Resource Efficiency & Pollution Prevention

Performance Standard 3 encourages the integration of sustainable practices and technologies.

Sustainable use of natural resources will be achieved through a number of actions. These include responsibly sourcing rock from quarries that have been screened for suitability and will be audited during use, and minimising impacts on freshwater by limiting dewatering. All effluents from our construction activities are either trucked to licenced waste disposal facilities or treated in compliance with local regulations prior to being discharged to surface watercourses. We are also minimising potential impacts from discharge through pre-commissioning the pipeline using air as a pipeline inspection medium, also known as a "dry" option that requires no water consumption and therefore no discharge.

Our greenhouse gas (GHG) emissions have also been estimated in the national EIAs. Most emissions (approximately 82 percent) will occur during the construction phase and are associated with the combustion of fuel in engines. The remaining emissions will be released during the subsequent operational phase of approximately 50 years and are predominantly the result of fuel combustion by maintenance vessels. Only the construction emissions are above the threshold considered significant in terms of GHG reporting for this performance standard. We will make annual emissions reports during construction.

Pollution Prevention

We are committed to preventing pollution. Appropriate measures for avoiding, reducing, mitigating and remedying (in the case of oil spills) this issue are included in the national EIAs as well as the overarching Espoo Report. Relevant measures are passed onto our contractors through activity specific management plans and contractual documentation. To monitor impacts effectively, thorough baseline surveys have also been undertaken both on and offshore. Noise will be monitored at key receptors at the start of construction to verify EIA findings. Corrective actions will be taken if acceptable noise limits are exceeded. Where munitions clearance was necessary, noise levels were monitored and additional mitigation measures, such as bubble curtains, were put in place to reduce the spread of underwater noise.

Our waste management procedures comply with several international, EU and national policies, plans and programmes, as well as with the requirements of this performance standard. All waste management measures are incorporated into our activity-specific management plans and then become part of contractor waste management plans. All solid wastes will be separated at the source to maximise opportunities for recycling, and then stored in designated containers before transport to licenced waste disposal facilities. Liquid waste generated on vessels will be treated on board and handled in accordance with the requirements of MARPOL and national legislation.

Pre-lay dredging or trenching will be undertaken along the German and Russian offshore sections. In Russia, the material removed will be subject to testing to ensure that it is cleaner than the receiving environment at a designated offshore disposal site. Compensation by way of fish fry release will be provided in case of potential damage to fisheries in the area. Monitoring will also be undertaken in accordance with Russian requirements.
In Germany, the excavated material is being stored temporarily and reused for trench backfilling or disposed of onshore. Other key mitigation for pollution prevention from dredging includes the appropriate selection of dredging equipment to minimise suspension of sediments, continuous monitoring of turbidity levels near the dredging sites and the cessation of dredging activities whenever threshold turbidity levels are exceeded. These measures will be incorporated into contractor-specific management plans.

Managing Hazardous Materials

Hazardous materials are handled in accordance with hazardous materials management plans for contractors that address our requirements. The risk and potential consequences of oil spills from vessels and gas leakages from the pipeline have been considered through a quantitative risk assessment process. Transboundary oil spills have been considered as part of this assessment. Our mitigation strategy requires our contractors to provide a Shipboard Oil Pollution Emergency Plan (SOPEP) and operating procedure to address Tier 1 spills. Through our activity-specific management plans, we also require our contractors to comply with our Oil Spill Contingency Plan (OSCP) for Tier 2 and Tier 3 spills, which also contains an Action Plan and a Reference Information chapter that includes a risk assessment and a vessel bridging document designed to supplement and support each vessel's individual SOPEP.

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