Dana Petroleum Western Isles FPSO DP 22-2-23 Draft For Consultation
Dana Petroleum Western Isles FPSO DP 22-2-23 Draft For Consultation
Decommissioning Programmes
March 2023
Consultation Draft
UK-WIS-DC-DCM-PLN-0003
1
Preface
This document sets out the Draft Decommissioning Programmes for the Western Isles Floating
Production Storage and Offloading Vessel (FPSO) and associated mooring systems, risers and
dynamic umbilicals. It has been submitted to the Offshore Petroleum Regulator for Environment
and Decommissioning (OPRED) which, in turn, triggers statutory and public consultation.
Stakeholders are invited to respond to the draft proposals during the 30-day consultation which
runs from 3 March to 3 April. Documentation referred to within this consultation draft can be
made available for inspection by arrangement.
After consideration of any responses and further discussions with OPRED, the document will
be updated and refined as required. Additional discussion with stakeholders may be needed
depending on the comments submitted. The ‘final’ version of the document will incorporate
details of comments from statutory and public consultees, indicating how these have been
addressed.
Readers should note that the Draft Decommissioning Programmes for the Western Isles
Subsea Infrastructure will form the basis of separate consultation in due course.
2
Document Control
Approvals
Reviewed by Keith Williams Keith Williams (Feb 23, 2023 16:16 GMT)
Revision Control
Distribution List
3
Contents
INST PL
1 EXECUTIVE SUMMARY 8
1.1 Combined Decommissioning Programmes 8 √ √
1.2 Requirement for Decommissioning Programmes 8 √ √
1.3 Introduction 9 √ √
1.4 Overview of Installation/Pipelines Being Decommissioned 10 √ √
1.5 Summary of Proposed Decommissioning Programmes 11 √ √
1.6 Field Location Including Field Layout and Adjacent Facilities 13 √ √
1.7 Industrial Implications 17 √ √
6 PROGRAMME MANAGEMENT 41
6.1 Project Management and Verification 41 √ √
6.2 Post-Decommissioning Debris Clearance and Verification 41 √ √
6.3 Schedule 41 √ √
6.4 Costs 42 √ √
6.5 Close Out 42 √ √
6.6 Post-Decommissioning Monitoring and Evaluation 42 √ √
7 SUPPORTING DOCUMENTS 43 √ √
4
Terms and Abbreviations
Abbreviation Explanation
AIS Automatic Identification Systems
CA Comparative Assessment
CNS Central North Sea
DFPV Drain, flush, purge and vent
DP Decommissioning Programme
EA Environmental Appraisal
ENE East North East
ENVID Environmental Impact Identification
ESDV Emergency Shutdown Valve
ESE East South East
FPSO Floating Production Storage and Offloading Vessel
HSE Health & Safety Executive
ICES International Council for the Exploration of the Sea
IHM Inventory of Hazardous Material
IMO International Maritime Organisation
INTOG Innovation and Targeted Oil and Gas Schemes
JNCC Joint Nature Conservation Committee
km kilometre
LSA Low Specific Activity
MAT Master Application Template
MEG Mono-Ethylene Glycol
MWA Midwater Arch
NDC North Drill Centre
NLB Northern Lighthouse Board
NNS Northern North Sea
NORM Naturally Occurring Radioactive Material
NRB North Riser Base
NSTA North Sea Transition Authority
OCR Offshore Chemical Regulations
OPRED Offshore Petroleum Regulator for Environment and Decommissioning
5
Abbreviation Explanation
OSPAR Convention for the Protection of the Marine Environment of the North-East
Atlantic (Oslo Paris Convention)
P&A Plug and Abandonment
PMF Priority Marine Feature
PWA Pipeline Work Authorisation
ROV Remotely Operated Vehicle
SAC Special Area of Conservation
SCAP Supply Chain Action Plan
SEPA Scottish Environment Protection Agency
SAT Supplementary Application Template
SDC South Drill Centre
SFF Scottish Fishermen’s Federation
SPA Special Protection Area
SRB South Riser Base
SSE South South East
Te Tonnes
TFSW Trans Frontier Shipment of Waste
THC Total Hydrocarbon Concentration
UKCS United Kingdom Continental Shelf
UKHO United Kingdom Hydrographic Office
6
Figures and Tables
Appendices
7
1. EXECUTIVE SUMMARY
1.1. Combined Decommissioning Programme
This document contains two decommissioning programmes (DPs) for each set of section 29 Notices
covering the floating production storage and offloading (FPSO) vessel including mooring lines and for the
disconnection and recovery of the associated flexible risers and dynamic umbilicals to enable FPSO
sailaway. The items included in the combined Western Isles DPs are:
These DPs include the full removal of the FPSO, flexible risers, dynamic umbilicals and the upper sections
of the mooring lines (top chain, buoyancy and polyester line) to and including the lower H-shackle,
excluding the bottom chain and anchors (please refer to Figure 1-2). The remaining field infrastructure,
which is listed on the Section 29 Notices, will be subject to a separate combined DP and will be submitted
separately to the Offshore Petroleum Regulator for Environment and Decommissioning (OPRED).
Preparatory activities for the midwater arch (MWA) removal are within the scope of this DP. These
preparatory activities, which will be carried out during the removal of the risers, are the sinking of the two
MWAs and their gravity bases (see configuration in Appendix 2) which will be temporarily wet stored and
removed later as part of the subsea decommissioning campaign. It is intended that the removal of the
items identified within this programme shall be performed in such a way as to not prejudice any further
decommissioning work in the field.
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1.2.2. Pipelines
In accordance with the Petroleum Act 1998, the Section 29 Notice Holders of the Western Isles pipelines
(see Table 1.4) are applying to OPRED to obtain approval for decommissioning the pipelines detailed in
Table 2- of this programme (see also Section 8 – Section 29 Notice Holder Letters of Support).
In conjunction with public, stakeholder and regulatory consultation, the DPs are submitted in compliance
with national and international regulations and OPRED guidelines. The schedule outlined in this document
is for a five-year project (from Define to post-decommissioning surveys), see Section 6.3 for more detail.
1.3. Introduction
The Western Isles FPSO produces from the Harris and Barra fields. The fields are located in the UKCS,
Block 210/24a situated 90km to the North East of Shetland and 12km west of the Tern platform (as the
crow flies) which is the nearest fixed facility. The water depth of field varies from approximately 150m to
165m.
The fields have been developed using a floating production, storage and offloading (FPSO) facility. Oil is
exported by shuttle tanker and excess produced gas is exported through a dedicated pipeline to the Tern-
North Cormorant gas pipeline. Later in the field life due to a reduction of produced gas, gas has been
continuously imported to balance the fuel gas deficit. The subsea facilities are tied back to the floating
production facility by two subsea pipeline bundles and flexible risers. Water injection is required to maintain
the reservoir pressure and gas lift is also required to assist production. Due to the nature of the reservoir,
the production and injection wells are clustered around two drill centres: the North Drill Centre (NDC) and
the South Drill Centre (SDC). Refer to Figure Figure 1-2 for schematic layout of the facilities.
The FPSO is not required to perform any further decommissioning related activities on the subsea
infrastructure after completion of the decommissioning activities detailed in section 1.1, and it is proposed
that the vessel is removed thereafter from its current location.
Following public, stakeholder and regulatory consultation, this combined DP is submitted without
derogation and in full compliance with OPRED guidelines.
It should be noted that an Environmental Appraisal (EA) shall support the combined DP for the remaining
subsea infrastructure following FPSO sailaway. Environmental impacts associated with the work in this
DP have been assessed and detailed in Section 4 of this document.
9
1.4. Overview of Installation/Pipelines Being Decommissioned
1.4.1. Installation
1
2385.2 Te is the total weight for the sections of the mooring lines being removed in this DP comprising the upper section of mooring lines (top chain,
buoyancy and polyester line) to and including the lower H-shackle; this is also shown in Figure 1-2.
10
1.4.2. Pipelines
Table 1-3 Pipelines Being Decommissioned
Number and total length (km) of Pipelines 11 pipelines with 5.809km total length
Full details given in Table 2.2 Note: this includes only the flexible risers and
dynamic umbilicals accounted for under the
total pipeline length stated
11
2. Mooring Lines
Full Removal – Mooring lines will be recovered for reuse and recycling, in Removes a potential
compliance with regulatory requirements - The upper sections of FPSO obstruction to fishing
mooring lines up to and including the lower H-shackle will be lowered to the operations and maximises
seabed and recovered during the FPSO sailaway campaign, the lower section reuse and recycling of
of the chain connecting to the anchor piles is out with the scope of this DP materials.
and will be recovered at a later date and is included within a separate DP.
Any applications and permits required for work associated with disconnection
and removal of the upper sections of the mooring lines will be submitted.
3. Risers & Umbilicals
Full Removal – The flexible risers and dynamic umbilicals will be disconnected Leaves clear seabed and
subsea and at the FPSO and recovered by vessel for transport ashore for water column and to
reuse, recycling or disposal. satisfy the regulatory
If recovery is not feasible at time of FPSO sailaway the risers and dynamic requirement.
umbilicals may be temporarily wet stored for recovery at a later date. In this
instance a guard vessel will remain on location after sailaway to mitigate
hazards for other users of the sea.
Investigations into potential reuse options are ongoing.
4. Interdependencies
There is no anticipated impact on third-party assets or pipelines.
This DP covers the FPSO sailaway and the disconnection and recovery of the upper section of its mooring
lines. This DP also covers the disconnection and recovery of the flexible risers and dynamic umbilicals.
Following riser recovery it is proposed that the MWAs will be sunk and temporarily wet stored in place
(adjacent to their respective gravity bases, see schematics at Appendix 2) awaiting recovery or fully
recovered intact as part of the subsea pipelines decommissioning campaign. The Western Isles subsea
infrastructure (including MWAs) shall not be decommissioned as part of the FPSO sailaway campaign and is
covered by a separate DP.
Once the FPSO vessel has been removed, the MWAs (previously falling under the protection of the FPSO
500m zone) and mooring piles (bottom chain and anchors) and other pipelines related infrastructure
(outside the FPSO 500m zone) will require appropriate safety measures to protect them to ensure they pose
no threat to other users of the sea prior to their decommissioning sometime in the future.
Given sailaway of the FPSO will occur prior to well P&A, well integrity testing will be conducted prior to
disconnection of the FPSO. Thereafter monitoring will be conducted through ROV inspections prior to the
commencement of the wells P&A operations.
It is acknowledged that navigational aids and/or a guard vessel will be required to mitigate hazards for other
users of the sea in instances where the 500m safety zone is no longer in place and/or potential navigational
hazards remain. Detailed removals plans have not yet been established, however Dana shall ensure that
Admiralty Charts and Notices to Mariners are updated, and engagement is maintained with the Health and
Safety Executive (HSE) and Northern Lighthouse Board (NLB) to ensure appropriate mitigation measures are
agreed and put in place.
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1.6. Field Location Including Field Layout and Adjacent Facilities
13
Figure 1-2 Field Layout – Red denotes equipment within this DP
14
Table 1-6 Adjacent Facilities
Owner Name Type Distance/ Information Status
Direction
TAQA Bratani Limited Tern Platform 12 km/ENE Third Party Asset Operational
TAQA Bratani Limited Cormorant A Platform 21.1 km/ESE Third Party Asset Operational
TAQA Bratani Limited Cormorant North Platform 21.4 km/ENE Third Party Asset Operational
TAQA Bratani Limited Eider A Platform 26.9 km/ENE Third Party Asset Operational
EnQuest Heather Heather A Platform 30.8 km/SSE Third Party Asset Operational
Fairfield Dunlin A Platform 45.7 km/ENE Third Party Asset Non-
operational
EnQuest Heather Thistle A Platform 47.2 km/ENE Third Party Asset Operational
CNR International Ninian Northern Platform 49.8 km/ESE Third Party Asset Non-
Operational
Impacts of Decommissioning Proposals
There is no direct impact on third party adjacent facilities as a result of the acitivies listed within this DP.
15
Figure 1-3 Adjacent Facilities
16
1.7. Industrial Implications
It is Dana’s intention to develop a contract strategy that will result in an efficient and cost-effective
execution of the decommissioning works. Details of decommissioning project opportunities will be
published to alert potential contractors to competitive tender opportunities, together with direct invitations
to relevant parties. Dana are already in discussion with the North Sea Transition Authority (NSTA)
regarding Supply Chain Action Plan (SCAP) requirements.
It may be appropriate to use existing framework agreements to enable FPSO sailaway. However, this will
be reviewed in the context of the wider Western Isles decommissioning project to achieve synergies with
the subsea activities. Collaborations with other operators will also be explored in order to reduce vessel
mobilisation costs.
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2. Description of Items to be Decommissioned
2.1. Installations: Surface Facilities – FPSO
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2.2. Pipelines Including Stabilisation Features
Table 2-2 Risers and Umbilicals to be Removed as Part of FPSO Sailaway
Description Pipeline Diameter Length Description of Product From – To Burial Status Pipeline Current Content
Number (inches) (km) Component Conveyed End Points Status
(as per PWA) Parts
Gas Import / PL3186 6 0.504 Flexible Gas Western Isles FPSO Initially surface Operational Import gas
Export Flexible ESDV to 6” Gas laid then in
Riser Import / Export suspension
Flexible Riser Flange over MWA to
FPSO
Production Flexible PL3729.1 8 0.501 Flexible Oil 8” Production Initially surface Operational Production fluid
Riser Flexible Riser Flange laid then in
to Western Isles suspension
FPSO ESDV over MWA to
FPSO
Production Flexible PL3729.2 8 0.502 Flexible Oil 8” Production Initially surface Operational Production fluid
Riser Flexible Riser Flange laid then in
to Western Isles suspension
FPSO ESDV over MWA to
FPSO
Water Injection PL3729.3 8 0.503 Flexible Water Western Isles FPSO Initially surface Operational Injection water
Flexible Riser ESDV to 8” Water laid then in
Injection Flexible suspension
Riser Flange over MWA to
FPSO
19
Table 2-2 Risers and Umbilicals to be Removed as Part of FPSO Sailaway
Description Pipeline Diameter Length Description of Product From – To Burial Status Pipeline Current Content
Number (inches) (km) Component Conveyed End Points Status
(as per PWA) Parts
Gas Lift Flexible PL3729.4 6 0.503 Flexible Gas Western Isles FPSO Initially surface Operational Lift gas
Riser ESDV to 6” Gas Lift laid then in
Flexible Riser suspension
over MWA to
FPSO
Dynamic Umbilical PLU3729.5 9 0.564 Dynamic Control Western Isles FPSO Initially surface Operational Pelagic (hydraulic
systems to NRB Trailing laid then in control
Towhead suspension fluid), Pelagic
over MWA to (hydraulic control
FPSO
fluid), Scale
inhibitor,
Corrosion
inhibitor, Wax
inhibitor, Biocide,
50:50 MEG/water,
Methanol, 50:50
MEG/water,
Electrical
Power/Signal
Cables
Production Flexible PL3730.1 8 0.530 Flexible Oil 8” Production Initially surface Operational Production fluid
Riser Flexible Riser Flange laid then in
to Western Isles suspension
FPSO ESDV over MWA to
FPSO
20
Table 2-2 Risers and Umbilicals to be Removed as Part of FPSO Sailaway
Description Pipeline Diameter Length Description of Product From – To Burial Status Pipeline Current Content
Number (inches) (km) Component Conveyed End Points Status
(as per PWA) Parts
Production Flexible PL3730.2 8 0.530 Flexible Oil 8” Production Initially surface Operational Production fluid
Riser Flexible Riser Flange laid then in
to Western Isles suspension
FPSO ESDV over MWA to
FPSO
Water Injection PL3730.3 8 0.530 Flexible Water Western Isles FPSO Initially surface Operational Injection water
Flexible Riser ESDV to 8” Water laid then in
Injection Flexible suspension
Riser Flange over MWA to
FPSO
Gas Lift Flexible PL3730.4 10 0.530 Flexible Gas Western Isles FPSO Initially surface Operational Lift gas
Riser ESDV to 6” Gas Lift laid then in
Flexible Riser suspension
over MWA to
FPSO
21
Table 2-2 Risers and Umbilicals to be Removed as Part of FPSO Sailaway
Description Pipeline Diameter Length Description of Product From – To Burial Status Pipeline Current Content
Number (inches) (km) Component Conveyed End Points Status
(as per PWA) Parts
Dynamic Umbilical PLU3730.5 9 0.612 Dynamic Control Western Isles FPSO Initially surface Operational Pelagic (hydraulic
systems to SRB Trailing laid then in control
Towhead suspension fluid), Pelagic
over MWA to (hydraulic control
FPSO
fluid), Scale
inhibitor,
Corrosion
inhibitor, Wax
inhibitor, Biocide,
50:50 MEG/wate,
Methanol, 50:50
MEG/water,
Electrical
Power/Signal
Cables
22
2.3. Inventory Estimates
The following diagrams indicate the percentage composition of the FPSO and associated subsea
infrastructure that will be decommissioned.
Figure 2-1 Pie Chart of Estimated Inventories (FPSO and Mooring System)
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3. REMOVAL AND DISPOSAL METHODS
Decommissioning of the Western Isles FPSO, flexible risers, dynamic umbilicals and mooring lines will
generate a quantity of waste. Dana is committed to establishing and maintaining environmentally
acceptable methods for managing wastes in line with the Waste Framework Directive and principles of the
waste hierarchy.
MOST PREFERRED
PREVENTION OPTION
REUSE
RECYCLING
OTHER
RECOVERY
DISPOSAL
LEAST PREFERRED
OPTION
In line with the waste hierarchy, Dana are investigating potential reuse options for the Western Isles FPSO,
flexible risers and dynamic umbilicals.
Where no reuse options exist, recovered infrastructure will be returned to shore and transferred to a
suitably licensed waste treatment facility. It is expected that the recovered infrastructure, i.e. risers and
umbilicals, will be cleaned before being reused / recycled. OPRED will be advised once a removal method
is defined and once a disposal yard is selected.
LL
An appropriately licensed disposal company and yard will be identified through a selection process that
will ensure that the chosen facility demonstrates a proven track record of waste stream management
throughout the deconstruction process, the ability to deliver innovative reuse / recycling options, and
ensure the aims of the waste hierarchy are achieved.
Geographic locations of potential disposal yard options may require the consideration of Trans Frontier
Shipment of Waste (TFSW), including hazardous materials. Early engagement with the regulatory
authorities will ensure that any issues with TFSW are addressed. Once an appropriately licensed waste
contractor has been selected OPRED and SEPA will be informed.
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3.1. Surface Facilities – FPSO
3.1.1. FPSO Decommissioning Overview
The Western Isles FPSO has a design life of 20 years when installed at the field and is capable of staying
on station for the full design life of the FPSO.
After completion of the operation of the Western Isles FPSO at its current site, the FPSO is to be reused,
subject to evaluation of reuse options. If a reuse option is not identified the FPSO shall be
recycled/disposed of at appropriate facilities; should this happen OPRED will be advised on the fate of the
vessel.
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3.1.3. Preparation/Cleaning
The Western Isles FPSO hull is compartmentalised into ballast tanks, cargo tanks, clean and dirty slops tanks
and various other utility systems including open drains, diesel and potable water.
Prior to FPSO mooring disconnection all hydrocarbon bearing tanks will be pumped out, flushed, purged
and vented as far as reasonably practicable.
It is expected that on completion of the drain, flush, purge and vent (DFPV) process and fluid reinjection
there will be a small volume of residual fluids left in the slops tanks. This will mainly consist of residual
flushing fluids (primarily seawater), and rainwater run-off from the open drains systems.
All other in deck tanks shall be DFPV as far as practicable including hazardous and non-hazardous open
drains that will likely hold residual run off and rain water.
The methods that will be used to vent and purge the FPSO prior to removal to shore are summarised in
Table 3.1.
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3.1.4. Removal Methods
Table 3-2 FPSO Removal Methods
Method Description
Reverse Install/Sailaway Pigging and flushing operations shall occur from the Western Isles FPSO in
order to ensure, where possible, that all pipelines have been
depressurised, cleaned, flushed and isolated prior to FPSO departure.
Mooring line lower section (bottom chain section) shall be cut below the
H-shackle, leaving anchors in place (the anchors discussed in the Western
Isles subsea infrastructure decommissioning programmes, which is subject
to comparative assessment). The flexible risers and dynamic umbilicals
shall be disconnected subsea and at the FPSO and recovered for transport
to shore. If recovery is not feasible at time of FPSO sailaway the risers and
dynamic umbilicals may be temporarily wet stored for recovery at a later
date. In this instance a guard vessel will remain on location after sailaway
to mitigate hazards for other users of the sea.
The FPSO will be towed to port for cleaning and, or refurbishment before
being reused, or towed to an alternative location at a licensed facility to
be decommissioned.
Reuse opportunities are actively being reviewed and are ongoing. OPRED
will be advised when any decisions regarding reuse are made.
27
3.2. Mooring Lines
The mooring system consists of 12 mooring lines (3 groups of 4 lines). The horizontal projection of the
mooring lines is presented in the figure below.
28
Figure 3-4 Mooring Line Arrangement
29
3.4. Waste Streams
Table 3-4 Waste Stream Management Methods
Waste Stream Removal and Disposal method
Bulk liquids On-board hydrocarbons will be offloaded by shuttle tanker. Remaining
hydrocarbons and wash fluids will be injected into a donor well. Should
this approach be unsuccessful, on-board hydrocarbons will be
transported ashore for reuse/disposal. Further cleaning and
decontamination will take place onshore prior to reuse.
Marine growth Marine growth on the FPSO and risers/dynamic umbilicals is expected to
dry out and detach during recovery/sailaway. As part of infrastructure
disposal or refurbishment operations remaining marine growth will be
removed and disposed of in accordance with the regulations. Annual ROV
inspection has shown no significant marine growth is present.
NORM/LSA Scale NORM may be partially removed offshore under appropriate permit.
Asbestos No asbestos is expected in or on the FPSO due to its recent construction.
Other hazardous wastes Will be recovered to shore and disposed of under appropriate permit.
Onshore Dismantling Appropriate licensed sites will be selected. Facility chosen by removal
sites contractor must demonstrate proven disposal track record and waste
stream management throughout the deconstruction process and
demonstrate their ability to deliver innovative recycling options.
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4. ENVIRONMENTAL APPRAISAL OVERVIEW
There will be some planned and unplanned environmental impacts arising from the sailaway of the
Western Isles FPSO. Dana has undertaken an ENVID in line with the Decommissioning Guidance Notes
regarding the activities described within this DP.
Long term environmental impacts from the decommissioning operations are expected to be low.
Incremental cumulative impacts and trans-boundary effects associated with the planned decommissioning
operations are also expected to be low.
Dana understands the importance of minimising the potential for environmental impact during
decommissioning, in parallel with safety and technical feasibility requirements. To this end, environmental
impacts will be fully considered in the design of arrangements for the disconnection and sailaway of the
FPSO. Where necessary, additional measures will be developed in order to limit the extent of any potential
impact.
All operations described in this DP will be subject to all the relevant environmental permits and approvals.
All permit applications and reporting will be managed through a Permits, Licences, Authorisations,
Notifications and Consents (PLANC) register.
The ENVID did not identify any activities required to undertake the removal of the Western Isles FPSO
that would be considered to have a significant environmental Impact. As a result a standalone EA has not
been considered necessary to support these decommissioning activities.
31
Table 4-1 Environmental Sensitivities
Environmental Main Features
Receptor
Seabed Site specific seabed data indicated that the sediments around the FPSO
and drill centres were poorly sorted silty shelly gravelly sands (medium
sands according to the Wentworth classification) (Gardline, 2010a, 2012).
The sediment particle size was generally smaller along the pipeline route
from the FPSO to Tern pipeline. The sediments were considered fine sand
under the Wentworth classification (Gardline, 2010a, 2010b).
The sediments near the Western Isles FPSO were typical of those at this
latitude and water depth in the North Sea (Gardline, 2010a, 2010b).
Sediment organic content and hydrocarbon concentrations were mostly
consistent with background levels for the Northern North Sea (NNS) and
were comparable between surveys (Gardline, 2010a, 2010b, 2012), with
the exception of two stations in 2012 which exhibited comparatively
elevated Total Hydrocarbon Concentration (THC) levels (Gardline, 2012).
As with offshore sediments in the North Sea, the Polychaetes was the
dominant infaunal species group across both surveys (Gardline, 2010a,
2012). Infaunal species composition was largely consistent between
surveys (Gardline, 2010a, 2012). In keeping with sediments at this latitude,
there were minor variations in densities between surveys at some
locations; however, the indices of diversity and evenness were broadly
similar. Whilst these metrics indicated a clean and undisturbed seabed at
most locations, there was evidence of organic enrichment through slightly
elevated THC concentration and reduced faunal densities at one location,
however the cause of this is not known (Gardline, 2012).
Fish The fields are located in an area of high nursery intensity for blue whiting
Micromesistius poutassou. Anglerfish (Monkfish) Lophius piscatorius,
European hake Merluccius merluccius, haddock Melanogrammus
aeglefinus, herring Clupea harengus, ling Molva molva, mackerel Scomber
scombrus, Norway pout Trisopterus esmarkii, spurdog Squalus acanthias
and whiting Merlangius merlangus all use the area as nursery grounds
(Coull et al., 1998; Ellis et al., 2012).
Haddock, Norway pout, saithe Pollachius virens and whiting use the area as
grounds for spawning, with spawning efforts for these species being
concentrated in the first half of the year (between January and June).
Of the species which are known to occur in the area in some capacity, a
number are species of conservation concern. Anglerfish (Monkfish), blue
whiting, herring, ling, mackerel, Norway pout, saithe and whiting are all
Scottish Priority Marine Features (PMFs). Additionally, spurdog is an
OSPAR listed Threatened and/or Declining Species.
32
Table 4-1 Environmental Sensitivities
Environmental Main Features
Receptor
Fisheries The Western Isles FPSO sits within ICES rectangle 51F0. According to
Scottish Government (2021) landings data for 2020, Rectangle 51F0 is
targeted primarily for demersal species. In 2020, demersal catch live
weight was 1,195 Te with a corresponding value of £1,190,217. This
accounts for approximately 99% of landings and approximately 99% of
value for that year.
To put landings into context, a total of 518,381 tonnes with a value of
£644,655,638 was landed in the UK in 2020 (Scottish Government, 2021).
Fisheries in Rectangle 51F0 contribute approximately 0.23% of landings
and 0.31% of value when compared to overall UKCS values (Scottish
Government, 2021).
Overall, fishing effort is relatively low, although there is a recent trend
showing increased effort; 2020 saw 303 fishing days compared to 2016
which experienced 121 days. This is due to the recent spread in fishing
effort throughout the year (in 2019 and 2020). In the past, effort was
mostly concentrated in the summer months and in November and
December. As of 2020, fishing took place in all months, with the exception
of December. However, overall fishing effort remains relatively low as
there are <100 days of fishing in each month Scottish Government (2021).
33
Table 4-1 Environmental Sensitivities
Environmental Main Features
Receptor
Marine Mammals Harbour porpoise Phocoena phocoena are frequently found throughout UK
waters. They typically occur in groups of one to three individuals in shallow
waters, although they have been sighted in larger groups and in deep
waters. They are present in UK waters throughout the year and are most
likely to be observed in the Western Isles fields in the summer months
(Reid et al., 2003). The density of harbour porpoise in the project area is
estimated to be 0.402 animals/km2 (Hammond et al., 2021). Harbour
porpoise is an Annex II listed species and European Protected Species
(EPS).
Minke whales Balaenoptera acutorostrata occur in water depths of 200 m
or less throughout the NNS and Central North Sea (CNS). They are usually
sighted in pairs or in solitude; however, groups of up to 15 individuals can
be sighted feeding. It appears that animals return to the same seasonal
feeding grounds (Reid et al., 2003). Minke whales are most likely to be
observed in the project area in the summer months and in low numbers.
Their density is predicted to be 0.0316 animals/km2 which is the highest
across all areas surveyed (Hammond et al., 2021). Minke whale are also
listed as a UK BAP species.
No other cetacean species are likely to be present in the project area.
Two species of seal are resident in UK waters: the grey seal Halichoerus
grypus and the harbour or common seal Phoca vitulina, both occurring
regularly over large parts of the North Sea. The estimated grey seal-at-sea
density within the Western Isles area is thought to be 0.009 individuals per
25 km2 (Russell et al., 2017). The percentage of the grey seal population in
the Western Isles area at any given time is ≤0.001% (Carter and Russell,
2020). The estimated harbour seal-at-sea density in the area is thought to
be 0.005 individuals per km2 (Russell et al., 2017). The percentage of the
harbour seal population in the Western Isles area at any given time is
≤0.001% (Carter and Russell, 2020).
Birds The area surrounding the Western Isles fields is utilised by the following
species at various times of the year: European storm petrel Hydrobates
pelagicus, long tailed skua Stercorarius longicaudus, northern gannet
Morus bassanus, great skua Stercorarius skua, black-legged kittiwake Rissa
tridactyla, glaucous gull Larus hyperboreus, great black-backed gull Larus
marinus, herring gull Larus argentatus, common guillemot Uria aalge, little
auk Alle alle, razorbill Alca torda and Atlantic puffin Fratercula arctica
(Kober et al., 2010).
34
Table 4-1 Environmental Sensitivities
Environmental Main Features
Receptor
Other Users of the Sea Shipping activity within Blocks 210/24 and 210/25 is considered to be very
low and low respectively (Oil and Gas Authority, 2016).
There are no operational offshore wind farms (OWFs) in the vicinity of the
Western Isles fields. However, the project area is close to areas identified
under the Innovation and Targeted Oil and Gas (INTOG) scheme. The
INTOG areas represent areas within which projects targeting oil and gas
decarbonisation or which will generate >100 MW of energy will be
considered for approval (Marine Scotland, 2021). The Western Isles FPSO
lies approximately 27 km southwest of the NE-a and NE-b INTOG areas.
There are no other renewables developments, proposed or active, near
the project area.
There are no active or disused cables within 100 km of the Western Isles
field. The CANTAT-3 active telecom cable is located approximately 107 km
northeast of the Western Isles FPSO.
Blocks 210/24 and 210/25 are not considered blocks of concern to the
Ministry of Defence (Oil and Gas Authority, 2019).
There are few wrecks recorded in the vicinity of the Western Isles fields.
The (non-dangerous) closest wreck is 20 km due east of the Western Isles
FPSO. Closer to the project area lies an area of foul ground and an
unknown obstacle; both are 10 km from the FPSO and are located <1 km
from the associated pipeline (NMPi, 2022).
35
4.2. Potential Environmental Impacts and their Management
4.2.1. Environmental Impact Assessment Summary
Table 4-2 Environmental Impact Management
Activity Main Impacts Management
FPSO Sailaway Fuel use/atmospheric emissions • Minimal number of vessels deployed
• Use of low sulphur diesel
• Compliance with Dana’s Vessel Assurance process/procedure
• Project Energy and Emissions study
Hazard to navigation • UKHO standard communication channels including Kingfisher, Notice to Mariners and
radio navigation warnings
• Use of Automatic Identification Systems (AIS) and other standard navigational controls
• Agreed passage plan and tow procedure
• Compliance with Dana Stakeholder Engagement Management Plan
Disturbance of nesting seabird • Compliance with relevant guidance (e.g. “Undertaking of Seabird Survey Methods for
habitat Offshore Installations: Black-legged kittiwakes” (JNCC, 2021)
• No history of nesting seabirds on the installation
• Implementation of a Nesting Seabird Monitoring Plan
36
Table 4-2 Environmental Impact Management
Activity Main Impacts Management
Disconnection and Chemical/oil discharge to sea • Appropriate Risk Assessment through the MATs/SATs (OCR) System
recovery of dynamic • Flushing and cleaning of the subsea system ahead of execution phase
flexible risers and • Selection of flushing chemicals with lesser potential for environmental impact
dynamic umbilicals
Fuel use/atmospheric emissions • Minimal number of vessels deployed
• Use of low sulphur diesel
• Compliance with Dana’s Vessel Assurance process/procedure
• Project Energy and Emissions study
Seabed disturbance (Contingency • Controlled lowering and laydown of dynamic flexible risers and dynamic umbilicals to
laydown and wet store) minimise area of seabed impacted
• Potential impacts will be addressed in the Environmental Assessment Justification
submitted in support of the requisite Marine Licence application
Physical presence (Contingency • Stakeholder engagement – notably with Scottish Fishermen’s Federation (SFF) and NLB.
laydown and wet store) • Controlled lowering and laydown of dynamic flexible risers and dynamic umbilicals
within 500m zone
• Any infrastructure outside the 500m zone is already exposed to fishing and managed
accordingly
• ERRV/Guard Vessel will remain on station in period between FPSO sailaway and
recovery of the dynamic flexible risers and dynamic umbilicals
• Potential impacts will be addressed in the Environmental Assessment Justification
submitted in support of the requisite Marine Licence application
37
Table 4-2 Environmental Impact Management
Activity Main Impacts Management
Cutting and recovery Fuel use/atmospheric emissions • Minimal number of vessels deployed
of mooring lines • Use of low sulphur diesel
• Compliance with Dana’s Vessel Assurance process/procedure
• Project Energy and Emissions study
Seabed disturbance (laydown and • Controlled lowering and laydown of mooring lines to minimise area of seabed impacted
potential wet store) • Potential impacts will be addressed in the Environmental Assessment Justification
submitted in support of the requisite Marine Licence application
Onshore waste management • Investigate redeployment/reuse opportunities
• Use of appropriately authorised waste management contractor(s) and facilities
• Compliance with the Waste Hierarchy
• Compliance with project Waste Management Plan
Vessels Hazard to navigation • Safety zones (where/when applicable and being mindful that arrangements will change
at certain stages of the project)
• UKHO standard communication channels including Kingfisher, Notice to Mariners and
radio navigation warnings
• Use of Automatic Identification Systems (AIS) and other standard navigational controls
• Compliance with Dana Stakeholder Engagement Management Plan
Discharges to sea • Treatment and maceration of wastewater to IMO standards
• Bilge management procedures
• Good operating practices
• Vessel equipment maintained according to manufacturer’s recommendations
• Compliance with Dana’s Vessel Assurance process/procedure
Noise • Vessel noise is unlikely to be above ambient noise levels
• No use of explosives
38
Table 4-2 Environmental Impact Management
Activity Main Impacts Management
Vessel (continued) • Fuel use/atmospheric • Minimal number of vessels deployed
emissions • Use of low sulphur diesel
• Vessel equipment maintained according to manufacturers’ recommendations
• Compliance with Dana’s Vessel Assurance process/procedure
• Project Energy and Emissions study
Waste • Use of landfill • Detailed inventories (including IHM)
• Radioactive waste/NORM • Use of appropriately authorised waste management contractor(s) and facilities
• Compliance with the Waste Hierarchy
• Compliance with project Waste Management Plan
• Compliance with project Waste Management Targets
• SCAP
39
5. INTERESTED PARTY CONSULTATIONS
5.1. Consultations Summary
40
6. PROGRAMME MANAGEMENT
6.1. Project Management and Verification
A Project Management team will be appointed to manage suitable sub-contractors for the removal of the
Western Isles FPSO. Standard procedures for operational control and hazard identification and
management will be used. Where possible the work will be coordinated with other decommissioning
operations in the NNS. The Project Management team will monitor and track the process of consents and
the consultations required as part of this process. Any changes in the details of the offshore removal
programme will be discussed and agreed with OPRED.
It is acknowledged that navigational aids and/or a guard vessel will be required to mitigate collision hazards
for other users of the sea in instances where the 500m safety zone is no longer in place and/or potential
navigational hazards remain. Detailed removals plans have not yet been established, however Dana shall
ensure that Admiralty Charts and Notices to Mariners are updated, and engagement maintained with the
HSE and NLB to ensure appropriate mitigation measures are agreed and put in place.
Following completion of all decommissioning works in the Western Isles (Barra and Harris) Fields a post-
decommissioning site survey will be carried out around a 500m radius of installation sites and a 100m
corridor (50m either side) along each existing pipeline route to identify any debris. Any seabed debris
related to offshore oil and gas activities will be recovered for onshore disposal or recycling in line with
existing disposal methods. There is an assumption that non-intrusive methods will be used and trawling
will only be used after non-intrusive measures have been exhausted. Upon verification of a clear seabed
a statement of clearance to all relevant governmental departments and non-governmental organisations
will be issued. It is proposed the verification work for the scope of this DP be completed in conjunction with
the subsea DP.
6.3. Schedule
A proposed schedule for the decommissioning of Western Isles is provided in Figure 6.1. The
commencement of any execution activities is subject to commercial agreements and contracts. At this time
this schedule is based on earliest anticipated CoP, subject to further discussions.
41
6.4. Costs
The decommissioning programme costs will be provided directly to OPRED.
Subject to agreement with OPRED, findings from these surveys shall be included in a close out report
submitted to OPRED within one year of the completion of the Western Isles FPSO decommissioning
scope. The report will detail the outcomes of surveys as well as explain any major variances from the
programme. The debris clearance, verification of seabed clearance and the first post-decommissioning
environmental survey shall be performed after completion of the Western Isles subsea infrastructure
decommissioning scope.
Prior to FPSO removal, a risk-based assessment will be undertaken to determine suitable marking of the
subsea infrastructure around the FPSO location. It is acknowledged that navigational aids and/or a guard
vessel may be required to mitigate hazards for other users of the sea.
42
7. SUPPORTING DOCUMENTS
It has not been deemed necessary to prepare a comparative assessment or an environmental appraisal
in support of this combined DP. This approach has been agreed with OPRED.
43
Oil and Gas Oil and Gas Authority, 2019. Other Regulatory Issues 32nd Licensing Round information
Authority, 2019 and Resources. Available online at:
https://www.ogauthority.co.uk/media/5883/other-regulatory-issues-july-2019.pdf
OPRED (2018) Offshore Petroleum Regulator for Environment and Decommisioning, 2018. Offshore Oil
and Gas Decommissioning Guidance Notes. Available online at:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachme
nt_data/file/760560/Decom_Guidance_Notes_November_2018.pdf
Reid et al., 2003 Reid, J., Evans, P. & Northridge, S., 2003. An atlas of cetacean distribution on the
northwest European Continental Shelf, Joint Nature Conservation Committee:
Peterborough.
Russell et al., Russell, D. F., Jones, E. L., Morris, C. D. (2017). Updated Seal Usage Maps: The Estimated
2017 at-sea Distribution of Grey and Harbour Seals, Scottish Marine and Freshwater Science
Report Vol 8 No 25. Available online at: https://data.marine.gov.scot/dataset/updated-
seal-usage-maps-estimated-sea-distribution-grey-and-harbour-seals
Scottish Scottish Government, 2021. Scottish Sea Fisheries Statistics, 2020. Scottish Government.
Government, Available online at:
2021 https://data.marine.gov.scot/dataset/2020-provisional-scottish-sea-fisheries-statistics-
fishing-effort-and-quantity-and-value
44
8. Section 29 Notice Holder Letters of Support
[Section to be updated prior to final submission]
45
9. STATUTORY CONSULTEE CORRESPONDENCE
[Section to be updated prior to final submission]
46
APPENDIX 1 COPY OF PUBLIC NOTICE
[To be added prior to final submission]
47
APPENDIX 2 MIDWATER ARCHES AND GRAVITY BASES
48
Western Isles MWA Primary Gravity Base
49