Petrojarl Banff

J. Spence/ 01 23.08.2019 Draft E. Morrison Rev. Date Reason for issue Prepared Checked Approved

Document Status Owner Company Name / Logo 1 Draft 2 For Comments 3 Comments Included 4 For Construction 5 Issued/As Built Teekay Petrojarl Floating Production UK Ltd 6 Void +I Issued for Information Sub Supplier Company Name / Logo

Originator/Contractor/Supplier Company Name/ Logo Sub Supplier Document Number

Originator/Contractor/Supplier Document Number

Project no Originator no. Contract/ PO No Document Title

45209 01 Banff SAL Buoy Removal Decommissioning Environmental Appraisal

Area Discipline System Doc. Client Document Number No of SFI Document Rev type Sheets Status Click Click Cli PJB- 1 01 here to here ck enter to her text. enter e text. to ent er tex t. Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 2 of 31

BANFF SAL BUOY REMOVAL DECOMMISSIONING ENVIRONMENTAL APPRAISAL

TABLE OF CONTENTS

ACRONYMS ...... 3 1 INTRODUCTION ...... 4 1.1 Field overview ...... 4 2 SAL BUOY REMOVAL WORKSCOPE ...... 8 3 EVIRONMENTAL DESCRIPTION ...... 11 3.1 Introduction ...... 11 3.2 Physical Environment ...... 11 3.2.1 Weather and sea conditions ...... 11 3.3 Bathymetry and seabed conditions ...... 11 3.4 Biological Environment ...... 12 3.4.1 Plankton ...... 12 3.4.2 Benthos ...... 12 3.4.3 Fish Spawning and Nursery, Shellfish Grounds ...... 13 3.4.4 Seabird Vulnerability ...... 13 3.4.5 Marine Mammals ...... 15 3.4.6 Socio-Economic Environment ...... 17 3.5 Conservation...... 19 3.5.1 Offshore Conservation ...... 19 3.5.2 Onshore Conservation ...... 22 4 ENVIRONMENTAL AND SOCIO-ECONOMIC IMPACT ASSESSMENT ...... 23 4.1 Discharges to Sea ...... 25 4.1 Emissions to Air ...... 25 4.2 Disturbance to the seabed ...... 26 5 CONCLUSION ...... 27 6 REFERENCES ...... 28 APPENDIX 1 ...... 31

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 3 of 31

km Kilometers ACRONYMS km2 Squared Kilometers LP Low Pressure % Percent m Metres < Less Than m3 Cubic Metres > More Than m3/day Cubic Metres per Day « Inches m/s Metres per Second ° Degree MARPOL International Convention for the °C Degrees Celsius Prevention of Pollution from Ships ‰ Parts per Thousand MCZ Marine Conservation Zone ALARP As Low As Reasonably Practicable mg/L Milligrams per Litre AHV Anchor Handling Vessel mm Millimeters bbls Barrels MP Medium Pressure BEIS The Department for Business, Energy MU Management Units and Industrial Strategy N2O Nitrous Oxide BMT BMT Cordah NCMPA Nature Conservation Marine BOP Blow Out Preventer Protected Areas CaCO3 Calcium Carbonate nm Nautical Mile CATS Central Area Transmission System NMP National Marine Plan Cefas Centre for Environment, Fisheries NMPi National Marine Plan interactive and Aquaculture Science NNS Northern North Sea CHARM Chemical Hazard Assessment and NOx Nitrogen Oxide Risk Management OCNS The Offshore Chemical Notification CMT Crisis Management Training Scheme CO Carbon Monoxide OGA Oil and Gas Authority CO2 Carbon Dioxide OPEP Oil Pollution Emergency Plan CH4 Methane OPOL Oil Pollution Operators Liability Fund CNRI Canadian Natural Resources OPPC Oil Pollution Prevention and Control International OSD Oil Safety Directive CNS Central North Sea OSPAR Oslo and Paris Convention CTR Cost Time and Resources OSR Oil Spill Response DECC The Department for Energy and OSRL Oil Spill Response Limited Climate Change OVI Oil Vulnerability Index DNV GL Det Norske Veritas and ROV Remotely Operated Vehicle Germanischer Lloyd RQ Risk Quotient DTI Department of Trade and Industry SAC Special Area of Conservation ED European Datum SAHFOS Sir Alister Hardy’s Foundation for EEMS Environmental and Emissions Ocean Science Monitoring System SAL Single Anchor Loading EA Environmental Appraisal SAT Subsidiary Application Template EIA Environmental Impact Assessment SCANS Small Cetacean Abundance in the EPS European Protected Species North Sea ERT Emergency Response Team SCOS Special Committee on Seals EU European Union SMRU Small Mammal Research Unit FPSO Floating Production Supply and SOSI Seabird Oil Sensitivity Index Offloading SOx Sulphur Oxides FRS Fisheries Research Service SPA Special Protected Area FSU Floating Storage Unit SRB Sulphate Reducing Bacteria GHG Greenhouse Gases SRT Site Receival Test H2S Hydrogen Sulphide SST Seabirds at Sea Team HP High Pressure STL Submerged Turret Loading HQ Hazard Quotient TEG Triethylene Glycol HSSE Health, Safety, Security and THPS Tetrakis-(hydroxymethyl)- Environmental Phosphonium Sulphate IAMMWG Inter-Agency Marine Mammal UK United Kingdom Working Group UKCS United Kingdom Continental Shelf ICES International Council for the UKOPP United Kingdom Oil Pollution Exploration of the Sea Prevention Certificate ISO International Organisation for UHC Unburnt Hydrocarbons Standardization UTM Universal Transverse Mercator JNCC The Joint Nature Conservation VOC Volatile Organic Compounds Committee WAT Wax Appearance Temperature

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 4 of 31

1 INTRODUCTION

Field overview

The Banff field is operated by Teekay Petrojarl Floating Production UK Limited (hereafter referred to as Teekay) and the licence holder is Canadian Resources Limited International (CNRI)). The field is in Blocks 29/02a and 22/27a of the Central North Sea (CNS) and is produced through the Petrojarl Banff Floating, Production, Storage and Offloading (FPSO) vessel (hereafter referred to as the Banff FPSO), located in Block 22/27a.

The Single Anchor Loading (SAL) midwater Buoy, which is the subject of this Environmental Appraisal (EA), is situated between the Banff FPSO and the Apollo Spirit Floating Storage Unit (FSU), 193 km from the nearest Scottish coastline and 62 km from the UK/ transboundary line in water depths of between approximately 90 and 95 m (Figure 1-1).

Figure 1-1: Banff Field Layout showing SAL Buoy position

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 5 of 31

The mid-water SAL Buoy was installed in 1998 (circled in Figure 1-2 and detailed in Figure 1-3). The SAL offloading system was made redundant in 2001. The SAL Buoy has a subsea 500 m safety zone which overlaps the safety zone of the Apollo Spirit FSU.

The buoy is situated approximately 51 m above the seabed. The mooring structure comprises of a mooring chain and suction anchor. The Buoy also has a 12” loading hose (PL1550A). The hose has been disconnected from the export pipeline and left filled with inhibited seawater.

The SAL offloading system was made redundant in 2001 due to low uptime and has since been wet stored with the intention of being decommissioned at the end of field life. However, following a visual subsea inspection (May 2019), the mooring wire of this SAL buoy was identified as corroding and in danger of coming loose, particularly in high weather (Autumn/Winter). Therefore, it has been deemed necessary to remove the SAL buoy as soon as possible.

As part of the planning for decommissioning and to obtain regulatory approval for the SAL Buoy Removal activities, a Decommissioning Programme (Teekay, 2019) will be prepared which is supported by this Environmental Appraisal (EA). The disused flexible loading hose (PWA 1550A) will be decommissioned together with the buoy.

The Decommissioning Programme for the SAL Buoy removal (TEEKAY, 2019) and this supporting EA do not cover any other Banff field decommissioning operations. These activities will be carried out as part of the wider field decommissioning at a future date following COP.

The scheduled start date for the SAL buoy decommissioning is 8th September 2019 and operations are expected to take 2 days to complete. For the purposes of this environmental appraisal (i.e. associated emissions), a maximum of up to 12 days has been assessed to account for mobilisation to and from site.

Following submission of the Decommissioning programme, Teekay will apply for a Marine Licence for the removal of items from the seabed as required under the Marine and coastal Access Act (MCAA).

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 6 of 31

Figure 1-2 Banff and Kyle Field Layout showing unused midwater SAL Buoy (circled red)

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 7 of 31

Figure 1-3 SAL Buoy System overview

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 8 of 31

2 SAL BUOY REMOVAL WORKSCOPE This section provides an overview of the proposed activities and the project schedule for the SAL buoy removal campaign. The proposed activities will be undertaken with the Island Valiant, an Anchor Handling Vessel (AHV) with dynamic positioning (DP). The subsea disconnection work will be undertaken by remote operated vehicle (ROV) with appropriate tooling.

The components of the SAL system to be removed are the SAL Buoy, the loading hose (including, valve end) and the mooring line, as summarised in Table 2-1. This proposed workscope does not include the removal of the suction anchor or the section of bonded hose on the seabed which runs from the assembly base to the pipeline end manifold (PLEM) on the 12” export pipeline (Figure 1-3). These will be left in situ until field decommissioning at a later stage and are not part of this scope.

The loading hose to be recovered is 276 m in length, of which a proportion (140 m) lies on the seabed. Upon recovery, this will incur some localised seabed disturbance. All other infrastructure to be removed (buoy and mooring wire) are situated in the water column.

The loading hose will be cut subsea at the assembly base. This hose is filled with 20 m3 inhibited seawater which will be discharged during the removal operations.

An overview of the proposed removal steps is listed below and illustrated in Figure 2-1

1. Cut loading hose at flow line assembly base

2. Connect soft sling around riser bend piece

3. Connect soft sling to aux winch wire

4. Apply tension to aux winch

5. Cut riser bend connection/swivel

6. Winch loading hose to deck

7. Clean buoy 85t lifting lugs

8. Connect soft slings to buoy lifting lugs using crane and ROV shackle

9. Disconnect crane from soft slings

10. Cut SAL mooring wire at base of anchor

11. Buoy rise to the surface

12. Connect the soft slings to the crane hook

13. Lift the buoy and place it on the deck

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 9 of 31

Table 2-1 Components of the SAL system to be recovered and their fate

Component Location From Location To Weight (tonnes) Length (m) Area of seabed impact (m2) Materials Fate 57° 00’ 30.46” N Steel Recovered and recycled Mid-water SAL buoy - 23 tonnes n/a Not applicable as in the water column 01° 19’ 01.45” E

276 m 140 m length on seabed Plastic (12” bonded hose) Reuse or appropriate 57° 00’ 30.46” N 57° 00’ 34.05” N 46 tonnes Loading hose from anchor disposal (23 x 12 m x (12” (30.5 cm) + 1 m impact corridor) 01° 19’ 01.45” E 01° 18’ 50.75” E sections) = 182.7 m2 57° 00’ 34.05” N Steel Re-used Hose end valve - 1.5 tonnes 1 m 1 m x 2m (impact corridor) = 2 m2 01° 18’ 50.75” E 57° 00’ 30.46” N Steel Recovered and recycled SAL buoy mooring wire - 4 tonnes 51.2 m Not applicable as in the water column 01° 19’ 01.45” E TOTAL 74.5 tonnes - 184.7 m2

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 10 of 31

Figure 2-1 Proposed stages of SAL system removal

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 11 of 31

3 EVIRONMENTAL DESCRIPTION

Introduction The following presents a summary of the key environmental sensitivities within the vicinity of the Banff FPSO and SAL Buoy system.

Physical Environment 3.2.1 Weather and sea conditions The predominant regional currents in the North Sea are the vertically well-mixed coastal and Atlantic water inflow of the Fair Isle/Dooley Current. This current flows around the north of Orkney and then south, where it turns east and circulates in the North Sea. The second influencing current is the East Shetland Atlantic Inflow, which flows just north of the Fair Isle/Dooley Current (DECC, 2016). The average wave height in the CNS region follows a gradient decreasing from the northern area of the Fladen/Witch Ground to the southern area of the Dogger Bank. The annual mean significant wave height in the area is c. 2.15 m (Scottish Government NMPi, 2018).

In the CNS tidal currents are strongest in shallow coastal areas, where the tidal stream is aligned parallel to the coast. Maximum surface current speeds are mainly in excess of 0.5 m/s out to about 50 km offshore, decreasing eastwards to less than 0.25 m/s (DECC, 2016).

Density stratification is well developed in the summer months of most years in the central and northern North Sea (NNS), with the relative strength of the thermocline determined by solar heat input and turbulence generated by wind and tides. Sea temperatures in Block 22/27a can vary through the water column. Annual mean near-bed temperatures are c. 7.3°C and annual mean surface waters are c. 9.6°C. Annual mean salinity is 35.01 near the seabed and 34.95 in surface waters (Scottish Government NMPi, 2018).

Prevailing winds in the North Sea are from a south-west and north-north-east origin. Winds of force 5 (8 m/s) and greater are recorded 60 to 65% of the time in winter and 22 to 27% of the time in summer. In April and July, winds in the central to northern North Sea, are highly variable and there is a greater incidence of north-westerly winds (DECC, 2016).

Bathymetry and seabed conditions The North Sea is a large shallow sea with a surface area of around 750,000 km2. The nature of seabed sediments in this area of the North Sea results from a combination of hydrographic conditions, bathymetry and sediment supply. Sediments classified as sand and slightly gravelly sand cover approximately 80% of the North Sea (DECC, 2016). Seabed sediments in the CNS generally comprise a veneer of unconsolidated terrigenous and biogenic deposits, generally significantly less than 1 m thick (Andrews et al., 1990). Sediments may have a significant mud content, particularly in basins and in deeper waters to the north.

The water depth in the area is approximately 95 m. A geophysical site survey conducted at Banff by RPS Energy (2008) found that the area around the Banff/Kyle wells comprised fine to medium silty sand with shell fragments and occasional accumulations of shell (RPS Energy, 2008). Only minor amounts of coarse sediment (>2mm) were recorded at four of the six sites sampled relating to broken shell fragments (0.1 to 1.3%), whilst fine sands made up 7.4 to 10.4% of the size distribution for all stations. Total organic matter in the area showed consistent proportions around naturally low levels of 1 to 1.2% and organic carbon showed levels of 0.14 to 0.16%.

Several small depressions were recorded in the survey area which was interpreted as relic pockmarks within the underlying Coal Pit formations and no indication of present day activity through geophysical and seabed camera investigation. Furthermore, several boulders were

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 12 of 31

located, one which showed a notable area of scour, exposing coarser sediments. There was no indication of potential Annex I habitats within the survey area (RPS Energy, 2008).

Biological Environment 3.4.1 Plankton Plankton consists of the plants (phytoplankton) and animals (zooplankton) that drift in the surface waters with the tides and currents. Plankton forms the basis of marine ecosystem food webs and the composition of planktonic communities is variable temporally, depending upon the circulation patterns of water masses, the season and nutrient availability. The distribution and abundance of plankton is heavily influenced by water depth, tidal mixing and thermal stratification within the water column (Edwards et al., 2010). The majority of the plankton occurs in the photic zone, i.e. the upper 20 m or so of the sea in temperate latitudes, which receives enough light for photosynthesis (Johns and Reid, 2001). However, zooplankton can extend to greater depths and many species undergo diurnal vertical migrations, rising to feed before returning to depth. Natural seasonality and high small-scale variability, both in species composition and abundance, is an important feature of planktonic communities. Many species of larger animals such as fish, birds and cetaceans, are dependent upon the plankton for food. The distribution of plankton therefore directly influences the movement and distribution of other marine species (DECC, 2016).

In both the NNS and CNS the dinoflagellate genus Ceratium (C. fusus, C. furca, C. lineatum) dominates the phytoplankton community (DECC, 2016). In the 10 year period between 1997 and 2007, phytoplankton levels within the CNS, based on the Phytoplankton Colour Index, spike in April. A second, lesser spike is seen in August before levels decrease through the winter months when light and temperature are less abundant (SAHFOS, 2015).

Calanus finmarchicus and C. helgolandicus dominate the zooplankton of the North Sea. There is a strong geographical divide between these two species, with C. finmarchicus more abundant in colder, more northern waters and C. helgolandicus dominating warmer waters in more southerly regions, though their ranges show considerable overlap (DECC, 2016). Overall abundance of C. finmarchicus has declined significantly over the last 60 years, attributed mainly to changes in seawater temperature and salinity (Beare et al., 2002; FRS, 2004). C. finmarchicus has been replaced, in particular, by a relative increase in the populations of C. helgolandicus (DECC, 2016; Baxter et al., 2011).

3.4.2 Benthos Knowledge of the composition of the infauna (invertebrates that live within benthic sediments) and epifauna (mobile or sessile species living on hard or sedimentary seabed types) is important in predicting the potential effects of the disturbance that might be caused by anthropogenic activities.

The RPS Energy benthic survey carried out in 2008 (RPS Energy, 2008) found that the macrofaunal community was of moderate richness and abundance for the sediment type (silty sands) As expected in this sediment and area of the North Sea the fauna was dominated slightly by polychaete worms. The most prevalent species, were the polychaetes Galathowenia oculata, Paramphinome jeffreysii and Spiophanes bombyx followed by the pea urchin Echinocyamus pusillus and the tanaiid crustacean Eudorellopsis deformis (RPS Energy, 2008). This showed a similar match to SS.SMu.OMu.-PjefThyAfil, a common offshore circalittoral habitat for muddy sands around the British Isles characterised by the polychaete Paramphinome jeffreysii, although the higher proportion of sand and the common appearance of the pea urchin Echinocyamus pusillus and the tanaied crustacean Eudorellopsis deformis would suggest similarity with the some of the offshore sand denominations (SS.SSa.OSa). Multivariate analysis showed that all replicates were statistically similar but did not group into the various stations, highlighting the homogeneity of the faunal assemblages. No faunal species considered to be important or

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 13 of 31

endangered were recorded during the survey and no Annex I habitats were found within the survey (RPS Energy, 2008).

3.4.3 Fish Spawning and Nursery, Shellfish Grounds Fish and shellfish spawning can be characterised as pelagic, in the water column, or demersal, on the seabed. Pelagic spawners can be negatively affected by suspended material in the water column which can cause eggs to sink before hatching therefore lowering survival rate. Demersal spawners are sensitive to smothering and impacts on the seabed (Bakke et al., 2013).

The SAL Buoy is located within the spawning and nursery grounds of a number of commercial fish species listed in Table 3-1. Coull et al., (1998) and Ellis et al., (2012) identified spawning grounds for cod, lemon sole, mackerel and Norway pout (the orange columns demark the operations period of the proposed operations).

Table 3-1 Fish Spawning and Nursery Timings in Block 22/27 (Coull et al., 19981 and Ellis et al., 20122; Aires et al., 2014)

Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Anglerfish2 NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ Blue whiting2 N N N N N N N N N N N N Cod2 SN *SN *SN SN N N N N N N N N Haddock1 NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ European hake2 NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ NJ Herring2 N N N N N N N N N N N N Lemon sole1 S S S S S S Ling2 N N N N N N N N N N N N Mackerel1,2 N N N N *SN *SN *SN SN N N N N Norway pout1 SNJ *SNJ *SNJ SNJ NJ NJ NJ NJ NJ NJ NJ NJ Plaice2 N N N N N N N N N N N N Sandeel2 S S N N N N N N N N S S Spurdog2 N N N N N N N N N N N N Whiting2 N N N N N N N N N N N N KEY Operational Period S = Spawning, * = Peak Spawning, N = Nursery, J = Juveniles

3.4.4 Seabird Vulnerability In the central and northern North Sea, the most numerous seabirds present are likely to be fulmar (Fulmarus glacialis), black-legged kittiwake (Rissa tridactyla) and common guillemot (Uria aalge) (DECC, 2016).

Seabirds are not normally affected by routine offshore oil and gas operations. In the unlikely event of an oil release, however, birds are vulnerable to oiling from surface pollution, which could cause direct toxicity through ingestion, and hypothermia as a result the bird’s inability to waterproof their feathers.

The Seabird Oil Sensitivity Index (SOSI) (JNCC, 2018) identifies sea areas where seabirds are likely to be most sensitive to oil pollution. The vulnerability of seabirds to surface oil pollution in

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 14 of 31

the region of the Banff field is presented in Table 3-2. It indicates that vulnerability is low throughout the year in Block 22/27 and adjacent blocks (Figure 3-1).

Table 3-2 Seabird Vulnerability in Block 22/27 and adjacent blocks (JNCC, 2018) Block Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 22/21 5 5* 5 5* 5* 5 5 5 5 5* N 5* 22/22 5 5 5 5* 5* 5 5 5 5 5* N 5* 22/23 5 5 5 5* 5* 5 5 5 5 5* N 5* 22/26 5 5* 5 5* 5* 5 5 5 5 5* N 5* 22/27 5 5* 5 5* 5* 5 5 5 5 5* N 5* 22/28 5 5 5 5* 5* 5 5 5 5 5* N 5* 29/01 5 5 5 5* 5* 5 5 5 5 5* N 5* 29/02 5 5 5 5* 5* 5 5 5 5 5* N 5* 29/03 5 5 5 5* 5* 5 5 5 5 5* N 5* Extremely Very high High Medium Low No data Key high Indirect Assessment – data gaps have been populated following guidance provided by the JNCC (JNCC, 2018). * Data gap filled gap filled using data from the same block in adjacent months. ** Data gap filled using data from adjacent blocks from same month

Figure 3-1 SOSI and indirect assessment of seabirds in Block 22/27 and adjacent blocks (JNCC, 2018).

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 15 of 31

3.4.5 Marine Mammals

3.4.5.1 Cetaceans The distribution of cetacean species in UK waters has been compiled in the Atlas of Cetacean Distribution in North-West European Waters (Reid et al., 2003). Three main sources, the JNCC Seabirds at Sea Team (SST), SeaWatch Foundation and the SCANS survey (Small Cetacean Abundance in the North Sea) were used to compile the atlas based on sightings data. Shipboard surveys were carried out in the region as part of the Small Cetaceans in the European Atlantic and North Sea (SCANS III) project more recently.

More than sixteen species of cetacean have been recorded in the CNS but only harbour porpoise Phocoena phocoena and white-beaked dolphin Lagenorhynchus albirostris can be classed as regularly occurring through the majority of the year. The minke whale Balaenoptera acutorostrata is also regarded as a frequent seasonal visitor here. The harbour porpoise is the most common cetacean in the North Sea with highest densities seen during the summer months. White-beaked dolphins are present all year round in the area, with most sightings being recorded between June and October (Reid et al., 2003).

Seasonal occurrence of the most frequently recorded species from (Reid et al, 2003) around the Banff Field is detailed in Table 3-3

Table 3-3 Sightings of Cetaceans in Block 22/27 (Reid et al 2003) Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Atlantic white-sided dolphin 3 3 Harbour porpoise 2 3 2 1 3 2 Minke Whale 3 3 2 3 3 White-beaked Dolphin 3 2 3 3 3 1 = High Density, 2 = Moderate Density, 3 = Low Density, Blank = No data

A series of SCANS surveys have been conducted to obtain an estimate of cetacean abundance in North Sea and adjacent waters, the most recent of which is SCANS-III (Hammond et al., 2017). Ariel and shipboard surveys were carried out during the summer of 2016 to collect data on the abundance of harbour porpoise, bottlenose dolphin, Risso’s dolphin, white-beaked dolphin, white- sided dolphin, common dolphin, striped dolphin, pilot whale, all beaked whale species combined, sperm whale, minke whale and fin whale.

Block 22/27 is located within SCANS-III survey area “R”. Aerial survey estimates of animal abundance and densities (animals per km2) within this area are provided in Table 3-4.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 16 of 31

Table 3-4 Cetacean abundance in SCANS-III Survey block “R” (Hammond et al., 2017). BLOCK SPECIES ANIMAL DENSITY ABUNDANCE (ANIMALS PER KM2)

Harbour porpoise 38,646 0.599

R Bottlenose 1,924 0.030 Dolphin White-beaked 15,694 0.243 dolphin

White-sided 644 0.010 dolphin Minke whales 2,498 0.039

N/A – it should be noted that bottlenose dolphins do occur with survey block R, however the species abundance is too low to represent as MU. Distribution of this species is found primarily along coastlines and not offshore.

3.4.5.2 Pinnipeds Five species of seal have been identified in the North Sea; these include the grey seal Halichoerus grypus, harbour seal Phoca vitulina, harp seal Phoca groenlandica, hooded seal Cystophora cristata and ringed seal Pusa hispida. Of these, only grey and harbour seals are found regularly in the northern and central North Sea. Both of these seal species are protected under Annex II of the EU Directive. Approximately 38% of the world’s grey seals breed in the UK and 88% of these breed at colonies in Scotland with the main concentrations in the Outer Hebrides and in Orkney, while approximately 30% of harbour seals are found in the UK. However, the harbour seal population has declined approximately 40% from population levels in 2002. Harbour seals are widespread around the west coast of Scotland and throughout the Hebrides and Northern Isles (SCOS, 2013).

Grey and harbour seals will feed both in inshore and offshore waters depending on the distribution of their prey, which changes both seasonally and annually. Both species tend to be concentrated close to shore, particularly during the pupping and moulting season. Seal tracking studies from the Moray Firth have indicated that the foraging movements of harbour seals are generally restricted to within a 40 – 50 km range of their haul-out sites (Special Committee on Seals, 2013). The movements of grey seals can involve larger distances than those of the harbour seal, and trips of several hundred kilometres from one haul-out to another have been recorded (SMRU, 2011) and may therefore be encountered occasionally in the vicinity of the Banff SAL Buoy. Distribution maps based on telemetry data (1991 ‐ 2012) and count data (1988 – 2012) indicate that grey seals are unlikely to occur in the vicinity of the Banff area (Figure 3-2) (Jones et al., 2013).

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 17 of 31

Figure 3-2 Harbour and grey seal distribution in the North Sea (SMRU, 2012; Jones et al., 2013)

3.4.6 Socio-Economic Environment

3.4.6.1 Oil and Gas Activities There is a long history of oil and gas activity in the North Sea, with oil being discovered in the early 1960s and the first well coming online in the early 1970s. The Banff Buoy is located in a region of the central North Sea where oil and gas development is extensive. The closest surface infrastructure is the Apollo FPSO approximately 2 km from Petrojarl Banff. The closest field is Gannet which lies circa 25 km southeast, in addition to which the Curlew oil field lies 29 km to the south of the Banff FPSO. Both of these fields are operated by Shell.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 18 of 31

3.4.6.2 Commercial Fisheries The International Council for the Exploration of the Sea (ICES) divides the north-east Atlantic into a number of rectangles measuring 30 nm by 30 nm. Each ICES rectangle covers approximately one half of one quadrant i.e. 15 license blocks. The importance of an area to the fishing industry is assessed by measuring the fishing effort which may be defined as the number of days (time) x fleet capacity (tonnage and engine power). It should be noted that fishing activity may not be uniformly distributed over the area of the ICES rectangle. The SAL Buoy lies within ICES rectangle 42F1. Table 3-5 lists the live weight and value of species type into Scotland from 42F1 in 2016 and 2017 (Scottish Government, 2018). Table 3-5 Live Weight and Value of Fish and Shellfish taken from ICES Rectangle 42F1 in 2016 & 2017 (Scottish Government, 2018)

2016 2017 Species type Live weight Live weight Value (£) Value (£) (tonnes) (tonnes)

Demersal 153 202,601 67 112,475

Pelagic 215 104,582 1 1,301

Shellfish 236 1,080,620 140 602,528

Total 604 1,387,803 209 716,304

The data for 2017 indicate that landings by vessels into Scotland for ICES rectangle 42F1 were dominated by shellfish in terms of weight and value. Shellfish contributed 67% of weight and 84% of value for 2017.

Logbooks submitted by fishermen allow the yearly pattern of fishing effort to be examined (Table 3-6). Overall, the fishing effort in ICES rectangle 42F1 is low in comparison to nearby rectangles.

Table 3-6 Number of Days Fished per month (all gears) in ICES Rectangle 42F1 in 2016 & 2017 (Scottish Government, 2018)

Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2017 51 D D D D 43 34 73 D D D D

2016 D D 101 16 94 10 14 51 102 8 18 99 Note: Monthly fishing effort by UK vessels landing into Scotland: D = disclosive data (implying very low effort levels/confidentiality). Green = 0 – 50 days fished, yellow = 51 – 100, orange =101-200, red = ≥201. The total may not be equal to the sum of the table as it includes data from months marked ‘disclosive’. Source: Scottish Government, 2018

3.4.6.3 Shipping There are no major shipping lanes or appreciable commercial traffic routes in the Banff FPSO area, other than those related to the oil and gas industry in the vicinity of Block 22/27. Shipping activities in the North Sea are categorised by the Oil and Gas Authority (OGA) to have either: very low; low; moderate; high; or very high shipping density. Block 22/27 is located in an area defined as having low shipping density (OGA, 2018).

3.4.6.4 Submarine Cables and Pipelines

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 19 of 31

No functioning cables have been reported in the vicinity of the Banff FPSO, although the CNS Fibre Optic cable passes the field at a distance of approximately 65 km to the northeast (KIS- ORCA, 2013; Scottish Government NMPi, 2018). The 36" CATS gas pipeline to Teeside passes north to south and transects the north-west section of Block 22/27. Two parallel pipelines (the 20" Fulmar to St. Fergus gas pipeline and the 16" Gannet to Fulmar oil pipeline) run diagonally from northwest to southeast through the block, with the closest point of approach approximately 5 km west of the Banff FPSO (Scottish Government NMPi, 2018).

3.4.6.5 Wrecks According to records from the UK Hydrographic Office there are 1,157 confirmed wrecks within the SEA 2 area. Two wrecks and one underwater obstruction are present in Blocks 22/27 and 29/2 (adjacent block). The closest wrecks are 2.6 km northwest and 1.6 km from the Banff FPSO. The underwater obstruction is 4.7 km west of the Banff FPSO (Scottish Government NMPi, 2018).

3.4.6.6 Military activity Four areas in the North Sea have been designated for use in military exercise areas by countries bordering the area, but no designated areas for military activities occur in the vicinity of the Banff FPSO. The closest military exercise area which is designated as a ‘danger area’ is found on the north-east Scottish coastline (north of Aberdeen) over 190 km from Petrojarl Banff.

Conservation A network of designated areas is in place to aid the protection of vulnerable and endangered species and habitats through structured legislation and policies. These sites include Special Areas of Conservation (SAC) and Special Protection Areas (SPA), designated under the EC Habitats Directive (92/43/EEC) and EC Birds Directive (2009/147/EC) respectively, along with Nature Conservation Marine Protected Areas (NCMPAs) designated under the Marine (Scotland) Act 2010 or the Marine and Coastal Access Act 2009. In addition, Scottish National Heritage (SNH) and JNCC list 81 species and habitats considered Priority Marine Features (PMF) considered to be of conservation importance in Scotland's seas.

3.5.1 Offshore Conservation The Banff FPSO is located within the boundaries of the East of Gannet and Montrose Field Nature Conservation Marine Protected Area (NCMPA) (Figure 3-3). This area is designated for the conservation of deepsea muds and Arctica islandica aggregations which is considered threatened and/or declining in the North Sea by the OSPAR Commission (JNCC, 2016). The Fulmar Marine Conservation Zone (MCZ) is designated for similar attributes and is located c. 52 km south-east of Block 22/27a. Qualifying features include subtidal sands, mud and mixed sediments, as well as A. islandica aggregations.

The closest Special Area of Conservation (SAC) is the Scanner Pockmark approximately 140 km north of Block 22/27a. The qualifying feature for this site is the Annex I habitat ‘submarine structures made by leaking gases’. Due to this large distance, neither the site integrity nor its conservation objectives are likely to be affected by the proposed operations.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 20 of 31

Figure 3-3 Marine protected sites within the CNS

3.5.1.1 European Protected Species

Both the Habitats Regulations and Offshore Marine Regulations prohibit the deliberate capture, injury, killing or disturbance of any wild animals of a European Protected Species (EPS); certain animals, including all species of cetaceans, are listed in Annex IV of the Habitats Directive as being in need of strict protection (JNCC, 2010). For the Banff FPSO area, cetaceans are the only EPS likely to be recorded, even if only rarely. The European sturgeon Acipenser sturio and some marine turtle species are EPS and occur in UK waters, but the Banff FPSO area is located at the furthest extent of their ranges and their occurrence in any numbers in the vicinity of the Banff FPSO is unlikely.

The only Annex II species likely to occur in the area with any regularity is the harbour porpoise. The harbour porpoise is the most common cetacean in UK waters, being widely distributed and abundant throughout the majority of UK shelf seas, both inshore and offshore.

3.5.1.2 National Marine Plan The National Marine Plan (NMP) covers the management of both Scottish inshore waters (out to 12 nautical miles) and offshore waters (12 to 200 nautical miles). The aim on the NMP is to help ensure the sustainable development of the marine area through informing and guiding regulation, management, use and protection of the Marine Plan areas. The proposed operations as described in this permit have been assessed against the Marine Plan objectives and policies, specifically GEN 1.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 21 of 31

Proposed operations at the Banff FPSO for SAL buoy removal do not contradict any of the Marine Plan objectives and policies. Teekay will ensure they comply with all the new policies that have been introduced, with particular attention being made to the following policies.

GEN 1- General planning and principle

Development and use of marine area should be consistent with the Marine Plan, ensuring activities are undertaken in a sustainable manner that protects and enhances Scotland’s natural and historic marine environment. Teekay will ensure that any potential impacts associated with the proposed operations will be kept to a minimum.

GEN 4- Co-existence

Where conflict over space or resources exists or arises, marine planning should encourage initiative between sectors to resolve conflict and take account of agreements where this is applicable. Teekay will ensure that any potential impacts on other sea users associated with the proposed operations will be kept to a minimum.

GEN 5- Climate change

Marine planners and decision makers should seek to facilitate a transition to a low carbon economy. They should consider ways to reduce emissions of carbon and other greenhouse gasses. Teekay will ensure that any potential impacts associated with the proposed operations will be kept to a minimum.

GEN 9- Natural heritage

Development and use of the marine environment must:

• Comply with legal requirements for protected areas and protected species;

• Not result in significant impact on the national status of Priority Marine Features;

• Protect and, where appropriate, enhance the health of the marine area.

Teekay will ensure that any potential impacts to protected species and sites associated with the proposed operations will be kept to a minimum.

GEN 12- Water quality and resource

Developments and activities should not result in a deterioration of the quality of waters to which the Water Framework Directive, Marine Strategy Framework Directive or other related Directives apply. Teekay will ensure that any potential impacts to water quality associated with the proposed operations will be kept to a minimum.

GEN 14- Air quality

Development and use of the marine environment should not result in the deterioration of air quality and should not breach any statutory air quality limits. Some development and use may result in increased emission to air, including particulate matter and gasses. Impacts on relevant statutory air quality limits must be taken into account and mitigation measures adopted, if necessary, to allow an activity to proceed within these limits. Teekay will ensure that any potential impacts to air quality with the proposed operations will be kept to a minimum.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 22 of 31

GEN 21- Cumulative impacts

Cumulative impacts affecting the ecosystem of the Marine Plan area should be addressed in decision making and plan implementation. Teekay will ensure that any potential cumulative impacts with the proposed operations will be kept to a minimum.

3.5.2 Onshore Conservation The Scottish east coast is the closest land feature to the Banff FPSO. Many sites on the east coast have been designated as sites of national, European and international importance. Considerable lengths of cliff coastline support nationally and internationally important populations of breeding seabirds. A number of sites on the coastline have been identified as SACs, Ramsar sites, SPAs, National Nature Reserves or National Scenic Areas. A number of sites have been designated as supporting a number of breeding seabird populations, including guillemots and kittiwakes. In addition, a number of sites have been identified as containing important vegetated sea cliff habitat (e.g. the Buchan Ness to Collieston SAC). Nationally important areas for common seals have been identified also; for example, the Dornoch Firth supports an estimated 2% of the UK population (JNCC, Undated).

Other potential sensitivities in coastal areas include fishing, mariculture, tourism and amenity. Whilst there may be localised examples of fishing and mariculture contributing significantly to the economy, tourism may be considered as the most important coast-related income to the east of Scotland.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 23 of 31

4 ENVIRONMENTAL AND SOCIO-ECONOMIC IMPACT ASSESSMENT

This section identifies the environmental and socio-economic impacts associated with the proposed activities outlined in Section 2. Teekay has considered the potential environmental hazards impacts associated with the proposed operations. The following issues have been considered:

• Location and time of the year the operation will take place, thereby accounting for monthly and seasonal variation in environmental sensitivities.

Considering the key environmental sensitivities described in Section 3 and the possible impacts from the proposed operations, the potential impacts are detailed in Table 4-1. Further discussion, where required, is provided in the subsequent sections. Table 4-1 Summary of Potential Impact from the Proposed Operations Aspect Receptor Potential impact Section Water 0 quality, The loading hose will be cut as part of the removal Marine plankton, operations. It is anticipated that this hose contains discharges fish and approximately 20 m3 of inhibited seawater. Marine (planned) shellfish and discharges resulting from these operations is marine assessed as part of this application. mammals All operations will be undertaken from the AHV. 0 Atmospheric Air quality The atmospheric emissions resulting from these emissions operations are assessed as part of this application. Seabed and 4.3 sediments, Physical The main impact from the removal of the SAL buoy benthos, fish presence – and loading hose will be disturbance to the seabed and seabed of a temporary and localised nature. Seabed shellfish, disturbance disturbance resulting from these operations is conservation assessed as part of this application. sites, No sites of cultural heritage have been identified - and given the distance from Banff FPSO to shore, no impacts to coastal landscape and onshore visual receptors are expected. Operations are not expected to have a significant Commercial impact on fish communities in the area as spawning shipping and Physical and nursery grounds form part of much larger fishing, presence – offshore areas (particularly for most species with landscape/ other users of planktonic eggs and larvae). Fishing effort in ICES seascape, the sea rectangle 42F1, in terms of the number of fishing cultural days, is low and represents only 0.17% of the UK heritage total. It should also be noted that shipping density in Block 22/27 is considered to be low (OGA, 2018). As the proposed operations will be undertaken within the 500 m safety zone of the SAL buoy, physical presence is not assessed further.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 24 of 31

Aspect Receptor Potential impact Section The potential source of acoustic disturbance from - the DP vessel is minimal given it will operate in an Underwater Marine open marine environment and the short duration of noise mammals the operations (maximum 12 days). Underwater noise is therefore not assessed further in this application. The likelihood of an oil spill during the proposed - operations is very low with any risk arising from loss of diesel inventory from the project vessel; the possibility of such a hydrocarbon spill during operations will be covered under the vessel’s approved Shipboard Oil Pollution Emergency Plans (SOPEPs). While operating in the field, the Banff Field OPEP would be utilised, including Tier 1, 2 and 3 spill response arrangements.

In the unlikely event of a diesel release, the benthic communities within the East of Gannet and Accidental Seabirds, Montrose Field NCMPA and other offshore event – marine protected areas would not be expected to be hydrocarbon mammals impacted by diesel as the release would likely release remain on the surface. Seabird vulnerability to surface oil pollution is low throughout the year in Block 22/27 and adjacent blocks. Given that the nearest coastline (Scotland) is 192 km away, the probability that a vessel diesel release would impact on coastal areas is low.

Therefore, given the low likelihood of a spill, the low vulnerability of seabirds in the area, and the distance to the nearest coastline, the risk to the environment is considered to be low and effectively managed.

Atmospheric emissions outlined are considered - not to represent a significant proportion of the UK offshore emissions and consequently are not significant in cumulative terms. Air quality, Cumulative The vessel involved with all proposed activities will marine impact be on-site only for the short period of operations mammals (maximum 12 days); cumulative impacts from noise sources within the operation area and with other projects in the area are not expected. These aspects are not considered further in this application. Marine The Banff FPSO is situated 66 km from the - mammals, UK/Norway median line, thus there is little potential Transboundary water for transboundary impacts and this is not assessed impacts quality, air further in this application. quality

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 25 of 31

Discharges to sea Chemical discharge to sea will occur during the proposed operations when the hose is cut subsea. As the hose was filled with inhibited seawater in 2001, it is not known exactly which product or dosage was used. The biocide currently used on Banff FPSO has been taken as a reference and the Cefas template dosage applied in order to carry out a realistic risk assessment. The Osborne- Adams risk assessment has been undertaken using the residual current speed of 0.35 m/s, a water depth of 94.9 m and an expected discharge time of 0.5 hours. The risk assessment indicates that chemical discharge is unlikely to have a significant impact on the marine environment. The results are included in Appendix 1.

Emissions to Air Atmospheric emissions may cause effects at local, regional and global scales. The potential effects include respiratory illness, ground-level ozone, acid rain, and climate change. Within the context of the proposed work at Banff, the atmospheric emission source will be the anchor handling vessel (AHV). Emissions emitted will include: carbon dioxide (CO2); methane (CH4); nitrous oxide (N2O); sulphur oxides (SOX as SO2); nitrogen oxides (NOX as NO2); carbon monoxide (CO) and volatile organic compounds (VOCs).

The maximum number of vessel days required is estimated at 12 days (which includes mobilisation), equating to a total fuel use of 60 tonnes (Table 4-2). Table 4-3 summarises the predicted atmospheric emissions associated with the vessel.

Table 4-2 Expected vessel activity during proposed operations Fuel use (tonnes Total fuel use Vessel type Vessel name Days active /day) (tonnes) AHV Island Valiant 12 5 60

Table 4-3 Atmospheric emissions (Oil and Gas UK, 2012) during the proposed operations Emissions (tonnes) Emission CO CO NO N O SO CH VOC factor 2 x 2 2 4 3.17 0.0157 0.059 0.00022 0.012 0.00018 0.0024 AHV 190.20 0.94 3.54 0.01 0.72 0.01 0.14

The proposed operations described in this application will generate approximately 190 tonnes of CO2. Impacts associated with the proposed operations may include elevated levels of atmospheric emissions in the immediate area where operations are taking place. This figure is a worst-case estimate. An exact figure for offshore emissions in UK waters does not exist. Part of this arises from shipping and it is possible to estimate this contribution by looking at refuelling activity at shipping fuel bunkers within UK ports and harbours (DEFRA, 2010), in which estimates of shipping emissions are included as a memo item in greenhouse gas inventories. In addition to this, the oil and gas industry reports atmospheric emissions annually to Oil and Gas UK (Oil and

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 26 of 31

Gas UK, 2018). By summing these totals, it is therefore possible to assess each operation in relation to the total UK offshore emissions. The total Oil and Gas UK E&P figure is 14,200,000 tonnes for 2017 (Oil and Gas UK, 2018) and the UK Ship Emissions Inventory Report (DEFRA, 2010) figure for shipping is 40,401,000 tonnes of CO2, giving a total of 54,601,000 tonnes of CO2. The proposed operations will therefore contribute to 0.0009% of the total atmospheric emissions associated with UK offshore activities in a year and no significant impact is therefore expected.

Disturbance to the seabed The activities associated with the removal of the SAL buoy and mooring line at Banff will cause temporary disturbance of the seabed. The activities will be carried out by an AHV which will use DP and will therefore not cause disturbance to the seabed by anchoring. Temporary impacts will arise from the disturbance and alteration of seabed habitats, potentially including smothering of animals from the temporary re-suspension and settling of sediment.

The anticipated maximum area of temporary disturbance associated with the removal activities is 184.7 m2 as given in Table 2-1.

The area is characterised by fine to medium silty sand with shell fragments and occasional accumulations of shell, with fauna dominated by polychaete worms. In most areas this has been classed as the biotope ‘Paramphinome jeffreysii, Thyasira spp. and Amphiura filiformis in offshore circalittoral sandy mud’ (RPS Energy, 2008).

The area of disturbed seabed will be relatively small, and the benthic species associated with the area are widespread. The seabed disturbance will occur within the East of Gannet and Montrose Field NCMPA (Figure 1-1), designated for the conservation of deepsea muds and A. islandica aggregations. Benthic surveys in the Banff area did not identify A. islandica aggregations. However, if present, the temporary re-suspension of sediment has the potential to affect any A. islandica present in the immediate vicinity because they rely on their siphons for feeding and respiration, making them vulnerable to suspended fines. They are thought to have no tolerance and low recovery to siltation changes and therefore have a high sensitivity to this pressure (Tillin et al., 2010). However, any increase in suspended sediments will be short lived and localised, and settling out from the water column to the substratum may increase food availability for the deposit feeding fauna that characterise the biotope. Therefore, the impact to benthic habitats is considered to be negligible.

As discussed in Section 3.4.3, several species of fish including cod, lemon sole, Norway pout, mackerel and sandeel are known to spawn within the vicinity of the Banff field, with other species using it as a nursery area. Adult and juvenile fish will move away from direct disturbance. Sandeels (Ammodytes marinus) burrow in to the seabed, and deposit their eggs on the seabed, making them potentially vulnerable to mortality or physical injury. However, the seabed in the vicinity is not expected to be suitable for sandeel which are found in coarse and medium sand seabed areas (Holland et al., 2005). In comparison to the extent of fish spawning and nursery areas in the North Sea, the area of seabed directly disturbed is very small. The significance of the impacts associated with direct seabed disturbance on fish has therefore been assessed as negligible.

The proposed activities do not contradict the NMP objectives GEN 1 (General Planning and Principle); GEN 9 (Natural Heritage) GEN 12 (Water Quality and Resource) and GEN 21 (Cumulative Impacts) (see Section 5).

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 27 of 31

5 CONCLUSION Teekay are applying for authorisation to remove the redundant SAL buoy system umbilical, situated between the Banff FPSO and the Apollo Spirit FSU. The proposed operations are scheduled to take place in September 2019.

The potential environmental sensitivities and impacts to the marine environment have been identified and assessed:

• A subsea discharge of 20 m3 historic inhibited seawater will occur when the hose is cut for removal. This discharge will be rapidly diluted in the water column. Given that this fluid is principally seawater with degraded biocide, any associated environmental affects form this discharge are anticipated to be negligible. The results of chemical risk assessment indicate that the chemical discharge to sea is not likely to pose a risk to the marine environment.

• The proposed work will amount to approximately 0.0009 % of the CO2 generated by shipping in UK waters in 2017. Gaseous emissions will disperse rapidly such that emissions from the vessels are not considered to have a significant impact.

• The area of disturbed seabed will be relatively small and temporary in nature. Furthermore, the benthic species associated with the area impacted are widespread. Therefore, the impact to benthic habitats is considered to be negligible.

Teekay has reviewed the environmental sensitivities in the area of the proposed operations and the significance of the potential impacts resulting from the anticipated time of operations. It is concluded that the proposed activities will not have a significant environmental impact.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 28 of 31

6 REFERENCES Andrews, I.J., Long, D., Richards, P.C., Thomson, A.R., Brown, S., Chester, J.A. and McCormac, M. (1990). United Kingdom offshore regional report: the geology of the Moray Firth. (London: HMSO for the British Geological Survey).

Aires, C., González‐Irusta, J.M., Watret, R. (2014). Scottish Marine and Freshwater Science Report, Vol 5 No 10, Updating Fisheries Sensitivity Maps in British Waters. Available at: http://www.gov.scot/Topics/marine/science/MSInteractive/Themes/fish‐fisheries/fsm [Accessed Jan 2018]

Bakke, T., Klungsøyr, J., Sanni., Steinar, s (2013). Environmental impacts of produced water and drilling waste discharges from the Norwegian offshore industry. Marine Environmental Research 92 (2013) 154-169.

Baxter, J.M., Boyd, I.L., Cox, M., Donald, A.E., Malcolm, S.J., Miles, H., Miller, B., and Moffat, C.F. (Editors) (2011). Scotland's Marine Atlas: Information for the national marine plan. Marine Scotland, Edinburgh. pp. 191. Available online at: http://www.scotland.gov.uk/Publications/2011/03/16182005/0 [Accessed 25th October 2016].

Beare, D.J., Batten, S., Edwards, M. & Reid, D.G (2002). Prevalence of boreal Atlantic, temperate Atlantic and neritic zooplankton in the North Sea between 1958 and 1998 in relation to temperature, salinity, stratification intensity and Atlantic inflow. Journal of Sea Research, 48, 29 – 49.

Coull, K.A., Johnstone, R. & Rogers, S.I. (1998). Fisheries Sensitivity Maps in British Waters. UKOOA Ltd., London.

DECC (Department of Energy and Climate Change) (BEIS) (2016). Offshore Energy Strategic Environmental Assessment 3 (OESEA3). Available at: https://www.gov.uk/government/consultations/ukoffshore‐energy‐strategic‐environmental‐ assessment‐3‐oesea3 [Accessed Jan 2018]

Edwards, M., Beaugrand, G., Johns, D.G., Licandro, P., McQuatters-Gollop, A and Wootton, M. (2010). Ecological Status Report: results from the CPR survey 2009. SAHFOS Technical Report, 7: 1-8. Available online at: http://www.sahfos.ac.uk/media/2326934/ecological%20status%202009%20low%20res.pdf [Accessed on 01/11/16]

Ellis, J., Milligan S., Readdy, L., Taylor, N. and Brown, M. (2012). Spawning and nursery grounds of selected fish Species in UK water. CEFAS Technical Report 147.

FRS (2004). Zooplankton and climate change – the Calanus story. Fisheries Research Services.Available online at http://www.marlab.ac.uk/FRS.Web/Uploads/Documents/Zooplankton.pdf. [Accessed 24th October 2011]

Hammond, P. S., Lacey, C., Gilles, A., Viquerat, S., Börjesson, P., Herr, H., Macleod, K., Ridoux, V., Santos, M. B., Scheidat, M., Teilmann, J., Vingada, J., Øien, N. (2017). Estimates of cetacean abundance in European Atlantic waters in summer 2016 from the SCAN‐III aerial and shipboard surveys. Available at: https://synergy.standrews.ac.uk/scans3/category/researchoutput/ [Accessed Jan 2018]

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 29 of 31

JNCC, (Undated). Dornoch Firth and Morrich More. Available online at http://www.jncc.gov.uk/protectedsites/SACselection/sac.asp?EUcode=UK0019806 [Accessed 6th January 2014]

JNCC, (2010). The protection of marine European Protected Species from injury and disturbance.Guidance for the marine area in England and Wales and the UK offshore marine area.DRAFT June 2010.

JNCC (2016). 1515S Cruise Report: Monitoring Survey of East of Gannet and Montrose Fields and Norwegian Boundary Sediment Plain Scottish Nature Conservation Marine Protected Areas. Report Number: 580 JNCC (2018). Using the seabird Oil Sensitivity Index to inform contingency planning. Available at: http://jncc.defra.gov.uk/page-7373 [Accessed Jan 2018] Johns, D.G. and Reid P.C. (2001). An Overview of Plankton Ecology In The North Sea. Technical report produced for Strategic Environmental Assessment – SEA2. Produced by SAHFOS, August 2001.Technical Report TR_005.

Jones, E., McConnell, B., Sparling, C & Matthiopoulos, J. (2013) Marine Mammal Scientific Support Research Programme MMSS/001/11: Grey and harbour seal density maps. Sea Mammal Research Unit Report to the Scottish Government. 21/02/2013: Version 1500.

KIS-ORCA (2013). Offshore Renewable and Cables Awareness website. Available online at http://www.kis-orca.eu/ [Accessed 24th December 2013].

OGA (2018). Information on levels of shipping activity. Available from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/540506/29R_Shi pping_Density_Table.pdf

Oil and Gas UK (2018). Environment Report 2018. Available at https://oilandgasuk.co.uk/environment-report/ Reid, J.B., Evans, P.G.H., Northridge, S.P. (Eds.) (2003). Atlas of Cetacean Distribution in North- west European Waters. JNCC, Peterborough.

RPS Energy (2008). Baseline benthic environmental survey at the proposed Deep Banff well (UKCS 22/27A). Report by RPS Energy to CNR International (UK) Ltd. Project Ref. BSL07410.

SAHFOS (2015). Sir Alister Hardy Foundation for Ocean Science. CPR Data: Standard Areas. Available from: http://www.sahfos.ac.uk/cpr-data/standard-areas.aspx [Accessed 25th October 2016].

Scottish Government National Marine Plan Interactive (NMPi) (2018). Available at: https://marinescotland.atkinsgeospatial.com/nmpi/ [Accessed Jan 2018] Scottish Government (2018). Scottish Government Scottish Fisheries Statistics Team. Available online at http://www.scotland.gov.uk/Topics/Statistics/Browse/Agriculture- Fisheries/RectangleData [Accessed Feb 2018]

SMRU (2011). Utilisation of space by grey and harbour seals in the Pentland Firth and Orkney waters. Scottish Natural Heritage commissioned report No. 441.

Sea Mammal Research Unit. (SMRU) (2012). Grey and Harbour Seal Distribution Data. Sea Mammal Research Unit 2012.

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 30 of 31

Special Committee on Seals (2013). SCOS Scientific Matters Related to the Management of Seal Populations: 2013 available at http://www.smru.st-and.ac.uk/documents/1619.pdf [Accessed 25th October 2016].

Teekay (2019) Banff Field Single Anchor Loading (SAL) buoy Decommissioning Programme

Teekay Petrojarl Floating Production UK Ltd Petrojarl Banff Banff SAL Buoy Removal DOC.NO. : PJB- Decommissioning Environmental Appraisal REV. : 01 DATE : 23/08/2019 PAGE : 31 of 31

APPENDIX 1

Quantity of Chemical Time Taken Residual Time Taken Estimated Discharge Discharge Expected Released LC50 Number of Function of to Reach Current Refreshme to Refresh Chemical Estimated Discharge Doasge Volume Discharge Rate Discharge per Second (Aquatic Test Test PNEC Water NOEC in Speed nt Rate (per Column Name Use (kgs) (Kgs) (mg/l) (m3) Depth (m) (m3/hr) Time (hrs) (mg/s) (QS) Tox Test) Groups Groups (mg/l) Volume (l) Hours (T1) (m/s) U hour) R (T2) (hours) T2>T1 ? RX-720 0 2.16 108 20 94.9 40 0.5 1200 0.612 3 10 6.2000 1.099E+11 6813800 0.35 0.432 2.31 FALSE