Last night SNH’s response to the initial consultation, tonight, the Scottish Environment Protection Agency (SEPA). You can read their full response HERE.
SEPA looked at the “potential releases to the environment and their consequences” stating that SNH were the lead authority on designated sites and that SEPA will generally not comment on potential impacts on particular sites or protected species. This is quite normal – so don’t expect to hear about the impact on the Special Area Conservation or bottlenose dolphins.
Firstly they considered emissions to the atmosphere, stating:
“…….crude oil is variable in nature consisting of a variety of hydrocarbons and impurities with varying chemical and physical properties. Some crude oils contain hydrocarbons that are readily volatised into gaseous form. The release of Volatile Organic Carbons, (VOC’s) and Hydrogen Sulphide, (H2S), into atmosphere is undesirable in terms of climate change effects, risk of ignition and local air quality and should be minimised wherever possible. Fortunately the properties of crude oil transferred are normally well documented and understood. Therefore an informed decision can be made on whether a cargo is likely to present a VOC’s release risk. SEPA would recommend that only tankers with VOC recovery systems are used where there is a risk of VOC or H2S release from the cargo transfer.”
If you want to know a bit more about VOC’s in crude oil, have a look at this presentation prepared by Intertanko (an independent tanker owners association) HERE. If you don’t want to get into the technicalities, here’s what the first slide says:
- Non Methane Volatile Organic Compounds (NMVOC) evolve in differing proportions from Crude Oil cargoes and, subject to conditions, are released to the atmosphere during loading and carriage.
- VOC gases are harmful and a pollutant to the atmosphere and Maritime Environment. They also act a precursor gas to the formation of OZONE which is a recognised Greenhouse Gas.
So, both SEPA and a tanker owners association seem to agree that Volatile Organic Compounds are not a good idea. In fact, SEPA recommend only using tankers with VOC recovery systems where there is a risk of VOC release. All crude oil will release VOC – the amount will depend on the origin of the oil. VOC recovery on oil tankers is not common place – it would appear to be at a developmental stage on ships being more common at shoreside facilities such as Nigg Oil Terminal. Remember the CFPA application will only use VOC recovery “where available” – Nigg can do it for all transfers regardless of what the oil tankers have on board.
Maybe there is better news under oil spill planning?
Well – the first point of interest is:
“Open sea transfers would seem to present more risk and greater difficulty in containing any oil spillage.”
Just what us scaremongers have been saying all along. They then listed further concerns:
- There are doubts raised on whether a 1 tonne release of oil is a realistic scenario as tanker transfer pumps could not be switched off immediately but would require to be gradually slowed down for safety reasons. With quoted pump rates of 2 tonnes per second it is likely that more than a 1 tonne spill is probably.
- SEPA noted that modelling was conducted using high tide as a starting point. Whilst we understand the reasons given for this we also think these models would have the effect of keeping an oil spill out of the Cromarty Firth area, as the falling tide would push water out of the area. It would seem appropriate to have run some models based on an incoming tide when oil would be swept in. This would also be applicable to the modelling of ballast water discharges, as none of the models show oil spill or ballast entering the Cromarty Firth area.
- There are doubts cast on the suitability, quantity and availability of oil recovery equipment in this open sea environment. SEPA recommend that this is reviewed to ensure it is adequate for offshore conditions and fit for purpose for realistic oil spill scenarios.
- SEPA note that two oil storage facilities are identified at Sureclean and MSIS which could be called upon for the storage of oil contaminated wastes after a spill event. It is not clear however what capacities these facilities have and how this might compare with the quantity of oil contaminated material that might arise in the worst case spill.
- A large oil spill in the designated area may have potentially serious consequences for sensitive habitats, nationally important species and economic activities in the area that depend upon the water environment. The costs involved in mitigation, clean up, habitat recovery and compensation could be huge. A contingency plan for covering the cost of such an incident should be developed.
Some interesting points – 1 tonnes spill is not realistic, modelling of incoming tide should be carried out both for oil spill and ballast water discharge, oil spill equipment should be reviewed to make sure it is suitable, and a large oil spill may have potentially serious consequences for habitat species and economic activities and costs could be huge. Well, I’m sure there would be no trouble getting a company with a Liberian registered tanker to put there hands in their pockets to pay up a couple of billion pounds.
The last points from SEPA are on ballast water and marine invasive non-native species:
- SEPA welcome the undertaking that ballast water discharges would be only to IMO standards. SEPA recommend that where D-2 compliant treatment systems are available these must be used. The D-2 standard offers a much higher level of protection from biological species than D-1. Whilst this doesn’t eliminate risks to the receiving environment, it does substantially reduce the likelihood.
- The Port Authority should develop a biosecurity plan.
- The Port Authority should set up a monitoring strategy for areas of ballast water discharge so that rapid response measures can be enacted before any accidental spread. Orkney Islands Council conducts such surveillance for example. Since surveillance started it is interesting to note that several non-native species have been identified including those which experts think are likely to have been transported in ballast water.
The point about the ballast water monitoring is interesting – several non-native species have arrived in Orkney including those that are likely to have been transported by ballast water. Also the new D2 treatment standard will reduce risks, but it doesn’t eliminate them. Since this response was written the IMO’s ballast water management convention has been ratified and comes into force next September – this will require the use of the stricter D2 standard. Although it will become international law anyway, according to the latest information as of 13th December 2016, the UK has still not signed up to the convention. We have more to say on ballast water and this will be the subject of a future oil leak.
SEPA finish by saying:
“SEPA object to the granting of a Ship to Ship transfer licence until the highlighted concerns are addressed”
Well, that’s not very positive then – a statutory consultee objects. Well maybe all their concerns will be addressed and their objection will be dropped. Interesting – both SEPA and SNH have significant concerns. What did port CEO Bob Buskie say? Something like “Were not going to doing anything that the statutory consultees won’t allow us to do” – hmmmm…..maybe he should read what they said!
