Performance Standard 1 aims to manage potential environmental and social risks of a project by finding ways to anticipate, avoid, mitigate and compensate for such impacts as much as possible.
Nord Stream 2 has developed an environmental and social management system that builds on the one developed for its successful predecessor Nord Stream. It is a live system that is subject to updates as the project evolves. The key elements are captured in our Health, Safety, Environmental and Social Management System (HSES MS) Manual, which outlines elements such as policy, aspects and hazards, objectives and targets, operational control requirements, management of non-conformities, and management review.
Company activities are directed by an over-arching HSES Policy and a set of eight additional policies aligned with the IFC's Performance Standards, which together set the high-level requirements and expectations for the project. Environmental and Social (ES) management plans form the basis for typical operational control of the management system and are the core of requirements handed down to contractors within individual work scopes. Their implementation is supported through contractual formalities and Nord Stream 2's ES audit and monitoring programmes.
The company management of ES topics applies an "avoid, mitigate, compensate" hierarchy, which is supported by subject-specific policies and procedures. Examples include finding the best route for the pipeline on the seabed, minimising the volume of rock to be placed, or the development of a tailored logistics concept that has resulted in reduced greenhouse gas emissions. Novel technologies or approaches are being used for reduction, such as using bubble curtains to buffer in-water shock waves to marine mammals, or flooded trench boxes in the Kurgalsky reserve.
Based mainly at company headquarters in Switzerland, a close team of designated and cross-functional personnel coordinates the application of ES management requirements. The environment and social, permitting, contracts management, engineering and other teams all work closely together, bringing in external specialist support when required. Nord Stream 2 has all of the appropriate resources and special knowledge in place to effectively meet the requirements of the management system, reinforcing our HSES management programme through training and awareness initiatives. These include HSES inductions for Swiss-based personnel and representatives working on vessels, in addition to security, first aid, fire, and emergency response training.
Future system developments will include a data repository for ES data gathered during various monitoring and reporting activities, for example. Core company personnel will continue to operate the management system during the operational phase of the project, where the focus will shift primarily to performance monitoring.
Identification of Risks and Impacts
The Environmental and Social Impact Assessments that have been carried out in all countries affected by the project are the first step towards identifying potential risks and impacts. The documents and conditions associated with the approvals of such assessments are part of developing an Environmental and Social Management system. In some instances, additional assessments have been carried out beyond the national statutory requirements when we have identified the need for further minimisation of the predicted environmental and social impacts.
In line with the company HSES Manual, activities will be planned so that the project can be implemented efficiently, while minimising risk and assuring legal compliance. Planning involves the systematic identification of legal requirements, hazards, aspects and potential impacts, followed by an assessment of risks and how to control them to a tolerable level. Monthly company Risk Committee meetings are held to drive risk reviews, record changes, and include the integration of ES risks in the company register. Risks to the project are overseen and managed at the highest levels within Nord Stream 2.
Emergency Preparedness and Response
Plans and procedures are in place to respond to foreseeable emergencies and minimise the HSES effects. These are periodically tested and improved. Contractors are required to develop their own Emergency Response Plans (ERPs) for the project, which we approve and audit. Equipment for detecting and responding to emergencies is also subject to a preventative maintenance programme. This includes testing and calibration according to the relevant standards through pre-qualifications, followed by an audit. Inspections are conducted for offshore equipment, for example, and vessels themselves are subject to marine warranty certification processes. Nord Stream 2 has a high degree of visibility on potential emergency scenarios and provides input for planning processes such as contractors' hazard and operability study exercises.
In the case of an incident that involved the release of grease from a contractor vessel in German territorial waters in May 2018, the vessel was visited for investigation immediately after Nord Stream 2 was informed. Operations were also halted within an hour of notification, and each clean-up activity was activated on the same day. We also quickly established a public hotline. Only when we were satisfied that the risk of further such incidents had been reduced to as low as reasonably practicable were operations resumed. We investigated the incident and considered eco-toxicological studies to assess and understand the grease properties and have incorporated lessons learned into our HSES planning. A set of mitigation measures approved by German authorities has also been developed and immediately implemented for all dredging vessels.
Nord Stream 2 has developed and applied a structured process for managing stakeholder engagement expectations. These expectations are set out in the Stakeholder Engagement Plans (SEPs) for each country concerned (Russia, Sweden, Finland, Denmark and Germany). Each has an “owner” at the country level within Nord Stream 2, which is where any dialogue between the company and third parties is typically managed. Comments or grievances on the project are recorded through a grievance mechanism, logging feedback and the company's response through to issue closure. During the permitting process, comments raised were passed on to the relevant company experts for response.
Monitoring and Review
Nord Stream 2 management reviews the effectiveness of the HSES Management System annually via audit and a variety of monitoring functions. Actual performance is compared with the requirements of the policy and the HSES MS to identify opportunities for improvement. Additionally, daily and weekly monitoring supplements scheduled audits for some activities, while country-level environmental monitoring programmes support ES assurance activities.