SPE-190536-MS

Shetland Gas Plant Waste Water Treatment Systems - Achieving Compliance

in a Fragile Ecosystem

Andy Bain and Rachael Ferguson, Total E&P

Copyright 2018, Society of Petroleum Engineers

This paper was prepared for presentation at the SPE International Conference on Health, Safety, Security, Environment, and Social Responsibility held in Abu Dhabi,
UAE, 16-18 April 2018.

This paper was selected for presentation by an SPE program committee following review of information contained in an abstract submitted by the author(s). Contents
of the paper have not been reviewed by the Society of Petroleum Engineers and are subject to correction by the author(s). The material does not necessarily reflect
any position of the Society of Petroleum Engineers, its officers, or members. Electronic reproduction, distribution, or storage of any part of this paper without the written
consent of the Society of Petroleum Engineers is prohibited. Permission to reproduce in print is restricted to an abstract of not more than 300 words; illustrations may
not be copied. The abstract must contain conspicuous acknowledgment of SPE copyright.

Abstract
The Shetland Gas Plant (SGP) is a large gas processing site built in a very fragile ecosystem (blanket bog)
at Sullom Voe on the Shetland Islands.
There are multiple environmental designations in the surrounding environment (RAMSAR, SSSI - Site
of Special Scientific Interest, MPA, …). The site processes gas and liquid, the produced water effluent from
these operations are then fed to the Effluent Water Treatment Plant (EWTP) for processing prior to being
discharged to Yell Sound via a 3.75 km pipeline.
There are numerous defined pathways and very sensitive receptors in the area which both the produced
water and drainage water could directly impact in a short period of time.
The regulatory regime is very intensive & wide ranging, this allied to the high societal expectations,
especially socio-economic, meant that careful design and construction criteria, along with very reactive
operational control methodologies, were required to manage the need for continuous monitoring and
modifications.
Best Available Technique (BAT) assessments were carried out to determine a predicted contaminant
level; actual recorded levels were then compared to the predicted level. Over the course of a lengthy
construction and commissioning period, it was found that the output contaminant balance was very complex
and susceptible to large movements with small input changes; these were recognised as associated issues
(multiple determinands and management of trigger levels).
This required prolonged and intensive adjustment to the process to ensure that the regulator agreed
Environmental Limit Values (ELV's) were met. This process had a multi analysis approach to allow for the
many different variables which required to be controlled in tandem to meet the ELV's. Final environmental
sign off from commissioning was achieved in July 2017 and even with the higher than anticipated usage
and the legacy construction issues, the site continues to improve its performance and protect the receiving
environment from process contaminant problems.
It was found that engagement with the regulator at an early stage and regular/informed updates, good
baseline assessments, a solid understanding of stakeholder management issues and initial and ongoing
biodiversity identification allowed the project to manage this very sensitive development in a very fragile
and reactive ecosystem.
2 SPE-190536-MS

Introduction
This paper is partly an adjunct to the paper presented at Offshore Europe Conference & Exhibition 2017
(Shetland Gas Plant - Effluent Water Treatment - R Ferguson, B Milne, O Bradshaw et al) and as such
tries not to replicate the technicalities discussed therein, it does, however, use some of the shared project
narrative to set the scene and will follow the same process descriptions, where deemed appropriate, as these
are site documents and, therefore, controlled documentation.
More significantly it focuses on the environmental aspects of managing effluent water treatment in an
ecosystem which is highly susceptible to large movements with small input changes. It will discuss the
regulatory background, the challenges faced by the project and the methods employed to meet the very strict
parameters set out within the legislation and the expectations of the relevant stakeholders in response to the
management of the effluent discharge from the site.
The Shetland Gas Plant (SGP), is adjacent to the Sullom Voe Terminal (SVT) on the Shetland Islands,
Scotland, United Kingdom. The plant receives reservoir fluids from the Laggan, Tormore, Glenlivet and
Edradour gas condensate fields located 125km, 143km and 105km north-west of the Shetland Islands
respectively. The multiphase fluids are transported to SGP via twin 18" 143km flowlines (Figure 1). At SGP
arrival the pressure is controlled at approximately 30 barg via inlet choke valves (18″ for normal operation
as well as a 10″ bypass for high pressure operation).

Figure 1—Shetland Gas Plant & Wells location

SPE-190536-MS 3

The fluids are received in two slugcatchers and separated into gas, condensate and an aqueous phase
consisting of approximately 60% Monoethylene Glycol (MEG) and 40% water. The gas undergoes
dehydration as well as 2 stages of compression before being sent to St Fergus via 2 pipelines. The condensate
is sent to SVT for stabilization and the aqueous phase goes undergoes regeneration to produce a lean MEG
solution of approximately 90% MEG. The reflux water removed from the MEG via regeneration is then fed
to the Effluent Water Treatment Plant (EWTP). This process is represented in Figure 2.

Figure 2—SGP Topsides Schematic

The processed effluent water is then discharged to Yell Sound via a 3.75km 10″ discharge pipeline. As
per the operating consents for SGP, the effluent water is required to meet strict specifications on various
parameters. In order to meet these stringent specifications, the EWTP consists of three stages: physical,
chemical and biological.
Many sensitive ecosystems are located in the Shetland Islands area. Under international designations,
there are 12 Special Protection Areas (SPA) for birds, of which 11 are designated for seabirds (one of which,
"Ronas Hill, North Roe and Tingon", is also a Ramsar site), and 10 Special Areas of Conservation (SAC)
of which 6 have marine components. National sites include Sites of Special Scientific Interest (SSSI) and
Nature Conservation Marine Protected Areas (MPAs).
There are 82 designated SSSIs in Shetland, including 31 with coastal geology as a notified feature and
29 for marine biology. In addition, Shetland has designated Nature Conservation MPAs at two coastal
and shallow inshore sites. The Shetland Islands Council has proposed 49 local nature conservation sites,
2 national nature reserves (NNRs) managed by Scottish Natural Heritage (SNH), and six bird reserves,
managed by the Royal Society for the Protection of Birds (RSPB).
Fishing and mariculture are important industries in Shetland. More than £90 million worth of fish
were landed in Shetland in 2011, making Shetland one of the UK's leading fishing ports (second only to
4 SPE-190536-MS

Peterhead). The most important inshore grounds include demersal fishing areas to the east and west of Unst
and Yell and between Fetlar and Bressay, together with areas off the west and southwest coast, although
the relative importance of particular grounds can be fluid and changes over time. In addition, coastal waters
around the entire coastline are used for shellfish dredging and creeling.
The aquaculture industry is a major component of the Shetland economy, worth £156.3m in 2011,
supporting 462 full time and 78 part-time jobs, as well over 200 jobs in fish processing, marine engineering
and transportation. This is important around the whole coast of Shetland with salmon, mussels, oysters and
seaweed being cultivated, with concentrations in Yell and Bluemull Sounds in Unst, Yell and Mainland, and
south towards Lerwick, and amongst the islands along the southwest coast.
The tourist industry is worth approximately £18-20m to the local economy with walking, ornithology,
sailing, fishing, archaeology and diving being the most important.
The landfall location of the incoming pipeline to SGP is adjacent to significant populations of marine
mammal and other environmental sensitivities - rocky reef habitats and protected species (Otters, Sea pens,
Horse mussels).
There are birds nesting, (April-July) and Seal breeding (June – August).
The waters surrounding the import and export pipelines are home to large populations of seals, dolphins
and sea trout, in fact much of the area surrounding SGP is designated SAC's.
There are a wide variety of birds and animals living in and around the gas plant site. These include otters,
golden plover, lapwings and skuas, amongst many others.
During the construction phase of SGP there were many commitments made to Scottish Environment
Protection Agency (SEPA) regarding the EWTP and associated processes which combine to become the
treated effluent discharged to the marine environment into the Yell Sound to the north of SGP. These were
eventually enshrined in the PPC permit and were monitored and measured accordingly during this period
of the project. Once the project had reached the commissioning phase prior to the initial startup it was
determined that a more managed approach was required to ensure that SEPA were kept fully appraised of
the commitments made and progress achieved on the way to compliance.
To ensure compliance with the water environment discharge conditions as stipulated in the PPC permit,
samples of discharge are carried out on a daily, weekly, monthly and quarterly basis as required at Aqueous
Discharge Point 4(ADP4). Treated water from the OWTP and EWTP are co-mingled and fed into an
observation basin, from which discharge pumps send treated water to ADP4 discharge point. The terminal
section of the effluent pipe is fitted with a multiport diffuser.
Effluent discharge at ADP4 is a batch operation carried out either manually or under automatic control
when the level in the observation basin reaches 46.6%. The mode of operation is dependent on operational
requirements. A recent modification to the system involved the installation of a restriction orifice on each
of the effluent discharge pumps in order to restrict the flow rate to 64 m3/h.
An overview of the sample requirements and limits of parameters from the emission source (ADP4) is
shown in Table 1. The method for sampling is carried out as agreed by SEPA.
The Pollution Prevention and Control (PPC) legislation required that the installation was to be operated
in such a way that, through the application of Best Available Technique (BAT), pollution was prevented
or minimised.
TEPUK had a requirement to satisfy the conditions associated with the PPC Permit for SGP this permit
was issued to Total E&P UK for SGP by SEPA on 4th September 2014.
SPE-190536-MS 5

Table 1—Effluent Sample Emission Limit Values

SGP was designed to minimise environmental impact, by utilising the BAT as follows:

• Prevent generation of waste waters requiring disposal through minimisation of water use and re-
use, maximise the recovery/recycling of process water where applicable;
• Control pollutant levels in water releases where they cannot be prevented; and

• Adhere to the indicative BAT requirements laid out by the SEPA general sector guidance

Now that the plant is operational, an Effluent BAT assessment for the discharge of the effluent into the
marine environment was undertaken to ensure that the design still adheres to those initial design principles
and also complies with current BAT guidance - Best Available Techniques (BAT) Reference Document for
the Refining of Mineral Oil and Gas (Report EUR 27140). In order to comply with conditions within the
permit, the objectives of the Effluent BAT Assessment were as follows:

• Analyse results obtained from effluent Characterisation study to assess treatment performance

• Assess effluent discharge PPC compliance since commencement of operational phase;

• Carry out a systematic BAT assessment of the quality of emissions discharged; and

• Outline any improvements and proposed upgrade work to current treatment of the effluent.

Description of Effluent Drainage & Effluent Treatment systems

The SGP site is fitted with drainage and secondary containment systems to avoid the risk of leaks containing
pollutants. The site has been broken down into discreet drainage systems to allow segregation of fluids and
to avoid fluids being routed to nonhazardous areas. The main drainage networks at SGP are OD1, OD2
6 SPE-190536-MS

and OD3 (below described). Effluent from OD3 is not discharged at ADP4. Depending on the nature of the
accumulated liquid and respective location, available options for disposal are:

• Routing of liquids into the OD1 network for processing and treatment;

• Routing of the liquids to the OD2 network for treatment; and

• Offsite disposal

OD1 Drainage System and Effluent Water Treatment Plant (EWTP)

The OD1 drainage system is a permanently oil contaminated open drains system, contaminated in normal
operation or other routine operations (e.g. maintenance) by quantities of hydrocarbon liquids. Generally the
inlets to these drains are located immediately adjacent to process equipment, which is likely to produce drips
and spillage of hydrocarbons in routine operations. These fluids are directed to the open drains drum and
combine with closed drains drum into the unstabilised condensate interchanger back into the system. The
non-oily fluids will go to the onsite MEG Regeneration Unit for recovery rather than to waste treatment. The
effluent produced during the regeneration process is routed to the Effluent Water Treatment Plant (EWTP)
Treated water is then routed to the Observation basin from the EWTP and then discharged offshore at ADP4.
In order to maintain the functionality of the process systems, it is prohibited at SGP to knowingly discharge
liquids to OD1 containing a TEG concentration greater than trace amounts (approximately 1-2%).

OD2 Drainage System and Oily Water Treatment Package (OWTP)

The OD2 drainage system is defined as an "Accidentally oil contaminated open drains". It collects drainage
waters from impermeable surfaces such as paved areas, steel plates, or concrete pads around and under
process and utility equipment, which may be contaminated in normal operation as a result of minor leaks or
spills. Water from OD2 is routed to the Oily water treatment package (OWTP). Treated water is then routed
to the Observation basin and then discharged offshore at ADP4. It is prohibited at SGP to knowingly add
any MEG process fluids or fluids containing chemicals to the OD2 drainage system, as there is no facility
as part of the OWTP to treat chemically contaminated water. Secondary containment systems are installed
at SGP in order to aid the mitigation of any potential chemical contamination; these may include the routing
of liquids to OD1 and containment for offsite disposal

Effluent Water Treatment Plant (EWTP) and Oily water treatment package (OWTP) description
The water from the drainage systems is routed to the water treatment plant which contains a physical a
chemical and a biological treatment as described hereafter (Figure 3).
SPE-190536-MS 7

Figure 3—OWT & EWT Process Schematic

The physical treatment contains:

– A Corrugated Plate Interceptor (CPI), which uses gravity to separate the free oil from the produced
water;
– A Stripping Column, which removes BTEX (Benzene, Toluene, Ethylbenzene, Xylenes) and volatile
hydrocarbons entrained in the water via transfer to fuel gas.
The chemical treatment contains;
– A Dissolved Air Flotation Treatment Unit (DAF), to remove any residual free oil and Total Suspended
Solids (TSS) utilising flocculants and coagulants.
The biological treatment contains;
– A Biological Aerated Flooded Filter (BAFF) Unit, which is an aerobic biological filtration process
whereby a biomass (bacteria) give biological degradation of soluble organics while simultaneously
removing suspended solids via filtration. The biological process removes the remaining MEG and
BTEX and has the ability to handle varying loads of COD and BOD.
The OD1 Drainage System is routed to the Effluent Water Treatment Plant (EWTP) comprises of the
following:

• Corrugated Plate Interceptor;

• Stripping unit;
8 SPE-190536-MS

• Dissolved Air Flotation Unit and

• BIOFOR® for MEG and BTEX removal

Water from OD2 is routed to the Oily water treatment package (OWTP) which comprises of a Dirt Trap,
Holding Basin (including oil skimmers) and Corrugated Plate Separator (CPS).
The EWTP has been in operation since the start-up of the SGP in February 2016.

Discharge Process
SGP was constructed between 2011 and 2015 in order to process gas volumes from the Greater Laggan Area
fields. The development included the installation of a 3.75 km outflow pipe (ADP4) into the Yell Sound to
the north of SGP (Figure 4). With SGP now operational, the treatment of gas/condensate at SGP involves
the requirement to discharge effluent water (a mixture of produced water and water from the oily drains)
into the marine environment via ADP4. The location of the ADP4 discharge point is illustrated in Figure 4.

Figure 4—ADP4 Discharge location

As mentioned previously, the process by which the treated water is discharged is three stage and is
designed to be as controllable as possible whilst still allowing for flexibility within the treatment and
discharge process.
Table 2 provides an overview of the emission points and sample point locations of the three emission
sources at SGP which are subject to PPC regulations; ADP2, ADP3 and ADP 4 (which correspond to Water
Emission numbers W01, W02 and W03 on the PPC Permit).
SPE-190536-MS 9

Table 2—SGP PPC discharge points

Effluent Characterisation study

As part of the conditions laid out in the applicable legislation, an Effluent characterisation study had to be
undertaken on the emissions (effluent stream) discharged from emission point W03 (ADP4). The objectives
of the characterisation study were as follows:

• Agree a proposed analysis suite with SEPA for screening;

• Ensure correct sampling procedure is carried out and obtain a representative sample of normal
effluent from a typical day;
• Characterise and quantify the sample using accredited methods as per proposed analysis suite; and

• Use the findings of this study to inform a future Effluent BAT assessment in order to comply with
several conditions of the PPC permit requirements
A proposed analysis suite was agreed with SEPA, which was based on the known composition of
produced fluids at SGP as well as treatment chemicals added to the process. A sample from ADP4 was
obtained on 14th July 2017 on a ‘typical’ day at SGP using a grab sampler to represent the composite for the
full day of the 14th July and sent to Intertek laboratory (UKAS accredited) in Aberdeen for analysis (Table 3).
10 SPE-190536-MS

Table 3—Effluent Sample Frequencies

Upon receipt of the results obtained by Intertek, a comparison of the measured concentrations obtained
for each substance detected was carried out against their permitted allowances to identify any pollutant
exceedances and against the original SGP Water Emissions BAT Document (SGP-GEN-00-F-RP-702830).
It should be noted, that where a comparison is made against the Environmental Quality Standards (EQS)
Annual Averages (WAT-SG-53), a mean dilution factor of x2260 has been used as per the Revised CORMIX
modelling – Effluent Dilution modeling at SGP (BUS-171017-138465).
The PPC Permit is now in the Operational Phase at SGP and as such TEP UK were required to comply
with all the conditions within this permit. PPC compliance tests have been carried out in order to demonstrate
that TEP UK can meet the relevant permit conditions, particularly Emission Limit Values (ELVs) relating
to water.
TEPUK then conducted a systematic assessment of the quality of discharged emissions at ADP4 to ensure
BAT is employed with respect to the required treatment of the emissions stream.

Results: Operational performance of ADP4

An Effluent characterisation study was undertaken on the emissions (effluent stream) discharged from
emission point W03 (ADP4) in order to characterise and quantify the concentrations of any pollutant present.
The results of study (illustrated in Appendix 2) have found that on a typical day as per the sample obtained
SPE-190536-MS 11

on 14th July 2017, there were no identifiable exceedances found within the effluent sample that should cause
concern.
However, since transitioning to the PPC Permit (Operational Phase) at SGP, there have been non-
compliances associated with Biochemical Oxygen Demand (BOD), Chemical Oxygen Demand (COD) and
Zinc (Zn). In accordance with the legislative conditions SEPA were notified of these non-compliances,
which all occurred in the initial months of the operational phase. A condensed summary where non-
compliances have occurred since the operational phase commenced is provided in Table 4 with the post
compliance phase detailed in Table 5.

Table 4—AD4 Effluent Sample Non –Compliances

Table 5—AD4 Effluent post mitigation measures

12 SPE-190536-MS

As can understood from the data shown in Figure 5, executing all the remedial measures identified during
the commissioning phase of the PPC permit achieved a significant reduction on the COD of the medium.

Figure 5—COD analysis of the EWTP and OD2 systems until compliance achieved

PPC Improvement Plan & environmental monitoring

Following subsequent discussions with SEPA, a PPC Improvement Plan was issued to SEPA with the
expectation that ADP4 discharges will comply with the PPC permit requirements by 31/12/2017.
The improvement plan stated that exceedances in BOD and COD discharged from the effluent water
treatment plant observation basin are mostly attributed to the levels of BOD and COD from the OD2
system. While breaches for zinc which were not consistent with previous results or subsequent results. The
investigation into the zinc breaches concluded that this breach was most probably due to an event where left
over zinc containing paint product was discharged into the OD2 drainage system as a result of human error.
To aid with the mitigation of further breaches, the following preventative measures as stated in Table
6 have been implemented at SGP. These measures alongside ongoing investigation work, additional
monitoring and a strengthening of clean up procedures as illustrated in the improvement plan have resulted
in the discharge of ADP4 being in compliance with the PPC permit.
SPE-190536-MS 13

Table 6—Preventative measures implemented at SGP

It is proposed in Phase 2 of plan, to:

• Continue to actively manage the drainage system

• COD analyser (Technical Review ongoing)

• Investigating alternative routing (Technical Review ongoing may prioritise MTA and continue with
a phased approach)
• Optimisation of the flushing procedure - ongoing

• Focus on BOD maybe more analysis required

• Fire water sampling results

Currently the continuous monitoring of ADP4 effluent (flow rate/Temperature) using the composite
analyzer will be recorded in the Integrated Control and Safety System (ICSS). The Daily sampling of Total
Petroleum Hydrocarbon (TPH) content is carried out and recorded internally.
The Weekly sampling of the following parameters is carried out and recorded internally:

• BOD

• COD
14 SPE-190536-MS

• Ammonia

• Phenols

• Benzene

• Mercury

• Cadmium

• Methanol.

The Monthly sampling of the following parameters is carried out and recorded internally:

• pH

• Suspended Solids

• Mono ethylene glycol (MEG).

The Quarterly sampling of the following parameters is carried out and recorded internally:

• Arsenic

• Chromium IV

• Copper

• Nickel

• Lead

• Zinc

A Drainage Improvement BAT Study was undertaken to investigate possible operational improvements
at site in order to achieve consistent BOD and COD levels in the ADP4 Effluent discharge below prescribed
ELV's. The study involved an additional resource brought in as part of this process with the support from
the wider SGP team.
The study split SGP into 12 areas where possible operational improvements could be carried out. A total
of 39 recommendations for improvements were discussed and investigated for the following parameters:

• Additional environmental benefit

• Cost

• Impact on operations

• Feasibility

• Risk Ranking

Any items that have not been closed out may undergo further investigation into the extended Phase 1
PPC Improvement plan As agreed with SEPA on 7th December 2017, which will be updated in due course.
Internal tracking cases were raised against recommendations which will require further technical review
prior to 31st March 2018, where an update on the likelihood of implementation will be given to SEPA on
the following:
○ Impact of winter rain water on the OWTP – ongoing monitoring
SPE-190536-MS 15

○ Ongoing studies/reviews relating to COD analyser and requirement for jumper re-routing OD2 to
OD1 in the MTA area. Broader studies are required regarding re-routing from OD2 to OD1 in terms
of the capacity of OD1 to receive and handle these additional fluids after MTA is completed.
○ The impact of this extension is that SEPA have suspended ELVs for COD and BOD (however we
will have to report x2 ELV) until the end of March 2018.
Shetland Gas Plant is a member of SOTEAG (Shetland Oil Terminal Environmental Advisory Group)
which was established in 1977, building upon the pioneering work of the Sullom Voe Environmental
Advisory Group (SVEAG).
SOTEAG continues to develop and manage comprehensive scientific monitoring programmes that ensure
the health of Shetland's marine and coastal regions, surrounding the area of the Sullom Voe Terminal (SVT),
SGP and Port in the North Sea.
Since 1974, the SVT area has been the focus of what is believed to be the most intensive monitoring
programme of any industrial installation in the UK, Europe or elsewhere.
SOTEAG examines and advises on all environmental implications surrounding the terminal area during
construction, commissioning and operations (including ad hoc reconstruction, site rehabilitation and new
developments), through to eventual decommissioning. The reviewed area includes West of Shetland
activities.
Recognised in 2004 after Sullom Voe's special geographical and biological features – which remain
unspoilt due to more than thirty years of high quality marine environmental management – this led to
its designation as a Special Area of Conservation (SAC) by the European Commission. Today it receives
legislative protection under the European Commission Habitats Directive.
SOTEAG is responsible for Sullom Voe's environmental status and so it oversees and advises any third
party developments that may impose on environmental conditions.
SOTEAG works alongside the international community and is an independent body with members drawn
from academia, the oil and gas industry, central and local government, government environmental agencies
and indigenous industries with a maritime focus.
One of the most important functions of SOTEAG is to provide early warning of environmental
change and, if appropriate, to advise on remedial action, which if neglected or unheeded, could lead
to unacceptable environmental consequences. On an annual basis, SOTEAG evaluate and analyse,
environmental monitoring reports. This ensures that the health of the marine and coastal environment around
the terminal is constantly maintained.
SOTEAG reports to and is funded by the Sullom Voe Association (SVA) Limited whose partners
comprise:

• The Shetland Islands Council (SIC)

• TAQA, Brent Pipeline.

• BP, Ninian North Sea Pipeline Systems

• TOTAL E&P UK

SVA Ltd is responsible for policy relating to the design, construction, commissioning, operation,
maintenance, new development and the eventual decommissioning of the Sullom Voe Terminal.
The Sullom Voe Terminal/Shetland Gas Plant area is one of the biggest and most complex of its kind in
Europe, with a high operational turnover. As a result, there is the potential for large and irreparable risks
(effluent discharge from the terminal and its effects…) to the surrounding environment.
SOTEAG's Monitoring Committee plays a key role in monitoring these risks and therefore maintains the
health of wildlife in Sullom Voe. The Committee designs and manages a series of extensive environmental
16 SPE-190536-MS

monitoring programmes that are carried out by scientific institutions and consultancies from across the UK.
The programme is designed to detect and measure both chronic and acute changes in the marine and coastal
environment.
Monitoring of Sullom Voe began in 1974, one year before work on the terminal began. A suite of baseline
ecological monitoring was commissioned, building the foundation of the SOTEAG existing monitoring
programme.
Monitoring provides an ongoing "health check" at Sullom Voe by evaluating the amount and significance
of change and advising The Sullom Voe Association Ltd. (SVA) whether remedial action is required.
SOTEAG's current monitoring programmes include:

• Chemical and macrobenthic monitoring (biennial)

• Intertidal rocky shore (annual) and dog whelk monitoring (biennial)

• Ornithological monitoring (full-time and annual)

Scottish Natural Heritage (SNH) also periodically works with SOTEAG to carry out further monitoring
that is specific to SAC requirements.
These monitoring programmes provide ongoing, independent assurance to the people of Shetland that
the environmental impact of the terminals in the area continue to be monitored. It provides an unambiguous,
independent check of the marine and coastal environment.

Conclusions
By engaging with the regulator at an early stage in the commissioning process it allowed SGP to identify
the areas of concern to SEPA and work with them on achieving a progressive methodology to both mitigate
the discharge effect of the EWTP and also to set realistic benchmarks for the ELV's.
Having regular contact with the regulator meant that as the commissioning process progressed towards
the operational phase plant operations were not compromised due to the inability to meet regulatory
requirements. A certain amount of latitude was granted during the process to ensure that the longer term
viability of the EWTP and overall effluent management system was embedded, thereby, guaranteeing less
outages and a much better understanding of the various interactions between the factors involved in the
input/output process of the waste water dynamic.
As was highlighted in (R. Ferguson, B. Milne et al) "All of the upstream optimisations have resulted in
a much higher quality water being fed into the Biological Aerated Flooded Filter BAFF allowing it to work
effectively to reduce BOD, COD and TSS to meet PPC specifications"….
"Since start up several chemical optimization trials, on both the coagulant and the flocculant, have been
carried out. These have increased the performance of the chemical treatment resulting in lower COD on the
outlet and improved sludge quality.
Executing the required BAT assessments with the correct background knowledge, using the published
monitoring data gathered from the previous 40 years, allied to a thorough understanding of the issues
involved in managing the effluent process made certain that the potential impacts were mitigated at source
where possible, in the design phase, commissioning phase or where appropriate the operational phase.
Particular attention will be paid in the future to any adjustment that may be required for the monitoring
and sampling procedures of the effluent discharge at ADP4 which is undergoing investigative work.
The methods used to minimise impact, including modification of construction practices are also
transferable in principle to all projects which have to manage any aspect of waste water within an ecosystem
which would struggle to withstand repeated highly concentrated excursions breaching the observed ELV's.
As can be ascertained from the findings from (R. Ferguson, B. Milne et al, 2016) "Chemical optimisation
is key to the successful operation / performance of the EWT plant".
SPE-190536-MS 17

One process which would be interesting to note is that the site has been recycling water to blend streams
to ensure specification prior to discharge, this may require more residence time but has had a significant
effect on the levels discharged.
Since the feed to the EWTP is directly from the MEG Regeneration Plant, the EWTP is dependent on
smooth operation of the MEG plant. Therefore any process upsets in the MEG plant have a corresponding
effect on the EWTP. One significant improvement to the design would be the installation of a buffer tank
between the 2 processes. This would prevent a short term MEG outage from shutting down the EWTP.
Furthermore, any unexpected changes within the MEG system which could cause, for example, a higher
MEG content in the reflux water, would have significantly less impact on the EWTP.
Having access to a world class dataset such as those provided by the work undertaken by SOTEAG gives
the project a very clear set of benchmarks to provide the route to managing stakeholder expectation in both
a viable and science based manner.
Workscopes at SGP have drawn upon this resource when setting up the working practices for the
operations which have a direct impact on the surrounding receiving waters. In utilising this long term study
records it was clearly evident that the managing of the ELV's were to be critical in achieving compliance in
the location to make sure that the areas biodiversity was not impinged in a manner which was denigratory.
Using the available study work went a long way to help understand the nature of the stakeholders and
their interaction with the surrounding environment. It became patently clear that this project would receive
a high level of scrutiny from both regulators and interested third parties; therefore, the precise management
of this aspect of SGP operations was pivotal in gaining both their trust and engagement.

Acknowledgements
The authors would like to thank the many, and numerous, individuals and organisations that have worked
on this project. Without their hard work, dedication and support the great achievements that the project has
made would not be possible.

Glossary of Terms

ADP Aqueous Discharge Point

BAFF Biological Aerated Flooded Filter
BAT Best Available Techniques
BOD Biological Oxygen Demand
BTEX Benzene, Toluene, Ethylbenzene, Xylene
COD Chemical Oxygen Demand
CPI/S Corrugated Plate Interceptor/Separator
DAF Dissolved Air Flotation Unit
ELV Environmental Limit Values
EWTP Effluent Water Treatment Plant
FUKA Frigg UK Association
LTA Liquid Treatment Area
MEG Mono-Ethylene Glycol
MPA Marine Protected Area
MTA Mercury Treatment Area
OWTP Oily Water Treatment Plant
PPC Pollution Prevention and Control
RAMSAR The Convention on Wetlands, called the Ramsar Convention
SEPA Scottish Environmental Protection Agency
18 SPE-190536-MS

SGP Shetland Gas Plant

SIRGE Shetland Island Regional Gas Export
SOTEAG Shetland Oil Terminal Environmental Advisory Group
SPA Special Protection Areas
SSSI Site of Special Scientific Interest
SVT Sullom Voe Terminal
TEPUK Total Exploration and Production United Kingdom Ltd
TSS Total Suspended Solids

References
Hoy A, 2012, Total E&P UK, Long Term Peat Management in an Onshore E&P Development, HSE-SPE, Perth, Australia.
Calum S. A. MacPherson, Rachel Keown, Craig Hynd, TOTAL E&P UK Managing Biodiversity Challenges in a Sensitive
Remote Scottish Island Environment HSE-SPE, Stavanger, Norway
Rachael Ferguson, Brian Milne, Oliver Bradshaw, Simon Hare, Total E&P UK, Cathy Fuchs, SUEZ Eau Industrielle,
Shetland Gas Plant - Effluent Water Treatment, Offshore Europe Conference & Exhibition, Aberdeen, United Kingdom
Shetland Oil Terminal Environmental Advisory Group - https://www.soteag.org.uk