gabbards
Transcription
gabbards
DOCUMENT NO: 577000/403 – MGT100 – GGR – 107 DOCUMENT TITLE: DECOMMISSIONING PROGRAMME GREATER GABBARD OFFSHORE WIND FARM PROJECT Fluor Project No. 577000 Airtricity Project No. 403 CONTROLLED COPY NO: ______ 1 31/08/07 0 REV 58 01/06/07 53 DATE PAGES Issued for Secretary of State Sign off CJH CH GM JCH Issued for Approval CJH CH GM JCH APPR APPR FLUOR AIRTRICITY DESCRIPTION BY CHKD Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Table of Contents 1.0 INTRODUCTION..............................................................................................................4 2.0 EXECUTIVE SUMMARY ...............................................................................................4 3.0 BACKGROUND INFORMATION .................................................................................7 3.1 Project Status ...........................................................................................................7 3.2 Project Overview .....................................................................................................7 3.3 Layout of Wind Farm and Ancillary Works ..........................................................10 3.4 Site Characteristics.................................................................................................11 3.4.1 Physical Characteristics .............................................................................11 3.5 Relevant Projects and Activities ............................................................................18 3.5.1 Offshore Wind Farms ................................................................................18 3.5.2 Marine Aggregate Extraction.....................................................................20 3.5.3 Disposal of Dredged Material....................................................................21 3.5.4 Subsea Cables ............................................................................................22 3.5.5 Oil and Gas ................................................................................................23 3.5.6 Fishing Activity .........................................................................................24 3.5.7 Shipping Activity .......................................................................................25 3.6 4.0 5.0 Nature Conservation ..............................................................................................26 DESCRIPTION OF ITEMS TO BE DECOMMISSIONED .......................................29 4.1 Guiding Principles .................................................................................................29 4.2 Proposed Decommissioning...................................................................................31 4.2.1 Offshore Wind Turbines ............................................................................32 4.2.2 Turbine Foundations & Transition Pieces .................................................35 4.2.3 Transformer Platforms ...............................................................................39 4.2.4 Anemometry Masts....................................................................................41 4.2.5 Cabling.......................................................................................................43 4.2.6 Scour Protection.........................................................................................46 DESCRIPTION OF PROPOSED DECOMMISSIONING MEASURES ..................48 5.1 Wind Turbines/Generating Equipment ..................................................................48 5.2 Foundations............................................................................................................49 Page 2 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme 5.3 T ransformer Platforms ...........................................................................................50 5.4 Anemometry Masts................................................................................................50 5.5 Cables.....................................................................................................................50 5.6 S cour Protection.....................................................................................................50 5.7 Waste Management................................................................................................50 5.8 Lighting and Marking ............................................................................................51 6.0 RE-POWERING ..............................................................................................................52 7.0 ENVIRONMENTAL IMPACT ASSESSMENT ..........................................................52 8.0 CONSULTATIONS WITH INTERESTED PARTIES ...............................................53 9.0 SCHEDULE AND THE REVIEW PROCESS .............................................................54 10.0 SEA-BED CLEARANCE................................................................................................55 11.0 RESTORATION OF THE SITE....................................................................................56 12.0 POST-DECOMMISSIONING MONITORING, MAINTENANCE AND MANAGEMENT OF THE SITE ...................................................................................56 13.0 SUPPORTING STUDIES ...............................................................................................57 14.0 ANNEX A: GREATER GABBARD ENVIRONMENTAL STATEMENT...............58 15.0 ANNEX B: GREATER GABBARD APPROPRIATE ASSESSMENT .....................58 16.0 ANNEX C: GREATER GABBARD DECOMMISSIONING PROGRAMME FINANCIAL SECURITY ARRANGEMENT ..............................................................58 Page 3 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 1.0 Decommissioning Programme INTRODUCTION The Greater Gabbard Offshore Wind Farm will feature 140 turbines, generating a total capacity of 500MW. Covering approximately 147km2, the project will be located some 26km off the Suffolk coast, adjacent to sandbanks known as Inner Gabbard and The Galloper. The wind farm is being developed by Greater Gabbard Offshore Winds Limited (GGOWL), a company formed specifically to develop, finance, construct, operate and decommission the project. The company is jointly owned by Airtricity Holdings (UK) Limited and Fluor International Limited. GGOWL obtained consent under Section 36 of the Electricity Act 1989 in February 2007 for the Greater Gabbard Offshore Wind Farm. At this time the DTI also issued GGOWL a notice under Section 105(2) of the Energy Act 2004 regarding the requirement to prepare and obtain approval for the decommissioning programme for the project prior to construction commencement. This document presents the decommissioning programme for the Greater Gabbard Offshore Wind Farm and is being submitted for approval in accordance with the Energy Act 2004 requirements. The decommissioning programme is informed and supported by the Environmental Impact Assessment (EIA) for the Greater Gabbard Offshore Wind Farm Project that was submitted to DTI in October 2005. The decommissioning programme addresses all components of the wind farm below mean high water springs. The onshore aspects of the project and the associated decommissioning requirements fall under the planning permission granted under Section 57 Town and Country Planning Act 1990 by Suffolk Coastal District Council. Whilst the design life for the wind turbines is 25 years, the lease term for the project is 50 years. As such, GGOWL’s expectation is that the project will be ‘re-powered’ midway through the lease term. Nonetheless, GGOWL acknowledges the UK’s international obligations requiring installations to be decommissioned as soon as is reasonably practicable. This programme therefore sets out the measures for decommissioning the project at the end of the design life of the equipment during year 25. It is expected that as this time approaches, GGOWL will seek approval from the Secretary of State to delay the decommissioning work in favour of re-powering the project. The programme is to be reviewed and revised as necessary throughout the lifecycle of the project to reflect changing circumstances and regulatory requirements, and to incorporate improvements in knowledge and understanding of the marine environment and advances in technology and working practices. 2.0 EXECUTIVE SUMMARY The Energy Act 2004 requires that GGOWL prepares and ultimately carries out a decommissioning programme for the Greater Gabbard Offshore Wind Farm. This document Page 4 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme constitutes the preliminary decommissioning programme for the project and is submitted for approval prior to the construction of the wind farm. The programme is informed and supported by the Environmental Impact Assessment (EIA) carried out for the Greater Gabbard Offshore Wind Farm Project. The resulting Environmental Statement was submitted as part of the project’s application for consent in October 2005. The Environmental Statement provides detailed analysis of the baseline physical, biological and human environment. The assessment of the impact of the project on receptors and stakeholders takes into account decommissioning provisions that are consistent with those presented in this document. A CD version of the Environmental Statement is provided as Annex A to this document. The programme is also informed by the outcome of the Appropriate Assessment undertaken prior to the consent of the wind farm. This document is also provided as Annex B. In considering appropriate decommissioning provisions, GGOWL have sought to adhere to the following key principles: • Safety for all at all times • Consideration of the rights and needs of legitimate users of the sea • Minimise environmental impact • Promote sustainable development • Adhere to the Polluter Pays Principle • Maximise the reuse of materials • Commercial viability • Practical integrity The following key documents have also informed the provisions presented: • Decommissioning of Offshore Renewable Energy Installations under the Energy Act 2004: Guidance notes for Industry, DTI, December 2006 • Guidelines and Standards for the Removal of Offshore Installations and Structures on the Continental Shelf and in the Exclusive Economic Zone, International Maritime Organisation (IMO), 19th October 1989 • Guidance Notes for Industry: Decommissioning of Offshore Installations and Pipelines under the Petroleum Act 1998, DTI, http://www.og.dti.gov.uk/regulation/guidance/decommission.htm Page 5 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Review of the Current State of Knowledge on the Environmental Impacts of the Location, Operation and Removal/Disposal of Offshore Wind-Farms, OSPAR, 2006, ISBN 978-1-905859-15-3, www.ospar.org • Guidelines for Environmental Risk Assessment and Management, Defra, September 2002, http://www.defra.gov.uk/environment/risk/eramguide/08.htm GGOWL’s starting assumption for establishing the extent of decommissioning is complete removal. This assumption has been assessed against the guiding principles listed above and, where appropriate, alternative solutions have been identified. A summary of the proposals for decommissioning the offshore components of the Greater Gabbard Offshore Wind Farm are outlined in the table below: Component Decommissioning Proposal Wind Turbine/generating equipment Complete removal from site Foundations (wind turbine, met mast, transformer platforms) Cut off at or below seabed and removed Cables (inter-array and export) Left in situ Anemometry masts Complete removal of structure Transformer platforms Complete removal of topside The measures proposed to decommission the installations as described above reflect the strong emphasis GGOWL puts on minimising risks to safety and to the environment. As such, GGOWL has sought practical solutions that involve minimal offshore operations. In the absence of re-powering, GGOWL intends to begin decommissioning the project at year 25. It is intended that this process offshore be completed over a period of 300 days. The decommissioning programme as currently proposed is to be reviewed and revised throughout the lifecycle of the project to reflect changing circumstances and regulatory requirements, and to incorporate improvements in knowledge and understanding of the marine environment and advances in technology and working practices. A formal schedule for review is proposed, where year 23 is identified as the final opportunity for a thorough review and consultation process. GGOWL’s approach to consultation about these works mirrors that undertaken during the EIA process for the project, where importance is attached to early and open communication Page 6 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme with all key stakeholders. Key stakeholders will have the opportunity to input into the draft decommissioning programme, and to consider the final programme to be agreed prior to decommissioning. Appropriate consultation and notification will be undertaken prior to the works taking place. A cost estimate for the programme has been derived based on the equipment and personnel requirements and the duration of the works. Financial security provisions have been carefully considered to ensure that this liability will be met. Details of the cost and financial aspects of the proposals are provided as Annex C to this programme. 3.0 BACKGROUND INFORMATION 3.1 Project Status The Greater Gabbard Offshore Wind Farm was awarded through the Round Two site allocation process in December 2003. An Environmental Impact Assessment was carried out and an application for consent for the project submitted in October 2005. The project was awarded the following consents in February 2007: • Section 36 Electricity Act 1989 (construction and operation of the wind turbines, offshore transformer stations and met masts; granted by DTI) • Section 5 Food and Environment Protection Act 1985 (installation of foundations of offshore structures, rock armouring, scour protection etc; granted by DEFRA) • Section 34 Coast Protection Act 1949 (obstruction to navigation works; granted by DEFRA) • Section 36A Electricity Act 1989 (navigation extinguishment declaration; granted by DTI). Planning permission has also been received under Section 57 of the Town and Country Planning Act 1990 for the onshore works at Sizewell. The project is scheduled to commence construction offshore in late 2008. 3.2 Project Overview The wind farm is to be located 26km off the Suffolk coast, adjacent to two sand banks known as Inner Gabbard and The Galloper. The project comprises 140 wind turbines which will be installed over a total area of 147km2 and will generate a maximum capacity of 500MW. The power will be brought to shore at Sizewell where an onshore sub-station will be located to connect the wind farm to the National Grid. Figure 1 below shows the site’s location, boundaries and the cable route to shore. Page 7 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Figure 1: Greater Gabbard Site Boundaries The site coordinates are as follows: Page 8 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Offshore transformer platforms will transform the turbine interconnection voltage from 33kV to 132kV for transmission ashore by up to four export cables. These offshore sub-stations will have typical dimensions in the order of 20m length x 20m width x 15m height. Up to six permanent meteorological masts of a nominal height of up to 105m will also be constructed. The foundations for the wind turbines will be steel monopiles of up to 6.5m diameter, driven into the seabed using a hydraulic hammer from a jack-up barge/drilling rig or purpose built installation vessel. Scour protection in the form of rock, gravel or frond mats may be used. Transition sections will be used to connect the wind turbine tower to the foundation by means of a grouted joint or a flanged connection. The foundations for the meteorological masts will consist of a steel monopile with a diameter of approximately 2.5m. Scour protection may be required and would be similar to that used for wind turbine monopiles. The foundations for the offshore substations will be based on a jacket structure which will be secured to the seabed with piles. If required, the use of scour protection around the foundations may consist of loose rock or rough gravel, to be installed by means of grab and drop or bulldozed over the side of a vessel. The use of mattresses for protection may also be used and installed by means of lowering from a vessel to the base of the foundation. The turbines will be connected to the offshore sub-stations via a network of 33kV cables (inter-array cables) that are laid between the wind turbines and the offshore sub-stations. Up to four subsea 132kV cables (export cables) will connect the wind farm to the shore. The inter-array and export cables are likely to be buried using an underwater cable plough that executes a simultaneous lay and burial technique by lifting a wedge of sediment, allowing the cable to fall into this trench and then folding the sediment back on top of the cable. In exceptional circumstances, and only following written authorisation from DEFRA, cable burial Remote Operated Vehicle (ROV) may be used. This utilises high-pressure water jets to fluidise a narrow trench into which the cable is located. The jetted sediments settle back into the trench. The inter-tidal cables may be installed from a barge or jack-up, which is either beached or moored near Sizewell beach. The cable will be pulled beneath the inter-tidal zone using a directional drilling technique, either beginning at the start of the run out to sea or at the end of the run from sea. Near shore and deep water lay may be separate operations. Page 9 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 3.3 Decommissioning Programme Layout of Wind Farm and Ancillary Works Figure 2 shows an indicative layout of the wind farm. The final layout will be determined in agreement with DTI prior to construction. Page 10 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Figure 2: Indicative Wind Farm Layout 3.4 3.4.1 Site Characteristics Physical Characteristics A range of surveys have been completed by GGOWL to establish the physical environment at the Greater Gabbard site. These studies informed the Environmental Impact Assessment for the project and included: • two geophysical surveys • a shallow geotechnical campaign (maximum penetration 25m) • a deeper geotechnical campaign (maximum penetration 50m) • a metocean campaign • benthic grab campaign Additional information has also been obtained from other sources to complement that obtained from the above surveys described above. The additional data acquisition includes: Page 11 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • SeaZone sea bed bathymetry data: to inform the far-field model domain and to provide base mapping • UK Hydrographic Office (UKHO) historical charts: to inform the study of historical changes in the Inner Gabbard and The Galloper banks shape and form. • Wavenet Data: a strategic wave monitoring network that provides a single source of real time wave data from a network of wave buoys located offshore from areas at risk from flooding. • TotalTide tidal level data: to synthetically generate astronomical tidal level data and current speed so that measured data from the metocean surveys can be compared against the model data for an assessment of consistency • British Geological Survey (BGS) surface sediment information: to provide a more regional indication of the sea bed material • Met Office data: wind and wave time series to provide details on the longer-term offshore wave climate The Greater Gabbard Environmental Statement (October 2005) presents a full description and analysis of the physical characteristics of the Greater Gabbard site. Following the submission of the ES in October 2005, further detailed site investigation works have been carried out to further GGOWLs understanding of the site. The following sections provide summary information sufficient to inform consideration of the decommissioning provisions. A. Metocean Characteristics The location for the proposed Greater Gabbard Offshore Wind Farm (GGOWF) has the following metocean characteristics: Estimated Average Mean Wind Speed (predicted) Water Depth Range Mean Surface Temperature Salinity 8.5-9.5 m/s at 80m AMSL -3.6m to – 8m CD (Inner Gabbard) -2.4m to – 10m CD (The Galloper) -20m to – 50m (off the sandbanks) 16.5°C (summer) 6°C (winter) <34.75g/kg (summer) >34.75g/kg (winter) Page 12 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme B. Topography& Bathymetry Regionally the bathymetry generally deepens gradually from the UK coastline to the central part of the Southern North Sea and shows a relatively flat surface predominantly between 20 and 40 metres water depth. The area is characterised by large areas of low gradient upon which 5 linear “open-shelf” sandbanks are formed. These sandbanks include the Inner Gabbard and the Galloper. Inner Gabbard and Galloper sandbanks are similar in shape and proportion: • A width of 1 to 1.2km in the middle and shallowest section • A width of 1.4km to 1.5km at the northern and southern ends • A length of approximately 26km Minimum depths on the Inner Gabbard and The Galloper are 3.8m and 2.5m CD respectively, as surveyed in 2004. Both banks are thought to be relatively stable, and are not expected to move significantly during the lifetime of the wind farm project. C. Currents, Tidal Streams, and Rise and Fall of Tide Tidal range varies across the area, with a spring/neap range at Harwich of 3.6/2.3 metres. Storm surges due to abnormal weather conditions can cause significant changes to predicted heights with the sea rising up to 3 metres above these heights in extreme NW and N conditions, or falling up to 2 metres below these heights in Southerly gales. General tidal flows are determined from the admiralty tidal stream atlas, tide tables and the tidal diamonds on the chart. At the Greater Gabbard site, these tidal streams run at approximately 200 degrees from about 5 hours before HW Dover turning to approximately 020 degrees by 2 hours after HW Dover. Tidal streams at the proposed site are noted as a maximum of 2.2 knots at spring tides. Astronomical tidal levels relevant to the Greater Gabbard site, determined from the Admiralty tide tables for the nearby Standard Ports of Walton-on-the-Naze and Harwich are summarised below. Tidal Level (mCD) Walton-on-theNaze Harwich Inner GabbardA GalloperB LAT MLWS MLWN MHWN MHWS HAT 0 +0.40 +1.10 +3.40 +4.20 +4.60 0 +0.6 +0.2 +0.40 +0.9 +1.0 +1.10 +1.4 +1.3 +3.40 +3.1 +3.2 +4.00 +3.7 +3.8 +4.40 +4.0 +4.2 Page 13 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme (A) Posn: 51’ 56” N 01’ 55” E (B) Posn: 51’ 48” N 01’ 58” E Tidal streams running across the outer part of the Thames Estuary (due south of Orford Ness) are generally rectilinear running in a SSW (ingoing) or NNE (outgoing) direction. Elsewhere tidal streams generally run in the direction of the coast. The tidal streams at The Galloper (51°44.3’ N 1°48.3’E) are presented below: Time from High Water at Sheerness (hrs) -6 -5 -4 -3 -2 -1 High Water +1 +2 +3 +4 +5 +6 Current Direction Spring Tide 320 215 209 211 216 221 275 029 037 039 038 036 020 0.1 0.4 0.7 0.9 0.8 0.5 0.1 0.4 0.7 0.9 0.7 0.5 0.2 Velocity (m/s) Neap Tide 0.1 0.3 0.5 0.6 0.5 0.3 0.1 0.3 0.5 0.6 0.5 0.3 0.1 D. Sea and Swell From metocean surveys undertaken at the site, the waves in the vicinity of the Inner Gabbard and The Galloper banks are all relatively small, short period wind swells. The local wind conditions appear to play an important role in determining the height and period of the waves in the region. The area is also well known for storm surges, and the extreme water levels in the area are caused by such surges acting over large tidal ranges. Metocean Surveys were undertaken in November 2004 and March 2005 to capture sufficient measures of waves, water levels, currents and suspended sediment concentrations within wind farm area. The data provided was used to demonstrate an understanding of the waves and tides in the area, and to allow a consideration of these processes in conjunction with sediment transport. Understanding was also required for the occurrence and effects of major events, in particular high frequency low energy events (tidally dominated events) and low frequency high energy events (wave dominated events). In general, the surveys show that: • Maximum tidal range is of the order of 4m Page 14 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • surface currents peaked at approximately 1.8m/s • bed currents were of the order of 0.7 to 1.7m/s • the currents were aligned with the local sea bed topography • typical significant wave heights were of the order of 3.6m • maximum wave heights of the order of 6.2m were recorded • the larger waves tended to originate from the north-east E. Geological Characteristics The solid geology at the site comprises a thick sequence of London Clay Formation of Eocene age, comprising firm to stiff marine silty clay, clayey and sandy silts and subordinate sands. This formation is evident underneath the site and surrounding area to a depth of over 100m (this being the penetration of the geophysical survey), with outcrops at the seabed throughout the area. Older Palaeocene strata (Lambeth Group and Thanet Formation) lie below the London Clay and above the surface of the Upper Chalk. Neither these formations, nor the chalk, outcrop at the seabed within the site. There is evidence at the northern end of the Inner Gabbard of an east to west trending channel feature, considered to be the Paleo-Stour, which is interpreted as being filled with clayey, sandy gravels and sandy, gravelly clays. The Inner Gabbard and The Galloper are part of a group of very similar tidal sand banks that also includes the Outer Gabbard, the North Falls and the South Falls. These banks are of the open shelf linear type but they are particularly straight and narrow examples compared to other banks of this type. F. Geophysical Surveys Two geophysical survey campaigns were undertaken during 2004 and 2005 to provide detailed information on the bathymetry, sea bed morphology, obstructions and shallow geology. The first campaign showed that: • The shallow geology is dominated by Holocene Sands overlying London Clay • The London Clay formation represents a sub-sea bed depth of between 60 and 100m • Water depths to either side of the banks reach 50m (CD) Page 15 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Sand waves occur on the sea bed to the south east of The Galloper • The remainder of the sea bed surrounding the banks is generally flat and featureless • Asymmetric sand waves occur on the flanks of both banks, with the steeper sides in opposing directions on either side of the banks • Large sand wave covered by smaller sand waves and megaripples are shown on the southern end of Inner Gabbard • A pronounced paleo channel can be seen to the north of Inner Gabbard running east-west reaching depths of 37m (CD), and passes beneath the overlying sandbank • The minimum depths on the Inner Gabbard and The Galloper are 3.80m and 2.48m (CD), respectively The second survey included areas that were added to the wind farm site following an agreed boundary change prior to the consent application. This second survey campaign showed that within the main survey area: • there are large areas of flat featureless seabed • zones of sand waves and mega ripples exist to the south and north • Holocene sediment (sands and gravels) overlay London Clay • the thickness of the Holocene material ranges from centimetres to 5m • the London Clay extends more than 100m below the sea bed • there is evidence of extensive faulting in sections of the London Clay • a paleo-channel exists to the north, running east-west and is approximately 400 to 900m wide, and up to 8m deep In general, the survey shows that along the cable route: • the formations are generally the same as the main wind farm site • in the vicinity of Aldeburgh Napes the sea bed material is composed of medium to coarse grained sands • in the last 5km to the shore, soft clays exist Page 16 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme G. Geotechnical Surveys A geotechnical survey was undertaken during September 2004 at four locations within the proposed Greater Gabbard Offshore Wind Farm site. Two of the locations were on the Inner Gabbard and The Galloper sandbanks and two in the surrounding area. The purpose of the survey was to acquire data relating to the underlying geology of the wind farm sites. This was undertaken using a combination of sample boreholes, Standard Penetration Tests (SPT) and Cone Penetrometer Test (CPT) at each location. In general, the survey shows that: • The sand layer is deeper on the banks than in the surrounding area. The sandbanks have sediment depths of 13.75m and 21.65m on The Galloper and the Inner Gabbard, respectively. • In the surrounding area to The Galloper and the Inner Gabbard the depths of sand are 0.4m and 0.1m, respectively • Sand found on the banks is essentially homogenous, as slightly silty, fine to medium sands. Sand generally contains less than 2% of gravel size particles • Sand found in the surrounding areas has generally the same composition as on the banks, but with a greater gravel size content (approximately 10%) including shell fragments • The clay layer ranges from 14.40m to 35.65m deep • The clay is part of the lower London tertiary deposits, known as London Clay • The clay is generally firm, becoming stiff to very stiff with depth • Proportions of silt and clay are consistent, typically about 45% and 55% respectively A thorough geotechnical campaign was undertaken in 2006. existing geotechnical knowledge. This work confirmed the H. Benthic Surveys Detailed surveys were undertaken during November 2004 and April 2005. The surveys covered the proposed wind farm site and cable route. The purpose was to acquire data relating to sediment characteristics and benthic communities, particularly Sabellaria spinulosa. In general, the survey shows that: • the Inner Gabbard and The Galloper sandbanks are composed of medium sands with some gravel content Page 17 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • the surrounding deeper sea bed is composed of differing sediment types, characterised by mud/clay, sand and gravels in differing proportions • the cable route is characterised by a mix of sediments running through sands and gravels to muds and then sands from the Inner Gabbard to the shore, respectively 3.5 Relevant Projects and Activities There are presently a range of different developments and activities taking place in the vicinity of the Greater Gabbard Offshore Wind Farm. GGOWL has undertaken extensive consultation with key stakeholders to inform the project’s EIA. A full analysis of the projects relevant to the Greater Gabbard project is contained in Section 8 of the Environmental Statement. It is proposed that the register of key consultees identified during the EIA process is reviewed and amended throughout the lifetime of the project and during the formal review opportunities identified in section 9 of this document. Similarly, a register of relevant activities and developments will be reviewed and maintained. A consultation strategy and schedule will be devised prior to decommissioning. The nature of this strategy will reflect the activities underway at the time; the interaction between these activities and the decommissioning works; the relationships that have been built up with stakeholders; and appropriate guidance and requirements that exist at the time. In any event, the strategy will be based on the principles of clear, timely and open communication. The starting point for the development of this strategy is the identification of existing and reasonably foreseeable proposed developments in the region surrounding the Greater Gabbard offshore wind farm. The following key activities currently take place in the area and a brief review is presented here: • Other offshore wind farms; • Marine aggregate extraction; • Disposal of dredged material; • Subsea cables; • Oil and gas activities It is noted that there are currently no oil and gas pipelines in the area. 3.5.1 Offshore Wind Farms A number of Round One and Round Two projects have been proposed or are in operation in the vicinity of the Greater Gabbard site: Page 18 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Site Kentish Flats Gunfleet Sands Gunfleet Sands II London Array Thanet Developer Round of Award Decommissioning Programme Capacity Status Vattenfall One 90MW DONG Energy One DONG Energy Two Up to Consented, 108MW construction due 2009 64MW Pre-consent DONG Energy/Shell/EON Warwick Energy Two Two Generating Up to Consented 1000MW 300MW Consented Page 19 of 58 Location Distance from GGOW F 8.5km off 55km Whitstable 8km off 40km Clacton 10km off 40km Clacton 20km off 15km Essex 13km off 35km Margate Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Figure 3: Offshore Wind Projects in the Greater Thames Estuary It is possible that there may be synergies and interactions between decommissioning activities at the various sites. GGOWL will promote formal industry collaboration on this issue and, as a minimum, will approach other developers to consider potential opportunities as part of the ongoing review process for the Greater Gabbard decommissioning programme. However, GGOWL’s starting assumption is that decommissioning will be undertaken in isolation at Greater Gabbard in order that the provisions can be fully costed and sufficient financial security provided. The status and requirements of surrounding projects will be carefully considered in the planning and execution of the decommissioning process. 3.5.2 Marine Aggregate Extraction The following areas are licensed, or are to be licensed (subject to consent) for the extraction of marine aggregate within 10 km of the wind farm site: Company RMC marine (SCS) RMC marine (SCS) Extraction Area Reference 239/1 452 Status Licence Application pending Page 20 of 58 Distance from Greater Gabbard 2.2km to NW 0.5km to W Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Company Extraction Area Status Distance from Reference Greater Gabbard Hanson 119/3 Licence 4.1km to W Figure 4: Marine Aggregate Areas in the vicinity of the Greater Gabbard Wind Farm 3.5.3 Disposal of Dredged Material The majority of sites for the disposal of dredged material are at the mouth of estuaries, and are primarily sized for the quantities of material excavated from rivers and ports. The Thames Estuary has several established disposal areas: Name Status Inner Gabbard Area 108/3 Inner Gabbard (east) North West Wash (HU199) Open Open Submitted Consent Ship Open Page 21 of 58 Distance from Greater Gabbard 5.2km 17.3km for 1km 19.2km Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme The proposed extension to the southern dock space in the Port of Felixstowe is currently under consideration. The material extracted during the construction process (up to 3.86 Mm3) is proposed to be disposed at the existing Inner Gabbard dispersive disposal site, and the site known as Inner Gabbard (east) disposal site. Figure 5: Marine Disposal Sites in the Vicinity of Greater Gabbard 3.5.4 Subsea Cables There are eight known subsea cables in the vicinity of the project. These are summarised in the following table (source: The Crown Estate): Company National Grid Transco Hermes GT UK BT Reference UK-Netherlands Interconnector (BritNed) Hermes Atlantic Crossing Seg B1 Farlands Status Consented Telecoms cable not in operation Telecoms cable, in operation Telecoms cable, in operation Page 22 of 58 Distance from Greater Gabbard South of turbine array Intersects export cable route 3km to east of turbine array Intersects export cable route Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Company Decommissioning Programme Reference BT BT UK Netherlands 4 UK Netherlands 12 Flute (interoute) Concerto North Flute (interoute) Concerto South Status Decommissioned Scheduled to be decommissioned Telecoms cable, in operation Telecoms cable, in operation Distance from Greater Gabbard N/A Intersects export cable route Intersects export cable route Intersects export cable route Figure 6: Subsea Cables in the vicinity of Greater Gabbard 3.5.5 Oil and Gas At the time of undertaking the Greater Gabbard offshore wind farm Environmental Impact Assessment, there were no known offshore oil and gas activities within 10km of the proposed Greater Gabbard Offshore Wind Farm. During 2007 the 24th licensing round for oil and gas was announced. A selection of the blocks awarded were within the Thames Estuary, albeit some distance from the Greater Gabbard wind farm. Figure 7 provides the details of those awards Page 23 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Figure 7: Blocks Awarded in the Thames Estuary Region through the 24th Oil and Gas Licensing Round 3.5.6 Fishing Activity Section 9.5.2 of the Environmental Statement provides a thorough analysis of the fishing activity on site and was informed by site surveys; a review of existing data; and consultation with industry. The type and volume of fishing activity currently taking place in the vicinity of Greater Gabbard offshore wind farm is relatively low. Whilst the ground conditions at the site are reasonable for most types of fishing, there are key constraints limiting activity including: Page 24 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Lack of shelter: The Inner Gabbard and The Galloper sandbanks provide little or no shelter to small vessels in any prevailing wind direction. The sea becomes choppy above the sand banks, making crossing and working the banks uncomfortable, difficult and at times dangerous. The sand banks themselves are, generally described as “uncomfortable’ by local fishermen. • Weather conditions: a major factor for many smaller vessels, given the large distance between the site and shore. • Wrecks: there are a number of wrecks in the area of the sandbanks that are avoided by the drifters and trawlers 3.5.7 Shipping Activity Section 9.5.3 of the Environmental Statement provides a thorough analysis of navigation activity in the vicinity of the Greater Gabbard offshore wind farm site and was informed by surveys; a review of existing data; and consultation with industry. A review of this activity is presented below. Shipping using the area includes commercial shipping, fishing, recreational yachting and dredging. The various sand banks in the area modulate the main routes for commercial traffic in the area, with the ‘gaps’ between them being well marked east-west navigable channels that are used by vessels making their way into the main ship channels of the Thames and Haven ports A Traffic Separation Scheme (TSS) and Vessel Traffic System (VTS) was proposed in August 2005 by the ‘Sunk User Group’. A submission to United Kingdom Safety of Navigation (UKSON) was presented to the International Maritime Organisation (IMO) for adoption in 2007. This scheme has been approved and will be in place before the project is constructed. Maritime traffic Surveys conducted during 2004 indicated an average of 88 vessels per day in the area with an average number of 115 vessel tracks seen by radar per day. Analysis shows that over 90% of these tracks were made by commercial shipping (cargo, passenger, tanker and dredger) with only 8% made by fishing vessels and 1% by recreational craft. Most of the vessels were small with only 12% of the commercial vessels being over 40,000 DWT. The predominant flags of registry were UK and Dutch. The following Figure 8 shows information gathered on the busiest survey day, 31st August 2004. Page 25 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Figure 8: Shipping Traffic within the vicinity of Greater Gabbard Wind Farm, 31/08/04 3.6 Nature Conservation There are no existing designations in the vicinity of the project that extend offshore, although many parts of the coastline adjacent to the Greater Gabbard Offshore Wind Farm and landfall have some form of conservation status. It is possible that the decommissioning process may impact the integrity of these sites. The relevant and important designations along the coastline of Suffolk are as follows: Figure 9: Nature Conservation Designations in the Vicinity of Greater Gabbard Page 26 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Ramsar Sites Ramsar sites are wetlands of international importance and are designated under inter governmental treaty for their waterfowl populations, their important plants and animal assemblages, their wetland interest or a combination of these. The convention allows for such sites to extend to 6m below mean low water. The relevant sites are: Site Name Grid ref Area (ha) TM465662 2004 Date Designated Minsmere1976, Walberswick extended (UK11044) 1992 Alde-Ore TM432487 2,437 1996 Estuary (UK11002) Qualifying Interest Representative Wetland, rare species Rare Species; substantial numbers of individual waterfowl indicative of wetlands; 1% of waterfowl species population Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) SACs are covered by the Habitats Directive (Council Directive 92/43/EEC on the Conservation of Natural habitats and of Wild Fauna and Flora) which requires European member states to establish sites for the purpose of contributing to the maintenance/restoration of habitants and species of favourable conservation status listed in Annexes I and II of the Directive. SACs relevant to the Greater Gabbard project are presented below. Site Name Grid Ref Area (ha) Date Designated Qualifying Interest Page 27 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Minsmere to Walberswick Heaths and Marshes (UK0012809) Alde, Ore and Butley Estuaries SAC (UK0030076) Orfordness – shingle Street SAC (UK0014780) Decommissioning Programme TM468682 1265 2001 Annex I qualifying habitats are: • Annual vegetation of drift line • European Dry Heaths TM444509 1562 2001 Annex I qualifying habitats are: • Mudflats and sandflats not covered by seawater at low tide • Atlantic salt meadows Annex I qualifying habitats are: • Coastal lagoons • Annual vegetation of drift lines • Perennial vegetation of stony banks TM440486 901 2001 SPAs are designated under the Birds Directive (Council Directive 79/409/EEC on the Conservation of wild birds) which requires member states to conserve habitats for rare or vulnerable species in addition to regularly occurring species of migratory birds. In the UK, all SPAs are first notified as SSSIs. Relevant SPAs are detailed below Site Name Grid Ref Area (ha) Date Designated Minsmere Walberswick (UK9009101) TM465662 2000 1992 Sandlings (UK9020286) Alde Ore Estuary (UK9009112) TM403602 1562 2001 TM432487 2437 1996 Qualifying Interest Nationally important numbers of six breeding species (Bittern, Marsh Harrier, Avocet, Little Tern, European Nightjar, Wood Larks) and three wintering species (Bittern, Hen Harrier, Avocet) Nationally important numbers of European Nightjar and Wood Larks Nationally important numbers of breeding Marsh Harrier, Avocet, Sandwich Tern and Little Tern and wintering Avocet; internationally important numbers of wintering Redshank and breeding Lesser Black Backed Gull; also important assemblages of breeding seabirds and wintering waterbirds. It is also possible that an SPA may be designated in the Greater Thames Estuary due to the presence of bird species including Red Throated Diver. Page 28 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme An Appropriate Assessment was carried out prior to the Greater Gabbard Offshore Wind Farm receiving consent in order to satisfy the requirements of the Habitats Directive (EC/92/42/EEC) and the Wild Birds Directive (EC/79/409/EEC), known together as the Habitats Directive. The Appropriate Assessment is provided as Annex B. This Assessment was considered necessary because of concerns raised about the potential impacts of the Greater Gabbard Offshore Wind Farm development on the breeding population of lesser black-backed gulls at the Alde–Ore SPA; and the potential cumulative impacts from the wind farm and other developments (proposed and extant) in the Thames Estuary on the integrity of the potential Greater Thames Estuary pSPA. The Assessment addressed both these issues and, taking into account impact predictions, evidence from other sites, uncertainties and whether there was reasonable cause for concern, it found that the Greater Gabbard Offshore Wind Farm would not have an adverse effect on the integrity of the Alde-Ore SPA. It was also found that, at the present state of knowledge, the wind farm would not have an adverse effect on the integrity of the Greater Thames Estuary pSPA, either alone or in combination with other projects. The Assessment took a lifecycle approach to the project, with the conclusions applying to all phases of the works, beyond construction and operation through to decommissioning. Sites of Special Scientific Interest Sites of Special Scientific Interest (SSSI) are areas designated under the Wildlife and Countryside Act 1981 (Section 28) as being of national nature conservation interest. They are intended to provide the best examples of wildlife habitats, geological features and landforms and receive greater protection through the Countryside and Rights of Way Act 2000. There are a number of SSSI’s and an Area of Outstanding Natural Beauty (AONB) situated close to the export cable landfall and associated onshore works. These are presented below Site Name Minsmere-Walberswick Heaths and Marshes Sizewell Marshes Leiston-Aldeburgh Grid Ref TM465662 TM466638 TM461595 Area (ha) 2326 104 534 Date Designated 1987 1992 1986 Areas of Outstanding Natural Beauty: Site Name Suffolk Coasts and Heaths 4.0 Area (ha) 40,400 Date Designated 1970 DESCRIPTION OF ITEMS TO BE DECOMMISSIONED 4.1 Guiding Principles In considering the proposed decommissioning programme for the Greater Gabbard Offshore Wind Farm, GGOWL has sought solutions that adhere to the following principles: Page 29 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Guiding Principle Decommissioning Programme Comments Safety for all at all times GGOWL is committed to adhering to the highest standards for health and safety throughout the lifecycle of the Greater Gabbard project. GGOWL seek to promote safe practices and minimise risk in the development and implementation of decommissioning solutions. Consideration of the rights GGOWL respects the rights and needs of other users of the and needs legitimate users seabed. Decommissioning activities will seek to minimise of the sea the impact on stakeholders and emphasis will be placed on clear, open communication. Minimise environmental In considering decommissioning measures, the Best impact Practicable Environmental Option (BPEO), will be chosen in order to minimise impact on the environment at an acceptable cost. Promote sustainable In decommissioning the Greater Gabbard project, GGOWL development will seek to ensure that, as far as is reasonably practicable, future generations do not suffer from a diminished environment or from a compromised ability to make use of marine resources. Adhere to the Polluter Pays GGOWL’s decommissioning and waste management Principle provisions acknowledge our responsibility to incur the costs associated with our impact on the environment. Maximise the reuse of GGOWL is committed to maximising the reuse of waste materials materials and pays full regard to the ‘waste hierarchy’. Commercial Viability Practical Integrity In order that commercial viability is maintained, the BATNEEC (Best Available Technique not Entailing Excessive Cost) decommissioning solutions will be sought. Solutions that are necessary to achieve one or more of the above objectives must be practicable. It is possible that not all of these objectives will be consistent with each other. In such circumstances, solutions will be optimised subject to the necessary constraints. For example, with respect to minimising the impact on the environment, the Best Practicable Environmental Option (BPEO) will be sought where the option will be chosen that provides the most benefit or least damage to the environment as a whole, at an acceptable cost, in both the long and short term. Similarly, BATNEEC solutions ensure that the reduction in risk is balanced with the practicability and cost of doing so. In seeking to achieve these objectives, GGOWL is also committed to adhering to UK legislation and international obligations. As such, GGOWL has drawn upon the following documents to ensure the decommissioning programme meets those requirements: • Decommissioning of Offshore Renewable Energy Installations under the Energy Act 2004: Guidance notes for Industry, DTI, December 2006 Page 30 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Guidelines and Standards for the Removal of Offshore Installations and Structures on the Continental Shelf and in the Exclusive Economic Zone, International Maritime Organisation (IMO), 19th October 1989 • Guidance Notes for Industry: Decommissioning of Offshore Installations and Pipelines under the Petroleum Act 1998, DTI, http://www.og.dti.gov.uk/regulation/guidance/decommission.htm • OSPAR guidance documents on offshore wind farms; • Guidelines for Environmental Risk Assessment and Management, Defra, September 2002, http://www.defra.gov.uk/environment/risk/eramguide/08.htm • United Nations Convention on the Law of the Sea (UNCLOS), 1982. Other legislation of relevance includes: • Hazardous Waste Regulations 2005; and • London Convention 1972 and the 1996 Protocol, relating to the prevention of marine pollution by dumping of wastes. • Construction (Design and Management) Regulations 2007 • Appropriate H&S Regulations It is noted that archaeological no-build zones have been defined for the Greater Gabbard project. Necessary measures will be put in place during the decommissioning of the project to ensure that these areas, or other such areas that may be identified during the operation of the project, are not compromised during decommissioning activities. 4.2 Proposed Decommissioning At the time of writing GGOWL is undertaking key design and development work for the project. The overriding aim is to develop a project that is safe, durable and cost-efficient throughout its lifetime. Taking a lifecycle approach to the design and development work ensures that decommissioning considerations are incorporated into decision-making and, where possible, means that the principles identified above are being incorporated into early decision-making. Taking into account the UK’s commitments under UNCLOS; IMO standards and the work of OSPAR, GGOWL’s starting assumption in establishing the decommissioning requirements has been complete removal of all offshore components to shore for reuse, recycling or incineration with energy recovery or disposal at a licensed site. This assumption has been assessed for all components against the key criteria presented above. In some instances this option has not been considered to be appropriate and alternative options have been Page 31 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme considered. These alternatives have also been assessed according to the above criteria and the optimum solution selected. A further prerequisite for not fully removing a component is consistency with at least one of the circumstances set out on page 25 of DTI guidance as situations where such a solution may be considered. These circumstances set out in the DTI guidance are listed below (it is noted that there is some duplication with the guiding principles described above). • “the installation or structure will serve a new use, whether for renewable energy generation or for another purpose, such as enhancement of a living resource (provided it would not be detrimental to other aims, such as conservation). In these situations, we would normally expect the decommissioning programme to set out the eventual decommissioning measures envisaged should the installation or structure finally become ‘disused’ and a point reached when extending its life or finding a beneficial reuse is no longer possible; • entire removal would involve extreme cost. It is considered that design decisions should, as far as possible, result in installations which are affordable to remove, but it is recognised that some elements, such as deep foundations, may nonetheless be costly to remove; • entire removal would involve an unacceptable risk to personnel; • entire removal would involve an unacceptable risk to the marine environment; • the installation or structure weighs more than 4000 tonnes in air (excluding any deck and superstructure) or is standing in more than 100 m of water and could be left wholly or partially in place without causing unjustifiable interference with other uses of the sea.” To facilitate assessment of the decommissioning proposals, the analysis is preceded by a description of each of the components of the project to be decommissioned. 4.2.1 Offshore Wind Turbines Component Description At the time of writing, the make, model and capacity of wind turbine to be installed at Greater Gabbard offshore wind farm has yet to be finalised. These details will be confirmed prior to sign-off of the GGOWL decommissioning programme and the following provisions are based on the maximum dimensions and weights associated with a 3.6MW turbine and are consistent with the dimensions and weights used in GGOWL’s Environmental Statement. Consistent with the conditions of consent for the works, the following decommissioning provisions assume a maximum tip height of 170m above Mean Sea Level (MSL), with a Page 32 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme nominal 105m hub height and a maximum rotor diameter of 130m. The towers will be tapered tubular steel towers There will be three blades attached to a nacelle housing the generator, gearbox and other operating equipment. The unit transformer will be located in the tower base (above the high tide level). The transformer will either be oil-filled (surrounded by a bund conforming to the required standards) or cast-resin. Figure 10: An Offshore Wind Turbine The hub components of the offshore wind turbines will have a complete weight of 95 tonnes and will be made up of: • Hub casting: nodular cast iron • Blades: three blades, each up to 52m long and made from carbon fibre Figures 11-13: Construction of an Offshore Wind Turbine Page 33 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme The Nacelle will have dimensions in the order of 20m x 10m x 10m and will weigh approximately 125 tonnes. Components will include: • • • • • Gear box: 50 tonnes Generator: 50 tonnes Main Shaft and bearings: 5 tonnes Transformer/power inverter: 1 tonne Housing: 19 tonnes Key components of the tower section will include: • Ladders • Lift • Power inverter • Power cable • Control equipment • Bolts • Tower sections Of these components the tower sections themselves will make up the bulk of the 250 tonne complete weight. Figure 14: Tower Section A. Decommissioning Proposal It is intended that all the above components are fully removed from site, before being disassembled onshore. This reduces offshore risk, for example in relation to spillage, and facilitates safe deconstruction onshore. In terms of the key criteria, this approach has been assessed as follows: Page 34 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme OFFSHORE WIND TURBINES Criterion Complete Removal Safety for all at all times Safest option, involving standard procedures and minimal work offshore. Consideration of the rights Complete removal of structure best long-term solution. and needs legitimate users of Appropriate notification and consultation would precede the sea temporary works/disturbance Risk of spillage slight as all pollutants are fully contained Minimise environmental inside the nacelle and removed in single lift. All impact dismantling takes place onshore therefore minimizing the risk of spillage. Materials completely removed from site, ensures future Promote sustainable generations do not suffer from a diminished environment or from a compromised ability to make use of marine development resources. Adhere to the Polluter Pays Entirely consistent: owner pays full cost of removal and Principle disposal Maximise the reuse of All deconstruction to take place onshore, maximum materials. potential for reuse of materials. Most commercially viable solution:, minimal works Commercial Viability offshore, maximum re-sale/reuse value from materials, minimum residual risk Known/tried procedures reduced risk due to minimal Practical Integrity offshore works 4.2.2 Turbine Foundations & Transition Pieces A. Component Description A monopile solution has been selected for the turbine foundations for the Greater Gabbard offshore wind farm project. This solution comprises driving a hollow steel pile into the seabed sub-strata, relying on the frictional properties of the seabed sediments for support. These structures will extend up to 65m in length, 6.5m in diameter and 700 tonnes in weight. Foundations will require ancillary equipment including: • Cable entry and protection features: The cables are to be installed in a “J-tube” arrangement, a steel tube of approximately 250mm diameter located internally within the monopile. Each structure will have between two and five J-tubes. At the end of each J-tube, cable entry will be facilitated by a bell-mouth shaped opening. Page 35 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Corrosion protection: a combination of a protective paint coating and installation of sacrificial anodes on the subsea structure. The anodes are standard products for offshore structures and are welded onto the steel structures. The anodes typically consist of zinc and aluminium, and are connected to the structure via doubler plates to ensure the integrity of the primary structure is maintained in the unlikely failure of an anode connection. Cadmium will not be used. The number and size of anodes will be confirmed during detailed design. • Transition pieces making the connection between the foundation and the tower will weigh up to 300 tonnes and will include the following components: • Boat fenders • Access ladders • Transformer (oil filled) • Switchgear (gas filled breakers) • Control equipment • Cables • Access deck • Handrail sections • Grating • Marine access door An access platform comprising two access ladders (with integral personnel safety protection) will enable access to the wind turbine at any state of the tide. The access ladders and platform will be constructed from steel. The structures will have provisions for personnel safety, e.g. life-rings. The total weight of these arrangements is typically 10 tonnes per installation, therefore 1400 tonnes of steel will be required for the 140 wind turbines. Figure 15: Monopile and Transition Piece at Arklow Bank (courtesy of GE Wind) Page 36 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme B. Decommissioning Proposal Design considerations have been made to ensure that the installations are affordable to remove. However, design codes and standards limit the ability to reduce steel thicknesses and to lighten the structures to ease future removal. The result is that the monopiles are of a size that means they will not be able to be removed from the seabed once piled to the design penetration depth of approximately 35m below seabed. Consequently it is proposed that the foundations are cut at or below seabed. In the first instance a general target of cutting one metre below seabed is proposed, though it may be necessary to vary the target depth for individual turbines subject to site specific factors such as the specific ground conditions at each turbine location. It is noted that in order to overcome vast frictional forces, considerable excavation will be needed. In order to be able to undertake the cutting procedure, the diameter of the excavation hole will increase by at least two metres for every additional metre in depth below seabed. As such, it may be considered too intrusive and damaging to consider cutting below one metre depth. It is proposed that, following the cutting operation, the foundations and transition pieces be removed as a single structure. The total lift weight of this structure will be in the order of 660 tonnes. The following table compares and contrasts the options of complete removal of foundations with the alternative of cutting below seabed as described above. The same considerations apply to the foundations used for transformer platforms and met masts. FOUNDATIONS Criterion Complete Removal Cutting Below Seabed High risk to personnel Fewer activities to be undertaken over Safety for all at all associated with lifting extreme a shorter time period offshore, times weights. Risk compounded by minimising risk to personnel. significant length of time Page 37 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Criterion Decommissioning Programme FOUNDATIONS Complete Removal Cutting Below Seabed needed to undertake works Post decommissioning site monitoring offshore. Diver operations will identify any unlikely exposure would be required with the result that safety risk is insignificant. Disadvantages to other users of the marine environment Consideration of include disruption over a the rights and needs longer time period whilst the legitimate users of works are undertaken and the sea remaining scour holes associated with excavation Minimise environmental impact Promote sustainable development Adhere to Polluter Principle Maximise the of materials. Commercial Viability No risk presented providing cutting is to sufficient depth, site is monitored post decommissioning; any unlikely exposure identified. Excavation pits over a wide area causing significant impact to marine environment. Associated dumping of excessive volume of waste material also required. Disturbance would take place over long time period. Some artificial reef habitat may be lost, but long term risk of decay and pollution will be eliminated. Considerably reduced works footprint relative to complete removal. Works would take place over reduced time period and involve less equipment. Seabed recovery time shorter than complete removal scenario. Some artificial reef habitat may be lost, but long term risk of decay and pollution will be eliminated. In the long term complete removal affords maximum flexibility over use of seabed, though considerable destruction over the whole site in short-medium term Some activities may be limited at turbine locations: eg extraction (given incidence of london clay on site demand for extraction unlikely). Providing remaining structures do not become exposed most future activities will not be affected. Seabed recovery is highly likely. Consistent in principle, assuming a suitable disposal the solution can be found for the Pays excavated waste material and that the seabed can be restored. reuse Maximum material potentially available for reuse Not commercially viable – excavation and extreme lifting Page 38 of 58 Consistent as far as is reasonably practicable – all remains to be suitably buried. Less material available for reuse relative to complete removal. Less expensive alternative to complete removal, involving minimal Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme FOUNDATIONS Complete Removal Cutting Below Seabed involves major equipment excavation requirements over longer periods of time Not a practical solution: Extreme risk associated with heavy lift, considerable Standard procedures and equipment excavation needed with associated storage or disposal of large volume of waste. Criterion Practical Integrity This analysis shows that cutting below seabed is preferable to complete removal on the grounds of safety, practical integrity and commercial viability. GGOWL consider that there to be consistency between this proposal and the relevant circumstances set out in DTI guidance: • entire removal would involve extreme cost. • entire removal would involve an unacceptable risk to personnel; It is also noted that this approach is standard practice within the oil and gas industry for similar structures. Although GGOWL is committed to cutting foundations below seabed, contingency plans will be put in place to ensure appropriate actions are carried out in the unlikely event that remaining structure(s) become exposed. Please see Section 12 for details. 4.2.3 Transformer Platforms A. Component Description The purpose of an offshore sub-station platform is to transform the voltage of the electricity generated at the wind turbine to a higher voltage suitable for transmission of power to shore. Up to four offshore sub-stations will be required and located at strategic points within the turbine array. The substations will have typical dimensions of 20m length x 20m width x 15m height. The total height of the sub-station including the foundation will be up to 40m above LAT. The components within the sub-station offshore platforms will include: • Medium to high voltage transformers • High voltage GIS (gas insulated switchgear) Page 39 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Back-up diesel generator and tank • Accommodation facilities • J-tubes • Medium and high voltage cables The foundations supporting transformer platforms include a four legged jacket and pin piles. The jacket structure will weigh approximately 450 tonnes, with the piles each weighing approximately 200 tonnes and the topsides weighing 500 tonnes. Figure 16 gives an indicative representation of an offshore transformer support structure. Figure 16: Indicative Transformer Support Structure B. Decommissioning Proposal It is proposed that all topside structures and ancillary equipment be removed. In particular, as the transformers may be oil or resin filled they will be taken to shore complete, reducing the potential for offshore spillage risk and facilitating safe deconstruction. The complete lift weight will be in the region of 500 tonnes. The justification for complete removal of the topsides is outlined below PLATFORM TOPSIDES Criterion Complete Removal Safety for all at all times Safest option, involving standard procedures and minimal work offshore. Consideration of the rights Complete removal of structure best long-term solution. Appropriate and needs legitimate users notification and consultation would precede temporary works/disturbance Page 40 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme PLATFORM TOPSIDES Criterion Complete Removal of the sea Minimise impact environmental Risk of spillage slight as all pollutants are fully contained and removed in single lift. All dismantling takes place onshore Materials completely removed from site, ensures future generations do Promote sustainable not suffer from a diminished environment or from a compromised ability development to make use of marine resources. Adhere to the Polluter Pays Entirely consistent: owner pays full cost of removal and disposal Principle Maximise the reuse of All deconstruction to take place onshore, maximum potential for reuse of materials. materials. Most commercially viable solution:, minimal works offshore, maximum Commercial Viability re-sale/reuse value from materials, minimum residual risk Main risk is heavy lift and this can be mitigated by use of correct Practical Integrity procedures and capable vessels and equipment. Most practical method It is proposed that the four legged jacket, including leg piles, are cut to 1m below seabed. This will involve a total lift of approximately 850 tonnes. The justification for cutting foundations below seabed provided in section 4.2.2.B above also applies to this proposal. 4.2.4 Anemometry Masts A. Component Description Permanent anemometry masts will be required for the operations phase. Such masts will be the same height as the wind turbine hub, ie up to 105m above mean sea level, and will feature a foundation installed in a similar manner to the foundations for the wind turbines, described above. The anemometry masts will be connected to the wind turbine array using buried subsea cables. A anemometry mast consists of the following parts: • Monopile foundation • Platform including boat landing • Met mast including instrumentation (above and possibly below water) • Control cabinet, solar panels and batteries • Aerial and marine navigational lights and markings Page 41 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme The foundations for the anemometry masts will consist of a steel monopile with a diameter of approximately 2.5m and a length of approximately 70m, of which up to 30m will be driven into the seabed. The monopile will be made of approximately 400 tonnes of steel. Scour protection is not envisaged to be necessary. Figure 17: Existing Anemometry Mast at the Greater Gabbard Offshore Wind Farm Site B. Decommissioning Proposal It is proposed that all anemometry equipment and supporting towers are completely removed and deconstructed onshore. The monopile foundation will be removed in accordance with the provisions made in Section 4.2.2 B. It is estimated that approximately 29m would remain below the seabed. The total lift weight of the removed section, including the weight of the deck, is approximately 200 tonnes. ANEMOMETRY MASTS Criterion Complete Removal Safety for all at all times Safest option, involving standard procedures and minimal work offshore. Consideration of the rights Complete removal of structure best long-term solution. Appropriate and needs legitimate users notification and consultation would precede temporary works/disturbance of the sea Page 42 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme ANEMOMETRY MASTS Criterion Complete Removal Minimise impact environmental Risk of spillage slight as all pollutants are fully contained and removed in single lift. All dismantling takes place onshore Materials completely removed from site, ensures future generations do Promote sustainable not suffer from a diminished environment or from a compromised ability development to make use of marine resources. Adhere to the Polluter Pays Entirely consistent: owner pays full cost of removal and disposal Principle Maximise the reuse of All deconstruction to take place onshore, maximum potential for reuse of materials. materials. Most commercially viable solution:, minimal works offshore, maximum Commercial Viability re-sale/reuse value from materials, minimum residual risk Main risk is heavy lift and this can be mitigated by use of correct Practical Integrity procedures and capable vessels and equipment. Most practical method 4.2.5 Cabling A. Component Description Export Cables: Subsea power cables are required to connect the wind farm to the electricity transmission system. These cables will also comprise internal fibre optics for wind farm control purposes. The 3-core cables will consist of copper conductors with integral insulation, core screening, and steel armour (for stiffness and impact resistance). The export cables will be buried to a depth ranging between at least 1.0m and 1.5m below seabed. It is considered that the proposed burial depths for export cables are sufficient to ensure that the cables do not become exposed by the removal of overburden material. Burial within clay, as opposed to within mobile sediment, ensures that cables remain buried indefinitely. At the beach end of the cable route, the export cables will be uncovered for a length below LAT. Inter-Array Cables: The inter-array cables will be relatively short in length (typically 650 to 1200m) and will interconnect the wind turbines within the arrays to each other and to the offshore sub-station platforms. The cables are expected to be standard 3-core, copper conductor, XLPE (or equivalent) insulated and armoured submarine cable, rated at 33kV. The cables have an external diameter of approximately 150mm. All cables are to be buried in the seabed to a nominal depth of 1–1.5m. Where the inter array cables cross sandbanks, burial shall be at 1.5m depth. It is proposed that cables will be set into the London clay underlying the sand waves to ensure that they stay buried throughout the lifetime of the project, and beyond. Page 43 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme It is proposed that turbine interconnecting cables adjacent to the substructures are cut at a point below the surface of the seabed to allow the cable to remain buried. The cut sections would be removed with minimal disruption of the seabed. For any inter array cable crossing sand banks, it would be proposed to leave in situ as the disruption caused by jetting and or excavating the sand bank to remove the cable is regarded as being detrimental to the seabed. It is considered that these proposed burial depths are sufficient to ensure that the inter-array cables do not become exposed by the removal of overburden material. Burial within clay, as opposed to within mobile sediment, ensures that cables remain buried indefinitely. The estimated total cable length, for both export and inter-array cables is approximately 320 km. Note that cables are not oil/fluid filled. Figure 18: Typical cross section of 3 core copper XLPE armoured 33kv subsea cable, representative of inter-array cables (courtesy Nexans) Figure 19: Typical cross section of 13 core copper XLPE armoured 132kV subsea cable, representative of export cables (courtesy Nexans) Page 44 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme B. Decommissioning Proposal At the time of writing GGOWL intends to follow the current industry standard by leaving both inter-array and export cables in-situ. As such, life-cycle costs and environmental impact will be considered in the design of the inter-array and export cables. Whilst it is considered that cables are buried at a safe depth, contingency plans will be put in place to ensure appropriate actions are carried out if the cables do become exposed. Please see Section 12 for details. An exception is made for the inter-tidal zone where GGOWL consider that the BEPO would be to cut and pull through the cables to the onshore jointing pit. This operation would not impact the seabed. CABLES Criterion Complete Removal Safety for all at all Risk to personnel not excessive times Leaving in situ Burial within stable clay seabed does not pose safety risks to marine users No risk presented from leaving Consideration of affords maximum buried cables in situ. Potential for the rights and needs Removal extraction activities limited legitimate users of flexibility over use of seabed the sea (though unlikely in London Clay) Given the considerable length of cable and the need for jetting techniques, removal would cause Benign - no environmental impact Minimise considerable damage and disruption associated with long term environmental to the seabed and established disintegration of buried cables. impact communities. These impacts could be considered large relative to the environmental gains from Page 45 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme CABLES Criterion Complete Removal removal. Though considerable ‘troughs’ would remain on the seabed in the Promote short-medium term, complete sustainable removal affords maximum development flexibility over use of seabed in the long term. Adhere to the Consistent, assuming suitable Polluter Pays disposal option is found for surplus Principle cable components Maximise the reuse Maximum material, eg copper, of materials. potentially available for reuse Commercial Expensive operation, offset to an Viability extent by copper re-sale value Possible to undertake. Likely to Practical Integrity cause damage to marine environment. 4.2.6 Leaving in situ Some future activities may be limited, eg extraction (unlikely on London clay). Benign, no pollution risk No reuse possible if left in situ Limited cost involved with re burial of cable ‘ends’ N/A Scour Protection A. Component Description Scour is the term used for the localised removal of sediment from the area around the base of support structures located in moving water. When a structure is placed in a current, the flow is accelerated around the structure. If the bed is erodable (and the shear stresses are of sufficient magnitude), a scour hole forms around the structure. This phenomenon is known as local or structure-induced sediment scour. Scour is not anticipated to be of concern at the Greater Gabbard offshore wind farm site given the underlying London Clay formation either exposed or with veneers of sand and gravel on top. As such, there is little perceived need for scour protection materials. Nonetheless, for the purposes of the EIA and this decommissioning programme, it has been assumed that some scouring of the upper softer clay and/or sand and gravel material may occur and, as such, scour protection measures around the structures, such as rock dumping or fronded mattresses, may be needed. For monopile foundations, the procedure involves establishment of a thin rock layer installed prior to pile driving, with a mean rock size (D50) of 100-300 mm. This layer will typically be 24 m in diameter with a height of 0.5 m (i.e. a total volume of 226 m). After driving of the pile, cover stones with D50 of between 400-750 mm are placed around the foundation. The total diameter of the scour protection is assumed to be a maximum of 5 times the pile Page 46 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme diameter (D), i.e. the total volume of cover stones will be 1,432 m³ per foundation, and up to 200,480 m3 for 140 foundations. It is possible that cable protection measures will be required at the sandbank margins. At the time of writing GGOWL do not have details of these measures but will revert to JNCC, MFA and DBERR about all scour protection requirements once this information is available. B. Decommissioning Proposal In the unlikely event that scour material is required, it is proposed that this is left in situ following decommissioning. Scour Material Criterion Complete Removal Other Safety for all at all Removal is a labour intensive activity, Reduced risk for contractors. times involving divers and posing an Marginal, increase in risk to marine users: some additional rock unacceptable risk to personnel. over small areas at specific locations Consideration of Removal affords maximum flexibility over May limit uses of seabed. May generate positive habitat benefits. the rights and needs use of seabed legitimate users of the sea Minimise Removal will cause considerable damage Habitat for established environmental and disruption to the seabed and communities retained, no short or impact established communities. Associated long term detrimental effects on equipment and vessels will generate marine environment anticipated. disturbance and additional noise over wide area. These impacts could be considered large relative to the environmental gains from removal. Materials gathered would need to be dumped elsewhere. Promote sustainable Consistent in principle, assuming suitable Prevents some future activities on development disposal solution found the seabed. Total area of sterilisation is small Adhere to the Consistent in principle Inferior option to complete Polluter Pays removal in this regard Principle Maximise the reuse Opportunities for reuse of materials N/A of materials. gathered are limited. Materials would need to be disposed of elsewhere. Commercial Expensive, labour intensive, high volume Costs Page 47 of 58 limited to ongoing Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme Scour Material Criterion Complete Removal Other Viability operation monitoring Practical Integrity High reliance on manual work, labour N/A intensive. Possible but not practical In relation to the circumstances set out in the DTI guidance where non-removal may be considered acceptable, it is considered that in this instance “the installation or structure will serve a new use … through the enhancement of a living resource”. It is also considered that entire removal would involve an unacceptable risk to personnel. 5.0 DESCRIPTION OF PROPOSED DECOMMISSIONING MEASURES The methods of decommissioning will be affected by site specific factors, by final design choices (for example in relation to foundation type) and by the equipment and vessels available at the time. The measures described in this section are based on current technology and information, but it should be recognised that the methods may evolve over time. Periodic review of the Decommissioning Programme and the measures proposed within it will take place throughout the lifetime of the wind farm to accommodate new information. For example, new offshore technologies are continually being evaluated, tested and developed. GGOWL expects considerable advances over the lifetime of the project with new techniques evolving as experience and knowledge in the sector grows. In particular, it is acknowledged that lessons may be learned through the construction and operation of the project and through industry experience in decommissioning renewable energy and other offshore installations. Sufficient time must be given to researching the different available technologies for each phase of the decommissioning operation It may also be necessary to amend these measures in order to comply with revised best practice guidelines and future legislation. Section 9 sets out a formal timetable for reviewing the decommissioning provisions for the Greater Gabbard offshore wind farm project in order to ensure that the best technology is selected and efficient and safe procedures are followed. 5.1 Wind Turbines/Generating Equipment The decommissioning of the superstructure (i.e. removal of turbine components including blades, nacelle, and tower) is likely to be a reversal of the installation process. Opportunities to re-use the generating equipment will be maximised. Health and Safety will be of paramount importance during decommissioning. All work will follow the Page 48 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme recommendations and requirements of the CDM regulations (or applicable codes and standards at the time the work starts). The general methodology for carrying this out is as follows: • De-energize and isolate from Grid (may be undertaken in phases) • Mobilise suitable heavy lift vessel(s) to the wind farm location • Remove rotor component parts • Cut turbine interconnecting cables adjacent to the substructures • Remove nacelle including gearbox and generator • Remove turbine tower • Transport all components to an onshore site at which they will be processed for reuse, recycling or disposal. Once onshore, the structures and substructures will be reduced to sizes suitable for disposal as follows: • Removal of all hazardous substances and fluids from the turbines (such as oil reservoirs and any hazardous materials and components). All components to be disposed of in accordance with relevant regulations • All steel components sold for scrap to be recycled. This forms the bulk of the structures and substructures • The turbine blades (fibreglass) will be disposed of in accordance with the relevant regulations in force at the time of decommissioning. One potential disposal method identified is to break down the fibreglass into a pulp for use as cavity insulation in buildings 5.2 Foundations On current knowledge, abrasive diamond wire cutting is likely to be the preferred method for cutting all the foundation structures at or below seabed. The final method chosen shall be the least damaging to the surrounding seabed and most environmentally acceptable means available. The use of divers for any of the removal works will be minimised and if possible removed completely. Page 49 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme The general methodology for decommissioning of the wind turbine monopiles is likely to be as follows: • Operate cutting procedure at or below seabed • Remove transition piece and upper part of monopile as a single object using suitable lifting vessel • Transport to onshore location for offloading/disposal. • Remove internal equipment, disassemble onshore. 5.3 Transformer Platforms The decommissioning of the transformer platforms will follow similar method as described for the turbines and turbine foundations. The complete ‘topside’ structure will be removed in a single lift, taken by suitable vessel to an onshore facility where the equipment and structure will be dismantled and the constituent parts processed for reuse, recycling and or disposal. 5.4 Anemometry Masts The Anemometry masts are envisaged to be decommissioned by reversal of the installation procedure, with the mast being removed with a relatively small crane barge. The monopile will be cut-off below sea-bed level using similar technology to the large foundation monopiles. 5.5 Cables In light of the proposal to leave cables buried under the seabed, the cable will be cut at a suitable point as close to the foundation as possible, with the ends buried to a proposed depth of 1 metre below seabed level. This will minimise the further disruption to the seabed and any established marine life in the area. 5.6 Scour Protection If required, it has been proposed that any scour protection will be left in situ. 5.7 Waste Management GGOWL is committed to maximising the reuse of waste materials and pays full regard to the ‘waste hierarchy’ which suggests that reuse should be considered first, followed by recycling, incineration with energy recovery and, lastly, disposal. In any event, waste management will be carried out in accordance with all relevant legislation and it would be intended that any disposal took place on land. Page 50 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme In following the waste hierarchy and subject to evolution of technology, change in regulations and demand for materials over the lifetime of the project, the waste management of the main project components might involve: Waste Type Pre-treatment Wind turbine foundations Steel from wind turbine foundations, tower and nacelle removed to shore Copper from power cables and transformers Glass-fibre Reinforced Epoxy (GRE) from the blades Used lubricants from wind turbine Non-recyclable materials and fluids Disposal / Recycle / Reuse Establish available design life at end of 25 years. Reuse by repowering with new/superior wind turbines or other renewable generation technology. Break down into transportable size Recycle Strip cable from power cables and transformers Recycle Break down into transportable size Recycle Filter Recycle Landfill As a part of the review process, all appropriate regulations and guidelines will be reviewed. A waste management plan will be drawn up well in advance of the commencement of decommissioning to ensure that adequate time remains for the proper provisions to be made. 5.8 Lighting and Marking In accordance with Clauses 4f and 5a of the Greater Gabbard consent under Section 36 of the Electricity Act 1989, GGOWL is committed to exhibiting the appropriate marks and lights during the decommissioning of the wind farm. In relation to aviation safety, the shape, colour and character of the lighting will be compliant with the Air Navigation Order 2005 (or as otherwise directed by the Civil Aviation Authority). In relation to navigational safety, lights and marks will be agreed with Trinity House, in consultation with the Maritime and Coastguard Agency. In particular, Trinity House will be consulted prior to decommissioning to specify any obstruction marking that may be required during the removal operations. In the event that any obstruction is left on site that may be considered to present a hazard to navigation GGOWL will provide the necessary marking specified. Page 51 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 6.0 Decommissioning Programme RE-POWERING Whilst the design life for the project is 25 years, the lease term for is 50 years. As such, GGOWL’s expectation is that the project will be ‘re-powered’ midway through the lease term. In comparison to full decommissioning as described above, this is only likely to involve removing and replacing the turbine topsides and possibly some additional equipment, such as that on the transformer platforms. Nonetheless, GGOWL acknowledges the UK’s international obligations that require that installations are decommissioned as soon as is reasonably practicable. As such, adequate provisions must be in place to ensure that the project can be fully decommissioned at year 25 in order that Government is not exposed to unacceptable risk. This programme therefore sets out the measures for decommissioning the project at year 25. At this point, GGOWL will present the case that re-powering is appropriate and achievable and seek approval from the Secretary of State that the agreed decommissioning programme be deferred in accordance with the remaining lease term for the project. 7.0 ENVIRONMENTAL IMPACT ASSESSMENT GGOWL completed an Environmental Impact Assessment (EIA) for the Greater Gabbard project between 2004 and 2005. The resulting Environmental Statement was submitted as part of the project’s successful application for consent in October 2005. A lifecycle approach was taken in considering and assessing the impacts of the project and in seeking to mitigate and minimise the effect of the works. In all instances a ‘worst case’ approach was taken to the assessment. As such, the assessment of the impact of the project on receptors and stakeholders takes into account decommissioning provisions that are either consistent or more onerous than those presented in this document. Consistent with the commitment to undertake reviews of the decommissioning provisions contained within this document, it is proposed that the existing EIA is reviewed throughout the lifetime of the project. A final review will be undertaken towards the end of the life of the installation when the final details of the decommissioning measures are known in order to address the impact of these has been appropriately assessed. At this point a decision will be made as to whether a more detailed assessment is required. Key criteria that will inform this decision include: • Identification and assessment of potential impacts on the environment, including exposure of biota to contaminants associated with the installation, other biological impacts arising from physical effects, conflicts with the conservation of species, with the protection of their habitats, or with mariculture have been identified Surveys in and around the wind farm that could inform this process could include: • Benthic: side scan sonar, imaging • Ornithological: a single year programme to identify key species and assess whether there are particularly sensitive times of year Page 52 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Marine Mammals: should decommissioning activity give rise to high noise levels, it may be appropriate to survey marine mammal activity • Review of Nature Designations • Identification and assessment of potential impacts relating to interference with other legitimate uses of the sea. It is possible that the nature and/or intensity of human activities taking place on/around the Greater Gabbard site such as commercial fishing may have changed over the lifetime of the project. A review will be undertaken to identify those activities with potential to be affected by decommissioning. • Identification and assessment of potential impacts on amenities, the activities of communities and on future uses of the environment • Identification and assessment of potential impacts on historic environment interests If required, the final EIA will fill any ‘gaps’ in relation to the above. It will also describe the measures envisaged to avoid, reduce and, if possible, remedy any significant adverse effects indicated. The use of explosives is not proposed, however should explosives be necessary during the course of decommissioning, the potential impact of these on marine life, particularly marine mammals, will be assessed. The use of explosives will be fully justified and a mitigation strategy proposed. All appropriate guidelines and regulations such as those currently available from JNCC will be followed. 8.0 CONSULTATIONS WITH INTERESTED PARTIES GGOWL regard effective and open communication and consultation as essential elements to the successful development of the Greater Gabbard offshore wind farm project. These principles were adopted during the development of the project and will be applied during the life of the offshore wind farm including the decommissioning phase of the project. GGOWL proposes to seek the advice and opinions of the following parties in drafting and reviewing the decommissioning programme for the project. • Centre for Environment, Fisheries and Aquaculture Science • Joint Nature Conservation Committee • Natural England • The Environment Agency • English Heritage Page 53 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • The Maritime and Coastguard Agency • Trinity House Lighthouse Service • National Federation of Fishermen’s Organisations • Kent and Essex Sea Fisheries Committee • Chamber of Shipping • Royal Yachting Association • Harwich Haven Harbour Authority • British Marine Aggregate Producers Association. In order that the impact on legitimate marine users and stakeholders is minimised, early and comprehensive consultation prior to decommissioning is required. This strategy will be finalised and undertaken as part of the final review process undertaken prior to decommissioning. At the time of decommissioning, and in accordance with Clauses 5c and 5d of the Greater Gabbard consent under Section 36 of the Electricity Act 1989, GGOWL will issue timely and efficient Notices to Mariners and other navigational warnings of the position and nature of the decommissioning activities that will be taking place. Efforts will be made to ensure that this information reaches mariners in the shipping and fishing industry as well as recreational mariners. The UK Hydrographic Office will be notified as appropriate on the progress and completion of the works. 9.0 SCHEDULE AND THE REVIEW PROCESS It is proposed that decommissioning commences at year 25, coinciding with the end of the design life of the turbines and the mid-life of the Crown Estate lease for the project. It is proposed that full decommissioning in accordance with the provisions described above will take 260 days to undertake: • Project management, planning and procurement – 90 days • Offshore decommissioning – 140 days • Onshore works (including dismantling and disposal) – 170 days Note that offshore decommissioning and onshore works will run in parallel. A detailed programme of the works will be provided towards the end of the life of the project. GGOWL acknowledges that the most important steps in the decommissioning process are the planning ahead and the selection of the best decommissioning options. As has been indicated throughout this document, it is intended that the current decommissioning provisions are rigorously reviewed and assessed over the lifetime of the project. Page 54 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme GGOWL intends to undertake internal reviews of the decommissioning programme throughout the life of the project and proposes that a formal review exercise is undertaken with DTI at the following times: • 2 years following commencement of generation; • 10 years following commencement of generation (2 years prior to provision of financial security); • 18 years following commencement of generation (mid way through the period during which financial security is provided). It is proposed that a final review is undertaken in year 23. This will be the opportunity to finalise the detail of the decommissioning provisions, schedule and costs. As indicated in Section 7, this is also the opportunity to ensure that the impact of the works has been appropriately assessed and to determine in consultation with DTI and key stakeholders, whether a revised EIA or Appropriate Assessment is necessary. This will also be the final opportunity to consult with the stakeholders identified in Section 8 above about the details of the decommissioning provisions and the schedule of works. 10.0 SEA-BED CLEARANCE In accordance with the Polluter Pays Principle, GGOWL proposes to clear the seabed in accordance with the provisions made in this decommissioning programme and to collect and provide evidence to reflect this. Following decommissioning, surveys will be carried out to show that the site has been cleared. These surveys will enable identification and subsequent recovery of any debris located on the sea-bed which may have arisen from activities related to the Greater Gabbard offshore wind farm and which may pose a risk to navigation, other users of the sea or the marine environment. It is currently intended that side scan sonar will be used to identify debris, with an ROV deployed to investigate and recover any potential hazards identified. The area to be covered will be determined prior to decommissioning but GGOWL is aware of the guidance for oil and gas installations which specifies a 500m radius around any installation. Reference will also be made to the “Archaeological No Build Areas” in order that these are not inadvertently cleared in the process of removing any debris. Analysis of the survey data will also ensure that items for removal and disposal relate only to the wind farm. The appropriate competent authority will be approached regarding the identification of other anomalies that may be of archaeological interest. It is important that this process of collecting and presenting evidence that the site is cleared is independent. GGOWL propose that an independent survey company complete the surveys and that they report in parallel to both GGOWL and DTI. Page 55 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 11.0 Decommissioning Programme RESTORATION OF THE SITE GGOWL is committed to restoring the Greater Gabbard offshore wind farm project site, as far as is reasonably practicable, to the condition that it was in prior to construction. Consistent with the decommissioning provisions detailed above, the key restoration work will relate to: • Ensuring that foundations cut below seabed (turbines, met mast, platforms) are made safe and adequately covered • Ensuring that cable ends are adequately buried Active restoration relying on intervention with equipment is not proposed as it is considered that such works present unnecessary and unacceptable risk to personnel. Rather, it is considered that allowing the seabed to ‘self-settle’ is sufficient and in proportion to the limited environmental impact of the proposed decommissioning. 12.0 POST-DECOMMISSIONING MONITORING, MAINTENANCE AND MANAGEMENT OF THE SITE Given that GGOWL is not proposing to fully remove all installations, some post decommissioning activities are proposed in order to identify and mitigate any unexpected risks to navigation or other users of the sea which may be posed by the remaining materials (for example, where cables or foundations may have become exposed due to natural sediment dynamics). The proposed post decommissioning activities are appropriate to: • the scale and nature of the remaining infrastructure • the degree of risk that any remains become exposed • the degree of risk to marine users Whilst the Greater Gabbard offshore wind farm project area is relatively large, it is considered that the risk of exposure is extremely low, primarily due to the depth at which foundations will be cut and cables buried and the relative stability of the seabed in the area. In comparison to the oil and gas industry where the likelihood of debris falling overboard over the life of the installation is relatively high, such risks are low for the Greater Gabbard project where offshore work associated with operations and maintenance is low and contained within the turbine structure. Given that the site is not heavily fished, and that the distance offshore deters recreational users from the site, it is also considered that the degree of risk to legitimate marine users is low. On the basis of this low degree of risk, it is proposed that the following monitoring surveys are undertaken for elements left in situ beneath the sea-bed: Page 56 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Once at the time of completion of decommissioning • Annually for the following two years • Once after 5 years • Once after 10 years At each proposed time, GGOWL will perform a geophysical survey including a magnetometer survey on the site. As indicated in section 10 above, GGOWL propose to use an independent survey company to complete the surveys. The company will be requested to report in parallel to both GGOWL and Government. In the event of protrusion, or in the event that scour protection materials are left on site following decommissioning (see section 4.2.6), GGOWL will ensure that notification is given to the Hydrographic Office so that suitable notation of a potential anchoring hazard can be marked on relevant charts and mariners informed accordingly. It is noted that, at the time of writing, a solution for addressing residual liability has not been finalised. Until a solution has been agreed GGOWL do not consider it appropriate to detail any specific management or maintenance procedures within this document. 13.0 SUPPORTING STUDIES The following documents inform and support the decommissioning provisions contained in the document: • Greater Gabbard Environmental Statement, October 2005 • Appropriate Assessment with regard to the Greater Gabbard Offshore Wind Farm, December 2006 • Decommissioning of Offshore Renewable Energy Installations under the Energy Act 2004: Guidance notes for Industry, DTI, December 2006 • Guidelines and Standards for the Removal of Offshore Installations and Structures on the Continental Shelf and in the Exclusive Economic Zone, International Maritime Organisation (IMO), 19th October 1989 • Guidance Notes for Industry: Decommissioning of Offshore Installations and Pipelines under the Petroleum Act 1998, DTI, http://www.og.dti.gov.uk/regulation/guidance/decommission.htm • Review of the Current State of Knowledge on the Environmental Impacts of the Location, Operation and Removal/Disposal of Offshore Wind-Farms, OSPAR, 2006, ISBN 978-1-905859-15-3, www.ospar.org Page 57 of 58 Greater Gabbard Offshore Winds Limited Greater Gabbard Offshore Wind Farm Project Fluor Project No. 66577000 Airtricity Project No. 403 Decommissioning Programme • Guidelines for Environmental Risk Assessment and Management, Defra, September 2002, http://www.defra.gov.uk/environment/risk/eramguide/08.htm • Guideline on Decommissioning Cost Estimation, Turner & Townsend Energy for UKOOA, December 2006, www.oilandgas.org.uk/ukooa 14.0 ANNEX A: GREATER GABBARD ENVIRONMENTAL STATEMENT Provided as a CD 15.0 ANNEX B: GREATER GABBARD APPROPRIATE ASSESSMENT 16.0 ANNEX C: GREATER GABBARD DECOMMISSIONING PROGRAMME FINANCIAL SECURITY ARRANGEMENT Page 58 of 58