20th January 2010: Chief Technical Advisor at Department of Energy argues that evaluating the consequences and not just the probability of accidents in the Corrib Pipeline Decision has created a precedent which would have the effect of prohibiting all significant infrastructure developments

The Shell Pipeline Decision:
The precedent of the Shell Pipeline decision by An Bord Plean�la of November 2nd 2009¹ where for the first time the consequences of an accident are being considered and not only the probability of an accident now needs to be equally implemented with the Shannon LNG project because it would be the most sizeable hazard in Ireland.

The Bord found as unacceptable in its decision letter in 2(c) :

“the impacts on the local community during the construction and operational phases of the development which would seriously injure the residential amenities of the area”.

We also noted in 3(c) with great interest the appropriate standard against which that major hazard pipeline would now be assessed:

“the routing distance for proximity to a dwelling shall not be less than the appropriate hazard distance for the pipeline in the event of a pipeline failure. The appropriate hazard distance shall be calculated for the specific pipeline proposed such that a person at that distance from the pipeline would be safe in the event of a failure of the pipeline”.

The decision letter goes on to state in part (d) on page 3:

“In order to eliminate any doubt please note that all failure modes should be included including the possibility of third party intentional damage”

In part I of page 3 the Bord requests:

“details of the hazard distances, building burn distances and escape distances in contours for the entire pipeline”

LNG expert Dr. Jerry Havens, in his submission to the Shannon LNG application noted:

“If an LNGC were to be attacked in the proximity of the shoreline, either while docked at the terminal or in passage in or out of the estuary, and cascading failures of the ship’s containments were to occur, it could result in a pool fire on water with magnitude beyond anything that has been experienced to my knowledge, and in my opinion could have the potential to put people in harm’s way to a distance of approximately three miles from the ship. I have testified repeatedly that I believe that the parties that live in areas where this threat could affect them deserve to have a rational, science-based determination made of the potential for such occurrences, no matter how unlikely they may be considered.”

In fact, a leak of LNG which is heavier than air will move laterally (along ground or water) until well beyond the distance at which it is still ignitable (12.4 kilometres);

The conclusion therefore is that allowing permission for a top-tier Seveso II LNG terminal, the most sizeable hazard in Ireland, where at least seventeen thousand people will live in harm’s way up to 12.4 Kilometres from the site and route of LNG tankers travelling the Estuary is unacceptable following the precedent created by the Shell pipeline decision by An Bord Pleanla.

There has not even been an initial evacuation plan proposed or assessed and we now demand that the hazard, burn and escape distances of both accidental and intentional damage be integrated into the assessment of this application as has been done for the Corrib Shell pipeline.

Bob Hanna's Comments on Corrib Pipeline Precedent

It has now even been acknowledged publicly by chief technical advisor at the Department of Communications, Energy and Natural Resources, Mr. Bob Hanna, that the precedent created would:

“have the effect of prohibiting all significant infrastructure developments” .

In an unsollicited letter to An Bord Plean�la on 20 January 2010 (attached below), Mr. Bob Hanna stated:

“In my capacity as Energy Installations Inspector for Ireland, I have observations on some issues raised in this letter. The risk assessment methodology espoused in the Board's letter is based solely on consequence, with no attention given to likelihood of occurrence or mitigation measures proposed. This is different from international best practice in this area. Risk, or hazard, assessment is considered to be a function of both consequence of occurrence of a specified event and likelihood or probability of that event occurring. There are very significant potential consequential implications arising from this approach. If it is deemed to establish a precedent, it would have the effect of prohibiting all significant infrastructure developments.”

As the proposed LNG terminal will become the most sizeable hazard in the country this intervention by the Energy Installations Inspector for Ireland is a recognition that an LNG accident would have significant consequences and therefore, at the very least, these consequences must now be assessed as part of the permissions for this project, requiring at the very least an LNG marine Risk Assessment and a Strategic Environmental Assessment (SEA). This lack of an SEA for the Shannon LNG project has already been found to be a discrepancy by the EU Commission in its interim findings of January 22^nd 2010²