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Licensing Process - LNG Terminal

Planning Permission for Shannon LNG Terminal

Submission by David Robinson,  LNG Safety lobby group 'Safe Haven' from Milford Haven, Wales.


Safe Haven.

PO box.27.

MILFORD HAVEN.

Pembs.

Tel.No. 01646 690190

Pav`s Mem No.270

E-mail Address:- shlng@tiscali.co.uk Website:- www.safehavenpembs.co.uk

To whom it may concern:-


I am 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 .

I am 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” Terminal.


Can I 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.


With 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 following questions:-


1/. 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 ?

Given 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.

Needless to say that Lng Project is not going ahead.


2/. 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)


3/. 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 ?

Given 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 melting point.


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?

What “Domino Effects” are expected from this Gas Cloud ignition ?

Note:- 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”.



5/. 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 water.(see Attachment)

(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”?

In 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).

In 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 above report)

In 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).



8/. 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.?

Note:- 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

Explosions& Gas Release from LNG Carriers” that 1.5kw/m3 is safe. (Page 3 of doc attached).

Also 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.

In 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.

Note:- 5kw/m3 burns bare skin to blisters in 30 seconds.


9/. An 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.




Finally I have heard it said that the probability of a Lng accident is so remote that it is not worth worrying about !

I 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

Lng Incident Identification- A Compilation and analysis by the International LNG Importers Group(GIIGNL)”.

This is a good example of a thorough co-operative safety study by the LNG industry:-

246 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.

There 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 document).


Lastly a Statement by the Society of International Gas Tanker and Terminal Operators :-


PLAYING BY THE RULES.


DISASTERS ARE NOT THE RESULT OF A LACK OF REGULATIONS, BUT THE LACK OF COMPLIANCE.

FIRST AND FOREMOST IT IS IMPORTANT TO ENFORCE THE RULES THAT ALREADY EXIST”,


Remember too that even if a Lng accident happens elsewhere in the world Talbert ,County Kerry will immediately be looked on in a different light.


Please feel free to comment to Safe Haven`s E-mail address see first page.

Thank you for your interest.