Memorandum submitted by Hartlepool Borough
Council
DISMANTLING OF
DEFUNCT SHIPS
Executive Summary
This submission relates only to the first two
aspects of the Sub-Committee's inquiry, as follows:
(a) facilities: subject to planning and the
other necessary statutory consents being obtained, the Council
would recognise the substantial potential of the Able UK Ltd.
site at Graythorp, in Hartlepool Borough, to serve as a major
facility on the national scale for the dismantling of defunct
ships.
(b) economic and environmental impact: again
subject to all necessary statutory consents being obtained, the
Council's relevant Cabinet member has welcomed the significant
job creation potential related to ships dismantling operations
at the Graythorp site.
With respect to environmental impact, the Council
has recognised a wide range of impacts which require formal environmental
assessment within the planning process; details are appended to
the submission.
Based on the local public debate on the proposals
for the dismantling of vessels from the US "Ghost Fleet"
within the Borough, the Council recognises that the most contentious
elements of such projects are the importation and disposal of
toxic waste, particularly via landfill. The Council would urge
that wherever practicable hazardous materials should be dealt
with and disposed within that country of origin. Where this option
is not practicable, the Council would prefer to see such materials
returned to the country of origin for disposal, wherever their
"repatriation" can be achieved in a safe and environmentally
sound manner. Where hazardous waste must be disposed of in this
country, the Council would wish to see rigorous controls and monitoring
within the waste management regulatory regime, applied in a clear,
publicly accountable manner.
1. The basis for this submission is the
Borough Council's experiences in the consideration of the proposed
dismantling of ships from the U.S. "Ghost Fleet" by
Able UK Ltd. at the firm's Graythorp site within the Borough.
The Council has fulfilled two roles in this context: firstly as
the local planning authority, with statutory responsibility to
consider the needs for planning permission and to determine any
necessary planning applications, having regard to material planning
considerations, and secondly, as "community leader",
pursuing the objectives arising from Hartlepool's Community Strategy.
Given this background, the Council is able to comment on the first
two bullet points of the inquiry's terms of reference.
2. Facilities and expertise: the Council
acknowledges that Able UK Ltd was successful in winning the "Ghost
Fleet" contract from the US Department of Transportation's
Maritime Administration (MARAD) for its Graythorp site within
what is understood to have been a worldwide competitive procurement
process (although on the assumed understanding that all appropriate
statutory consents were in place or could be secured in the short
term). The Council has still to consider planning applications
and a comprehensive Environmental Statement relating to the proposed
use of the site for ship dismantling and the necessary physical
development to create a dry dock. As such it would clearly be
premature to express a full view on the suitability, in planning
and environmental terms, of the Graythorp facilities for the purposes
of ship dismantling. Subject, however, to planning and the other
necessary statutory comments being obtained, the Council would
recognise the substantial potential of the Graythorp site to serve
as a major facility on the national scale for the dismantling
of defunct ships. The scale of the potential dry dock and associated
quays and the range of land-based facilities within the site would
appear to make the site well-suited to this function. In planning
policy terms, both the adopted Hartlepool Local Plan, and the
emerging new Local Plan (which is subject to Inquiry in June,
2004) recognise the site as being suitable for a range of business,
general industrial and warehousing uses.
3. Demand, economic and environmental impact:
the Council is not in a position to offer any specific evidence
on the likely demand for any such facilities, but is mindful of
the reported requirements for the decommissioning of single skin
tankers as a substantial demand generator over a lengthy time
period, providing potential continuity of contract work and employment
opportunities. In early discussions in relation to the "Ghost
Fleet" project, Able UK Ltd. indicated the prospect of the
creation of up to 200 jobs at management, technical and administrative
levels. In a Borough still facing persistent economic and social
deprivation, such prospects are significant: the Council's Regeneration
and Economy Portfolio Holder, in August, 2003, welcomed the significant
job creation associated with the project and endorsed a proposed
local recruitment service to be developed by Able UK Ltd., the
Council and partner agencies (on the understanding that all necessary
statutory consents for the project would be obtained).
4. With respect to the environmental impact
of such activity, the specific proposals for the Graythorp site
have given rise to a number of issues requiring to be addressed
via the planning and other regulatory regimes. The location of
this particular site in relation to a Site of Special Scientific
Interest, a Special Protection Area and a RAMSAR site raises particular
sensitivities. The Council has liaised closely with other regulatory
bodies and interested parties to produce a scoping opinion for
the necessary Environmental Statement which will accompany the
anticipated planning applications. A copy of the scoping opinion,
is attached as Annex 1: it will be noted that it identifies a
number of potential impacts including in relation to human health,
ecology, water and ground condition, noise and vibration, odour,
traffic, visual impact and economic regeneration. Able UK Ltd.
is currently preparing the Environmental Statement in response
to this scoping opinion.
5. Based on the local public debate on the
Able UK Ltd. proposals and their potential impacts, it appears
clear that the most contentious elements of such projects are
the importation and disposal of toxic waste particularly via landfill.
Indeed, such concerns prompted the Council, in November, 2003,
(whilst four US ships were being towed across the Atlantic ),
to agree unanimously a motion calling for the Secretary of State
for Transport to use the powers available to him to turn back
the ships. Whilst the Council must accept that those ships are
now berthed at Hartlepool, these aspects of the overall proposals
continue to be of concern. The Council recognises that toxic components
will form only a small fraction of the total material involved
and that disposal will be subject to the appropriate regulatory
regime, but, as a matter of principle, the Council would urge
that hazardous materials should, wherever practicable, be dealt
with and disposed within their country of origin. It is recognised
that there are likely to be particular difficulties with materials
such as asbestos and solid p.c.b's which may form part of the
fabric of ships, making separation and disposal before trans-shipment
impracticable; in those circumstances, the Council would prefer
to see such materials returned to the country of origin for disposal,
wherever their "repatriation" can be achieved in a safe
and environmentally sound manner. In dealing with U.K generated
waste materials, or others where repatriation is not practicable,
the Council would wish to see rigorous controls and monitoring,
in a clear, publicly accountable manner, applied within the waste
management regulatory regime.
Hartlepool Borough Council
May 2004
Annex 1
SCOPING OPINION IN RELATION TO PROPOSED PROJECT
FOR:
1. Application No 1 for change of
use to include all types of structures that may be delivered to
TERRC either on a floating vessel such as a barge or delivered
under its own power or delivered by being towed including ships,
Salm's (a large steel cylinder either floating vertically or moored
to the sea being used mostly in the oil & gas industry offshore
normally for mooring ships), Buoys, submarines, aircraft carriers,
tankers, crane ships, cargo ships, Tension leg platforms, jackets,
topsides, Mobile production Units, Navy Ships, Ro-Ro Ships, Barges,
Drilling Rigs, Gravity Base structures, Jack Ups (a type of platform
that jacks itself up from the sea bed) etc. This permission is
to allow construction, repairs, refurbishment and decommissioning.
2. Application No 2 for a bund in
the same location as per Laing application which was approved
Oct 1997 (plan ref: TDC/95/010)
3. Application No 3 for a bund in
the same location as per our last application (received 20 August
2003) which was withdrawn (17 September 2003), this is in front
if the existing gate location.
Issues that are required to be encompassed within
Environmental Statement for the proposed developments.
A. Actions related to the extended usage of the
site (application 1) considered to give rise to impacts requiring
assessment:
(i) Transportation of the various structures
to the site (Transfrontier impacts are required to be assessed).
(ii) Storage of the structures at the
site and potentially outside the bund area eg in Tees Bay or within
the Tees Estuary. The maximum dimensions of the various structures
specified need to be stated.
(iii) Dismantling, refurbishment, repair
and construction of structures in both wet and dry dock conditions
or on land (this should include description of the different processes
involved in relation to each type of structure where relevant).
Wet dock working is a key risk area.
(iv) Processing of materials including
breaking, salvage, storage and removal of recyclable materials
and the temporary presence, handling, extraction and removal of
waste materials (in both wet and dry dock conditions or on land).
Such materials include Bilge water; Ballast water; Ballast sediments;
Invasive plant / animal material; Sewage and domestic waste; Hydrocarbon
oils; Oily sludges; Oil and fuel; Chemicals and gases; Asbestos;
Non ferrous metals; Paints, including TBT and other organotin
compounds; Materials containing PCBs; Refrigerants; Acids; Solvents;
Antifreeze; Dust; Radioactive substances; and Other liquids.
(v) Land reclamation/changes to land
surface required to accommodate processes listed at (iv).
(vi) Transportation of waste and recyclable
materials from and within the site.
(vii) Disposal of all waste materials
(including any nuclear related materials) whether by landfill,
chemical treatment or incineration.
(viii) Recycling of recyclable materials
both at and beyond the site.
B. Bund (application 2)/cofferdam (application
3) related actions considered to give rise to impacts requiring
assessment:
(i) Construction and removal of proposed
bund/cofferdam including transportation of constituent materials
to and from the site, preliminary dredging work and steel piling
operations. Assessment should also consider the necessary upkeep
and maintenance of the bund/cofferdam. Assessment of the combined
implications of carrying out construction work on and removal
of both the bund and cofferdam should be covered if both structures
could be installed. The repeated impacts of constructing and deconstructing
the bund/cofferdam should also be considered.
(ii) Erection of new dock gates (if
proposed).
(iii) Dredging operations in order
to "finish" the dry dock and to allow for the berthing
of vessels.
(iv) The use(s) to which the dry dock
created by the bund/cofferdam and/or dock gates will be put.
(v) Repeated dewatering and re-flooding
of the dock basin.
Each of the aforementioned actions in sections
A and B will need to be assessed in terms of their impacts in
combination with one another and with existing, approved and proposed
uses and activities eg the nearby power station and any proposed
nearby windfarm construction.
POTENTIAL IMPACTS
(Actions likely to cause the following impacts
are denoted in brackets. Many of the following overlap and interrelate)
1. Human Health
(a) During all operations and processes,
including ancillary operations such as post operation cleansing
units and due to inadvertent transfer of contaminated material
for example on footwear and clothes. The assessment should cover
the quality or toxicity of air, water, foodstuffs and other products
consumed by humans. (Ai-viii) (Bi-v)
(b) Vulnerability of communities in the
short, medium and longer term to disease and any abnormal mortality
rate as a result of exposure to pollution with particular regard
to the proximity between the waste disposal sites and residential
areas should be assessed. (Ai-viii) (Bi-v)
2. Ecology
(a) General impacts on marine, estuarine
and terrestrial life
During all stages of a project from importation
of structures to recycling and disposal of the associated waste.
Particular focus is required on release of toxic, persistent or
endocrine disrupting substances such as anti-foulants during dismantling
operations or re-flooding of the basin. The assessment should
cover the presence of toxic heavy metals within flaking paints
including indicative quantities of such substances. (Ai-viii)
(Bi-v)
(b) Waterbird populations
The extent and magnitude of any adverse effects
including potential contamination of the food chain, noise and
visual disturbance impacts and how such effects might vary throughout
the year should be examined in relation to the Seal Sands Site
of Special Scientific Interest (S.S.S.I.), The Teesmouth and Cleveland
Coast Special Protection Area (S.P.A.) and Ramsar site. (Ai-viii)
(Bi-v)
(c) Seal populations
The extent and magnitude of any adverse effects
including potential contamination of the food chain, noise and
visual disturbance impacts and how such effects might vary throughout
the year should be examined in relation to the Seal Sands Site
of Special Scientific Interest (S.S.S.I.), The Teesmouth and Cleveland
Coast Special Protection Area (S.P.A.) and Ramsar site. (Ai-viii)
(Bi-v)
(d) Introduction of alien species and
pathogens
For example from fauna encrusted on ships and
present within ballast water. The potential for importing non-native
species is a risk, from within ballast/bilge/waste waters, ballast
sediment and on the hull (especially significant if vessels are
in a poor state of repair and are untreated with anti-fouling
substances). Assessment must be made of the provisions in place
for dealing with ballast water in particular. (Ai-viii) (Biv-v)
(e) Hydrological and Hydrodynamic effects
The effect of the developments in terms of changes
in tidal currents, local wave climate, sediment transport potential,
patterns of sediment erosion and accretion and contaminant transport
particularly that brought about by the exclusion of tidal waters
from Graythorp dock. These effects all need to be considered in
combination with existing discharge consents. The assessment should
include the current proposal to remove 616,000 cubic metres of
sediment from in front of adjacent Quays 10 and 11 and the effects
of any proposal to deepen Seaton Channel. This is relevant as
the current channel depth is not deep enough to permit passage
of large vessels such as aircraft carriers, therefore a capital
dredge is implied by this application. A properly modelled assessment
of the likely hydrological and hydrodynamic effects of a capital
dredge capable of allowing their safe passage and the consequential
impacts on the subtidal and intertidal habitats should be provided.
This would then have to be related to any consequential impacts
on the qualifying interests of the Seal Sands SSSI and the SPA/Ramsar
site. (Bi-v).
(f) Re-suspension of contaminated sediment
Its transport to intertidal areas during dredging
operations. (Ai-vi) (Bi-v).
3. Water and ground condition
(a) Construction/fill material of bund/cofferdam
The source of the material should be identified
and any impacts associated with its procurement investigated.
The potential for fill material to contain contaminants and for
those contaminants to be leached away should be scrutinised. Measures
to ensure contamination of Seaton Channel is avoided on removal
of the bund/cofferdam should be set out. (Bi)
(b) Dewatering and reflooding of the
dock basin
Potential contamination to tidal waters in general
and those overlying statutory nature conservation sites (Seal
Sands SSSI and the SPA/Ramsar site) in particular resulting both
from the controlled dewatering and reflooding processes and also
through escaping via any weaknesses in the dock gates (if proposed)
and/or bund/cofferdam should be investigated. The potential conflict
with estuarine birds (especially ground nesting terns) from any
scavenging animals drawn as a result of the dewatering process
should be assessed. Further advice should be sought from English
Nature. (Ai-vi)(Bi, iv and v)
(c) Airborne matter
Including any impacts on air, land, water and
local ecology and human health from the transfer of any airborne
matter arising as a result of the transportation, storage of structures,
any of the processes taking place within the dock whether in wet
or dry conditions, during the breaking of dismantled material,
during the period of transfer of the material from the site to
its place of disposal or following disposal and arising from the
construction presence and removal of the bund / cofferdam. (Ai-viii)
(Bi-v).
(d) Surface water drainage run off
Any impacts on land, water, local ecology and
human health. Assessment must be made for the potential for seepage
from the yard, from surface water run-off and contaminants. Safety
measures in place to deal with this should also be detailed. An
assessment of the robustness of existing and proposed flood defence
measures in relation to both water ingress and subsequent water
run-off should be made. (Aii-viii) (Bi-v).
(e) Site flooding
Any impacts on land, water, local ecology and
human health due to flooding of the application site and waste
disposal site taking account of the predicted rises in sea level.
(Aii-viii) (Bi-v).
(f) Disposal of waste material
Potential contamination of groundwater and migration
of gas and any other leachate resulting from the disposal of wastes
including hazardous wastes. (Avii)
4. Condition of dock basin and entrance sill
(a) Dredging
The disposal of potentially contaminated dredged
sediments overlying both the footprint of the bund/cofferdam,
the dock basin and to enable access to any of the berths prior
to any operations being undertaken in the dock whether in wet
or dry conditions will need to be addressed. Dredging will need
careful planning and monitoring to avoid problems with the intakes
by the Power Station and the contamination of the Seal Sands SSSI
and the SPA/Ramsar site. Any capital and maintenance dredging
required should be assessed for its impact on water turbidity
(see below), local ecology including increased disturbance to
seals and birds, and contaminated sediment re-suspension.
From a marine perspective, this represents the
most significant risk to the environment. Thorough assessment
needs to be made of the degree of historical contaminants (heavy
metals, pesticides, PCBs, TBT, PAHs) present in the sediment within
and outside the dock area. This must include assessment of both
contaminant levels and potential impacts of any such contaminants.
Re-suspension of contaminants caused by dredging could affect
interest features in the area such as estuarine birds and marine
mammals via bioaccumulation through the food web. It is essential
that any sediment sampling examines deep, underlying sediment
(deep coring required).
As mentioned above dredging will also increase
water turbidity and the effects of this (such as reduced primary
productivity) need to be assessed. Increased turbidity will cause
the smothering of benthic infauna, leading to a reduction in food
availability to estuarine birds. Loss of invertebrates is also
undesirable as they play a role in burying contaminated sediment
and reducing its bioavailability.
Dredging activities in the area are regulated
in conjunction with English Nature so as to disturb birds as little
as possible. Further advice on suitable dredging times should
be sought from English Nature.
The assessment of methods to reduce the impact
of dredging is essential, eg silt screens. A realistic dredging
volume should be sought from PD Teesport.
(Ai-vi)(Bi-v)
(b) Impacts on sediments within dock
This should be examined both within the context
of exclusion of tidal waters in itself and taking account of the
impact of any operations within or affecting the dry dock. The
disposal of potentially contaminated sediments will need to be
addressed. (Ai-vi) (Bi-v)
(c) Leachate from contaminated sediments
The potential for any sediment pollutants in
the dock basin emanating from any operations in the dock whether
in wet or dry conditions to be conveyed to the Seaton Channel
via weaknesses in any dock gates and/or the bund/cofferdam. (Ai-vi)
(Bi-v)
5. Noise and vibration impacts
(a) Impact of noise and vibration on human
health and on environmentally sensitive sites (Seal Sands SSSI
and the SPA/Ramsar site) having particular regard to sensitive
periods. (Ai-Aviii) (Bi-v)
6. Odour impacts
(a) Impact of odour on human health and
on environmentally sensitive sites (Seal Sands SSSI and the SPA/Ramsar
site). (Ai-Aviii) (Bi-v)
7. Traffic Impacts including (road, rail and
sea)
(a) Impacts in terms of noise and other
forms of pollution (Ai-Aviii) (Bi-v)
8. Risk of accidents occurring
(a) From explosions, spillages eg oil and
ballast discharge, fires or from the failure of pollution control
systems both within and outside the bund areas. The impact of
oil spillage near Hartlepool power station (particularly its relationship
with cooling water) must be assessed in liaison with British Energy.
(Ai-Aviii) (Bi-v)
9. Visual impacts
(a) Visual impact of proposed development
on the surrounding area. (Ai-Aviii) (Bi-ii)
10. Waste Management Capacity
(a) What impact will proposal have on long-term
waste disposal requirements? Would the project bring forward the
need for additional landfill site provision? (Avii).
11. Cradle to Grave
(a) Assessment should be made of the life
span of the dock and the ecological implications for its removal.
Assessment should look at levels of contaminants predicted to
be present within the dock at the end of its working life. Assessment
should also look at the necessary upkeep and maintenance of the
bund / cofferdam. (Ai-Aviii) (Bi-v)
12. Economic Regeneration
(a) Direct and indirect employment creation
and safeguarding associated with construction operations
and later processes. (Ai-Aviii) (Bi-v)
(b) Any detrimental economic impact relating
to the visitor economy (Ai-Aviii) (Bi-v)
13. Archaeology
(a) An assessment should be made of the
impact on undisturbed prehistoric peat deposits which may lie
beneath the existing dock. (Ai-Aviii) (Bi-v)
Informatives
(i) All of the above need to be assessed
in relation to baseline data which should be clearly identified
within the Environmental Statement.
(ii) The Environmental Statement will be
expected to indicate the extent and content of monitoring programmes
necessary to facilitate ongoing assessment of the impacts referred
to.
(iii) The preparation of the Environmental
Statement should have full regard to the requirements of both
Parts I and II of Schedule 4 of the Town and Country Planning
(Environmental Impact Etc.) Regs. 1999.
Hartlepool Borough Council
May 2004
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