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Project: ACT Acorn Feasibility Study
Terms of Use
The ACT Acorn Consortium partners reserve all rights in this material and retain full copyright. Any reference to
this material or use of the material must include full acknowledgement of the source of the material, including
the reports full title and its authors. The material contains third party IP, used in accordance with those third
party’s terms and credited as such where appropriate. Any subsequent reference to this third party material
must also reference its original source. The material is made available in the interest of progressing CCS by
sharing this ACT work done on the Acorn project.
Pale Blue Dot Energy reserve all rights over the use of the material in connection with the development of the
Acorn Project. In the event of any questions over the use of this material please contact [email protected].
D14 Outline Environmental Impact Assessment 10196ACTC-Rep-17-01
May 2018
www.actacorn.eu
ACT Acorn, project 271500, has received funding from BEIS (UK), RCN (NO) and RVO (NL), and is co-funded by the European Commission under the ERA-Net instrument of the Horizon 2020 programme. ACT Grant number 691712.
Acorn
D14 Outline Environmental Impact Assessment Contents
ACT Acorn Consortium Page 3 of 68
Contents
Document Summary
Client Research Council of Norway & Department of Business, Energy & Industrial Strategy
Project Title Accelerating CCS Technologies: Acorn Project
Title: D14 Outline Environmental Impact Assessment
Distribution: Client & Public Domain
Date of Issue: 31st May 2018
Prepared by: Frances Harding supported by Tim Dumenil, Charlie Hartley and Tiana Walker (all Pale Blue Dot Energy)
Approved by: Steve Murphy, ACT Acorn Project Director
Disclaimer:
While the authors consider that the data and opinions contained in this report are sound, all parties must rely upon their own skill and judgement when using it. The authors do not make
any representation or warranty, expressed or implied, as to the accuracy or completeness of the report. The authors assume no liability for any loss or damage arising from decisions
made on the basis of this report. The views and judgements expressed here are the opinions of the authors and do not reflect those of the client or any of the stakeholders consulted
during the course of this project.
The ACT Acorn consortium is led by Pale Blue Dot Energy and includes Bellona Foundation, Heriot-Watt University, Radboud University, Scottish Carbon Capture and Storage (SCCS),
University of Aberdeen, University of Edinburgh and University of Liverpool.
Amendment Record
Rev Date Description Issued By Checked By Approved By
01 29/05/18 First issue C Hartley T Dumenil S Murphy
D14 Outline Environmental Impact Assessment Contents
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Table of Contents
CONTENTS ................................................................................................................................................................................................................................................... 3
1.0 EXECUTIVE SUMMARY .................................................................................................................................................................................................................. 10
2.0 INTRODUCTION TO ACT ACORN .................................................................................................................................................................................................. 11
3.0 SCOPE ............................................................................................................................................................................................................................................. 16
4.0 ENVIRONMENTAL SCOPING REPORT ......................................................................................................................................................................................... 17
5.0 PROJECT DESCRIPTION ............................................................................................................................................................................................................... 19
6.0 ONSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................. 22
7.0 ONSHORE ENVIRONMENTAL IMPACT ASSESSMENT .............................................................................................................................................................. 26
8.0 OFFSHORE DESCRIPTION ............................................................................................................................................................................................................ 30
9.0 OFFSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................ 35
10.0 OFFSHORE ENVIRONMENTAL IMPACT ASSESSMENT............................................................................................................................................................. 42
11.0 PERMITS AND CONSENTS ............................................................................................................................................................................................................ 46
12.0 CONSULTATION ............................................................................................................................................................................................................................. 59
13.0 CONTENTS OF THE ENVIRONMENTAL STATEMENT ................................................................................................................................................................ 61
14.0 CONCLUSIONS AND NEXT STEPS ............................................................................................................................................................................................... 64
15.0 REFERENCES ................................................................................................................................................................................................................................. 65
16.0 ANNEX 1: CONSENT REGISTER ................................................................................................................................................................................................... 67
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CONTENTS ................................................................................................................................................................................................................................................... 3
TABLE OF CONTENTS .................................................................................................................................................................................................................................... 4
FIGURES ...................................................................................................................................................................................................................................................... 9
TABLES ........................................................................................................................................................................................................................................................ 9
1.0 EXECUTIVE SUMMARY .................................................................................................................................................................................................................. 10
2.0 INTRODUCTION TO ACT ACORN .................................................................................................................................................................................................. 11
ACT ACORN OVERVIEW................................................................................................................................................................................................................... 11
ACORN DEVELOPMENT CONCEPT ..................................................................................................................................................................................................... 14
3.0 SCOPE ............................................................................................................................................................................................................................................. 16
PURPOSE ........................................................................................................................................................................................................................................ 16
SCOPE ............................................................................................................................................................................................................................................ 16
PROJECT SCHEDULE ....................................................................................................................................................................................................................... 16
4.0 ENVIRONMENTAL SCOPING REPORT ......................................................................................................................................................................................... 17
SCOPING OPINION ........................................................................................................................................................................................................................... 17
SCOPING OPINION QUESTION ........................................................................................................................................................................................................... 18
LAYOUT OF THE ENVIRONMENTAL SCOPING REPORT ......................................................................................................................................................................... 18
5.0 PROJECT DESCRIPTION ............................................................................................................................................................................................................... 19
ONSHORE FACILITIES ....................................................................................................................................................................................................................... 19
OFFSHORE FACILITIES ..................................................................................................................................................................................................................... 19
DESIGN BASIS ................................................................................................................................................................................................................................. 19
5.3.1 Existing CO2 Capture Plant .................................................................................................................................................................................................... 19
5.3.2 New CO2 Capture Plant ......................................................................................................................................................................................................... 20
5.3.3 Compression and Dehydration .............................................................................................................................................................................................. 20
5.3.4 Material Selection .................................................................................................................................................................................................................. 20
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5.3.5 Utilities .................................................................................................................................................................................................................................... 20
5.3.6 Offshore ................................................................................................................................................................................................................................. 20
BLOCK FLOW DIAGRAM .................................................................................................................................................................................................................... 21
6.0 ONSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................. 22
LANDSCAPE AND TOPOGRAPHY ........................................................................................................................................................................................................ 22
SITE DESCRIPTION AND EXISTING LANDSCAPE CHARACTER ............................................................................................................................................................... 22
VISUAL RECEPTORS ........................................................................................................................................................................................................................ 23
GEOLOGY ....................................................................................................................................................................................................................................... 23
HYDROLOGY ................................................................................................................................................................................................................................... 23
DESIGNATIONS ................................................................................................................................................................................................................................ 23
7.0 ONSHORE ENVIRONMENTAL IMPACT ASSESSMENT .............................................................................................................................................................. 26
POTENTIAL LOCATIONS FOR A NEW BUILD CAPTURE PLANT ............................................................................................................................................................... 26
POTENTIAL IMPACTS ........................................................................................................................................................................................................................ 27
7.2.1 Ecology Rattray to Kirkton Head SINS .................................................................................................................................................................................. 27
7.2.2 Water Resources River Blackwater ....................................................................................................................................................................................... 27
7.2.3 Visual Impacts ........................................................................................................................................................................................................................ 27
7.2.4 Traffic and Transport .............................................................................................................................................................................................................. 28
7.2.5 Air Quality ............................................................................................................................................................................................................................... 28
7.2.6 Noise and Vibration ................................................................................................................................................................................................................ 28
7.2.7 Ecology .................................................................................................................................................................................................................................. 28
8.0 OFFSHORE DESCRIPTION ............................................................................................................................................................................................................ 30
LOCATION ....................................................................................................................................................................................................................................... 30
TRANSPORT .................................................................................................................................................................................................................................... 30
8.2.1 Facilities Re-use Versus New Infrastructure .......................................................................................................................................................................... 30
8.2.2 New 16” Infield Pipeline to the Acorn CO2 storage site Manifold .......................................................................................................................................... 32
APPROACH FOR OFFSHORE FACILITIES ............................................................................................................................................................................................. 32
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8.3.1 Pipeline .................................................................................................................................................................................................................................. 32
8.3.2 Subsea ................................................................................................................................................................................................................................... 32
8.3.3 Control System and Umbilical ................................................................................................................................................................................................ 33
8.3.4 Wells ...................................................................................................................................................................................................................................... 33
8.3.5 Decommissioning of Existing Equipment ............................................................................................................................................................................... 34
9.0 OFFSHORE ENVIRONMENTAL DESCRIPTION ............................................................................................................................................................................ 35
INTRODUCTION ................................................................................................................................................................................................................................ 35
PHYSICAL ENVIRONMENT ................................................................................................................................................................................................................. 35
PLANKTON ...................................................................................................................................................................................................................................... 37
BENTHIC COMMUNITIES ................................................................................................................................................................................................................... 37
9.4.1 Fish Populations .................................................................................................................................................................................................................... 37
9.4.2 Seabird Populations ............................................................................................................................................................................................................... 38
9.4.3 Marine Mammals ................................................................................................................................................................................................................... 38
9.4.3.1 Cetaceans ................................................................................................................................................................................................................................................. 38
9.4.3.2 Pinnipeds ................................................................................................................................................................................................................................................... 38
9.4.4 Commercial Fisheries and Shipping ...................................................................................................................................................................................... 38
9.4.5 Conservation Designations .................................................................................................................................................................................................... 39
PROTECTED AREAS ......................................................................................................................................................................................................................... 39
SOCIO-ECONOMIC INTERESTS .......................................................................................................................................................................................................... 41
10.0 OFFSHORE ENVIRONMENTAL IMPACT ASSESSMENT............................................................................................................................................................. 42
INTRODUCTION ................................................................................................................................................................................................................................ 42
PHYSICAL PRESENCE ...................................................................................................................................................................................................................... 42
SEABED AND HABITAT DISTURBANCE ................................................................................................................................................................................................ 42
DISCHARGES TO SEA ....................................................................................................................................................................................................................... 43
UNDERWATER NOISE ....................................................................................................................................................................................................................... 43
ATMOSPHERIC EMISSIONS ............................................................................................................................................................................................................... 44
WASTE............................................................................................................................................................................................................................................ 44
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ACCIDENTAL EVENTS ....................................................................................................................................................................................................................... 44
CUMULATIVE AND TRANSBOUNDARY EFFECTS .................................................................................................................................................................................. 44
DECOMMISSIONING AND PIPELINE RE-PURPOSING ......................................................................................................................................................................... 45
11.0 PERMITS AND CONSENTS ............................................................................................................................................................................................................ 46
ONSHORE CONSENTS REGISTER ...................................................................................................................................................................................................... 47
OFFSHORE CONSENTS REGISTER .................................................................................................................................................................................................... 49
12.0 CONSULTATION ............................................................................................................................................................................................................................. 59
INTRODUCTION ................................................................................................................................................................................................................................ 59
PREVIOUS AND ON-GOING CONSULTATION........................................................................................................................................................................................ 59
SUMMARY OF CONSULTEES ............................................................................................................................................................................................................. 59
13.0 CONTENTS OF THE ENVIRONMENTAL STATEMENT ................................................................................................................................................................ 61
14.0 CONCLUSIONS AND NEXT STEPS ............................................................................................................................................................................................... 64
CONCLUSIONS ................................................................................................................................................................................................................................. 64
NEXT STEPS ................................................................................................................................................................................................................................... 64
15.0 REFERENCES ................................................................................................................................................................................................................................. 65
16.0 ANNEX 1: CONSENT REGISTER ................................................................................................................................................................................................... 67
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Figures
FIGURE 2-1: ACT ACORN CONSORTIUM PARTNERS .......................................................................................................................................................................................... 11
FIGURE 2-2: KEY AREAS OF INNOVATION ......................................................................................................................................................................................................... 12
FIGURE 2-3: ACT ACORN WORK BREAKDOWN STRUCTURE .............................................................................................................................................................................. 12
FIGURE 2-4: ACORN OUTLINE MINIMUM VIABLE DEVELOPMENT PLAN ............................................................................................................................................................... 14
FIGURE 2-5: ACORN BUILD OUT SCENARIO FROM THE 2017 PCI APPLICATION ................................................................................................................................................... 15
FIGURE 3-1: PROJECT SCHEDULE ................................................................................................................................................................................................................... 16
FIGURE 5-1: BLOCK FLOW DIAGRAM ................................................................................................................................................................................................................ 21
FIGURE 6-1: AERIAL PHOTOGRAPH OF THE ST FERGUS TERMINAL (TOTAL, 2009) ............................................................................................................................................. 22
FIGURE 6-2: ECOLOGICAL DESCRIPTION, (PEFROFAC ENGINEERING LIMITED, 2012) ......................................................................................................................................... 24
FIGURE 6-3: ECOLOGICAL DESIGNATINS, ADAPTED FROM (ERM, 2007) ............................................................................................................................................................ 25
FIGURE 7-1: APPROXIMATE BOUNDARIES OF THE FOUR OPERATIONS (ADAPTED FROM GOOGLE MAPS, 2017) .................................................................................................... 26
FIGURE 7-2: AVAILABLE LAND SOUTH OF THE NSMP PHASE 3 PLANT, (NSMP, 2017) ....................................................................................................................................... 27
FIGURE 8-1: PIPELINE ROUTE FOR ACORN CO2 STORAGE SITE (ATLANTIC PIPELINE IS SHOWN IN GREEN) ........................................................................................................... 31
FIGURE 8-2: INFIELD PIPELINE ROUTE FOR ACORN CO2 STORAGE SITE (NEW 16” PIPELINE SHOWN IN BLACK) ..................................................................................................... 32
FIGURE 9-1: HABITATS (CIRCLES REPRESENT PRE-DECOMMISSIONING ENVIRONMENTAL SURVEY STATIONS), (BG GROUP, 2016) ....................................................................... 36
FIGURE 9-2: SHIPPING DENSITY MAP, (BG GROUP, 2016) ................................................................................................................................................................................ 39
FIGURE 9-3: PROTECTED AREAS, (BG GROUP, 2016) ..................................................................................................................................................................................... 41
Tables
TABLE 2-1: ACT ACORN MILESTONES AND DELIVERABLES .............................................................................................................................................................................. 13
TABLE 8-1: UTM COORDINATES FOR ACORN CO2 STORAGE SITE MANIFOLD AND SUBSEA WELL ......................................................................................................................... 30
TABLE 11-1: ONSHORE CONSENTS REGISTER .................................................................................................................................................................................................. 48
TABLE 11-2: OFFSHORE CONSENTS REGISTER ............................................................................................................................................................................................... 58
TABLE 16-1: CONSENT REGISTER ................................................................................................................................................................................................................... 68
D14 Outline Environmental Impact Assessment Executive Summary
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1.0 Executive Summary
With respect to an Environmental Impact Assessment (EIA), Pale Blue Dot view
the Acorn Project as a Schedule 2 project which may require an EIA.
Aberdeenshire Council’s provisional view is that, irrespective of being Schedule
1 or 2, the Acorn Project will need to complete an Environmental Impact
Assessment (EIA) and subsequent Environmental Statements which separately
cover onshore and offshore requirements.
A definitive view will be provided by Aberdeenshire Council upon submission of
an Environmental Scoping Report.
An Environmental Scoping Report would need to be submitted for review and
approval by Aberdeenshire Council between mid-2019 and mid-2020. If
confirmed as required, an EIA would then be completed in 2020/21 as part of
FEED.
As detailed within this report, the regulations, permits and consents influencing
the EIA are well understood as is the required contents and structure of the two
Environmental Statements.
The current assessment of both the onshore environmental impact and offshore
environmental impact indicates minimal impact beyond current activities.
The re-use of the Atlantic pipeline for the transportation of CO2 will result in a
lower environmental impact versus the need to install a new pipeline.
Beyond the main pipeline, the opportunity to re-use infrastructure is minimal.
This deliverable has established that an
Environmental Scoping Report will need to be
submitted to Aberdeenshire Council to confirm if the
Acorn Project is Schedule 1 or Schedule 2 under
the Building (Scotland) 2017 Regulation and if an
Environmental Impact Assessment (EIA) is required.
The provisional view from Aberdeenshire Council is
that an EIA will be required which will require the
EIA and respective Onshore Environmental
Statement and Offshore Environmental Statement
to be completed during the Front End Engineering
Design (FEED) stage of project development
The current assessment of both the onshore and
offshore environmental impact indicates minimal
environmental impact beyond current activities.
D14 Outline Environmental Impact Assessment Introduction to ACT Acorn
ACT Acorn Consortium Page 11 of 68
2.0 Introduction to ACT Acorn
ACT Acorn Overview
ACT Acorn, project 271500, has received funding from BEIS (UK), RCN (NO)
and RVO (NL), and is co-funded by the European Commission under the ERA-
Net instrument of the Horizon 2020 programme. ACT grant number 691712.
ACT Acorn is a collaborative project between seven organisations across
Europe being led by Pale Blue Dot Energy in the UK, as shown in Figure 2-1.
Figure 2-1: ACT Acorn consortium partners
The research and innovation study addresses all thematic areas of the ACT Call
including ‘Chain Integration’. The project includes a mix of both technical and
non-technical innovation activities as well as leading edge scientific research.
Together these will enable the development of the technical specification for an
ultra-low cost, integrated CCS hub that can be scaled up at marginal cost. It will
move the Acorn development opportunity from proof-of-concept (TRL3) to the
pre-FEED stage (TRL5/6) including iterative engagement with relevant investors
in the private and public sectors.
Specific objectives of the project are to:
1. Produce a costed technical development plan for a full chain CCS
hub that will capture CO2 emissions from the St Fergus Gas
Terminal in north east Scotland and store the CO2 at an offshore
storage site (to be selected) under the North Sea.
2. Identify technical options to increase the storage efficiency of the
selected storage site based on scientific evidence from
geomechanical experiments and dynamic CO2 flow modelling and
through this drive scientific advancement and innovation in these
areas.
3. Explore build-out options including interconnections to the nearby
Peterhead Port, other large sources of CO2 emissions in the UK
region and CO2 utilisation plants.
4. Identify other potential locations for CCS hubs around the North Sea
regions and develop policy recommendations to protect relevant
D14 Outline Environmental Impact Assessment Introduction to ACT Acorn
ACT Acorn Consortium Page 12 of 68
infrastructure from premature decommissioning and for the future
ownership of potential CO2 stores.
5. Engage with CCS and low carbon economy stakeholders in Europe
and worldwide to disseminate the lessons from the project and
encourage replication.
CCS is an emerging industry. Maturity improvements are required in the
application of technology, the commercial structure of projects, the scope of
each development and the policy framework.
The key areas of innovation in which the project will seek insights are
summarised in Figure 2-2.
Figure 2-2: Key areas of innovation
The project activity has been organised into 6 work packages as illustrated in
Figure 2-3. Specific areas being addressed include; regional CO2 emissions; St
Fergus capture plant concept; CO2 storage site assessments and development
plans; reservoir CO2 flow modelling, geomechanics; CCS policy development;
infrastructure re-use; lifecycle analysis; environmental impact; economic
modelling; FEED and development plans; and build out growth assessment.
The project will be delivered over a 19-month period, concluding on the 28th
February 2019. During that time, it will create and publish 21 items known as
Deliverables. Collectively these will provide a platform for industry, local
partnerships and government to move the project forward in subsequent phases.
It will be driven by business case logic and inform the development of UK and
European policy around infrastructure preservation. The deliverables are listed
in Table 2-1.
Figure 2-3: ACT Acorn work breakdown structure
D14 Outline Environmental Impact Assessment Introduction to ACT Acorn
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Milestone Deliverable
1) St Fergus Hub Design
D01 Kick-off Meeting Report
D02 CO2 Supply Options
D17 Feeder 10 Business Case
2) Site Screening & Selection
D03 Basis of Design for St Fergus Facilities
D04 Site Screening Methodology
D05 Site Selection Report
D13 Plan and Budget for FEED
3) Expansion Options D18 Expansion Options
4) Full Chain Business Case
D10 Policy Options Report
D11 Infrastructure Reuse Report
D14 Outline Environmental Impact Assessment
D15 Economic Model and Documentation
D16 Full Chain Development Plan and Budget
5) Geomechanics D06 Geomechanics Report
D07 Acorn Storage Site Storage Development Plan and Budget
6) Storage Development Plans D08 East Mey Storage Site Storage Development Plan and Budget
D09 Eclipse Model Files
7) Lifecycle Assessment D12 Carbon Lifecycle Analysis
8) Project Completion
D21 Societal Acceptance Report
D19 Material for Knowledge Dissemination Events
D20 Publishable Final Summary Report
Table 2-1: ACT Acorn Milestones and Deliverables
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The Consortium includes a mix of industrial, scientific and CCS policy experts in
keeping with the multidisciplinary nature of the project. The project is led by Pale
Blue Dot Energy along with University of Aberdeen, University of Edinburgh,
University of Liverpool, Heriot Watt University, Scottish Carbon Capture &
Storage (SCCS), Radboud University and The Bellona Foundation. Pale Blue
Dot Energy affiliate CO2DeepStore are providing certain input material.
Acorn Development Concept
Many CCS projects have been burdened with achieving “economies of scale”
immediately to be deemed cost effective. This inevitably increases the initial cost
hurdle to achieve a lower lifecycle unit cost (be that £/MWh or £/T) which raises
the bar from the perspectives of initial capital requirement and overall project
risk.
The Acorn development concept use a Minimum Viable Development (MVD)
approach. This takes the view of designing a full chain CCS development of
industrial scale (which minimises or eliminates the scale up risk) but at the
lowest capital cost possible, accepting that the unit cost for the initial project may
be high for the first small tranche of sequestered emissions.
Acorn will use the unique combination of legacy circumstances in North East
Scotland to engineer a minimum viable full chain carbon capture, transport and
offshore storage project to initiate CCS in the UK. The project is illustrated in
Figure 2-4 and seeks to re-purpose an existing gas sweetening plant (or build a
new capture facility if required) with existing offshore pipeline infrastructure
connected to a well understood offshore basin, rich in storage opportunities. All
the components are in place to create an industrial CCS development in North
East Scotland, leading to offshore CO2 storage by the early 2020s.
Figure 2-4: Acorn Outline Minimum Viable Development Plan
D14 Outline Environmental Impact Assessment Introduction to ACT Acorn
ACT Acorn Consortium Page 15 of 68
A successful project will provide the platform and improve confidence for further
low-cost growth and incremental development. This will accelerate CCS
deployment on a commercial basis and will provide a cost effective practical
stepping stone from which to grow a regional cluster and an international CO2
hub.
The seed infrastructure can be developed by adding additional CO2 capture
points such as from hydrogen manufacture for transport and heat, future CO2
shipping through Peterhead Port to and from Europe and connection to UK
national onshore transport infrastructure such as the Feeder 10 pipeline which
can bring additional CO2 from emissions sites in the industrial central belt of
Scotland including the proposed Caledonia Clean Energy Project, CCEP. A
build out scenario for Acorn used in the 2017 Projects of Common Interest (PCI)
application is included as Figure 2-5.
Pale Blue Dot Energy is exploring various ways and partners to develop the
Acorn project.
Figure 2-5: Acorn build out scenario from the 2017 PCI application
D14 Outline Environmental Impact Assessment Scope
ACT Acorn Consortium Page 16 of 68
3.0 Scope
Purpose
The purpose of the ACT Acorn Deliverable 14 (D14) Outline Environmental
Impact Assessment (EIA) is to provide a clear summary of the environmental
issues relating to the Acorn development scenario.
Scope
The scope of this deliverable is:
• Outline of development concept
• Assessment of the environmental impacts
• Summary of relevant permits and consents required
• Preliminary list of likely consultees
• Assembly of baseline information
This report draws heavily on a previous Carbon Capture and Storage (CCS)
study commissioned by CO2DeepStore, (Pefrofac Engineering Limited, 2012)
and the EIA completed by BG for the Atlantic and Cromarty Decommissioning
Programme, (BG Group, 2016).
Project Schedule
In respect to timing for this report, the current planned schedule for the Acorn
Project is for the project financial investment decision (FID) to be made in Q1
2020 with first injection at the start of 2023. Pre-FEED (Front End Engineering
Design) and FEED will need to be completed to enable FID. The EIA will be
completed as part of FEED, thus is likely to be developed and submitted for
review and approval by Aberdeenshire Council between mid-2019 and mid-
2020.
Figure 3-1: Project schedule
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4.0 Environmental Scoping Report
An Environmental Impact Assessment (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) (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 for Business Energy and Industrial Strategy
(BEIS) to take into consideration environmental information before making
decisions on whether or not to consent certain offshore activities. As of 2010 the
EIA Regulations include CCS developments under the Energy Act 2008
(Consequential Modifications) (Offshore Environmental Protection) Order 2010.
Scoping Opinion
Screening is the determination of whether an EIA is needed and is a formal
requirement under the EIA Regulations. A formal Scoping Opinion can be
sought from the competent authorities concerning the need for an EIA. When a
competent authority receives an application for consent without an
accompanying Environmental Statement and there appears to be a possibility
that it is for a Schedule 1 or 2 development, the authority must adopt a Scoping
Opinion. Scoping is the process of determining the content and extent of matters
that should be covered in the environmental information to be submitted to a
competent authority. Good practice involves early consultation with statutory
consultees and other stakeholders. An Environmental Scoping Report enables
the competent authority to assess the project and provide a Scoping Opinion
summarising the specific advice the competent authority has concerning the
required coverage and content required for an Environmental Statement for an
application.
An Environmental Scoping Report would be submitted to Aberdeenshire Council
as the basis of a request for a formal Environmental Impact Assessment (EIA)
Scoping Opinion for the proposed Acorn development. This report forms the
basis of the Environmental Scoping Report. The scoping process allows
statutory consultees to comment on the proposed development, the scope of
the EIA and the proposed assessment methodology. It also provides an
opportunity for consultees to raise any issues that they consider may be
important to the EIA process providing direction on the topics on which the
Environmental Statement should focus. A scoping report aims to provide:
• A description of the proposed project
• A summary of the EIA process and approach
• Available environmental baseline information
• Identify any potential significant effects and those lesser effects that
may be able to be scoped out of the assessment
• Describe the proposed approach and methodologies to assess these
potential effects, and
• Propose the structure and content of the Environmental Statement
Aberdeenshire Council and other statutory consultees will be invited to provide
a formal scoping opinion on the proposed Acorn development and identify any
other relevant environmental information relating to the site and surrounding
area. The scoping opinion will be used to inform the EIA in addition to
consultation to be undertaken during the EIA process. The local planning
D14 Outline Environmental Impact Assessment Environmental Scoping Report
ACT Acorn Consortium Page 18 of 68
authority will determine whether the project is of a type listed in Schedule 1 or
Schedule 2 of the Building (Scotland) 2017 Regulations:
• If it is listed in Schedule 1 an Environmental Impact Assessment is
required in every case
• If the project is listed in Schedule 2, the local planning authority
should consider whether it is likely to have significant effects on the
environment
Schedule 1 projects include:
Installations for the capture of carbon dioxide streams for the purposes of
geological storage pursuant to Directive 2009/31/EC from installations referred
to in this Schedule, or where the total yearly capture of carbon dioxide is 1.5
megatonnes or more.
Schedule 2 projects include:
“(j) Installations for the capture of carbon dioxide streams for the purposes of
geological storage pursuant to Directive 2009/31/EC from installations not
included in Schedule 1.”
Acorn is therefore currently a Schedule 2 project. To confirm this a Scoping
Opinion question must be formally asked.
Scoping Opinion Question
With regards to the Acorn project and the planned modifications to the St Fergus
plant and associated offshore infrastructure, initial meetings have taken place
with Aberdeenshire Council (Buchan Area) to discuss requirements for
completing an EIA to support the planning application. Aberdeenshire Council
have confirmed that it is probable that an EIA will be required. To confirm this a
formal approach is required to extract a Scoping Opinion:
• Will the Acorn development require an EIA under the
Environmental Impact Assessment (Scotland) Regulation
2011?
A formal scoping report will be prepared to determine the EIA requirements for
the Acorn scope of work at St Fergus. An Environmental Scoping Report will be
issued by the end of 2018, and Scoping Opinion sought over Q1 2019.
Layout of the Environmental Scoping Report
The scoping report has been structured as follows:
• Section 5: Project Description
• Section 6: Onshore Environmental Description
• Section 7: Onshore Environmental Impact Assessment
• Section 8: Detailed Offshore Description
• Section 9: Offshore Environmental Description
• Section 10: Offshore Environmental Impact Assessment
• Section 11: Permits and Consents
• Section 12: Consultation
• Section 13: Contents of the Environmental Statement
For now, it is still assumed that a full EIA and associated Environmental
Statement will be required within FEED to support the Planning Application and
so the contents of the Environmental Statement have been outlined.
.
D14 Outline Environmental Impact Assessment Project Description
ACT Acorn Consortium Page 19 of 68
5.0 Project Description
Onshore Facilities
An existing gas sweetening plant has been separating CO2 from natural gas at
the St Fergus SAGE terminal for 20 years. Within the next few years it will no
longer be required for this purpose and could become available for separating
CO2 from flue gas. The potential for re-using the SAGE CO2 plant and, as an
alternative, the option of a new build capture facility is under consideration.
At this stage both capture options appear viable, although without detailed
information on the condition of the SAGE plant and further design studies, it is
not possible to be certain about the viability of the SAGE plant re-use. Additional
work is required especially regarding plant condition, throughput
capacity/constraints and the cost of re-purposing the facility.
Space exists to build a standalone capture plant, which would have the
advantage of being purpose built, new and in a location to optimise collection of
CO2 emissions from multiple sites.
More detailed technical engineering studies are required to assess the two
capture alternatives, which along with other commercial, risk and regulatory
factors, will enable an effective option selection prior to Front End Engineering
and Design (FEED).
Offshore Facilities
Currently there is the option to re-use one or more of three existing preserved
offshore pipelines connected to St Fergus for CO2 transportation. Several
appraised offshore CO2 stores can also be considered. The ACT Acorn project
reviews both the Captain and East Mey sandstone formations as potential
storage locations.
For the purpose of the EIA, the current base case for Acorn is to use a location
called the Acorn CO2 storage site, (yellow pin in Figure 8-1), which would be
accessed via repurposing the existing 16” Atlantic pipeline from St Fergus to the
Atlantic depleted condensate field. The Acorn CO2 storage site will be developed
subsea rather than using a platform, with an umbilical to shore as the base case
for providing power and control to the wellheads. Remote technology options
are currently being explored, which would eliminate the need for an umbilical to
shore.
Design Basis
The design basis draws heavily on previous conceptual studies commissioned
by CO2DeepStore, (Pefrofac Engineering Limited, 2012).
5.3.1 Existing CO2 Capture Plant
One of the two amine gas sweetening trains within the SAGE plant is being
decommissioned. The condition of the plant and whether it has been preserved
to allow future reinstatement is unknown. It is understood that the second train
will also be decommissioned over the next few years. Pale Blue Dot Energy will
continue to engage with the present terminal owners to determine the present
condition of the unit and identify any corrosion issues and missing piping,
equipment and instrumentation which may have been used as spares for the
operating unit.
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The current assumption is that the existing operating SAGE gas sweetening
amine train will be suitable for re-purposing to capture CO2 from flue gas.
5.3.2 New CO2 Capture Plant
It is more likely that a new CO2 capture plant is required to accommodate the
volumes of CO2 for which a new amine (or similar) solvent capture system is
assumed. Key elements of a solvent capture system are:
• Flue gas cooling and compression (blowers)
• Waste heat recovery
• CO2 absorption
• Solvent regeneration unit
• Solvent storage and make-up
• Compression
• Dehydration
• Metering and monitoring the exported CO2
Upstream of the CO2 capture process, there is a need to cool and boost the
pressure of the flue gas stream. As far as practical, waste heat can be recovered
from the flue gas for use in the CO2 capture process to increase overall energy
efficiency and reduce CO2 emissions associated with solvent regeneration.
5.3.3 Compression and Dehydration
The CO2 from the capture plant will be water saturated and at around
atmospheric pressure. Prior to transport through the offshore pipeline for
geological storage the CO2 must be dehydrated and compressed to sufficient
pressure for transportation offshore in dense phase. A CO2 specification will also
be finalised which will include almost zero water content to ensure no free water
forms in pipeline or wells and that the system operates outside of the hydrate
region. Typically, dehydration is achieved by either glycol or molecular sieve.
Options for CO2 compression include centrifugal, reciprocating and integrally
geared. Drivers are likely to be electric with the requirement for high efficiency
variable speed drives to be considered. The export pressure of the CO2 is
assumed to be between 120-160barg.
5.3.4 Material Selection
Due to the potential for corrosion in the presence of amine solvents, CO2,
oxygen and any other degradation products, at this stage stainless steel is
assumed for the majority of the equipment and piping. The solvent storage tank
is assumed to be of clad carbon steel construction.
5.3.5 Utilities
The following site utilities are assumed to be required and will be available or
will be installed as part of the project:
• Electricity
• Hot oil system or steam system Cooling water
• Nitrogen
• Instrument air
• Drains
5.3.6 Offshore
The base case development plan is for CO2 transportation via existing and new
pipelines with subsea injection via one well into the Captain Fairway in the
vicinity of the Atlantic depleted gas condensate field.
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Block Flow Diagram
Figure 5-1: Block flow diagram
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6.0 Onshore Environmental Description
Landscape and Topography
The landscape surrounding the St Fergus Gas Terminal, Figure 6-1, is typical of
the northeast Scotland coast. A shore margin of sandy beach is backed by
dunes, behind which lies flat grassland rising into low hills. The St Fergus Gas
Terminal is located on a plateau 400m west of the coastline. Pipeline landfalls
and corridors pass through the beach and dune systems to the terminal facilities.
The western and southern sides of the wider St Fergus Gas Terminal have been
landscaped to reduce the visual impact of the site and shelter belts of deciduous
native trees have been planted.
Figure 6-1: Aerial photograph of the St Fergus Terminal (Total, 2009)
Within 2km of the St Fergus Gas Terminal, the landscape consists of two
distinctive natural landform sequences:
• A coastal zone: consisting of the nearshore, beach and dune
complex
• A landwards plateau: this surface slopes westwards (i.e. landwards)
and southwards towards the catchment of the Blackwater and
Annachie Burns
These two landform sequences are separated by a steep, seaward facing
escarpment, termed the inner escarpment, which marks the location of the
former cliff line and represents the boundary between the differing surface
geology and hydrology in this area.
The Acorn capture facility will be located entirely within the St Fergus Gas
Terminal on the plateau. The pipeline landfalls and corridors associated with the
existing SAGE plant pass through the beach and dune systems to the terminal
facilities.
Site Description and Existing Landscape
Character
The area is characterised by its open and exposed nature. There is little
vegetation other than planted shelter belts of trees, and screen planting around
the existing terminal.
The terminal itself comprises numerous large-scale structures, pipes and towers,
set with gravel and concrete roads, with a low existing landscape value and few
landscape resources of note.
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Visual Receptors
The area is sparsely settled with a few small villages (St Fergus, Kirktow,
Inverugie, Crimond) all over 1km from the proposed development, scattered
farms and hamlets connected by rural roads.
There are views of the gas terminal from scattered recreational resources, such
as the Loch of Strathbeg Local Nature Reserve to the north, and St Fergus Links
picnic area and car park to the south. However, it is unlikely that the existing St
Fergus SAGE plant will be visible from the north.
Geology
The St Fergus terminal is situated on wind-blown sand overlying silts and clays
of approximately 10m thickness. Below these sediments, there are 2m to 3m of
glacial till which cover a 2m layer of pink granite bedrock which extends below
sea level.
Hydrology
The most significant water courses within 2km of the St Fergus terminal are:
• Blackwater Burn and its tributary
• Annachie Lagoon, at the mouth of the Blackwater Burn
• Winter Loch
Natural surface water drainage is away from the coast towards the Blackwater
stream in the north and the Annochie Burn in the south, both of which combine
near the coast to flow into a tidal lagoon. As all the gas receiving terminals are
sited on the plateau described above, site water drainage is also directed
landwards, downslope, to the Blackwater stream.
Designations
There are no Sites of Specific Scientific Interest (SSSIs), Special Protection
Areas (SPAs) or Ramsar (UNESCO Convention on Wetlands) sites within a 2km
radius of the St Fergus gas terminal (Figure 6-3), but there is a Site of Interest
to Natural Science (SINS) adjacent to the site along the coast. This area
includes the St Fergus Dunes and Winter Loch and is located outside the
perimeter fence of the St Fergus terminal. This SINS has been designated for
its botanical, entomological and ornithological interest. The Rattray to Kirkton
Head SINS is an Aberdeenshire Council local designation. The SINS is
protected through the Aberdeenshire Local Plan, (Aberdeenshire Council, 2017),
which states:
• Development will not be allowed if it fragments habitats or is not
designed to minimise any adverse impact on the sites environmental
quality, ecological status or viability.
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Figure 6-2: Ecological description, (Pefrofac Engineering Limited, 2012)
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Figure 6-3: Ecological designatins, adapted from (ERM, 2007)
(Note: In Figure 6-3, the circle designates the 2km buffer, the hashed area
designates the Rattray to Kirkton Head SINS and the magenta lines designate
the area of local landscape value.
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7.0 Onshore Environmental Impact Assessment
The environmental issues that are likely to arise from the installation and
operation of the Acorn Project CO2 capture and compression equipment are
very limited for the following reasons:
• There will be no continuous atmospheric emissions
• There will be no continuous aqueous emissions or discharges
• There will be no change to the surface water drainage regime
currently in place at the St Fergus terminal
• The new Acorn infrastructure will be small within the gas terminal
with little visible impact
• There are no international or national ecological designations within
2km of the site
• The nearest noise sensitive receptors are approximately 1km
beyond the site boundary
• The Acorn infrastructure will be located entirely within an existing
industrial setting of the St Fergus Gas Terminal
Potential Locations for a New Build Capture
Plant
The ACT Acorn project seeks to evaluate the repurposing of the existing SAGE
gas sweetening facility for CO2 capture whilst also assessing the option for a
new build capture plant. As shown in Figure 7-1 the Shell plant is located
between the SAGE facility (Ancala) and the North Sea Midstream Partners
(NSMP) complex, thus geographically ideally suited as the focal point for a flue
gas gathering network to either head north to SAGE or south to a new build
capture plant.
Figure 7-1: Approximate boundaries of the four operations (adapted from Google Maps, 2017)
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NSMP have space within their fence line and potential for an “emissions
gathering network” that supplies a capture plant within their boundary.
Wayleaves exist which enable all three gas processing operators to run
pipelines etc. across all three complexes. More than sufficient land area can be
made available within the NSMP footprint for a new build capture plant including:
• A large rectangle of land just south of the Shell boundary fence
• A large rectangle of land just south of the NSMP Phase 3 plant,
Figure 7-2
• The decommissioned and cleared Miller processing areas where
concrete ground structures are retained
Figure 7-2: Available land south of the NSMP Phase 3 plant, (NSMP, 2017)
Potential impacts
This section provides an overview of the environmental issues relating to the
installation of the new infrastructure.
7.2.1 Ecology Rattray to Kirkton Head SINS
There will be no physical effects.
7.2.2 Water Resources River Blackwater
Operation
There are no continuous aqueous emissions from the plant that could have an
effect on the water environment. The drainage arrangements at the site will
remain as they currently are.
7.2.3 Visual Impacts
Residential
The St Fergus gas terminal is located in North East Scotland in a sparsely
populated area. NSMP are very keen for any development to occur within their
boundary, Figure 7-1. There is a big green space between the Shell Terminal
and NSMP’s Phase 2 operation, Figure 7-2. If any new capture plant is needed,
SMR etc. then this would be the logical location. A rectangular green space
adjacent to the south side of Phase 3 is the preferred location and the old Miller
Phase 1 processing area also offers a location. The latter has all been removed
bar the control room building, concrete foundations and the capped ends of the
two pipelines. The new plant and equipment will have a similar profile to the
existing gas processing towers and will be screened from the north and west by
the existing St Fergus Gas Terminal infrastructure and shelter belts of deciduous
native trees.
If the space between Phase 2 and Shell is the selected location, then there will
be limited visibility from the North and West and the view profile from the South
profile should be no different to what is already in place. However, if the space
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south of Phase 3 or the old Miller location is used then this will not be correct.
The profile at Miller will have a visual impact from St Fergus village and the south
but likely to be no different from the Miller profile that previously existed. If the
rectangle adjacent to the south side of Phase 3 is used, the profile will match /
blend into the NSMP facilities behind.
Amenity areas
The new plant and equipment will be visible from the sand dunes and will present
a profile similar to that of the former MRF infrastructure.
The site is within an existing developed industrial complex and will not be out of
character with the rest of this industrial facility. As a result, the scattered villages,
isolated farms and hamlets are unlikely to be affected by changes in their views.
The residents in these areas and the people who travel through them, or spend
time participating in recreational activities at nearby locations do already have
views of the existing St Fergus Gas Terminal.
7.2.4 Traffic and Transport
The roads around the terminal are generally quiet.
Construction
A traffic management plan will be developed in conjunction with the local police
force to ensure minimal disruption from any extra construction traffic.
Operation
Operational traffic is not expected to be greater than existing vehicle movements
at the site. Exact requirements will be determined during FEED.
7.2.5 Air Quality
Operation
This project will remove a current venting stream by capturing the CO2 for
storage. There are no plans for continuous venting. There are no continuous
atmospheric emissions from the plant that could impact receptors.
At the Front End Engineering Design (FEED) stage of the Acorn Project, the
modelling of the emergency venting of CO2 will be completed to demonstrate
that there will be no serious threat to onsite personnel from ground level
concentrations of CO2.
7.2.6 Noise and Vibration
Construction
The concrete piling for the Miller facility at St Fergus all remains in place and
could be built upon to minimise noise and vibration impact.
A new pipeline is not anticipated. A new umbilical is planned to supply a power
and control line from onshore to the planned new offshore subsea installation
for which beach crossings as per for previous pipelines have required only
conventional trenching and ground restoration techniques.
Operation
Based on the current basis of design, there are no expected sources of noise
that would impact on receptors.
7.2.7 Ecology
Figure 6-3 shows the location of the key environmental designations within 2km
of the St Fergus site. The site sits within a locally designated Area of Landscape
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Significance, which will be affected. It is, however, already within an existing
industrial complex. Similarly, it is adjacent to a stretch of coast designated as
Undeveloped Coast, but the coast adjacent to the site is affected by the existing
facility.
After previous pipeline trenching, in general, one or two annual cycles were
required for restoration to reach an acceptable varied ecological status but
between five and ten years are needed before the landfall and pipe‐trench are
more or less indistinguishable from contiguous areas.
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8.0 Offshore Description
This section of the scoping report provides an overview of the base case for the
offshore design of the Acorn project.
The current base case for the Acorn CO2 storage development consists of
utilising the existing 18”/16” Atlantic and Cromarty (Atlantic & Cromarty) pipeline
from St Fergus to Atlantic, (via an acquisition from BG International, now Shell).
A new 8km 16” pipeline will be laid between Atlantic and the injection site located
above the Captain aquifer, approximately midway between the Atlantic and
Cromarty developments. The new 16” pipeline will be surface laid (laid on the
seabed) and stabilised/protected with concrete weight coating.
The Acorn CO2 storage site development will take the form of a seabed manifold
and injection well. The manifold will be piled to the seabed and will incorporate
a fishing friendly protection structure. It is anticipated that dense phase CO2 will
be injected into the Captain aquifer via one subsea well over the 20-year design
life.
The well will be controlled from shore via an umbilical run directly to the Acorn
CO2 storage site injection well location.
Location
The optimum platform location for the Acorn CO2 storage site manifold and well
has been determined through geomechanical studies and is approximately 8km
north west of the Atlantic manifold location. UTM coordinates are presented in
the table below.
Subsea Development UTM coordinates
Eastings (m) Northings (m)
Acorn CO2 storage site Well and Manifold
6,440,500 263,000
Table 8-1: UTM coordinates for Acorn CO2 storage site manifold and subsea well
Transport
8.2.1 Facilities Re-use Versus New Infrastructure
There is a 12km 12” export pipeline from Cromarty to Atlantic that passes in the
vicinity of the Acorn CO2 storage site injection location, however it has been
assumed that a new pipeline section from the end of the Atlantic pipeline to the
injection manifold will be required for the following reasons:
• Smaller diameter/reduced ullage (12” versus 16”)
• The 12” Cromarty pipeline was specified for a design life of 10 years
(2016) whilst the 16” Atlantic pipeline was specified for a design life
of 20 years (2026). Extending the design life until 2056 years may
not be feasible
• Trenched and buried therefore it would require excavation and
cutting at the manifold location to facilitate tie-in
• It will not be possible to inspect the line via intelligent pig due to large
internal diameter changes (18”/16”/12”)
Consideration was initially also given to utilising the existing 20” Goldeneye
pipeline. The Goldeneye field is located approximately 100km north east of
Aberdeen, and approximately 30km west of the existing Atlantic facilities. The
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selected location for the Acorn CO2 storage site injection well is approximately
8km west of the Atlantic development and as such the existing Atlantic pipeline
is the preferred choice, (8km new pipeline versus a 38km new pipeline),
provided its integrity can be confirmed. Furthermore, the original design
pressure of the 20” Goldeneye pipeline is 132barg, which would likely lead to
operability issues given the required tubing head pressures for CO2 injection in
the Captain aquifer. The Goldeneye pipeline has therefore not been considered
further at this stage.
The existing 16” Atlantic & Cromarty pipeline connected between the St Fergus
terminal to the Atlantic manifold is proposed to be reused. The Atlantic and
Cromarty development was commissioned in 2006. The 16” pipeline was
specified for a 20 year design life based on transporting hydrocarbons (and
water) at relatively high pressure, however production ceased in 2009 (after less
than 4 years) and formal Cessation of Production (CoP) was granted by the
Department of Energy and Climate Change (DECC) in 2011. In 2012 the
pipeline was filled with a mixture of produced water, MEG (mono ethylene glycol),
corrosion inhibitor and hydrocarbons, before the pipeline was cleaned and
rendered hydrocarbon free.
The UK Government Department of Business Energy and Industrial Strategy
(BEIS) decommissioning website, (UK Government, 2018), has a copy of the
decommissioning programme that was submitted in 2016. Since this submission
Shell acquired BG and Shell have since indicated that they plan to resubmit the
decommissioning programme for Atlantic and Cromarty.
Adoption of the pipeline following decommissioning may still be possible.
However, the pipeline integrity may be compromised and would require
extensive inspection, reconnection and testing thus leading to the high likelihood
of re-use becoming commercially unfeasible.
Figure 8-1: Pipeline route for Acorn CO2 storage site (Atlantic pipeline is shown in green)
Commercial considerations and decisions will not be discussed in this report but
will be informed by any environmental effects influencing the decision to re-use
or re-lay pipework. It is worth noting that any acquisition will also take on liability
for decommissioning some, or all, of the remaining Atlantic and Cromarty
transportation facilities.
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A full pipeline integrity and life extension study will be required to confirm
suitability. This will involve detailed internal and external inspection to requalify
the pipeline and verify that it is suitable for re-use to transport CO2 for up to 20
years. Requalification shall comply with the same requirements as for a pipeline
designed specifically for transportation of CO2. This work will be carried out as
part of FEED.
8.2.2 New 16” Infield Pipeline to the Acorn CO2 storage site
Manifold
A new 16” pipeline will be required to connect the existing 18”/16” Atlantic-
Cromarty pipeline to the Acorn CO2 storage site termination skid, via tie-in
spools. This infield pipeline is shown in Figure 8-2. The 8km 16” pipeline route
has been selected to minimise route length while avoiding existing facilities.
There are two pipeline crossings, where it crosses the existing Cromarty pipeline
and umbilical.
Figure 8-2: Infield pipeline route for Acorn CO2 storage site (new 16” pipeline shown in black)
A full study will be required to confirm the pipeline route and ensure that all
seabed obstructions (wells, platforms, pipelines, umbilicals, cables etc.) and
seabed features (rocks, sandwaves, pockmarks, mud slides, etc.) are identified
and accounted for appropriately.
Approach for Offshore Facilities
8.3.1 Pipeline
The existing 16” pipeline from Atlantic to St Fergus is believed to be capable of
being used in reverse flow at an operating pressure of up to 170barg. The
landfall comprises 1.2km of 18” pipeline (17.5mm wall thickness).
Running parallel to the 16” pipeline is a 4” MEG pipeline. This line can be tied
into the new system and can be used to depressurise the 16” line from the
Atlantic end should the facility ever be required, for example, to help clear a
hydrate blockage. It is not considered necessary to internally inspect this
(smaller) line. External inspection of the 4” line will be completed by ROV at the
same time as the 16” line is inspected. The pipeline will require an external and
internal inspection prior to the final investment decision.
8.3.2 Subsea
The existing production manifold, jumpers and wells are considered unsuitable
for reuse for CO2 injection. A new injection distribution manifold will be installed
at the Acorn CO2 Storage Site. A new 16” pipeline will be installed from the end
of the 16” Atlantic pipeline to the new manifold. The existing 16” and 4” rigid
spools at Atlantic connecting the two pipelines to the Atlantic manifold will be
removed and two new flexible spools will reconnect the 16” and 4” lines to the
new pipeline. These will be protected by mattresses.
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The 4” line will be connected to the injection manifold through a remotely
operated block valve and choke. This will enable the manifold and 16” line to be
depressurised back to St Fergus should a hydrate blockage occur.
The subsea configuration proposed for the Acorn project is based on a long
distance tie-back from the gas capture facility to the injection reservoir and is
similar to Statoil’s Snøhvit CO2 project in the Barents Sea. The key input
parameters used to size and cost the installation for the Acorn CO2 storage site
are listed below.
Subsea well and manifold:
• 115m water depth
• 20-year design life
Manifold:
• Pig receiver or tie-in point for a temporary pig receiver
• Filter (optional)
• Subsea umbilical termination unit (SUTU)
• Pipeline monitoring
• Fishing friendly protection structure
To ensure a robust system design given the early level of engineering definition
and to maximise overall system availability, a modular approach is
recommended with the manifold being designed to allow additional wells to be
connected via a daisy chain arrangement.
8.3.3 Control System and Umbilical
The subsea power and control system is assumed to be an electrohydraulic
design. The base case is for an 80km umbilical with high and medium pressure
hydraulics and communications between the onshore control room and the
injection manifold. Control of the injection tree will be via the subsea control
modules (SCMs) located on the injection tree.
8.3.4 Wells
The Captain sands are very permeable and the injectivity potential is high. The
key design criteria for the injection wells is that they must be capable of injecting
between 0.1 and 2MT/yr CO2 in liquid phase throughout the project life and
require minimal intervention during that time.
A single injection well is envisaged, but this may change as the development
expands in the future.
The manifold will be connected to the well by a 6” flexible jumper and a
control/instrumentation flying lead.
The key elements of the well design assumptions are summarised as follows:
1. Reservoir 1500-2005m (tvdss)
2. Water depth 115m
3. Well deviated at 60o in the target formation
4. The wells will consist of 95/8’’ production casing with 5½” stand
alone sand screens.
5. The well will be completed with a upper dual completion with 27/8’’
and 41/2’’ tubing string
6. All flow wetted surfaces will be 13% chrome material
7. Maximum injection rates will be 2MT/yr
8. Minimum FTHP will be 44.5barg
9. Maximum FTHP will be 160barg or pipeline limit, if lower
10. Maximum WHT will be 6°C during injection
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8.3.5 Decommissioning of Existing Equipment
Before the new infrastructure associated with CO2 disposal is installed and
commissioned, existing equipment that is now redundant must be removed. It is
assumed that this work will be completed by the current Operator.
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9.0 Offshore Environmental Description
Introduction
The key environmental sensitivities in the area are described in the Atlantic and
Cromarty Decommissioning EIA (2016), (BG Group, 2016). The following
provides a summary of that information. A full updated environmental description
will be provided in the Acorn Project Environmental Statement.
A pre-decommissioning environmental survey carried out in August 2015 found
the environment at the Atlantic and Cromarty (Atlantic & Cromarty) fields to be
typical of much of the Central North Sea. The water depth at Atlantic is 114m
and at Cromarty 113m. The maximum tidal flow is 0.51m/s, with residual
currents moving to the southeast. Sea surface temperatures range from 8.5°C
in the winter to 15°C in the summer. At the seabed, temperatures range between
8°C and 9°C. The seabed between the Cromarty field and the Goldeneye
platform primarily comprises muddy sand with shell fragments that is typical for
the ‘circalittoral muddy sand’ habitat widespread in the Central North Sea at
water depths above 100m. The benthos, fish, marine mammals and seabirds
associated with the area are typical of the Central North Sea and occur over the
wider North Sea region.
The seabed in the shallower part of the Atlantic & Cromarty export pipeline route,
up to approximately 45km from shore, comprises a ‘circalittoral mixed sediment’
habitat, in which sandy areas occur that exhibit low biodiversity, and areas
where shell material, gravel, pebbles, cobbles and boulders occur that exhibit
relatively high biodiversity. The mixed stable sediment in the latter supports the
tube worm sabellaria spinulosa at the extreme of its geographic range and depth
tolerance. This species can form biogenic reefs, but a habitat assessment
concluded that the sabellaria spinulosa accumulations along the pipeline route
do not form a contiguous reef.
The Atlantic & Cromarty pipeline passes through an area that is being
considered for designation as a possible Marine Protected Area (MPA), the
Southern Trench MPA proposal. The Atlantic & Cromarty pipeline is 30km from
the biodiversity and seabed geological features for which the site may be
designated in the future, but it passes through an area where the thermal
characteristics are associated with nursery grounds for fish.
Commercial users of the area are mainly associated with the oil and gas industry,
shipping and fishing.
Physical Environment
The pre-decommissioning environmental survey of the Atlantic & Cromarty
fields and the pipeline routes, (Fugro, 2015), distinguished three biotopes (or
biotope complexes) as defined by the European Nature Information System:
• The ‘circalittoral muddy sand’ biotope complex (EUNIS type A5.26)
was found at all the survey stations beyond 45km from the shore.
This is typical for the seabed with over 90m water depth and is a
widespread habitat in the Central North Sea.
• The ‘circalittoral mixed sediments’ biotope complex (EUNIS type
A5.44) was found at survey stations up to 45km from the shore (see
Figure 9-1. The seabed in these areas comprises quantities of shell
material, gravel, pebbles, cobbles and in some places areas of
numerous boulders. In the first 16km from shore, the sediments are
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Figure 9-1: Habitats (circles represent pre-decommissioning environmental survey stations), (BG Group, 2016)
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predominantly cobbles and boulders with gravel and sand. Beyond
16km from the shore sand predominates with some pebbles and
cobbles.
• Patches of a biotope ‘sabellaria spinulosa on stable circalittoral
mixed sediment’ (EUNIS type A5.611) 3-16km from the shore.
The seabed in the 500m exclusion zones at Atlantic and Cromarty consists of
muddy sand with shell fragments, typical of the widespread ‘circalittoral muddy
sand’ habitat. Genesis observed that the seabed at Goldeneye comprises silt
sediment over very soft, silty/sandy clay and soft to firm clay, (Genesis, 2002).
Fugro, (Fugro, 2015) examined three camera transects in the ‘circalittoral mixed
sediments’ and ‘sabellaria spinulosa on stable circalittoral mixed sediment’
habitats. Two of the transects coincide with the section of the pipeline route
between 6.4 and 8.9km from the shore, where the pipe was laid on the surface.
The combination of indicators including elevation, the presence of cobbles and
visible biota, allowed patches with moderate potential as stony reef to be
identified. Review of transect data suggested that sabellaria spinulosa
aggregations are likely to occur throughout the ‘circalittoral mixed sediment’
biotope complex, but assessment against indicators for elevation, area and
patchiness concluded that that the aggregations in the nearshore pipeline area
do not form a contiguous sabellaria spinulosa reef.
Plankton
The project area currently has the common North Sea phytoplankton species,
dominated by the dinoflagellate ceratium and the diatom skeletonema.
Water currents cause continual movement of individuals through the area (North
Sea Task Force (NSTF), 1993) and the rapid maximum doubling times of the
phytoplankton cause blooms to occur in the North Sea each spring with a
smaller peak in the autumn. The timing and species composition of these
blooms can be variable, (Bresnan, 2009).
Throughout the North Sea, the previously dominant population of cold water
zooplankton species (e.g. calanus finmarchicus) have declined in biomass by
70% since the 1960s, and species with warmer-water affinities (e.g. calanus
helgolandicus) have been moving northward (Edwards, 2013).
Benthic Communities
The pre-decommissioning environmental survey of the Atlantic & Cromarty
fields found to constitute a tiny part of habitats that are widespread throughout
the Central North Sea. It supports species that are found throughout the region.
9.4.1 Fish Populations
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 clupea), 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 (ammodytes sp.), sole
(solea solea) and whiting (merlangius merlangus) live on or near the
seabed. Many demersal species also migrate between areas during
their lifecycles.
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9.4.2 Seabird Populations
The large seabird colonies on the coast of Aberdeenshire support important
populations of:
• Gulls including herring gull (larus argentatus), kittiwake (rissa
tridactyla), gannet (morus bassanus), fulmar (fulmarus glacialis),
• Auks including guillemot (uria aalge), razorbill (alca torda) and puffin
(fratercula arctica).
• Shags (phalacrocorax aristotelis),
The birds forage at sea for fish and occur throughout the Atlantic & Cromarty
project area of influence. Some species depend on particular fish species, for
example puffin breeding success is closely associated with the availability of
sand eels. Seabirds in nearshore areas spend much of their time in the water
and are vulnerable to pollution throughout most of the year. Species such as
fulmar spend more time on the sea surface, than herring gull, great black-backed
gull (larus marinus) and kittiwake and are consequently more vulnerable to
pollution, (Stone, et al., 1995).
After the breeding season ends in June, auks disperse into offshore waters
including the Atlantic & Cromarty decommissioning project area of interest. The
auks spend much of their time on the surface of the water and raft in large
numbers to moult, at which time they are flightless. Any auks at the Atlantic &
Cromarty Fields are therefore particularly vulnerable to surface pollutants
between July and September.
The Joint Nature Conservation Committee’s (JNCC) Offshore Vulnerability
Index maps monthly seabird vulnerability to surface pollution taking account of
seasonal changes in the species and number of birds present in each UKCS
offshore block.
9.4.3 Marine Mammals
9.4.3.1 Cetaceans
The cetacean species that are most likely to be observed at the Atlantic Fields
are Atlantic white-sided dolphin, harbour porpoise, bottlenose dolphin, white-
beaked dolphin and minke whale (Reid, 2003). These same species are also
the most regularly sighted cetacean species throughout the North Sea. Risso’s
dolphin and large baleen whales are also occasionally sighted.
9.4.3.2 Pinnipeds
Large populations of grey seal (halichoerus grypus) occur along the east coast
of Scotland. Tracking of individual grey seals has shown that they can feed up
to several hundred kilometres offshore although most foraging tends to be within
approximately 100km of the coast (Sparling, 2012), (Thompson, 2010). Mapping
completed indicates the Atlantic & Cromarty export pipeline passes through an
area where grey seals are present at medium densities, whereas the density is
low at the Atlantic & Cromarty Fields, (BG Group, 2016).
The foraging range of the harbour seal (phoca vitulina) (also known as common
seal) is typically 40-50km from their haul-out site. Results from telemetry data
indicate that harbour seals are unlikely to occur in the project area of interest,
(BG Group, 2016).
9.4.4 Commercial Fisheries and Shipping
There is a concentration of coastal shipping on routes rounding Rattray Head a
few kilometres north of St Fergus. The vessels entering or leaving the Moray
Firth typically pass by several kilometres out to sea. Commercial shipping traffic
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is less dense on routes from the UK to continental ports or to supply offshore oil
and gas operations.
DECC categorised the coastal shipping activities in the UKCS block off Rattray
Head as having a high density, Figure 9-2. The average effort by UK fishing
vessels in the ICES rectangles encompassing the Atlantic & Cromarty
decommissioning project between 2010 and 2014 was 956 vessel days per year,
(BG Group, 2016).
Figure 9-2: Shipping density map, (BG Group, 2016)
9.4.5 Conservation Designations
The Scottish Government designates Nature Conservation Marine Protected
Areas (MPA) under the Marine (Scotland) Act. Marine Scotland, Scottish Natural
Heritage, the Joint Nature Conservation Committee and other organisations put
forward MPA proposals for designation. The nearest designated MPA to the
Atlantic & Cromarty project area of interest is the Turbot Bank, located
approximately 66km south of the Fields. However, the Atlantic & Cromarty
export pipeline passes through the boundaries of an area that has been
identified for possible future designation as an MPA (the Southern Trench MPA
proposal).
The EU Habitats Directive (92/43/EEC) lists habitats in Annex I and species in
Annex II whose conservation requires the designation of special areas of
conservation (SAC) sites of community importance (SCI). The habitat
assessment carried out as part of the Atlantic and Cromarty Pre-
Decommissioning Environmental Survey, (Fugro, 2015), determined that no
Annex I habitat occurs in the project area of influence. Marine mammals listed
in Annex II (cetaceans and pinnipeds) have been observed in the outer Moray
Firth where the Atlantic & Cromarty Fields are located (bottlenose dolphin,
harbour porpoise) and along the export pipeline route (common seal). However,
the Atlantic & Cromarty Fields are approximately 125km from the nearest SAC
for marine species which is the Moray Firth SAC designated for bottlenose
dolphins.
Protected Areas
The area extending for 12nm from the Aberdeenshire coast between Buckie and
Peterhead is being studied by Scottish Natural Heritage regarding potential
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future designation as a Nature Conservation Marine Protected Area (MPA). The
Atlantic & Cromarty export pipelines pass through this area that is termed the
Southern Trench MPA proposal. The Southern Trench, after which the site is
named, is an enclosed glacial seabed basin 200m deep located 10km north of
Fraserburgh. The Atlantic & Cromarty pipeline passes about 30km southeast of
this basin. A thermal front extends round Rattray Head towards Peterhead that
is associated with plankton richness and juvenile fish. The proposed boundary
of the MPA proposal would encompass this front. The Atlantic & Cromarty
pipeline passes through the part of the site where the front occurs, Figure 9-3.
Three Special Protection Areas (SPAs) designated under the EU Birds Directive
are in the vicinity of the Atlantic & Cromarty export pipeline landfall at St Fergus.
• Buchan Ness to Collieston Coast SPA: the northern boundary of the
SPA is approximately 6km south of the pipeline landfall. Its
designation protects a seabird assemblage (guilliemot, kittiwake,
herring gull, shag, puffin and fulmar) of international importance.
During the breeding season the area supports 95,000 seabirds
(JNCC, 2001a)
• Loch of Strathbeg is a dune loch approximately 4km north of the
pipeline landfall. Gulls, terns and wading birds nest there in summer.
In winter, thousands of wild geese, swans and ducks fly in, including
20 per cent of the world's population of pink-footed geese
• The Troup, Pennan and Lion’s Heads SPA: the eastern boundary of
the SPA is located approximately 20km west of the pipeline landfall.
It was designated for its breeding guillemot population of European
importance and seabird population (razorbill, kittiwake, herring gull,
fulmar) of international importance. The SPA supports 150,000
seabirds during the breeding season (JNCC, 2001b).
The Turbot Bank Marine Protected Area located approximately 30km south of
the Atlantic & Cromarty export pipeline and 50km south of the Atlantic &
Cromarty Fields is a site of particular importance for sand eels which are an
important source of food for seabirds including puffins and kittiwakes (JNCC,
2014).
Annex I to the EU Habitats Directive lists stony reefs and biogenic reefs as
protected habitat types. During the Atlantic & Cromarty pre-decommissioning
survey, BG commissioned a habitat assessment which evaluated the
‘circalittoral mixed sediment’ habitat against ‘reefiness’ against criteria for stony
reef and biogenic reef. Although the reef-forming species sabellaria spinulosa
was observed, the assessment concluded it did not form a contiguous reef in
this area.
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Figure 9-3: Protected areas, (BG Group, 2016)
Socio-Economic Interests
Socio-economic activities in the offshore area where Atlantic & Cromarty
decommissioning activities will take place include commercial shipping and
fishing.
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10.0 Offshore Environmental Impact Assessment
Introduction
This section of the scoping report outlines the key potential offshore
environmental impacts from the proposed Acorn Project. It should be
emphasised that these are potential impacts only. Whether or not they are likely
to occur, and the level of significance will be assessed during the EIA. Possible
mitigation measures are also included. Benefits from the proposed project will
also be addressed during the EIA as appropriate, and through the consideration
of alternatives.
Physical Presence
The Acorn Project will involve the installation of a new seabed manifold at the
location of the Acorn CO2 storage site injection point. An 8km length of new
pipeline will connect the end of the existing Atlantic & Cromarty pipeline to the
manifold and a new umbilical will be installed from the St Fergus terminal to the
Acorn CO2 storage site manifold. The EIA programme will include:
• Review of subsea infrastructure and physical footprint
• Review of installation/commissioning vessel schedule and ongoing
reservoir support/supply vessels
• Review of any specific environmental effects noted in the Atlantic &
Cromarty Environmental Statement
Seabed and Habitat Disturbance
Seabed and habitat disturbance is expected to be minimal with re-use of most
of the subsea infrastructure. Some short-term disturbance will be seen from the
installation of the new pipeline and tie-in point at the Atlantic pipeline, the new
umbilical and the installation of the manifold and wellhead and tree at the new
well site. An Environmental Identification (ENVID) Summary will be completed
during FEED once the Basis of Design for the Acorn Project has been finalised.
The overboard disposal of oil or synthetic based drilling muds was eliminated
after the OSPAR Decision 2000/3 came into effect on 16 January 2001.
Therefore, the only drill cuttings that will be disposed of to the seabed will be
water-based drill cuttings and disturbance from the deposit of cuttings during
drilling, as has been demonstrated by post drilling surveys, will be limited to the
immediate vicinity of wellheads.
New subsea infrastructure and any associated disturbance will be fully
addressed within the EIA as appropriate.
The EIA programme will include:
• Assessment of disturbance from subsea infrastructure installation
and vessel activities
• Assessment of disturbance from installation of the new pipeline and
associated activities e.g. mattressing and rock dumping activities
• Assessment of disturbance from installation of the new umbilical and
associated activities e.g. trenching, mattressing and rock dumping
activities
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Discharges to Sea
Discharges to sea from drilling operations including drill cuttings, drilling mud
and associated chemicals will occur. Drill cuttings contaminated with water-
based mud (WBM) will be discharged from the mobile drilling rig into the sea
following mud recovery operations. Most chemicals in WBM pose little or no risk
to the marine environment. Discharge of drill cuttings can cause a temporary
plume in the water column that may have short-term localised impact on
plankton and pelagic fish species, e.g. irritation of gills.
Results of seabed surveys at Atlantic have demonstrated that there are no
significant long-term cumulative impacts from the discharge of WBM
contaminated cuttings. Oil based mud (OBM) contaminated drill cuttings are
shipped to shore for treatment and disposal.
Chemicals, used mainly for drilling and workover operations, may enter the
marine environment through several routes including subsea control systems
and drainage systems. They can affect the marine environment in different ways,
mainly through immediate toxic effects (acute toxicity) or over long periods
(chronic toxicity).
Other discharges associated with the routine operation of the subsea control
system, will also be included in the EIA. For example, control of subsea valves
is usually via a water-based hydraulic fluid which is discharged to sea during
standard valve operations.
The EIA programme will include:
• Identification and quantification of all sources of discharges to sea
• Risk assessment and dispersion modelling of WBM contaminated
cuttings
Underwater Noise
Noise can come from many sources associated with exploration, construction,
installation and production of offshore developments. There are two main types
of noise:
• Continuous and intermittent noise sources which include drilling and
injection operations; noise from ships such as supply vessels,
installation vessels and guard vessels; and transponders.
• Temporary impulsive noise sources which include seismic surveys
and piling operations.
It is important that noise/vibration impacts are assessed during the EIA process
and a mitigation strategy developed to minimise disturbance. In recent years
there has been increasing concern about the effects of noise on marine
mammals. There may be a range of effects from industrial noise, including direct
effects such as hearing damage and disturbance and indirect effects such as
displacement of prey species or stress.
The EIA programme will include:
• Identification of potential noise sources and application of noise
reduction opportunities in design;
• Identification of noise control and noise management measures;
• Underwater noise modelling as appropriate;
• Assessment of disturbance, in particular any potential disturbance to
marine European Protected Species.
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Atmospheric Emissions
The main source of atmospheric emissions from the Acorn offshore operations
is the combustion of diesel during installation of the subsea installation, with the
associated release of carbon dioxide (CO2), carbon monoxide (CO), unburnt
hydrocarbons (UHC), sulphur oxides (SOx) and oxides of nitrogen (NOx). The
subsea installation will subsequently be powered from shore.
The EIA programme will include:
• Identification and quantification of all sources of atmospheric
emissions (including shipping)
• Best Available Technology (BAT) assessment of power generation
options
• Dispersion modelling CO2 emissions from unplanned release
Waste
Waste generated from offshore operations comprising: special waste (including
oils, paints, chemical drums, and hazardous waste) and general waste with non-
hazardous properties, which requires being shipped to shore, will be addressed
as appropriate in the EIA. Strict legislation governs the separation, handling and
disposal of such wastes generated from subsea infrastructure maintenance
operations and the Environmental Statement will detail the compliance
measures and waste management strategy in place.
The EIA programme will include:
• Identification and quantification of all potential waste sources
• Waste management strategy based on the hierarchy of remove,
reduce, reuse, recycle
Accidental Events
All marine activities carry with them some risk of accidents which can result in
the spillage of harmful substances into the sea. Small oil and chemical spills
may originate from bunkering and chemical transfer operations, subsea
operations and drilling operations. There is a remote risk of CO2 loss from
pipeline damage.
The EIA programme will include:
• Identification of potential leak sources and spill pathways and
associated risks
• Leak prevention and review programme during design
• CO2 release modelling
• Review of knowledge transfer documents from UK CCS
programmes 1 and 2, CO2 modelling and risk evaluation
Cumulative and Transboundary Effects
Potential cumulative effects of the various impacts identified such as water
quality and global warming will be considered in the EIA. This will involve
examining the activities and potential impacts, both positive and negative of the
Acorn Project in the context of existing and known planned developments in the
area.
The EIA programme will include:
• Assessment of the potential cumulative impacts to ecological
habitats especially those of rare and protected species
• Socio-economic impacts including presence, fishing and fishing
grounds
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• Shipping and navigational risk
Decommissioning and Pipeline Re-purposing
The circalittoral mixed sediments in the nearshore sections of the Atlantic &
Cromarty export pipeline are relatively biodiverse. The communities appear to
have recovered after the installation of the Atlantic pipeline and adapted to its
presence. BG completed stakeholder engagement with the JNCC, (BG Group,
2016), which suggested that further disturbance of the habitat in this area, for
example by removing a buried pipeline, would be undesirable as it would initiate
a further recovery period. The presence of sabellaria spinulosa accumulations
at the extreme of their geographic and depth range, even if they are not
considered at present to form a continuous reef, suggests that unnecessary
disturbance of this habitat should be avoided. Thus, consideration of the above
must be made within the Acorn EIA to address the impact of laying the umbilical.
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11.0 Permits and Consents
An initial consents register has been prepared for the capture plant, onshore
infrastructure and offshore infrastructure. The register forms part of D14 ACT
Acorn Outline Environmental Impact Assessment (Pale Blue Dot Energy, 2018).
This register is reflective of the current stage of the project and therefore may
not represent a comprehensive list of all permit, licences, application
notifications and consents that would be required through the full life cycle of the
project. Many of these are developed and understood through design
development of the project. It is recommended that this register provides a basis
to understand the project needs from business planning to concept select stage.
This document should be subject to detailed review at each project stage gate
to allow it to be updated and brought in line with the project concept and
understanding at that stage.
The onshore element of the project will take place on an existing Control of Major
Accident Hazards (COMAH) regulated industrial site. The consents register
covers key terrestrial authorisations required to construct and operate the
capture plant in terms of planning, environmental and health and safety based
on the current regulatory framework. At this stage, 13 key terrestrial
authorisations have been identified. These are listed in Table 16-1.
The offshore element of the project will take principally at the Acorn injection site
which is currently planned to be approximately 80 north west of St Fergus. The
consents register covers key terrestrial and marine authorisations required to
construct and operate the capture plant in terms of planning, environmental and
health and safety based on the current regulatory framework. At this stage, 26
key terrestrial and marine authorisations have been identified. These are listed
Table 16-1.
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Onshore Consents Register
Aspect Requirement Determining Body Comment
Planning Permission
Planning permission for capture plant under the Town and Country Planning (Scotland) Act (TCPA) 1997 (as amended by the Planning etc. (Scotland) Act 2006).
Aberdeenshire Council (AC).
Planning permission for the transmission pipeline under the Pipeline Act 1962 and TCPA 1997.
AC.
Due to the small scale of the pipeline ~1km and low environmental sensitivity we assume that the pipeline would not be EIA development and could either be rolled up into the application for the capture plant or be subject to its own planning application.
Based on the assumption that the proponent is not a public gas transporter and the proponent can apply under the Gas Transporter Pipe-line Works (Environmental Impact Assessment) (Amendment) Regulations 2007.
Environmental Impact Assessment (EIA)
Subject to the EIA screening opinion / direction EIA for the capture plant under the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2011.
AC. It may be possible to screen the capture plant out of the need for EIA particularly if the existing SAGE facility is used. This will be confirmed during the next phase.
Environmental Permit
Environmental Permit for the operation of the capture plant under the Pollution Prevention and Control (Scotland) Regulations 2012.
The Scottish Environment Protection Agency (SEPA).
Application to vary an existing permit or a new permit subject to agreement with SEPA.
Habitats Regulations Screening Assessment
Habitats Regulations Assessment (HRA) the Conservation (Natural Habitats, &c.) Amendment (Scotland) Regulations 2012.
The competent authority will vary for planning and permitting. For planning AC; for permitting SEPA.
The need for, and level of assessment will vary depending on potential (if any) pathways for effects to occur on nature sites.
Water Abstraction
A water abstraction license is subject to the Water Environment (Controlled Activities) (Scotland) Regulations 2011 more commonly known as the Controlled Activity Regulations (CAR).
SEPA. On the assumption that there is not sufficient ‘headroom’ within the existing license it may also be possible to use the existing terminal operator extraction license.
Hazardous Substance Consent
Consent for Hazardous Substances under the Planning (Hazardous Substances) (Scotland) Regulations 2015.
AC. Subject to the capture technology included within the project e.g. amines.
European Protected Species
European protected species license (i.e. for badgers, bats, Great Crested Newts etc.) under The Conservation of Habitats and Species Regulations 2010 and Habitats Regulations 2010
Scottish Natural Heritage (SNH) and if applicable Marine Scotland
May be required depending on which species, if any are present within and around the project area and the effect of the projects upon those species present.
Building Regulations Approval
Building Regulations Approval under Building (Scotland) Regulations 2017 (as amended).
AC. Detailed design to be completed before Building Regulations application(s) can be made.
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Aspect Requirement Determining Body Comment
EU ETS Permit EU ETS Greenhouse Gas Emissions Trading Permit under the Greenhouse Gas Emissions Trading Scheme Regulations 2012.
The Greenhouse Gas Emissions Trading Scheme Regulations 2012.
Installations covered by the Scheme are required to monitor and report their emissions. At the end of each year they are required to surrender allowances to account for their installation’s actual emissions. They may use all or part of their allocation and have the flexibility to buy additional allowances or to sell any surplus allowances generated from reducing their emissions below their allocation.
REACH Registration Evaluation, Authorisation and restrictions of Chemical Regulations.
The Competent Authority is hosted by the Health and Safety Executive (HSE), working with SEPA and other government departments.
Subject to the capture technology included within the project. There could be a requirement to register as a downstream user of chemicals, e.g. amines.
COMAH Variation to COMAH Safety Report under the Control of Major Accident Hazards Regulations 2015.
The HSE and SEPA are jointly the Competent Authority (CA) for COMAH in Scotland.
The CO2 stripping process uses chemicals such as amines that, depending upon the characteristics and the volumes stored and used in process, may be a qualifying substance under COMAH. The CA has published guidance on the storage of bulk hazardous materials. If the amine to be used falls under the COMAH regulations, the detailed design will need to incorporate specific consideration on secondary and tertiary containment provisions.
Pipeline Operational Safety
SI 1996/825 The Pipeline Safety Regulations 1996 (PSR) - Major Accident Emergency Plan and notification prior to construction.
HSE.
PSR require a local authority to prepare emergency plans for pipelines which have the potential to cause a major accident for pipelines conveying ‘dangerous fluids’, defined in Schedule 2 of the Regulations. The Regulations also require a pipeline operator to establish emergency procedures for such pipelines.
CDM The Construction (Design and Management) Regulations 2015.
HSE.
During the design and construction phase of a project there are key responsibilities for safety management that lie with the Client, the appointed Construction Design and Management Coordinator (CDMC), designers and the appointed principal contractor. Provided that these responsibilities are implemented in line with regulation, all relevant safety management considerations should be met.
Table 11-1: Onshore consents register
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Offshore Consents Register
Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S01.0 Planning Permission
Town and Country Planning (Scotland) Act 1997 (as Amended by the Planning etc. (Scotland) Act 2006).
Add new pipework / new pipeline
St Fergus to Atlantic & Cromarty link
Aberdeenshire Council
S02.0 Pipelines Work Authorisation
Petroleum Act 1998
Add new pipework / new pipeline
St Fergus to Atlantic & Cromarty Link
Department of Business, Energy and Industrial Strategy (BEIS)
Need to provide Pipeline/flowline details, details on rock dumping, chemical discharges etc. Approval of PWA may be linked to Environmental Statement approval, therefore approval period may be extended.
S03.1 PON15C Approval
Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360)
Change Atlantic & Cromarty pipeline to CO2 duty
CO2 export pipeline
OGREP/EMT
1. Uncertain if required for change of use of pipeline to CO2 duty.
2. Linked to Environmental Statement for overall Project. Even if the pipeline was included in an approved Environmental Statement, a PON15C may still be required.
3. OGA currently advise 6 months maximum approval process for oil and gas Environmental Statement.
4. PON15C also used for Chemical Permit application. Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS.
The PON 15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted, then it must be explicitly requested as part of the PON 15 submission.
Relevant Considerations will be included within the Offshore Environmental Statement.
S03.2
Chemical Permit (PON15C Approval)
Offshore Chemicals Regulations 2002 (SI2002/1355)
Use / Discharge of chemicals during pipeline installation, commissioning, maintenance, repair and
Atlantic & Cromarty export pipeline
OGA
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
decommissioning operations.
S03.3
Approval of updated Major Accident Prevention Document
SI 1996/825 The Pipeline Safety Regulations 1996 (PSR)
Re-use Atlantic & Cromarty pipeline
Atlantic & Cromarty export pipeline
Health & Safety Executive (HSE)
1. Existing MAPD to require update/ re-development and submission to reflect changes due to CCS.
S03.4
Notification before use / re-use of a major accident hazard pipeline
S1 1996/825 Pipeline Safety Regulations 1996 (PSR) Reg 21
Re-use Atlantic & Cromarty pipeline
Atlantic & Cromarty export pipeline
Health & Safety Executive (HSE)
1. Notification anticipated to be required prior to commencement of re-use of pipeline
2. Minimum 14-day notification required.
S03.5 Notification in other cases
SI 1996/825 The Pipeline Safety Regulations 1996 (PSR) Reg 22
Atlantic & Cromarty export pipeline
Health & Safety Executive (HSE)
1. Notification anticipated to be required for change of use to CO2 duty.
2. Minimum 3-month approval period.
3. Some uncertainty surrounding requirements for change of use from natural gas to CO2 and associated legislation.
S04.0 Greenhouse Gas Permit
Greenhouse Gas Emissions Trading Scheme Regulations 2012
Transport Greenhouse Gas
Combustion activity
SEPA
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S05.1 Exploration Licence
Energy Act 2008 / Petroleum Act 1998
Explore the store OGA
1. Non-intrusive exploration activities, in areas below the low water mark, are already regulated under the Petroleum Act 1998. Since the activities involved in such exploration do not depend on its ultimate purpose, BEIS have adapted the existing Exploration Licence, issued under the Petroleum Act, so that it becomes a combined licence issued under the Petroleum Act and the Energy Act 2008;
2. The amended exploration licence covers any combination of exploratory activities relating to petroleum, carbon dioxide storage, or storage and gas unloading of natural gas as applicable (e.g. cover seismic, gravity and magnetic surveys, sample collection and shallow drilling).
3. An Exploration Licence is currently valid for three years, and it is renewable on request. The cost of the licence is currently £500, which covers the internal departmental costs of administering the regime.
4. Agreement to the award of an Exploration Licence does not in any way replace the need for consents, in relation to these activities, required by the Offshore Marine Conservation (Natural Habitats &c.) Regulations 2007.
5. For the purposes of such exploration a developer will not be required to have a Crown Estate lease or a carbon storage licence.
6. Non-intrusive exploration activities (seismic, gravity & magnetic surveys, sample collection & shallow drilling)
S05.2
Consent to Survey (PON14A Approval)
Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001, (SI 2001/1754)
Store data gathering
OGA
1.These Regulations cover seismic survey or geological survey in offshore waters and require written consent from the Secretary of State before undertaking a seismic or geological survey.
2. Amendments made under the 2007 Regulations extend this requirement to include all UK waters. New Guidance incorporating the 2007 amendments is currently being drafted.
3. Consent for survey is required for all seismic surveys and high resolution seismic site surveys on the UKCS. Additional requirements may also apply within licence conditions.
4. Application for Consent must be made using the PON14A. If the survey involves several survey techniques, a single PON14A should be submitted.
5. Relevant Considerations will be included within the Offshore Environmental Statement
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S05.3 Combined Operations Notification
SI 2005/3117 Offshore Installations (Safety Case) Regulations 2005 (SCR05)
Operation of mobile drilling rig alongside existing fixed installation
Acorn
Health & Safety Executive (HSE)
1. Required for use of mobile drilling rig during workovers ops and drilling.
2. Required at least 21 days prior to combined operation.
S06.1
Chemical Permit (PON15B Approval)
Offshore Chemicals Regulations 2002 (SI2002/1355)
Chemical use / discharge when drilling for new or sidetracked wells, including exploration, appraisal, injection and monitoring wells
Drilling new wells
OGA 1. Submission of PON 15B.
2. WONS notification (PON 4 - Consent to drill) also required prior to drilling.
S06.2 OPPC Permit
Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (SI2005.2055), as amended
Discharge or reinjection of any aqueous well work-over, intervention and service fluids contaminated with reservoir hydrocarbons when drilling new or sidetracked wells, including exploration, appraisal, injection and monitoring wells
Drilling new wells
OGA 1. Submission of OPPC Permit Application. 2. WONS notification (PON 4 - Consent to drill) also required prior to drilling.
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S06.3 PON15B Approval
Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360) (and Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001, (SI 2001/1754))
Drilling new or sidetracked wells, including exploration, appraisal, injection and monitoring wells
Drilling new wells
OGA
1. Linked to Environmental Statement for overall project. Even if the wells were included in an approved Environmental Statement, a PON15B will still be required in support of each of the well consents. 2. Uncertain if drilling for CO2 injection / monitoring several years into the project will trigger requirement for full Environmental Statement. 3. WONS notification (PON 4 - Consent to drill) also required prior to drilling. 4. PON15B also used for chemical permit application. 5. Conservation of Habitats Regulations require that an environmental assessment identify any habitats or species covered by the Conservation (Natural Habitats &c) Regulations 1994, determine the likely impacts on them and where an adverse impact on a site integrity are likely, propose mitigation and propose an appropriate system to manage the mitigation measures and other commitments identified to remove of reduce the potential impacts. These findings should be documented in the Environmental Statement as well as providing sufficient information to inform any Appropriate Assessment which may be undertaken by BEIS.
Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement. process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS. The PON 15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted then it must be explicitly requested as part of the PON 15 submission.
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S07.1 Carbon Storage licence
Storage of Carbon Dioxide (Licensing etc) (Scotland) Regulations 2011
Appraisal of the store. Drilling and test injection of CO2
Intrusive exploration and test injection activities
OGA
1. Further to the obligations of the EU CCS Directive the UK Government made provisions in the 2008 Energy Act for a regulatory regime for carbon dioxide storage in the UK offshore area. The Act also provides for certain relevant existing offshore oil and gas legislation to be applied to facilities used for carbon storage.
2. Intrusive exploration, including test injection, may be undertaken during the agreed appraisal phase of a carbon storage licence. This licence will allow deep drilling and test injection of carbon dioxide in addition to the activities permissible under a general Exploration Licence (above).
3. The potential award of a carbon storage licence will require prior assessment under the Habitats Regulations as is the case for Petroleum Production Licences. Drilling and test injection would also need to be assessed and approved under the Habitats Regulations and the Offshore Petroleum Production and Pipe-lines (Assessment of Environmental Effects) Regulations 1999 “the EIA Regulations” (as extended to include carbon storage) as is also the case for petroleum drilling.
4. Where the licensee intends intrusive exploration, the licence will specify a work programme to be undertaken within the appraisal term defined by the licence. The work programme will be agreed with the developer at the time of the award of the licence and will be detailed in a Schedule appended to the Licence. This phase of the licence corresponds to the “exploration permit” within the meaning of the Directive and will be issued for a limited time period to prevent unnecessary blocking of territory for potential developments.
5. Subject to the outcome of an ongoing consultation BEIS propose that the duration of the appraisal period of the carbon storage licence could have a benchmark period of four years where a depleted petroleum reservoir is in question.
6. In addition the Operator will also need to enter into an agreement with The Crown Estate (Scotland) to secure a corresponding 'Agreement for Lease'. It is the intention of The Crown Estate (Scotland) and BEIS that the lease will not be issued until the terms of the licence are agreed, and that the licence will not be issued until the terms of the lease are agreed.
S07.2 PON15D Approval
Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360)
Injection of CO2 OGA
1. Linked to Environmental Statement for overall Project. Even if the facilities development/ operations were included in an approved Environmental Statement, a PON15D may still be required.
2. BEIS currently advise 6 months maximum approval process for oil and gas Environmental Statement.
3. Issues of timing related to CO2 Storage Licence to be resolved.
Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS. The PON 15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted then it must be explicitly requested as part of the PON 15 submission. Relevant considerations will be included within the Offshore Environmental Statement
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S07.3
Chemical Permit (PON15D Approval)
Offshore Chemicals Regulations 2002 (SI2002/1355)
Use or discharge of chemical offshore
OGA
1. Permit currently required for use and discharge of production chemicals offshore.
2. Anticipated to be required for use of MEG offshore as a pressure control fluid. Requirements needs clarifying as proposal is for MEG use in a closed system.
S07.4 PON 6 Metering 'non-objection'
Petroleum Act 1987 and in the Petroleum (Production) Regulations 1988, as amended
Determination that our proposed metering is adequate
CO2 injection
OGA
1. Depends on terms of CO2 Storage Licence
2. Model Clauses of the Schedules in the Petroleum Act 1987 and in the Petroleum (Production)
Regulations 1988 currently set requirements on metering oil and gas production. The PON6 sets out the procedure to be followed by Licensees in order that their proposals for a 'Method of Measurement' may be reviewed by BEIS.
S08.1
Carbon Storage Permit (new legislation)
Storage of Carbon Dioxide (Licensing etc) (Scotland) Regulations 2011
Store Carbon Dioxide
Licensed area, surface facilities and CCS operations
OGA
1. A storage permit would convey permission to construct facilities, including any offshore installation which might be necessary and to conduct storage operations. It would also provide the necessary legal framework for obligations to ensure that the storage operations will secure permanent geological containment of the carbon dioxide, that the facilities are properly decommissioned after use, and that the behaviour of the stored material is adequately monitored during and after storage operations.
2. In accordance with the requirements of the Directive, the consultation document makes clear that obtaining a storage permit will be conditional upon BEIS approval of the following from the applicant:
• Storage Development Plan
• Environmental Impact Assessment
• Monitoring Plan
• Corrective Measures Plan
• Financial security
• Site closure / post-closure plan
In addition, BEIS will need to approve the proposed Operator and will need to be satisfied that the applicant(s) have secured a seabed lease from the Crown Estate.
3. The potential award of a consent for storage operations will need to assess under the EIA and Habitats Regulations and may require approval under other environmental regulations that will be applied to carbon storage. The procedure will be similar to that applied in the case of oil and gas Field Development Plans.
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S08.2
Environmental Statement & PON16 Approval
Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (SI 1999/360) (and Offshore Petroleum Activities (Conservation of Habitats) Regulations 2001 (SI 2001/1754)
Develop the project, as designed within the constraints of the EIA
Licensed area, seabed and surface facilities including pipeline
BEIS
1. Environmental Statement approval anticipated to be required prior to Storage Permit issue
2. BEIS currently advise 6 months maximum approval process for oil and gas Environmental Statement
3. Conservation of Habitats Regulations require that an environmental assessment identify any habitats or species covered by the Conservation (Natural Habitats &c) Regulations 1994, determine the likely impacts on them and where an adverse impact on a site integrity are likely, propose mitigation and propose an appropriate system to manage the mitigation measures and other commitments identified to remove of reduce the potential impacts. These findings should be documented in the Environmental Statement as well as providing sufficient information to inform any Appropriate Assessment which may be undertaken by BEIS.
Currently, if a preliminary environmental investigation indicates that the project or modification is unlikely to have a significant adverse effect on the environment, and none of the mandatory conditions apply, then the operator may apply for a dispensation from the requirement to undertake the full Environmental Statement process (i.e. a Direction). The procedure for doing this is to complete a Petroleum Operations Notice 15 (PON15) and submit this to BEIS. The PON15 requires detail about the proposed project and the environmental sensitivities of the area. It may be useful to prepare a preliminary environmental assessment as background to the PON. If a Direction is wanted then it must be explicitly requested as part of the PON15 submission.
Relevant Considerations will be included within the Offshore Environmental Statement
S09.1 Marine Licence (new legislation)
Marine and Coastal Access Act 2009 & The Marine (Scotland) Act 2010
Locate drilling well or deposit substances in the sea or under the seabed (FEPA) Surface facilities (CPA)
Marine Scotland
The Marine Licensing regime came into force on 06 April 2011 and relates to all activities within Scottish Seas. The Licence subsumes all previous consenting requirements under the Food and Environmental Protection Act (FEPA) and Coastal Protection Act (CPA).
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S09.2
Environmental Impact Assessment Approval
Marine Works (EIA) Regulations 2007, as amended
Locate Drilling Well or Deposit of any articles or substances in the sea or under the seabed (FEPA) Surface facilities (CPA)
Marine Scotland
1. Considered unlikely to apply on assumption that EIA Rags (SI199/360) would apply to full scope of project.
2. Would only be required to support applications under the Marine & Coastal Access Act 2009 / Marine (Scotland) Act 2010, and Harbour Works 1999 involving deposits in the sea and works to ensure navigational safety if the activity is not sufficiently covered by other EIA legislation.
S10.1
Agreement for Lease for Carbon Storage
Energy Act 2008 / 1982 United Nations Convention on The Law of the Sea
Scotland Act 2016
Storage of carbon dioxide
Licensed three-dimensional subsurface volume, seabed and surface facilities
Crown Estate Scotland
1. The Energy Act 2008 provides for a regulatory regime for carbon dioxide (CO2) storage within the limit of the territorial sea and beyond into a newly designated Gas Importation and Storage Zone (GISZ). The exclusive right to store CO2 offshore has been vested in the Crown within an area extending from the seaward limits of the territorial sea to the boundaries of the GISZ. The Crown Estate already has the right to grant leases for any purpose within the area of the territorial sea.
2. Crown Estate Scotland was established following the Scotland Act 2016. The vesting provisions of the Energy Act allow Crown Estate Scotland to grant similar authorisations in respect of carbon storage activities beyond the territorial sea but within the area of the GISZ. The new licensing scheme will operate in parallel to the leases and authorisations granted by Crown Estate Scotland, by regulating those activities within both the territorial sea and the GISZ.
3. Crown Estate Scotland has confirmed its intention to lease specific sub-seabed formations defined by three-dimensional coordinates, together with related areas of the seabed and water column for the platform/subsea infrastructure (The position will therefore differ from traditional oil and gas licences which give exclusive rights for petroleum exploitation within an area defined by reference to a two-dimensional plan view).
4. The Agreement for Lease will cover intrusive drilling, test injection and other exploration activities covered by a concurrent Carbon Storage Licence.
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Reference Consent / License Title
Statutory Instrument
Consent to: Key
Project Elements
Determining Authority
Summary of Key Consent / License Aspects
S10.2 Lease for Carbon Storage
Energy Act 2008 / 1982 United Nations Convention on The Law of the Sea
Scotland Act 2016
Storage of carbon dioxide
Licensed three-dimensional subsurface volume, seabed and surface facilities
Crown Estate Scotland
1. The Energy Act 2008 provides for a regulatory regime for carbon dioxide (CO2) storage within the limit of the territorial sea and beyond into a newly designated Gas Importation and Storage Zone (GISZ). The exclusive right to store CO2 offshore has been vested in the Crown within an area extending from the seaward limits of the territorial sea to the boundaries of the GISZ. The Crown Estate already has the right to grant leases for any purpose within the area of the territorial sea.
2. Crown Estate Scotland was established following he Scotland Act 2016. The vesting provisions of the Act allow Crown Estate Scotland to grant similar authorisations in respect of carbon storage activities beyond the territorial sea but within the area of the GISZ. The new licensing scheme will operate in parallel to the leases and authorisations granted by Crown Estate Scotland, by regulating those activities within both the territorial sea and the GISZ.
2. Crown Estate Scotland has confirmed its intention to lease specific sub-seabed formations defined by three-dimensional coordinates, together with related areas of the seabed and water column for the platform/ subsea infrastructure (The position will therefore differ from traditional oil and gas licences which give exclusive rights for petroleum exploitation within an area defined by reference to a two-dimensional plan view).
3. Lease granted by Crown Estate Scotland will have defined geographical boundaries. As a condition of the lease, the developer will be required to apply to OGA for a licence for storage which will provide the framework for regulatory consent for the physical activities at the site, for example drilling and facilities construction.
4. The Lease will cover construction activities, carbon injection and storage operations, and the post closure monitoring phase of a project. The lease, and responsibility for long-term liabilities, will return to Crown Estate Scotland only when the project developer has satisfied the conditions for handover.
S11.1 Pipeline Crossing Agreements
General Property Law
Atlantic export pipeline
Crown Estate Scotland
1. Confirmation required that existing agreements will remain in place.
2. Any specific new requirements for the CO2 storage project will be progressed in parallel with negotiations for the CO2 storage lease for the Acorn site.
S11.2
Crown Estate seabed lease for pipeline section in Scottish Territorial waters
General Property Law
Offshore CO2 pipeline within Scottish Territorial Waters
Crown Estate Scotland
Co-ordinate with lease for storage.
Table 11-2: Offshore Consents Register
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12.0 Consultation
Introduction
A key component of the EIA process is communication and stakeholder
consultation. Legislation such as the Public Participation Directive prioritises this
even further. Pale Blue Dot Energy recognises the benefits of stakeholder
consultation to ensure that all relevant concerns and opinions regarding a
particular project are integrated into the project decision making process and
are adequately addressed in the EIA process.
Previous and On-going Consultation
An initial consultation meeting was held with BEIS early in the project concept
phase. The objective of this meeting was to make BEIS aware of Pale Blue Dot
Energy’s plans regarding the Acorn Project, to solicit feedback on any future
changes/additions to legislation which may affect the development, and to
discuss the consenting process for the project.
The next phase of consultation provides stakeholders with an opportunity to
enter a discussion about the proposed project so that any issues and concerns
can be identified and clarified at an early stage. This scoping report provides a
basis for this dialogue. Consultation will not be limited to the scoping phase of
the project but will be ongoing as part of the EIA process. In this way, issues are
‘worked through’ to ensure that there are no ‘surprises’ on submission of the
Environmental Statement. This ongoing consultation will take the form of
meetings as needed with relevant organisations or individuals on key issues. In
addition, a close-out meeting will be held in Aberdeen to present feedback on
the consultation and EIA process prior to submission of the Environmental
Statement to the Oil & Gas Authority.
Pale Blue Dot Energy has established a web link to key documents to facilitate
the consultation process (www.pale-blu.com/acorn). This outline report will be
made available via the project website, www.actacorn.eu.
A database will be maintained to document all responses received from
consultees and track the project’s responses. A summary of the consultee and
project responses will be included as part of the Environmental Statement.
Summary of Consultees
The following provides a list of consultees for the Acorn Project EIA:
• Aberdeenshire Council
• Council Archaeologist
• Crown Estate Scotland
• Department of Business Energy and Industrial Strategy (BEIS)
• Grampian Fire Brigade
• Health & Safety Executive (HSE)
• Historic Scotland
• Marine Scotland
• Natural Heritage Team, Planning
• North of Scotland Water Authority (NOSWA)
• Oil & Gas Authority (OGA)
• RSPB Scotland
• St Fergus Coastal Environmental Committee
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• St Fergus Community Council
• Scottish Environmental Protection Agency (SEPA)
• Scottish Executive Development Department (SEDD) Roads
Network Management and Maintenance Division (RNMMD)
• SEDD Planning Division
• Scottish Natural Heritage (SNH)
• Scottish Wildlife Trust
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13.0 Contents of the Environmental Statement
As outlined in Section 4, it is assumed that a full EIA and associated
Environmental Statement will need to be completed during FEED. Two separate
Environmental Statements will be required:
1. Onshore: All onshore and intertidal works to the Mean Low Water Spring
(MLWS) are covered under a submission as set out under the Town and
Country Planning (Environmental Impact Assessment) (Scotland)
Regulations 2011.
2. Offshore: All offshore activities associated with the CCS project as set out
in the Offshore Petroleum Production and Pipelines (Assessment of
Environmental Effects) (Amendment) Regulations 1999 (as amended 2007
and 2010).
In preparation the contents of the more comprehensive Offshore Environmental
Statement have been outlined below based on the Environmental Statement
completed by Shell for the Peterhead CCS Project, (Shell, 2016).
NON-TECHNICAL SUMMARY
ACRONYMS
GLOSSARY
1. INTRODUCTION
1.1. Environmental Impact Assessment: Requirements and Purpose
1.2. Scope of the Environmental Statement
1.3. Legislative Overview
1.4. Environmental Management System
1.5. Contractor Interface
1.6. Acorn CCS Project HSSE Plan and Environmental Commitments
1.7. Environmentally Critical Elements
1.8. Areas of Uncertainty
1.9. Consultation Process
2. PROJECT DESCRIPTION
2.1. Carbon Capture and Storage Proposal
2.2. Project Background
2.3. Development Options
2.4. Onshore Project Scope
2.5. Pipeline Project Scope
2.6. Existing Infrastructure
2.7. Offshore Project Scope
2.8. CO2 Storage at the Acorn CO2 Storage Site
2.9. Environmental Performance
2.10. Key Permits and Consents
2.11. Decommissioning
3. BASELINE ENVIRONMENT
3.1. Surveys
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3.2. Metocean Conditions
3.3. Climate
3.4. The Seabed
3.5. Habitats and Species of Conservation Concern
3.6. Marine Flora and Fauna
3.7. Socio-Economic Environment
3.8. Overview
4. ENVIRONMENTAL ASSESSMENT METHODOLOGY
4.1. Impact Assessment Approach
4.2. Assessment of Potential Impacts and Control Measures
5. USAGE OF SPACE
5.1. Physical Presence
5.2. Seabed Disturbance
6. GASEOUS EMISSIONS
6.1. Pipeline Installation Phase
6.2. Well Completion, Subsea Installation & Umbilical Replacement
6.3. Injection and Storage
6.4. Total Emissions
6.5. Mitigation Measures, Safeguards and Controls
7. DISCHARGES TO SEA
7.1. Pipeline Installation Phase
7.2. Works at the Acorn CO2 storage site
8. UNDERWATER NOISE
8.1. Introduction
8.2. Impact Assessment Method
8.3. Potential Impact of Underwater Sound associated with the development
8.4. Modelling Results
8.5. Noise Impact Assessment
8.6. Mitigation Measures, Safeguards and Controls
9. WASTE GENERATION
9.1. Waste from Vessels
9.2. Pipeline Installation
9.3. Subsea Installation & Umbilical Phase
9.4. Well Completion Phase
9.5. Injection Phase
9.6. General Waste
9.7. Special Waste
9.8. Mitigation Measures, Safeguards and Controls
10. ACCIDENTAL HYDROCARBON RELEASES
10.1. Overview of Potential Hydrocarbon Releases
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10.2. Oil Spill Regulations and Risk on the UKCS
10.3. Hydrocarbon Release Modelling
10.4. Modelling Results
10.5. Impact Assessment
10.6. Mitigation Measures, Safeguards and Controls
11. ACCIDENTAL CO2 RELEASE
11.1. Impacts Associated with CO2 Release
11.2. Sources of CO2 Release
11.3. Injection Strategy
11.4. Monitoring
11.5. Corrective Measures
12. CONCLUSIONS
12.1. Environmental Impacts
12.2. Cumulative Impacts
12.3. Transboundary Impacts
12.4. Socio-Economic Impacts
12.5. Commitments
12.6. Overall Conclusions
13. REFERENCES
APPENDIX A - REGISTER OF ENVIRONMENTAL LEGISLATION
APPENDIX B - ENVIRONMENTAL IMPACT ASSESSMENT
A.1. Subsea Activities - Planned Activities; A.2 Subsea Activities - Unplanned
Events; A.3 Offshore Activities - Planned Activities; A.4 Offshore Activities -
Unplanned Events; A.5 Onshore Activities - Planned Activities; A.6 Onshore
Activities - Unplanned Events
APPENDIX C - SEDIMENT MODELLING
C.1. Pipeline Installation; C.2. Methodology; C.3. Modelling Results; C.4.
Environmental Impacts; C.5. Conclusions
APPENDIX D - UNDERWATER NOISE ASSESSMENT
D.1. Introduction; D.2. Sound Sources Associated with the Project; D.3. Impact
Assessment Method; D.4. Underwater Sound Modelling; D.5. Species
Sensitivities; D.6. Modelling Results; D.7. Mitigation Measures, Safeguards and
Controls; D.8. Impact Assessment; D.9. Conclusions
APPENDIX E - OIL SPILL MODELLING
E.1. Introduction; E.2. Oil Spill Regulations and Risk on the UKCS; E.3. Spill
Risks; E.4. Modelling Results; E.5. Environmental Sensitivities; E.6. Response
Measures; E.7. Conclusion
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14.0 Conclusions and Next Steps
Conclusions
1. With respect to an Environmental Impact Assessment (EIA), Pale Blue Dot
view the Acorn Project as a Schedule 2 project which may require an EIA.
2. Aberdeenshire Council’s provisional view is that, irrespective of being
Schedule 1 or 2, the Acorn Project will need to complete an Environmental
Impact Assessment (EIA) and subsequent Environmental Statements which
separately cover onshore and offshore requirements.
3. A definitive view will be provided by Aberdeenshire Council upon submission
of an Environmental Scoping Report.
4. An Environmental Scoping Report would need to be submitted for review
and approval by Aberdeenshire Council between mid-2019 and mid-2020.
If confirmed as required, an EIA would then be completed in 2020/21 as part
of FEED.
5. The regulations, permits and consents influencing the EIA are well
understood as detailed within the report. The contents and structure of two
Environmental Statements are also well understood.
6. The current assessment of both the onshore environmental impact and
offshore environmental impact indicates minimal impact beyond current
activities.
7. The re-use of the Atlantic pipeline for the transportation of CO2 will result in
a lower environmental impact versus the need to install a new pipeline.
8. Beyond the main pipeline, the opportunity to re-use infrastructure is likely to
be minimal.
Next Steps
1. Submission of the Environmental Scoping Report to Aberdeenshire Council
confirm if Acorn is Schedule 1 or 2 and whether an EIA is required.
2. On the assumption that an EIA is required, the completion of an EIA and the
subsequent, linked but separate, Onshore Environmental Statement and
Offshore Environmental Statement.
D14 Outline Environmental Impact Assessment References
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15.0 References
Aberdeenshire Council. (2017). Aberdeenshire Council. Retrieved from Local
Development Plan 2017 Part 2:
https://www.aberdeenshire.gov.uk/media/20619/local-development-
plan-2017-part-2.pdf
BG Group. (2016). Atlantic & Cromarty Decommissioning Programme:
Environmental Impact Assessment.
Bresnan, E. H. (2009). Seasonal and interannual variation in the phytoplankton
community in the north east of Scotland. Journal of Sea Research, 61:
17-25.
Edwards, M. B. (2013). Impacts of Climate Change on Plankton. Marine Climate
Change Impacts Partnership: Science Review, 97-112.
ERM. (2007). DF1 Project: St Fergus CO2 Compressor Plant Planning
Application Supporting Statement.
Fugro. (2015). Atlantic & Cromarty Fields Pre-Decommissioning Survey.
Genesis. (2002). Atlantic and Cromarty Environmental Statement. DECC
reference number: D/1530/2002.
JNCC. (2001a). SPA Description: Buchan Ness to Collieston Coast. Retrieved
from JNCC: http://jncc.defra.gov.uk/default.aspx?page=1922
JNCC. (2001b). SPA Description: Troup, Pennan and Lion's Heads. Retrieved
from JNCC: http://jncc.defra.gov.uk/page-1921
JNCC. (2014). Turbot Bank MPA Site Summary Document. JNCC. Retrieved
from JNCC: http://jncc.defra.gov.uk/page-6490
JNCC. (2017, October 04). Turbot Bank MPA. Retrieved from JNCC:
http://jncc.defra.gov.uk/page-6490
North Sea Task Force (NSTF). (1993). North Sea Subregion 2b Assessment
Report. Quality Status of the North Sea. NSTF.
NSMP. (2017). 7th December 2017 Site Visit by Pale Blue Dot Energy.
Pale Blue Dot Energy. (2018). D03 ACT Acorn Basis of Design for St Fergus.
ACT Acorn Consortium.
Pale Blue Dot Energy. (2018). D14 ACT Acorn Outline Environmental Impact
Assessment. ACT Acorn Consortium.
Pefrofac Engineering Limited. (2012). Caledonia Clean Energy Project
Conceptual Study Report (Internal report for CO2DeepStore).
Reid, J. E. (2003). Atlas of Cetacean Distribution in North West European
Waters. Peterborough: JNCC.
Ritchie, W., Kingham, L., & Livingston, J. (2013). A Glossary of Coastal
Environmental Features at the Pipeline Landfalls at St. Fergus.
University of Aberdeen.
Scottish MPA Project. (2013). Data Confidence Assessment: Southern Trench
MPA Proposal.
Shell. (2016). Peterhead CCS Offshore Environmental Statement. Shell UK
Limited and Genesis Oil and Gas Consultants Ltd.
D14 Outline Environmental Impact Assessment References
ACT Acorn Consortium Page 66 of 68
Sparling, C. R. (2012). Baseline Seal Information for the FTOWDG Area. SMRU-
FDG-2012-0.
Stone, C., Webb, A., Barton, C., Ratcliffe, N., Reed, T., Tasker, M., . . .
Pienkowski, M. (1995). An atlas of seabird distribution in north-west
European waters. ISBN 1 873701 94 2.
Thompson, D. D. (2010). Berwickshore and Northumberland Coast European
Marine Site: Grey Seal Population Status. Natural England 20100902-
RFQ.
Total. (2009). Retrieved from Offshore Europe: https://www.offshore-
europe.co.uk/__novadocuments/29214
UK Government. (2018). Oil and Gas Decommissioning of Offshore Installations
and Pipelines. Retrieved from www.gov.uk:
https://www.gov.uk/guidance/oil-and-gas-decommissioning-of-
offshore-installations-and-pipelines
UK Government. (n.d.). EIA Thresholds.
D14 Outline Environmental Impact Assessment Annex 1: Consent Register
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16.0 Annex 1: Consent Register
Aspect Requirement Determining body Comment
Planning
Permission
Planning permission for capture plant under the
Town and Country Planning Act (TCPA) 1990. Aberdeenshire Council (AC).
Planning permission for the transmission pipeline
under the Pipeline Act 1962 and TCPA 1990. AC.
Due to the small scale of the pipeline ~1km and low environmental sensitivity we assume
that the pipeline would not be EIA development and could either be rolled up into the
application for the capture plant or be subject to its own planning application.
Based on the assumption that the proponent is not a public gas transporter and the
proponent can apply under the Gas Transporter Pipe-line Works (Environmental Impact
Assessment) (Amendment) Regulations 2007.
Environmental
Impact Assessment
(EIA)
Subject to the EIA screening opinion / direction
EIA for the capture plant under the Town and
Country Planning (Environmental Impact
Assessment) (Scotland) Regulations 2011.
AC. It may be possible to screen the capture plant out of the need for EIA particularly if the
existing SAGE facility is used. This will be confirmed during the next phase.
Environmental
Permit
Environmental Permit for the operation of the
capture plant under the Pollution Prevention and
Control (Scotland) Regulations 2012.
The Scottish Environment
Protection Agency (SEPA). Application to vary an existing permit or a new permit subject to agreement with SEPA.
Habitats
Regulations
Screening
Assessment
Habitats Regulations Assessment (HRA) the
Conservation (Natural Habitats, &c.) Regulations,
1994 and Habitats Regulations 2010.
The competent authority will vary
for planning and permitting. For
planning AC; for permitting SEPA.
The need for, and level of assessment will vary depending on potential (if any) pathways
for effects to occur on nature sites.
Water Abstraction
A water abstraction licence is subject to the Water
Environment (Controlled Activities) (Scotland)
Regulations 2011 more commonly known as the
Controlled Activity Regulations (CAR).
SEPA. On the assumption that there is not sufficient ‘headroom’ within the existing license it may
also be possible to use the existing terminal operator extraction licence.
Hazardous
Substance Consent
Consent for Hazardous Substances under the
Planning (Hazardous Substances) (Scotland)
Regulations 2015.
AC. Subject to the capture technology included within the project, e.g. amines.
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European Protected
Species
European protected species licence (i.e. for
badgers, bats, Great Crested Newts etc.) under
The Conservation of Habitats and Species
Regulations 2010 and Habitats Regulations 2010
Scottish Natural Heritage (SNH)
and if applicable Marine Scotland
May be required depending on which species, if any are present within and around the
project area and the effect of the projects upon those species present.
Building
Regulations
approval
Building Regulations Approval under Building
(Scotland) Regulations 2017 (as amended). AC. Detailed design to be completed before Building Regulations application(s) can be made.
EU ETS Permit
EU ETS Greenhouse Gas Emissions Trading
Permit under the Greenhouse Gas Emissions
Trading Scheme Regulations 2012.
The Greenhouse Gas Emissions
Trading Scheme Regulations 2012.
Installations covered by the Scheme are required to monitor and report their emissions.
At the end of each year they are required to surrender allowances to account for their
installation’s actual emissions. They may use all or part of their allocation and have the
flexibility to buy additional allowances or to sell any surplus allowances generated from
reducing their emissions below their allocation.
REACH Registration Evaluation, Authorisation and
restrictions of Chemical Regulations.
The Competent Authority is hosted
by the Health and Safety Executive
(HSE), working with SEPA and
other government departments.
Subject to the capture technology included within the project. There could be a
requirement to register as a downstream user of chemical, e.g. amines.
COMAH
Variation to COMAH Safety Report under the
Control of Major Accident Hazards Regulations
2015.
The HSE and SEPA are jointly the
Competent Authority (CA) for
COMAH in Scotland.
The CO2 stripping process uses chemicals such as amines that, depending upon the
characteristics and the volumes stored and used in process, may be a qualifying
substance under COMAH. The CA has published guidance on the storage of bulk
hazardous materials. If the amine to be used falls under the COMAH regulations, the
detailed design will need to incorporate specific consideration on secondary and tertiary
containment provisions
Pipeline operational
safety
SI 1996/825 The Pipeline Safety Regulations 1996
(PSR) – Major Accident Emergency Plan and
notification prior to construction.
HSE.
PSR require a local authority to prepare emergency plans for pipelines which have the
potential to cause a major accident for pipelines conveying ‘dangerous fluids’, defined in
Schedule 2 of the Regulations. The Regulations also require a pipeline operator to
establish emergency procedures for such pipelines.
CDM The Construction (Design and Management)
Regulations 2015. HSE.
During the design and construction phase of a project there are key responsibilities for
safety management that lie with the Client, the appointed Construction Design and
Management Co-ordinator (CDMC), designers and the appointed principal contractor.
Provided that these responsibilities are implemented in line with regulation, all relevant
safety management considerations should be met.
Table 16-1: Consent Register