SINTEF (2014) ‘OSCAR – Oil Spill Contingency and Response’, accessible online via:
http://www.sintef.no/home/SINTEF-Materials-and-Chemistry/About-us/Software-
development/OSCAR--Oil-Spill-Contigency-and-Response-/, last accessed 14th April 2014.

Shell U.K. Limited
APPENDIX H. OPEP SUBMISSION - PAN-W WELL BLOWOUT

4.3 Scenario Setup
Table 11: Scenario Setup (Scenario 1 – PAN-W well head blowout)
Well loss parameters
Loss from
Well/FPSO/Rig/Other (Please Loss of well control Instantaneous loss? No
Specify)
Worst case volume 413,367 m3 Will the well self kill? No
3
Flow rate 3,444.7 m /day If yes, when? N/A
Based on outflow without a completion and a fixed seabed water gradient
Justification for predicted
derived pressure in compliance with internal standards (DEP 25.80.10.12-
worst case volume
Gen.). Rates change with time based on expectation subsurface models.
Location
Spill source point Latitude 61°37’43’’ N Longitude 001° 29’ 43’’ E
Quad/ Quadrant 211,

Installation/Facility name PAN-W well head
Block Block 13
Hydrocarbon properties
Hydrocarbon name Penguins A North oil
Assay available No Was an analogue used for oil spill modelling? Yes
ITOPF Specific Pour Wax Asphaltene
Name API Viscosity
category Gravity Point Content Content
Hydrocarbon Penguins A Group 2 - 38.9 4.7 - 4.7 Very Low
Analogue YME Group 2 0.833 38.4 4.0 6 5.9 0.3
Metocean parameters
Sea surface
Air Temperature 10 °C 8-12 °C
temperature
Wind data Data period Jan 2012-Dec 2013 (2 years)
Wind data reference UK Oil & Gas (ECMWF)

Current data Data period Jan 2012-Dec 2013 (2 years)
Current data reference UK Oil & Gas (Shelf daily currents)

Modelled release parameters
Surface or Subsurface Subsurface Depth 165 m
Release duration 120 days Instantaneous No
3
Persistence duration 30 days Release rate 3,444.7 m /day
Total simulation time 150 days Total release 413,367 m3
Oil spill modelling software
Name of software OSCAR Version 6.5

4.4 Results
Figure 25: Probability of contamination (Scenario 1 – PAN-W well Blowout)

Figure 26: Minimum arrival time of oil (Scenario 1 - PAN-W well Blowout)
Shell U.K. Limited
Table 12: Key results (Scenario 1)

Oil spill modelling summary
Spill Scenario/Description S01 (a-d) Well blowout
Median Crossing
Identified Median Line Probability and shortest time to reach
Dec-Feb Mar-May Jun-Aug Sep-Nov
100 % 100 % 100 % 100 %
Norway
6 hours 6 hours 6 hours 6 hours
88 % 78 % 91 % 9%
Denmark
31 days 57 days 76 days 146 days
70 % 58 % 60 % 0%
Sweden
94 days 84 days 99 days n/a
98 % 73 % 52 % 76 %
Faroe Islands
40 days 49 days 57 days 41 days
Landfall
Identified Shoreline Probability, shortest time to reach and maximum volume of emulsion to reach each country/county
66 % 67 % 65 % 92 %
Shetland Islands 20 days 10 days 6 days 13 days
11,214 m³ 11,986 m³ 1,057 m³ 422 m³
6% 8% 0% 0%
Orkney 81 days 53 days n/a n/a
34 m³ 59 m³ n/a n/a

Shell U.K. Limited
2% 1% 0% 0%
Highland 117 days 124 days n/a n/a
21 m³ 22 m³ n/a n/a
100 % 100 % 100 % 100 %
Norway 15 days 14 days 13 days 13 days
2,388 m³ 69,35 6,318 m³ 2,682 m³
0% 21 % 3% 0%
Sweden n/a 91 days 111 days n/a
n/a 22 m³ 5 m³ n/a
34 % 29 % 9% 0%
Denmark 35 days 70 days 110 days n/a
38 m³ 46 m³ 17 m³ n/a
0% 3% 0% 0%
Faroe Islands n/a 49 days n/a n/a
n/a 25m³ n/a n/a
Key sensitivities at risk
Sensitivities/Sites of concern Shetland Islands coastline, Norwegian coastline

Shell U.K. Limited
APPENDIX I. OPEP SUBMISSION – LOSS OF CRUDE INVENTORY 88,006 M³

4.5 Scenario setup
Table 13: Scenario Setup (Scenario 2 – Loss of Crude Inventory at Penguins FPSO)
Inventory loss parameters
Loss from
Well/FPSO/Rig/Other (Please Loss of crude inventory Instantaneous loss? Yes
Specify)
Worst case volume 88,006 m3 Will the well self kill? N/A
Flow rate 88,006 m3 instant (3 hour) If yes, when? N/A
Justification for predicted

88,006 m³ is the total geometrical volume of the 13 cargo tanks.
worst case volume
Location
Spill source point Latitude 61°32’01’’ N Longitude 001° 36’ 18’’ E
Quad/ Quadrant 211,

Installation/Facility name Penguins FPSO
Block Block 13
Hydrocarbon properties
Hydrocarbon name Penguins A North oil
Assay available No Was an analogue used for oil spill modelling? Yes
ITOPF Specific Pour Wax Asphaltene
Name API Viscosity
category Gravity Point Content Content
Hydrocarbon Penguins A Group 2 - 38.9 4.7 - 4.7 Very Low
Analogue YME Group 2 0.833 38.4 4.0 6 5.9 0.3
Metocean parameters
Sea surface
Air Temperature 10 °C 8-12 °C
temperature
Wind data Data period Jan 2012-Dec 2013 (2 years)
Wind data reference UK Oil & Gas (ECMWF)
Current data Data period Jan 2012-Dec 2013 (2 years)
Current data reference UK Oil & Gas (Shelf daily currents)
Modelled release parameters
Surface or Subsurface Surface Depth 0m
Release duration 3 hour Instantaneous Yes
Persistence duration 60 days Release rate 88,006 m3
Total simulation time 60 days Total release 88,006 m3
Oil spill modelling software
Name of software OSCAR Version 7

4.6 Results
Figure 27: Probability of contamination (Scenario 2 – Loss of Crude Inventory)

Figure 28: Minimum arrival time of oil (Scenario 2 - Loss of Crude Inventory)
Shell U.K. Limited
Table 14: Key results (Scenario 2)

Oil spill modelling summary
Spill Scenario/Description S02 (a-d) Loss of crude inventory
Median Crossing
Identified Median Line Probability and shortest time to reach
100 % 99 % 100 % 100 %
Norway
<1 hour 2 hours 4 hours 2 hours
7% 3% 0% 2%
Denmark
39 hours 44 days, 4 hours n/a 52 days, 19 hours
0% <1 % 0% 0%
Faroe Islands
n/a 27 days, 19 hours n/a n/a
Landfall
Probability, shortest time to reach and maximum volume of emulsion to reach
Identified Shoreline
each country/county
<1 % 44 % 16 % 2%
Shetland Islands 53 days, 16 hours 7 days, 4 hours 6 days, 4 hours 13 days, 7 hours
6 m³ 4,013 m³ 540 m³ 9 m³
96 % 53 % 82 % 93 %
Norway 11 days 9 days, 2 hours 10 days 8 days, 19 hours
4,633 m³ 2,212 m³ 2,838 m³ 1,959 m³
<1 % 0% 0% 1%
Denmark 53 days, 2 hours n/a n/a 54 days, 2 hours
3 m³ n/a n/a 5 m³
Key sensitivities at risk
Sensitivities/Sites of
Shetland Islands coastline, Norwegian coastline
concern


Penguins Redevelopment

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PENGUINS FIELD REDEVELOPMENT PROJECT

Project Name: Penguins Field Redevelopment Project

Project Reference Number: PRD-PT-GEN-00-D-HE-0702-00007

DECC Reference Number: D/4184/2015

Type of Project: Field Redevelopment

Undertaker name: Shell U.K. Limited

Undertaker address: 1 Altens Farm Road, Nigg, Aberdeen, AB12 3FY

Short description: The Penguins fields were brought onstream in 2003 as a

The Project comprises the drilling and completion of new wells

Produced oil will be exported via shuttle tanker and produced

Anticipated commencement of works: Circa 2020

Date and reference number of any

Significant environmental impacts No significant impacts identified after the implementation of

Environmental Resources Management Ltd (ERM) and Shell U.K.

NON-TECHNICAL SUMMARY ............................................................................................................... i

6. PHYSICAL PRESENCE ............................................................................................................... 6-1

10. WASTE MANAGEMENT ......................................................................................................... 10-1

APPENDIX A – SUMMARY OF ENVIRONMENTAL LEGISLATION

1.2. PROJECT DESCRIPTION

Table 1 Notional Project Schedule

Year 1 Year 2 Year 3

FPSO ARRIVAL IN THE NORTH SEA

Manifolds/Spools and mattresses Installation

Mooring Lines Installation

Multiphase pipeline conversion to Gas Export line

Riser and umbilical installation to the FPSO

FPSO FIRST OIL

Figure 3 Project Infrastructure Locations

1.2.3. Project Alternatives

1.2.4. Concept Selection

1.2.5. Technical Selection

1.3. BASELINE ENVIRONMENT

1.3.2. Physical Environment

1.3.3. Biological Environment

1.3.4. Human Environment

1.3.5. Designated Sites and Protected Habitats

1.3.6. Coastal Sensitivities

1.4. ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

Figure 4 Prediction, Evaluation and Mitigation of Impacts

Table 2 Significance evaluation matrix

1.4.3. Physical Presence

1.4.4. Discharges to Sea

1.4.5. Atmospheric Emissions

1.4.6. Underwater Noise

1.4.8. Accidental Hydrocarbon Release

Table 3 Environmental Risk matrix

Table 4 Risk of Accidental Hydrocarbon Spills

SCENARIO LIKELIHOOD CONSEQUENCES OVERALL

1.5. MITIGATION MEASURES, CONTROLS AND SAFEGUARDS

Table 5 Control Measures / Mitigation that Shell will implement

ASPECT ACTIVITY POTENTIAL IMPACT CONTROL MEASURE/COMMITMENTS

STANDARD INDUSTRY PRACTICE / LEGISLATIVE PROJECT SPECIFIC

ASPECT ACTIVITY POTENTIAL IMPACT CONTROL MEASURE/COMMITMENTS

STANDARD INDUSTRY PRACTICE / LEGISLATIVE PROJECT SPECIFIC

ASPECT ACTIVITY POTENTIAL IMPACT CONTROL MEASURE/COMMITMENTS

STANDARD INDUSTRY PRACTICE / LEGISLATIVE PROJECT SPECIFIC

ASPECT ACTIVITY POTENTIAL IMPACT CONTROL MEASURE/COMMITMENTS

STANDARD INDUSTRY PRACTICE / LEGISLATIVE PROJECT SPECIFIC

ASPECT ACTIVITY POTENTIAL IMPACT CONTROL MEASURE/COMMITMENTS

STANDARD INDUSTRY PRACTICE / LEGISLATIVE PROJECT SPECIFIC

ASPECT ACTIVITY POTENTIAL IMPACT CONTROL MEASURE/COMMITMENTS

STANDARD INDUSTRY PRACTICE / LEGISLATIVE PROJECT SPECIFIC

1.6. OVERALL CONCLUSION AND KEY RESIDUAL ISSUES

1.1. FIELD HISTORY AND PROJECT PURPOSE