Tel.No. 01646 690190
Pav`s Mem No.270
whom it may concern:-
Mr.David Robinson aged 61 years;I have lived and worked all my life
on both sides of Milford Haven Waterway for Oil & Utilities
Companies. In the 70`s 80`s & 90`s I spent 12 years working in
Saudi Arabia & Oman for Oil ,Utilities & Mod Companies . I am
now retired my last job being a Shift Charge Engineer for a Power
Station in the Sultans Armed Forces of Oman .
here today to represent “ Safe Haven” which is a group of
concerned residents from around Milford Haven ,asking about the
reasonably insurmountable safety concerns
we have regarding the Largest Lng Receiving Terminals in the World,
namely Exxon`s “South Hook” Terminal & British Gas`s “Dragon”
state straight away, that we are not
a group who are against Lng ; as although it is a fossil fuel which
has cause for concern for Climate Change; it is the reasonably
insurmountable safety concerns and the
way regasified Lng will be used in large Power Stations, that concern
us. Although I must add at this point that in the Lng producing
countries around the world, the liquefaction process of Lng produces
1 tonne of CO2 for every 5 tonnes of Lng produced and that same 1
tonne of CO2 is not counted in our CO2 footprint in the West ,under
the Kyoto agreement. Our preferred way of burning regasified Lng
would be in Combined Heat & Power(CHP) Power Stations that are
built near to the place of consumption. (See www.youtube.com
then search for a short video called “What are we waiting for”)
This would allow us here in the West to burn half as much gas through
the greater efficiency that CHP allows. There is another bonus to
this too; this being it would allow more Lng to be burnt by China &
India who are both intent on burning high polluting low grade coal.
regard to your deliberations on the Planning application for a Lng
Terminal at Tarbert County Kerry can I be
so bold as to ask you to ask the Lng Companies to answer the
Will Shannon Lng(Hess) indemnify the Local Planning Authority , Eire
Government and the EU for any Claim/Lawsuit brought by Third Parties
as a result of damages due to an accident at a Lng Jetty , Lng
regasification Plant or a Pipeline ?
that this exact question was asked by the Mayor of Long
Beach,California of the Lng Companies(SES(Conoco/Philips)) planning a
Lng Receiving Terminal in Long Beach
Harbour. to which theCompanies answered they would not indemnify.
say that Lng Project is not going ahead.
What is the worst case scenario for a
spill of Lng on water at the jetty,
that a Quantitative Risk Assessment (QRA) has been done by either
the Port Authority , Lng Companies or an Independent Risk Assessor ?
Note:- If a proper Full Independent Quantitative Risk Assessment were
to be done for a spill of Lng on
Water, it would be for one
fifth of the Cargo which equates to
50,000cu mtr(one tank of the five in the Lng Carrier)
What would the “Domino Effects” be if a Lng Pool Fire were to
occur ,that resulted from a 1 mtr, 5 mtr or 12 mtr hole in one tank
of a Lng Carrier ? Where would the burning Lng Carrier be carried by
wind and tide ?
that a Lng Pool Fire burns at well over 1000 Centagrade and the Lng
Carrier is Moored with ropes made of Polypropylene which have a low
4/. Is the
deliberate ignition of any Gas Cloud on water being considered by the
Lng Companies or the Port Authority ? Who will be responsible for the
ignition of the cloud?
Effects” are expected from this Gas Cloud ignition ?
The Sandia Report 2004 makes this statement on page 46 . “This
suggests that LNG vapour dispertion analysis should be conducted
using site-specific atmospheric conditions,location topography, and
ship operations to assess adequately the potential areas and levels
of hazards to public safety and property. Risk
mitigation measures, such as development of procedures to quickly
ignite a dispertion cloud and stem the leak, should be considered if
conditions exist that the cloud would impact critical areas”.
Do you agree with the Society of International Gas Tanker &
Terminal Operators statement in their power point presentation that
the risks differences between Crude Oil and Lng if either are
spilled are as follows:-
Crude Oil = The Environment.
Lng = People & property.?
6/. Do you
agree with the HSE confirmation that Lng has TWO properties that are
not fully understood ,as follows:-
(a). Rapid Phase Transition(RPT) .This is a
Phenomenon when Lng is spilled and mixes with water causing flameless
explosions that have been observed to damage surrounding structures.
Computer modelling predicts larger explosions than are predicted
using physical test spills of smaller quantities of lng into
(b). The Percentage of Contaminent gases in Lng
that make it as explosive as LPG . This is of extreme importance as
when Lng is spilled on water and regasified; the Lng companies will
lead you to believe that regasified Lng will not explode . Please
note:- On 19th
of January 2004 in Skikda, Algeria a Lng vapour cloud did explode,
resulting in the death of 27 souls and the injury of 120 people. This
is Known as a “Seeded” explosion , in this case a steam boiler
blew up under a vapourized cloud of Lng, this Phenomenon is not fully
understood but is believed to alter the explosive range of a Gas
cloud which is normally 5%- 15% in air, it is thought that the
explosive range could be altered to 5%- 45% in air if the Lng has
contaminent gases are higher than 14% . i.e. 86% methane and 14%
Butane, Ethane & Propane the latter three being detonator gases.
Hence the reason for this question.
7/. Are you
aware of the GAO Report for the US Congress GAO -07 – 316 MARITIME
SECURITY “Public Safety consequences of a Terrorist Attack on a
tanker carrying Liquified Natural Gas need clarification”?
your risk assessment deliberations have you taken into account of the
relationship between “Hole size and cascading tank failure”? Hole
size is an important parameter for modelling LNG spills because of
its relationship to the duration of the event--- larger holes allow
LNG to spill from the tanker more quickly, resulting in larger LNG
pools and shorter duration fires. Conversely, small holes could
create longer duration fires. Cascading failure is important because
it increases the overall spill volume and duration of the spill.
(Page 11 of the above report).
your risk assessment deliberations did you take into account that
“Waves and wind “ will tend to tilt a Lng Pool Fire downwind,
increasing the heat Hazard zone in that direction ? (Page 12 of the
your risk assessment deliberations did you take into account that
the Surface Emissive Power of a large
LNG Pool Fire is unknown
?(Page 12 of above report).
What level of Thermal Radiation(Flux) do you expect the public to
endure offsite in the event of a Lng fire on land or on water, given
that a hot summers day give a value of 1.2kw/m3.?
Mr.Gordon Milne Senior Risk Analyst of Lloyd`s Register of shipping.
Comments in a document released under the Freedom of Information to
Safe Haven entitled
Gas Release from LNG Carriers” that 1.5kw/m3 is safe. (Page 3 of
Dr Jerry Havens who is to talk to you tomorrow is of the opinion that
1.5kw/m3 is safe for the public. Please ask him tomorrow.
our case in Milford Haven the HSE have used 5kw/m3 as safe for the
public. The HSE quote an OFFSHORE report
(HumanVulnerability to Thermal Radiation Offshore HSL/2004/04) as
evidence that this level of Thermal Radiation is safe for the public.
It seems perverse that when offshore workers are paid, trained,
clothed and have shelters to withstand such radiant heat , that the
general public are expected to endure 5kw/m3 without being paid,
trained, clothed or have shelters provide.
5kw/m3 burns bare skin to blisters in 30 seconds.
Emergency Plan has to be in place before the Lng Plant can start up,
for onsite personnel and offsite personnel. I am not sure who is
responsible for writing this Emergency Plan in Shannon but it has
confounded us in Milford Haven how this can be written without a
Quantitative Risk Assessment for a spill of Lng on water.
I have heard it said that the probability of a Lng accident is so
remote that it is not worth worrying about !
would ask you to review the The
14th International Conference and Exhibition on Liquefied Natural
Gas(LNG14) that took place in Doha,Qatar on March 21-24 2004 where a
Mr Tony Acton of British Gas in conjunction with Tractebel LNG, Gaz
de France, Osaka Gas and Tokyo Gas presented a paper
Incident Identification- A Compilation and analysis by the
International LNG Importers Group(GIIGNL)”.
is a good example of a thorough co-operative safety study by the LNG
incidents of releases of hazardous material, near misses and other
incidents of concern over the period 1965 to 2000 have been reported
and analysed by GIIGNL members LNG reception terminals and peak
shaving facilities. Only 11%
of the events reported resulted in an explosion
fire or rapid phase transition, and the
frequency of reported incidents is low 0.33
incidents per site per year.
is a trend towards a decrease in the
relative number of events where significant quantities of hydrocarbon
have been released. GIIGNL is commited both to improving further the
reporting of incidents and to maintaining its database up to date
for the general good of the LNG industry. (See attached highlighted
Statement by the Society of International Gas Tanker and Terminal
PLAYING BY THE RULES.
ARE NOT THE RESULT OF A LACK OF REGULATIONS,
BUT THE LACK OF COMPLIANCE.
AND FOREMOST IT IS IMPORTANT TO ENFORCE THE RULES THAT ALREADY
too that even if a Lng accident happens elsewhere in the world
Talbert ,County Kerry will immediately be looked on in a different
feel free to comment to Safe Haven`s E-mail address see first page.
Thank you for your interest.