5. Response Procedures and Checklists

5.1. Pollution Incident Response Procedure

5.1.1. Introduction

  1. Any spill (actual or likely) into the marine environment, irrelevant of its size and whether it arises from the activities at the Array or not, must be reported, following the procedures set out in sections 5.1.2 to 5.1.4, whilst a Contractor or Subcontractor is working on the Array.
  2. In the event of a spill, priority should be given to taking measures to ensure the safety of personnel, offshore installations and vessels, and to prevent escalation of the spill.
  3. Should the spillage be part of a wider emergency, such as fire or explosion, reference should also be made to the ERCoP, which will be produced post consent.

5.1.2. Spills Originating from a Vessel – Response and Notification Overview

  1. In the event of a marine pollution incident (hydrocarbon or chemical), where the spill originates from a vessel or a vessel related activity, during construction or operation and maintenance at the Array, the steps described below should be followed:
  • report the spill to the Vessel Master as soon as it is observed;
  • the Contractor/Subcontractor Vessel Master will report the spill as soon as it is safe to do so, to the Coastguard Operations Centre (CGOC) via phone, and then to the Marine Coordinator via phone. Verbal communication should be followed up when practicable with the submission by the Contractor/Subcontractor Vessel Master of a Marine Pollution Report (POLREP) via email (or fax) to the CGOC and the Marine Coordinator, who in turn will notify the Applicant personnel (see volume 4, appendix 22); and
  • the Contractor/Subcontractor responsible for the vessel from which the spill has originated will engage the vessel SOPEP and assume primacy for the incident ensuring ongoing reporting on spill status, as necessary, and initiating response or clean-up operations as required. The relevant Contractor/Subcontractor, as the primary responder, will request support from a specialist spill response contractor as required. The Marine Coordinator will provide a supporting role and assist with communication throughout an incident.
  1. In the very unlikely event that a regional or national (Tier 2 or 3) response is required, the MCA may take charge of the situation and implement the National Contingency Plan (NCP) (MCA, 2014).

5.1.3. Spills Originating from an Installation Associated with the Array – Response and Notification Overview

  1. The following steps should be followed when the spill originates from an installation associated with the Array:
  • report the spill to the Marine Coordinator as soon as it is observed;
  • the Marine Coordinator will report the spill as soon as it is safe to do so, to the Coastguard Operations Centre (CGOC) via phone, and then to The Applicant Environmental Manager via phone. Verbal communication should be followed up when practicable with the submission by the Marine Coordinator of a Marine POLREP via email (or fax) to the CGOC; and
  • the Marine Coordinator will engage the MPCP and assume primacy for the incident. The Marine Coordinator will be responsible for ongoing reporting on spill status and coordinate the initial response with the spill observer who may utilise spill kits on the offshore installation. The primary responder will request support from a specialist spill response Contractor as required.
  1. The type and volume of hydrocarbons and chemicals on the wind turbines and OSPs/offshore convertor station platforms are not considered to warrant a Tier 2 or Tier 3 response ( Table 4.1   Open ▸ ) due to volume and type of chemical. It is therefore not anticipated that the implementation of an NCP would be required. Nonetheless, the MCA will be kept informed by verbal communications and through ongoing submission of the POLREP.

5.1.4. Spills within a Port

  1. For Port/Harbour spills the Contractor/Subcontractor will contact the relevant Port/Harbour Authority in the first instance and follow all port processes as advised. Each Contractor MPCP will provide details of all ports/harbour authorities of relevance.
  2. The Contractor/Subcontractor will provide details in advance of their works, of the main ports/harbour authorities anticipated to be used whilst working on the Array, therefore contact detail will be updated by the Contractor/Subcontractor. All incidents that occur whether in the Array working area or not, must be notified to The Applicant Environmental Manager and Marine Coordinator.

5.2. Reporting Requirements

  1. There is a requirement for all Employees, Contractors and Subcontractors to report all accidents, incidents and hazards to the Applicant Environmental Manager and Marine Coordinator.
  2. Significant or potentially significant incidents (including marine incidents) are required to be immediately reported and escalated through the business management chain within 30 minutes of their occurrence or when safe to do so.
  3. In the event of a pollution incident, the Spill Observer shall notify the Applicant Environmental Manager. The Applicant Environmental Manager shall then notify the Vessel master and Marine Coordinator. The Marine Coordinator shall then notify the CGOC and the MCA.
  4. If the spill originates from a vessel, or from operations taking place on a vessel, the Spill Observer shall report it directly to the Vessel Master. The Vessel Master shall then notify the Applicant Environmental Manager and Marine Coordinator. The Vessel Master shall also notify the CGOC and the MCA.

5.2.1. Statutory Reporting Requirements

  1. There is a statutory requirement to report marine pollution incidents to Marine Scotland (HM Government, 2018) and SEPA for coastal waters (Scottish Government, 2022). There is also a requirement to report any spill incident to the Applicant 24-hour reporting line within 30 minutes of the incident occurring.
  2. The flow chart in Figure 5.1   Open ▸ should be followed for all responses.

Figure 5.1:
Reporting Requirements for any Potential Spills at the Array

Figure 5.1: Reporting Requirements for any Potential Spills at the Array

 

5.2.2. Response Checklists

  1. Table 5.1   Open ▸ to Table 5.4   Open ▸ provide key actions and notification for key personnel identified in Figure 5.1   Open ▸ with which they would be expected to comply.

 

Table 5.1:
Spill Observer

Table 5.1: Spill Observer


Table 5.2:
Applicant Environmental Manager or Vessel Master

Table 5.2: Applicant Environmental Manager or Vessel Master


Table 5.3:
Marine Coordinator

Table 5.3: Marine Coordinator

 

Table 5.4:
Harbour Master

Table 5.4: Harbour Master

 

5.3. Response Strategies

5.3.1. Response Strategies for Tier 1 Incidents

  1. The key response strategy for Tier 1 spills will be to allow natural dispersion, together with monitoring and evaluation using a small vessel. This is the best option for Tier 1 spills of water-soluble chemicals, or of light oils such as diesel or hydraulic oil. Natural dispersion can be encouraged using a technique called ‘prop-washing’.

5.3.2. Response Strategies for Tier 2/3 Incidents

  1. It is expected that any spills associated with the Array will be Tier 1 spills due to the small inventories of oil/chemicals and the low risk nature of activities to be carried out.
  2. In the event of a Tier 2 incident, it is expected Marine Scotland will request assistance from the relevant Port Authority with regards to access to the stockpile of pollution response equipment and the relevant Port Authority as an Oil Spill Response Co-operative known as the Oil Clean Up Committee. Access to this stockpile is by mutual agreement between Marine Scotland and the relevant Port Authority.
  3. The decision on whether to engage a Tier 2/3 contractor would likely be made by relevant Port Authority in consultation with Marine Scotland. The relevant Port Authority Tier 2 contractor will be confirmed post consent. They will store and maintain a stockpile of equipment. In the event of a Tier 2 incident the contractor Response will be managed by the relevant Port Authority (in ongoing consultation with Marine Scotland where required).
  4. Figure 5.2   Open ▸ details the environmental sensitivities in the vicinity of the Array that will require consideration during a Tier 1 to 3 spill.

Figure 5.2:
Protected Areas in the Vicinity of the Array

Figure 5.2 Protected Areas in the Vicinity of the Array