Climate Emergency – What Climate Emergency? The Peel Ports / Valaris Drill Ships Scandal

Climate Emergency – What Climate Emergency?
The Peel Ports / Valaris Drill Ships Scandal

A picture showing two drill ships at Hunterston jetty

In June 2019 North Ayrshire Council declared a Climate Emergency. Laudable, I am sure, but what are the Council actually doing to implement remedial actions? At the Full Council Meeting of Wednesday 31 March 2021 I watched the Leader of the Council give a comprehensive listing of the actions which have been taken, and are planned, by the Council in its drive to combat Climate Change. Many high-capital spend and positive decisions such as solar energy schemes, electricity from waste scheme at Irvine, housing insulation improvements, and public consultation actions are some things which I particularly noted and all of which are appreciated.
These actions signal to me a genuine attempt by the Council to meet the stated aims outlined in its declaration of a Climate Emergency.
However there is a glaring anomaly in North Ayrshire which makes the Local Council, and also, by implication, the Scottish Government look absurd where Climate issues are concerned.
Two gigantic, currently redundant, Oil Drilling Ships which belong to Valaris plc are berthed at Peel Ports Jetty at Hunterston. Valaris is in Chapter 11 bankruptcy in the USA. Valaris have stated that the Drill ships may not be required for up to two years.
The Drill Ships came to Hunterston for long term storage and were inadequately moored at the Peel Ports Jetty. The mooring and manning arrangements were challenged by Fairlie Community Council. The Community Council also asked Peel Ports to give an assurance that shore power would be made available to prevent noise and fumes being produced for the on-board electrical requirements and also to reduce Climate Impact. Peel Ports responded that arrangements were being made to provide shore power. None has been provided to date, to my knowledge.
Just under two weeks after Fairlie Community Council had raised its concerns in writing, both ships broke free from the jetty and were in imminent danger of being grounded on the Cumbrae shore and causing a major environmental disaster in the Clyde Estuary.
During the week following the initial breakaway from the jetty, six large tugs were required to run at close to full power to keep DS8 on the berth. In addition two lifeboats and a pilot boat were on permanent standby at DS4, all burning large quantities of diesel fuel.
DS4 and DS8 are now again berthed at the jetty. The long-term arrangements appear to be that these ships will run their diesel generators to provide electrical power.
Much more importantly, DS4 and DS8 are both running a number of their main engines to provide power to the appropriate thrusters on the ships in order to prevent them from being blown off the jetty once more!
This is a completely unacceptable long term solution in terms of the effects on residents from constant noise, light pollution, exposure to oxides of nitrogen fumes, sulphur dioxide fumes and particulates. These ships are burning marine diesel fuel. The statutory limits applied to such a marine activity fall well short of those imposed on land based vehicles such as lorries, buses and cars. This is because the limits are based on the expectation that the ships are operating out at sea and well away from exposed populations.
For a Country and a Local Council who have declared Climate Emergencies the situation is frankly, farcical.
The First Minister stated in the recent election debate that 97.4% of Scotland’s electricity demand had been met by renewables in 2020. Sounds great, but look what is going on with these Valaris Oil Drilling Ships in Ayrshire!
Each ship has six diesel engines. Each engine has a rated output of 8,000kw. Marine diesel engines have a thermodynamic efficiency of 40 to 50% so if all engines were being deployed the input energy required to power both ships would be 192,000kw. In the more likely situation of only the three outboard thrusters on each ship being deployed to keep the vessel in position at the jetty, this still equates to 96,000kw at full power. Taking a conservative estimate of the engines being driven at half rated power we are still looking at 48,000kw of energy being required to be delivered from the burning of the diesel fuel to keep these vessels safely on the jetty. This is taking place 24 hours a day, seven days a week any time that there is any significant wind, i.e. nearly all the time. Even in flat calm conditions the on-board diesel generation sets are being used to provide electrical power.
An average house has a central heating system of around 20kw. Even if we assume the heating in the house is left on 24 hours a day we find the Valaris Oil Drilling Ships efforts to stay on the jetty equate to the heating energy required for 2,400 homes!
The emissions of course are much worse from the ships due to the fact that they are burning diesel fuel and not the much cleaner, natural gas!
How can this situation be tolerated by North Ayrshire Council in terms of their declared Climate Emergency?
How can North Ayrshire Council possibly defend this situation? To effectively allow a medium sized power station, powered by diesel fuel, to be constructed at the Hunterston site which they are promoting along with Peel Ports as a potential ‘Green Energy Parc’!
This situation should really form the basis of a presentation at the forthcoming COP26 meeting in Glasgow.
It could illustrate perfectly the divide that exists between what organisations say they will do in hyped terms of Climate Change and what they do in reality.
The running of diesel generators and main engines on the vessels is also causing an unnecessary noise nuisance for many local residents. Constant noise 24 hours per day has been taking place since the vessels arrived on 27 December 2020. Local Council personnel have measured the total noise level and stated that it is below the allowable statutory value. My personal view is that for some proportion of the population, this is not adequate to provide protection against disturbance. Some people are being affected and have reported a constant low frequency noise. I would suggest that the low frequency sound is being generated by a ‘Beat Frequency’ effect caused by the interaction between the exhaust sound from two or more main engine exhaust stacks. Two similar exhaust frequencies, but which are only slightly different in frequency, will be amplified and will generate sound at a frequency which is equal to the difference in frequency of the two sources. This could readily explain the reported low frequency sound complaints. The solution is obviously to provide shore power and fix the problem at source.
Regarding underwater noise it is also totally unacceptable that these ships should be allowed to run their thrusters day and night. The adjacent waters are home to many cetaceans, all of which rely on sound for navigation and detection of food sources.
If these vessels cannot be safely berthed at Hunterston Jetty without running their main engines, then it is clear to me that there is no option other than to request Peel Ports to move these vessels to a proper secure location where there is no need for constant main engine power to deliver safe berthing.
North Ayrshire Council must assert their authority over the location and activities of these vessels.
Locals have been calling for a proper investigation of the February incident and have met with an extremely poor response from all those who should be taking this event seriously.
A state of confusion over the status of the ships and who should be responsible for conducting a proper independent incident enquiry exists.
The Marine Accident Investigation Branch has stated that they do not intend to investigate the major incident of 2nd February when the vessels were blown off the jetty. They state that at the time the Valaris DS4 and DS8 were not ‘ships’, due to their de-manned state and Flag State paperwork. In that case these ‘things’ are ‘Deposited Structures’ and fall under the jurisdiction of land based authorities such as the Health and Safety Executive and the Local Council.
As a result of the misleading CGI video produced by the Decontamination Operator, CessCon Decom, who was at the time located on the Peel Ports site, and whose video showed Oil Rigs moored at the Hunterston Jetty, North Ayrshire Council informed local residents that this could not take place since no planning permission existed for such an activity.
Given that the marine Accident Investigation Branch have confirmed that the Valaris assets are not ‘ships’ it would appear to me that Peel Ports do not have planning permission to store these assets at the Hunterston Jetty, since they must be similar in definition to the Oil Rigs discussed above.
In terms of the lease for the Hunterston Jetty pertaining to the sea-bed below MLWS and which was granted to ClydePort by the Crown Commissioners
Clause 4.4 states:
‘not to use the subjects of let other than as or for a terminal for the handling of iron ore and coal and other commodities comparable with such use and for all operations normally associated with the proper and usual enjoyment of such use, including without prejudice to the foregoing generality for anything reasonably necessary to deal with an accident, malfunction or emergency.’
This, I believe, was written to align with the Secretary of State Planning Approval of the Hunterston Terminal which envisioned a Bulk Handling Facility and which had been the subject of a full Public Enquiry and Parliamentary Debate at Westminster. One might assume that the current Crown Commissioners Scotland would take cognisance of this in any request to amend the conditions of lease.
In my opinion it would appear that Peel Ports do not have planning permission for the current activity, and Peel Ports are not in compliance with the terms of the lease for the sea-bed on which the Hunterston Jetty is constructed.
If this is indeed the correct interpretation then it would appear to me that the Local Council would be in a strong position to instruct Peel Ports to resolve this issue immediately and stop this ridiculous state of affairs from continuing, with damage to the environment, damage to the health of local residents, damage to the well-being of sea creatures, and crucially, damage to the Local Council’s reputation in terms of its stance on its declared Climate Emergency.
Dr Pearson

The Need for a Full In Depth Independent Investigation of Two Deep-Water Drill Ships out of control at Peel Ports Hunterston Jetty on Tuesday 2nd February 2021

BACKGROUND 

This local Fairlie Community Council has requested a full and independent investigation inquiry into the incident involving the Valaris owned drill ships DS4 and DS8 which occurred on the evening of Tuesday 2nd February 2021. 

This document seeks to provide further detailed information and rationale in support of this request. 

This information is provided from the standpoint of concerned local residents who witnessed the event and who have researched, as far as external individuals can, the background and key points which they believe should be included in a formal independent investigation. 

The request for a full independent investigation is to ensure, as far as possible, that all the failures leading up to the incident have been identified, and to make recommendations which ensure that similar incidents will be prevented and to provide lateral learning to others to avoid repetition of the failures which led to this incident. 

The call for an independent investigation is entirely valid because this incident had very high potential, both in terms of environmental damage and also for the potential risk to the safety and lives of the ships’ crew members, the rescue service personnel, support boat crews, and also the safety of all those subsequently involved in the recovery operations. 

The only difference between the incident as it happened, and an incident in which both of these massive drill ships had been driven ashore on the rocky coast of the Great Cumbrae island, was LUCK. 

The incident investigation should be carried out with the detail and vigour which would take place if the latter situation had prevailed. The only difference between what happened on the night, and the grounding of both of these ships, is the outcome. 

It is clear that many management controls failed in this incident, resulting in one ship breaking entirely free from the jetty, and the other being on the point of doing so. 

Only the fact that the DS4 had its anchor already deployed, which in our view was part of a flawed mooring arrangement, saved the day and prevented both ships being driven ashore. The anchor appeared to have been utilised in the mooring operation as a substitute for a properly oriented bow line, which resulted from the berthing of two ships whose combined overall length exceeded that of the jetty head. 

Although the anchor was fortuitously already deployed, it was not immediately effective in preventing the downwind drift of the vessel. From AIS data we believe the anchor dragged from its original laid position, North of Fairlie Patch Buoy, approximately 0.5 mile to a position due West of the jetty head. Only at this point did it, again fortuitously, bite into the seabed and finally halt the ship’s drift towards the Great Cumbrae. At this point the anchor was already heading down the

seabed slope from its original laid depth of approximately 20m towards the mid channel depth of 45m. 

The Mayday call transmitted by DS4 triggered the emergency response. 

No tugs were on site at Hunterston, despite the fact that the strong, 40 knots plus, Easterly wind had been blowing for some considerable time. 

We also believe there was no Peel Ports management on site at Hunterston. 

Tugs had to be sent from Greenock, some 18 nautical miles away. Average tug speeds are around 11 to 12 knots and so a steaming time of an hour and a half is required to get to Hunterston. In addition there is the time required to make ready and cast off. 

Had the DS4 anchor not finally bit into the seabed the ship would likely have been aground on the Great Cumbrae shore in approximately 30 minutes, based on its rate of drift up to the point of the anchor holding. 

Clearly this is well in excess of the time required to get any tugs on scene from the transmission of the Mayday signal. 

When the tugs did arrive they did not go to the assistance of DS4, which by this time was secured by its anchor and was positioned approximately half way from the jetty to the Great Cumbrae shore. 

On arrival the tugs immediately went to the assistance of DS8 which was on the point of breaking free from the jetty. 

DS8 had no anchor already deployed, and had it broken free prior to the arrival of the tugs, would likely have been driven ashore in around 15 minutes, based on its high windage and total lack of anything to slow its drift. 

We believe the scenario outlined is entirely credible and as such provides the basis for a strong case for a thorough independent investigation. 

We believe this investigation should not be lead by Peel Ports or the Port Authority, which is also operated by Peel Ports. This arrangement does not provide an acceptable separation from the organisation involved in the incident and the organisation tasked with investigation. 

We firmly believe that the Marine Accident Investigation Branch should carry out the investigation of this incident and call the relevant parties in to provide evidence and statements.

This should include Valaris, as the ship owners, Noah Ship Management as the shipping agents, Republic of Marshall Islands Maritime Administrator as authority for flagging of the ships, and in particular for authorising any changes to manning levels, Intermoor as the providers of the mooring plan, the Providers of the original mooring lines, Peel Ports as the operators and owners of Hunterston Port and jetty, Peel Ports as port authority, Marine Coastguard Agency as incident co-ordinators, RNIB as emergency lifeboat providers, Prestwick SAR as helicopter rescue providers, Tug and support boat providers, Mooring line providers, Civil engineers or Government Agencies or Military Agencies with knowledge of the Hunterston jetty construction and its original design

parameters and expected life expectancy and current status, Contractors involved in the supply of replacement mooring lines, Crane hire company involved in the lift to remove the damaged gangway from the DS4 which was required in order to allow re-berthing of the vessel, and Any others involved in this incident and deemed to be relevant.

The reason for asking for such a wide range of organisations to provide input to this investigation is that we believe that this incident is extremely serious, and in order to get to all the root causes which contributed, a wide ranging and full investigation is required. Only by adopting this approach will the full learning outcomes be delivered. 

As outsiders we do not know what investigation activity has taken place so far. Ideally we would hope that interviews with all relevant people involved in the incident have already taken place and the outcomes recorded. 

In addition to these first hand interview statements we would wish to see the following aspects covered in the investigation, in addition to, or in reinforcement of, those areas that the MAIB would already consider. 

These are our initial queries, and they are not exhaustive, and in the course of any investigation it would be expected that they would lead to more questions. 

TIMING OF EVENTS 

Examination of the detailed time-log of events recorded during the incident. 

A full time-log of the incident should be prepared which co-ordinates inputs from all the emergency services, support organisations, ship management and port management sources.

In addition to this basic time-log information the following time based aspects should also be considered: 

Rapid change of plan in accepting DS4 and DS8 at Hunterston. 

The original plan had been for the cable layer Castorone to come to Hunterston jetty on 21st December. AIS data showed that in mid December the Castorone was on route with Hunterston as its destination, but this abruptly changed to Rotterdam, and the owners Saipem had the courtesy to let Fairlie Community Council know that the vessel would indeed not be coming to Hunterston as initially planned. 

On 19th December Valaris DS4 was then underway from Las Palmas, where it had been located for several weeks, bound for Hunterston and was then closely followed by DS8. These ships had, immediately prior to this date, been destined to go from Las Palmas to Almeria in Spain, presumably for long term ‘preservation stacking’. 

The question this poses is: Did Peel Ports have sufficient time to conduct a proper risk assessment of the ‘preservation stacking’ berthing arrangements for these drill ships at Hunterston, given this rapid change in plan?

How long will the ships be held in this ‘preservation stacking’ mode? 

This has implications for the ongoing assurance of the secure berthing arrangements, including agreed manning levels and readiness status of the vessels, and for the environmental aspects of continuing electrical generation from on board diesel engines, and also for possible accumulation of non native invasive species on the ships’ underwater structure from known risk organisms in the area of the jetty, notably Carpet Sea Squirt, Didemnum vexillum. It also poses questions regarding the type of anti-fouling employed on these vessels. Is a TBT based system in use, and if so, have the environmental risks to the enclosed Clyde Estuary been evaluated?

If the ships will now require full on-board readiness to hold position through utilisation of main engines and/or dynamic positioning thrusters, what are the implications for crew levels and ongoing environmental damage from constant emission of diesel exhaust fumes?

Confirmation of the time taken after the Mayday call before the arrival of tugs on scene.

This is important for assessing the robustness of any backup assistance plan and raises questions such as the provision of tug assistance at Hunterston.

Time when DS4 had achieved propulsive power, and how long this was after it was requested by the Coastguard.

This is relevant in the event of a failure of the current tug response arrangements and the rate of drift of DS4. It may also have implications regarding the training and competence of the skeleton crew aboard DS4 at the time of the incident.

ORGANISATION 

This is a complex area and requires full investigation. 

Valaris, the ship owners appear to have a well developed approach to Health, Safety and Environment as detailed in their HSE Policy document dated April 2019 and signed by their President and CEO Dr Tom Burke. This statement makes, among others, a commitment to ‘Identify the root causes of incidents and non-conformities, and apply measures to prevent reoccurrence.’ As such we would expect them to welcome this document in assisting them to achieve this commitment. 

However, Valaris as ship owners are in the midst of a demanding bankruptcy, debt for equity swap process, and business restructuring exercise. This poses questions regarding the focus of the Valaris senior management on the day to day operational aspects of the business.

Who in Valaris had operational responsibility for these ships?

What level of scrutiny was applied by Valaris to the long term berthing of these high value assets, approximately one billion dollars per ship, at the Hunterston jetty?

Has the Texas based judge who is overseeing the Valaris bankruptcy and restructuring plan, and the bond-holders who must agree the conditions of the restructuring plan been made aware of the near potential loss of the remaining two Valaris deep water drilling vessels? 

Valaris have already committed to the scrapping of the other three deep water drill ships of this class in their fleet. The loss of the two ships at Hunterston could have had dramatic consequences for the future of the Valaris business through capital loss, bond- holder confidence loss, and significant other reputational damage. These are credible consequences, had the incident taken the course we have presented as having only been avoided by luck. 

Have the Valaris board taken these factors into account in their decision making around the need for a thorough, in-depth investigation of this incident?

Ship Management company 

What were the responsibilities of Noah Ship Management, which is based in the United Arab Emirates, regarding the berthing arrangements at Hunterston?

What knowledge did Noah Ship Management have of Hunterston as a ‘preservation stacking’ base for high windage ships of the type DS4 and DS8?

Who determined the reduced manning levels for these ships?

Was the reduced manning level properly and legally authorised by the Maritime Administrator of the ships’ flag state of The Republic of The Marshall Islands?

Was a written request for Minimum Safe Manning Certificates submitted to the Maritime Administrator?

Did the Maritime Administrator approve the request?

Were the approval certificates available for inspection on the vessels as required?

These reduced manning issues are legally enforced and are internationally agreed. It is important that these factors are clearly investigated and either verified as being within compliance or not. If they are not in compliance this will require further investigation.

Company Providing the Mooring Plan 

Intermoor were the providers of the mooring plan. Failure of the mooring arrangements poses the following questions:

What responsibility does Intermoor have for the failures?

What detailed knowledge of the location, the jetty arrangements and design, the vessel parameters, in particular the wind loading, and the local meteorological conditions, did Intermoor have to allow them to calculate and specify the number, type and orientation of the mooring lines employed?

Did Peel Ports, as operators of the Hunterston jetty, supply detailed information as above to assist Intermoor in their calculations?

Peel Ports as Operators of the Hunterston Jetty and as Port Authority for the wider Clyde Estuary 

A significant conflict of interest arises from the involvement of Peel Ports as both a commercial operator and as Port Authority in the Clyde. This is particularly relevant in incident investigation situations such as the present example. 

This lack of independence can manifest itself in terms of standard setting and compliance monitoring, particularly in respect of safety and environmental controls. 

The commercial pressures to obtain business for the organisation should not outweigh the responsible controls. 

When both roles are within the same overall company structure an unhealthy tension can be created and can lead to poor decision making and management failures. 

The dual role of Peel Ports as both commercial operator and as Port Authority should be challenged as part of the longer term safety and environmental improvement plan for the Clyde area.

Peel Ports management presence on site at Hunterston is to all intents, absent. The site is essentially manned by a single security operator at the entrance gate. 

What management presence at Hunterston does Peel Ports claim to have at present? Given this latest incident, what management presence will Peel Ports introduce?

During the recovery operations required following the current incident several examples of breaches of safety practice took place on the jetty and were witnessed by local residents. 

Evidence of lack of clarity of required Personal Protective Equipment. Most organisations present had operators suitably equipped. However some operators involved with shore line replacement handling appeared to not be wearing life-jackets, despite being at the unprotected quay edge. 

During a difficult and high hazard lift operation to remove a damaged gangway from the starboard side of DS4, which involved the use of a large mobile crane located on the jetty, and the ship not yet moored but holding station close to the jetty, two of a team of five shore based operators, who were trying to control the load from below, were not wearing hard hats. This put them in serious danger from possible falling objects from the damaged gangway and was in breach of any good lifting practice and was clearly non compliant. 

Was there any Peel Ports management presence on the jetty during these safety critical aspects of the recovery operation?

If there was any Peel Ports management present on the jetty at these times why did they not stop the activity and ensure the proper Personal Protective Equipment was being worn by all personnel involved?

These questions are raised because the recovery activities are essentially part of the overall incident. 

Marine and Coastguard Agency, Marine Accident Investigation Branch, Health and Safety Executive. 

We believe it would be appropriate for all three of these external agencies to be involved in the investigation of this incident. 

The MCA have much of the first hand incident information generated during the actual event, including clear time-logs. 

The MAIB are best placed to head the appropriate independent investigation. The HSE should be involved to examine any shore-side aspects. For example: Any shore-side risks arising from breaking of mooring lines under tension.

Risks to emergency personnel and others accessing the jetty at night in poor lighting conditions and severe weather in order to render assistance.

Investigation of the Health and Safety concerns outlined above during the recovery operation, and assessment of the appropriateness of the level of management presence at the site in general.

The three organisations have a Memorandum of Understanding for dealing with cross sector events, and it appears that this incident fulfils the requirements for such an approach. 

PEOPLE 

The skills and training of those involved in the incident should be examined. 

In particular the skills and training of the skeleton crew members should be explored in depth in order to establish whether they were adequate to deal with the situation on the night of the incident. 

Did they have sufficient knowledge to start the main engines when requested to do so by the coastguard?

If not, what was the reason?

Were people of the appropriate level in place, and were there enough of them? Was there a person of Captain level aboard at the time of the incident?

If not, what was the rationale for dealing with an emergency situation of this type or similar? SIMILAR EVENTS

Large ships being blown off berths is not a particularly uncommon incident. 

Most codes of practice and regulations rely on the readiness of the vessel to take appropriate action and to have sufficient trained crew in place to deal with such circumstances. 

They also rely on the appropriate availability of tug assistance at short notice in the event of on-board difficulties. 

In this incident it appeared that the ships had been left in an unready condition and with a much reduced crewing level. 

Why was this decision made?

Was the decision influenced by cost saving?

Was the decision influenced by the berthing offer made by Peel Ports?

The last question is important because Peel Ports have recent experience of a similar un-berthing incident in 2018. In this incident the Oceania Cruises ship ‘Nautica’ broke free from her berth at Greenock Terminal and had to summon tug assistance to prevent her drift and to get her back to the berth. The ship was an eleven deck design with very high windage characteristics, particularly when beam-on to the wind. These conditions are very similar to those encountered with the drill ships at Hunterston, albeit the wind during the latest incident was somewhat lower than that encountered in the 2018 event. 

Was the ‘Nautica’ incident investigated and by whom?

What lessons did Peel Ports learn from the ‘Nautica’ incident?

Did Peel Ports apply this learning to the berthing of the drill ships at Hunterston?

ENVIRONMENT 

Environmental Aspects with possible impact on the incident 

The easterly wind at the time of the incident was high, but not abnormally so for this location at Hunterston 

The Largs Channel is well known as an area where high velocity, offshore, katabatic winds exist. 

The low temperatures at the time of the incident would have contributed to a small, but significant increase in air density and hence, by direct proportion to the wind loading on the ship. 

Much more importantly however was the peak wind velocity, and in particular at height. The wind loading on the ship at the point where the first lines parted would be determined by the square of the maximum wind gust velocity. At the higher parts of these ships the wind velocity will be considerably higher than at sea level. 

Given that it is well known that offshore winds in the vicinity of Hunterston are extremely gusty in nature, were any of the above factors communicated by Peel Ports to the ship owners, their agents or those involved in preparing the mooring plan, and before anyone took a decision to bring such high windage vessels to this location for long term, low manned, storage?

Change in environmental condition of the jetty following demolition activities 

In its original design the Hunterston jetty was equipped with two very large off-loading cranes, one substantial on-loader, and a high capacity overhead covered conveyor system. 

All this equipment has been removed. The jetty is now a bare structure. Any wind deflecting or attenuating features are now absent. This is particularly relevant to ships moored on the west side of the jetty and exposed to unabated easterly winds pushing them off the berth. 

The jetty head is approximately a kilometre from the shore line. There is consequently no, or very little, land based shelter as would be normally expected from trees, hedges, hillocks, buildings etc. on a shore based quay. Indeed the previous location of Hunterston National Offshore Wind Turbine Testing Facility some 1.5km away, and which claimed an environment similar to real offshore locations, would leave no doubt that this is an exposed site. The turbine test centre was located on Peel land. 

Locating two extremely tall drill ships, with a combined length in excess of the total jetty head length appears illogical, particularly if the intention was to leave them essentially skeleton manned for up to two years. 

Did Peel Ports as owners of the jetty consider these changed factors before bringing these drill ships to Hunterston?

Other jetty environment/location factors 

The location of the jetty less than 1.5km from the shore of the Great Cumbrae may well provide shelter from westerly winds, but in the event of un-berthing in strong easterly winds, as was the case in this incident, it poses a significant risk to serious grounding. The Cumbrae shore in that region is almost entirely red sandstone rock. Had either of the vessels been driven ashore there then it is likely that significant damage to the vessel hulls would have taken place. 

The jetty is also located relatively close to Hunterston Nuclear Station. Had the wind been from a more northerly direction there is a possibility that the ships could have been blown towards either the outlet or the inlet water offshore facilities of the Station. 

Were these environmental factors considered by Peel Ports and the other organisations involved in the berthing proposals?

Environmental Risks arising from the ships 

Had the incident resulted in grounding of these vessels, what were the possible environmental effects on the local area and the Clyde estuary in general?

We know from examination of the Valaris data sheets that vessels such as DS4 have the following approximate capacities for the main materials required: 

Diesel Fuel Oil 4,400 te 

Drill Water 2,600 te 

Liquid Mud 7,000 te 

Bulk Stored Solid Barytes ( Barium Sulphate) 2,000 te 

What are the current inventories of potentially environmentally damaging materials on the two ships?

What tonnage of fuel oil? 

What tonnage of drilling mud and what composition of drilling mud stored? What other potentially environmentally damaging materials?

What assessment has been done to determine the environmental risks posed and the measures to be taken in the event of environmental releases, particularly associated with the long term nature of the ship storage and the low manning?

In the aftermath of the incident it would appear that the ships are now holding station at the jetty in easterly wind conditions by running their main engines and thrusters. The implication of this is that fuel oil combustion products from the ships will be emitted in the local area for the foreseeable future. The actual effects of this are not acceptable, but the sheer irony of the situation will not be lost on elected officials once it is made clear. This is taking place at a site which Peel Ports has titled ‘Hunterston Green Energy Parc’. The Scottish Government is pouring millions of pounds into the

nationalised shipyard at Ferguson, Greenock in an attempt to deliver two Dual Fuel Ferries, one destined for the Ardrossan to Brodick route on the Clyde. Glasgow is spending millions on hydrogen powered bin lorries and Scotland is about to host the COP 26 world conference in Glasgow in November. 

Have Peel Ports considered the acceptability of this situation and what is their response?

How does this situation fit with the wording of the Valaris statement on its website in the section ‘Our Commitment’. ‘Through our values we strive to behave with integrity and do not cause harm to people, property, environment, and the communities around us’?

Are Valaris senior management aware of the issues we have identified?

Environmental risks associated with Non Native Invasive Species 

It is well known that there is an environmental risk associated with carpet sea squirt, Didemnum vexillum in the Largs Channel area. This species has been detected in Largs Marina and is believed to be present on the jetty structure at Hunterston. The species is particularly attracted to man-made structures and thrives in shaded underwater areas where lower tidal currents are present. There is a distinct possibility that this species could colonise the underwater hull area of the two ships, particularly due to the long term storage and non movement of the vessels. 

Peel Ports are well aware of the Didemnum vexillum problem in the Clyde and have issued their own guidance notice as part of their Port Authority responsibility. 

Did Peel Ports consider the risks from Non Native Invasive Species before arranging the long term berthing of these vessels in a known hot-spot for Didemnum vexillum?

TECHNICAL 

Mooring warps 

There are a number of technical questions around the specification and condition of the mooring warps used prior to the incident, but this is difficult for us to comment on in detail from a remote perspective. 

We would expect any investigation to cover such aspects as: 

Material of construction, load characteristics, age, storage conditions, previous use, UV exposure, damage, chafe and chafe protection, point of failure under load, tensile tests on samples of recovered lines, number of lines employed etc.

At a more general level we would make the following observations. 

The angle at which some of the shore-lines passed from the jetty to the ship seemed to be very steep. This was particularly true near the bow section and was most pronounced where shore-lines were rigged from the separate mooring dolphin at the north end of the jetty. Here lines were very steeply angled upwards from a centre point of the dolphin and since the ship was essentially moored

alongside the dolphin, with its bow projecting further northward, resulted in short lines with little or no longitudinal angle to the ship. In fact no line at this mooring point was secured forward of the bow. In order to compensate for this lack of forward oriented bow line we believe a decision was made to deploy the ship’s anchor to achieve a measure of longitudinal stability. 

The centre fixing point on the dolphin was, we believe, originally designed to utilise hook style warp fixings and was intended to provide a suitable bow or stern fixing location for warps deployed by a single cape-sized vessel whose full hull lay along the jetty head proper. It appears to us that the dolphin was clearly designed as a ‘mooring dolphin’. In the case of the DS4 mooring arrangement the bow of the ship projected beyond the dolphin, which makes it appear more akin to a ‘berthing dolphin’. There must have been some question in the minds of those at Peel Ports regarding the suitability of the dolphin since just prior to the original berthing of DS4 a tug appeared to attach a tow line to the central mooring point of the dolphin and proceeded to pull on the fixing for some considerable time. 

If this was a test to determine the strength of the fixing how was it quantified, and approved?

Had the fixing failed during the ‘test’, what were the possible consequences and was this ‘test’ risk assessed?

Although failure of the mooring lines was the event immediately preceding the un-berthing of DS4 from the jetty it is only one small, but significant factor in the cause of the incident, and it would be useful to keep this in mind. It is important to identify the immediate cause failures of the lines, but 

all the factors outlined in this paper need to be considered to get to the real root causes of the incident. 

Deployment of the anchor on DS4 

As we have already indicated, the fact that DS4 had its anchor already deployed, which in our view, was part of the flawed mooring arrangement described above, saved the day and prevented both ships from being driven ashore. 

However we know from AIS data that the anchor dragged for nearly half a mile before eventually biting into the sea bed and halting the drift. It would appear then that the anchor was not bedded in at its original drop position to the north of Fairlie Patch buoy. This may have been due to the efforts to get the anchor as far forward of the bow of DS4 as possible to provide as much bow stabilising tension as could be delivered? It appeared that DS4 reversed to the berth while paying out chain at the appropriate rate. It is likely that the load applied to the anchor during this operation was not sufficient to bed the anchor in. When the high loading was suddenly applied by the ship leaving the berth it appeared that the anchor merely skipped along the seabed for some considerable distance. We do not know precisely how much chain was originally deployed and we do not know whether the crew let out more chain during the drifting period to arrest the ship. These questions require to be answered by those involved.

Wind Loading on the ship 

Clearly the wind loading on these types of ships is very large and in particular in a beam-on to wind situation as was the case on the night of the incident. We are aware of the complicated fluid

dynamic calculations required to determine the precise wind loading and the resulting force exerted on the ship and therefore on its mooring lines. 

Does this data exist for the vessels involved?

If the data exists was it provided to Intermoor for their calculations?

Can a calculation be done which inputs the weather information for the night of the incident in order to define categorically what loads were put on the lines and which then resulted in the line failures and the incident?

Did Peel Ports consider asking for this data in order to risk assess the suitability of the shore-side mooring hardware at the jetty?

In order to help us gain knowledge of the effects of wind loading on mooring practices we have studied the documentation available for Faslane in the Gareloch which is controlled by the Queens Harbour Master as Port Authority. Their documentation, Clyde Dockyard Ports, Entry and Departure Guidelines for Vessels, March 2011, sets wind speed limits for berthing at Jetty numbers 1 and 2, which are used for conventional ships. These limits are set for vessels having a large air cross section in order to protect both the ship and the berthing infrastructure. The limit is set at 3,500 m2. The relevant statement is as follows: 

‘Vessels with air cross section greater than 3,500 m2, berthed at 1 & 2 berth will be directed to proceed to sea at sustained winds of 35 kts.’ 

A very approximate calculation of the beam-on air cross section of a Samsung drillship of the DS4 type gave a value of 8,800m2. Even if the estimate is not precise we believe this shows the scale of the air cross section or windage issues present. This poses the question: 

Do Peel Ports as Hunterston jetty owners or as Port Authority have a similar set of controls for directing ships to sea where high air cross section and high wind speed conditions are present?

If they do not have such controls, why not?

In order to have appropriate wind speed data we believe a receiving jetty should be equipped with appropriate real-time wind speed and direction equipment. We can see no evidence of such equipment on the Hunterston jetty structure. There is a wind instrument at the control tower, but this is located inland over a kilometre from the jetty head. 

Does Peel Ports have adequate wind speed and direction equipment installed at the jetty head to allow safe berthing of incoming vessels and inform masters of the real-time conditions at the berth before arrival?

Equipment such as that described was formerly located on top of one of the un-loader cranes, but does not appear to have been replaced following demolition of the cranes.

Condition of the Hunterston Jetty and its suitability for current and proposed uses 

This incident involving large forces being exerted on the jetty has raised questions locally as to the general engineering status of the jetty. The jetty is over 50 years old. The questions arising are: 

What was the original design life of the jetty?

Are the original engineering drawings and specifications held by Peel Ports or others? Is the design suitable for the current and proposed uses being considered by Peel Ports? When was the last full civil engineering status survey completed and what was the outcome? How is corrosion protection provided for the jetty?

Did the jetty have an impressed current cathodic protection system as part of its original design? If so how does this function in the absence of shore power?

Fairlie Community Council have prepared this document because it wishes to see a properly conducted investigation into the incident of Tuesday 2nd February. 

If such an investigation is carried out properly then everyone will learn from it and improve standards. Our document may appear excessive, but one thing is sure, no serious incident occurs because of one or two isolated failures. All serious incidents have many failures of barriers which have been breached and finally lead to the event itself. This is an ideal example to do a proper investigation free from the burden on the conscience imposed by possible death, injury or environmental destruction. 

We repeat again. The only reason there was no major environmental damage, loss of life or serious reputational damage to the many organisations involved in this incident was LUCK. Ultimately luck was the factor determining the actual outcome. 

We have prepared this in good faith as a group of unpaid residents. We urge you to take it seriously.

Fairlie Community Council

Peel Ports meeting with FCC on the 12th July 2018

As promised, we said we would let you know what was discussed at the Peel Ports meeting last week. If you have any  questions or comments please use our contact page.  Thank you, FCC Members

Peel Port 12th July 2018 notes v1.2

If you want to get involved in working to stop oil rigs being decommissioned so close to our village write to our MSPs, MP and Environment Minsters.  The more individual letters they receive, the more attention they will give the matter.

Marine Scotland Pre-consultation Event – 8th August 2018

New date for the Marine Scotland pre-consultation event: 8th August 2018, Fairlie Village Hall, 2 pm to 7pm. 

In April 2018 NAC granted Peelports planning permission to prepare a ‘marine yard’ and the coal jetty for dismantling oil rigs and large vessels without an Environmental Impact Assessment (EIA).  That means they can dredge, pile drive, and re-landscape coast line without needing to protect the unique adjacent SSSI, colonies of seals and porpoises, a unique ‘lone’ dolphin, and the Clyde marine area which is highly dependent upon tourism and fisheries.

However, SEPA and Marine Scotland also need to give Peelports permission to do this.  We need to make sure our voices are heard and Peelports are made to do an EIA at the very least.

Peelports are currently demolitioning equipment on the Coal Jetty, working at least 12 hours a day, 7 days a week.  The beach and waters are being contaminated with silt and coal dust which our families and dogs are swimming in and playing on.  How much worse will this be when oil rigs are being taken apart there?

In June we put a leaflet through your door asking you to attend Marine Scotland’s pre-consultation public event at Sea Mill Hydro regarding the construction of a huge ‘caisson gate’ which will allow oil rigs to float in and out of the marine yard.  The hotel actually cancelled the event due to “concerns about public order”.  At that time, 1400 people had signed the on-line petition “Protect Clyde Marine Life: STOP PeelPorts Oil-Rig Decommissioning Facility” *.  Now over 2200 have signed and rising!

Jobs for local people have not been promised, and at other similar sites employees are living on ‘off shore accommodation’ and contributing very little to the local economies.

We need to make sure that Marine Scotland deny permission, or at worst require an EIA. We know that about four tonnes of radioactive waste (scale, sludge and sediments) has been found in each offshore installation decommissioned in Norway.  We will also have to cope with the noise and light pollution.

FCC met with Peelports on the 12th July when Peelports told them that after 50 years at the Hunterston Parc they know the site is very profitable. The meeting notes will be published in the next few days.

Help us to help you to live in a safe and clean environment.

Sign the petition * and come along on the 8th August 2018 to make your views heard by Marine Scotland.

Thank you,

“Fairlie residents against decommissioning oil rigs”

Comment on Peelports Pre-Consultation for Jetty Construction by 8th March 2018

Peelports held a statutory Marine Scotland Pre-Consultation event at Seamill Hydro on the 22nd February 2018. The public notice indicates that the  developments at the Hunterston Platform Yard and this Consultation concerned construction of a jetty and ‘alterations’ to the abutments.

  • Representatives from Peelports, Arch Henderson LLP and EnviroCentre Ltd were present but were difficult to identify and was left to the public to try and ascertain who was responsible for different aspect of the proposed development. It was impossible to engage in coherent communication and ascertain any facts  as continually directed to different representatives. 
  • People from Isle of Bute and the Cumbraes have expressed concern that due to travel and ferry constraints that it was impracticable for them to attend the event. 
  • Before the event we emailed Arch Henderson LLP for further information and to express some concerns as instructed in the Public Notice. We were told that these concerns would be addressed at the Pre-Consultation event. This did not happen. 
  • The only information on display consisted of the HUNTERSTON PARC flyer for Jetty Expansion (below) and a plan of the Construction Yard. There is limited information contained in this flyer. The only ‘useful’ information is a photograph of the proposed Pier/Dock development location. There was no information on the dock construction or construction of the abutments or caisson gates. 
  • There was no information of the environmental sensitivities or impacts from this development to the Southannan SSSI.
  • There was no information on how the wider proposal of oil rig decommissioning will effect the Clyde sea area.
  • There was no information or social economic appraisal and how this development will effect the tourist offering of the North Coast. 
  • The only environmental data that was present was an ‘illegal copy’ of Clyde Porpoise CIC sightings. A poster was  presented to mislead the public and give impression that EnviroCentre Ltd Consultants were working with the marine mammal project. The director of Clyde Porpoise CIC confiscated the poster (below).
non-consented use of marine mammal sightings data by Enviro Centre Ltd during Peelports statutory Marine Scotland pre-consultation.

Fairlie Community Council are meeting to discuss the pre-consultation event on Monday 5th March 2018. Please note that comments about the proposal and general comments about the event must be submitted by the 8th March 2018 to Arch Henderson LLP and/or Marine Scotland.

Contact Details:

Lara Ferreiro at Arch Henderson LLP
Peter Miller at Marine Scotland Licensing
Kathy Dale at Enviro Centre Ltd

No need for an Environmental Impact Assessment for construction on SSSI and critical habitat says Marine Scotland

Marine Scotland have given their opinion that an Environmental Impact Assessment is not necessary for constructing a massive oil-rig jetty and one of Europe’s largest caisson ‘dry dock’ gate structures at the Hunterston yard. These developments will require a considerable amount of dredging and impact pile driving and may have significant impact on local marine animals and the integrity of Southannan Site of Special Scientific Interest. Developers and planners seem to be relying on ‘scoping reports’ to capture Ministers opinion and left by the statutory and regulatory authorities to develop their own in-house environmental policy. There has been no consideration to wider group and public interests in developing the environmental statements put forward for Hunterston decommissioning yard. This seems  contrary to National Planning policy and guidance.

MS Screening Opinion

Peel Ports ‘2017 Coal Migration Report’ findings are unacceptable for communities and environment #BluePlanet2

Fairlie Community Council is concerned by the ‘quasi-deccommisioned’ status of the Hunterston Coal Terminal and on going pollution that is impacting the Southannan SSSI. FCC reported the issue to Scottish Natural Heritage, Marine Scotland, Scottish Environmental Protection Agency and the Clyde Marine Planning Partnership. In the spirit of community involvement in the participatory planning process we invited these organisations to visit Fairlie but they have failed to engage with our coastal community. Peel Port commissioned their own ‘Coal Migration Report‘ in a knee-jerk response to our concerns.  The findings and lack of effective recommendations are unacceptable to Fairlie Community Council and we are now calling for a rigorous environmental appraisal of Southannan SSSI and surrounding marine environment.

Please read the report  and comment at bottom of page:

Hunterston Coal Migration Report Sept 2017

Hunterston Coal Migration Report Sept 2017

Letter from Peelport: