Jul 01 – GSD Provides Comprehensive Commentary On HSL Statement
The GSD says it has taken time to review the brief statement by the Health and Safety Laboratory and says it has only served to reinforce the “extraordinary lengths” to which the Government is resorting in order to discredit the Lloyds Report.
The GSD says it would like to remind people that those attempts included “blatant lies” such as the allegation that the report had been redacted by some 80 pages or that it had been based on a single skin tank. Both of these allegations, calims the GSD, have been proved to be false. Indeed, argues the Oposition, in one communique reported by GBC, the Government said the HSL had said the Lloyds Report was based on a single skin tank when the HSL document says nothing of the sort.
Quoting directly from a GSD release this afternoon, these are the points the party has highligthed with regards to the HSL document:
Point 1 – capacity of the tanks
It is true that the Lloyds report is based on two LNG tanks of 10,000 m3. The reason for that is that the Government invited expressions of interest for tanks with a minimum storage capacity of 12,000 m3 and two tanks of 10,000 m3 would be needed to make it economical for use supplying the power station and bunkering. Even if the capacity were to be 12,000 m3 (i.e. the minimum stated by Government) the concerns of the GSD would be the same. 12,000 m3 is still a very substantial amount and these terminals are simply too close to residential areas.
Whether slightly smaller or larger, the consequences of an LNG release do not significantly change. The Lloyd’s report actually assumes that measures would be in place to limit a release of LNG to between 60 seconds and 5 minutes. There has never been an assumption that the entire contents of a storage tank could be released into the environment in a single event, though worryingly, this possibility is what Government appears to be alluding to by suggesting the size of the tanks is significant. However, even a limited release as described in the Lloyd’s report will have unacceptable consequences for our community, as described in that report.
There is an additional difficulty of using smaller tanks and that is that they would need to be re-supplied more often, which would introduce new risks into the equation. It is also important people note that the HSL does not say what size of tanks are proposed. This is symptomatic of the lack of information which is being provided to the public.
Point 2 – position of the tanks vis a vis cruise liners
Of course, positioning tanks so close to a cruise terminal “may not be the best position on the North Mole”! This is the precise point that we have been making all along and it is noteworthy that the HSL do not say that the position considered by Lloyds is not the one being considered.
In any event, the reality is that any repositioning will only make a difference of a few metres and it will still be very close to a cruise liner terminal.
Point 3 and 5 – the subsea pipe line and further land reclamation
Lloyds and HSL would appear to be in agreement so it cannot be relied upon to undermine the report.
HSL say: “ Option 2 involved storage on the Detached Mole with a subsea LNG (refrigerated liquid) pipeline to shore. All options that HSL have been asked to consider for the Detached Mole involved regasification on the Mole and a subsea gas pipeline. It is not clear why an LNG pipeline was considered as it would be a novel design and introduce significant technical difficulties.Option 2 involved storage on the detached mole with a sub-sea LNG pipeline to shore. All options that HSL have been asked to consider involve regasification on the mole and a subsea gas pipeline”. It then goes on to say that because an LNG pipeline (as opposed to gas) would be difficult further land reclamation would be necessary if it is feasible.
Lloyd’s in their report state:
“The proposed option for installing LNG terminal and storage facility on to Detached Mole is potentially feasible, however, due to current technology limitations concerning LNG subsea pipelines it will require to undergo further design evaluation. The incorporation of a regasification facility at Detached Mole will provide the ability to directly export gas through a subsea gas pipeline across to the North Mole or at a landing area nearest to the Power Station”. It then goes on to say that there is however no space currently at the detached mole for a regasification facility.
It is therefore not true to say that Lloyds have not considered these issues. HSL does not, for example, state whether further land reclamation, which it (together with Lloyds) acknowledge is necessary in order to re-gasify at the Detached Mole, is feasible.
In this respect the GSD highlights that experts will have to have regard to the possibility of a sea surge similar to that which happened some years back as the result of land reclamation at Isla Verde in Algeciras which destroyed Westview park promenade.
Point 4 – Large carriers
HSL say:
Section 3 of the report indicates that very large LNG carriers (LNGC) were assumed to be used to deliver LNG. For example, QFlex LNGC are mentioned. Such very large carriers have not been assumed in any concept designs from developers that have previously been considered by HSL.
The Lloyds report does not assume anything about the size of carriers. On the contrary it says that large carriers cannot be used because of shallow waters. It says:
“Serious limitations due to existing shallow water draught impose restrictions to typical trading LNGCs (138k m3-148k m3) entering port waters, manoeuvring and berthing at either the Western or Eastern side of the North Mole or the Eastern side of the Detached Mole. Project needs to establish the maximum size of LNGC able to undertake cargo offloading at Terminal”.
For our part, the GSD would add that using smaller bunkering vessels will undoubtedly have commercial implications and would introduce new risks as smaller vessels would require a higher frequency of operations.
Points 6 to 8 on methodology
It is not for the GSD to get involved in a debate as to methodology employed by Lloyds. Lloyds are the leading risk assessors in the world and we are entitled to assume that their methodology to assess risk is the correct one.
Point 9 and 10 – recommendations
We note that the HSL state that the recommendations of the Lloyds Report represent good practice and we are glad that they will be taken on board, it is however not true that the Lloyds report is based on wrong assumptions as we have explain above.
Conclusion
The Lloyds Report continues to be the only report published. A careful comparison of the HSL document and page 8 section 3 of the Lloyds report shows that the Lloyds Report and the HSL are in agreement on the very issued highlighted as showing that Lloyds relied on false assumptions. We invite environmentalists and the public to undertake that comparison.
In their carefully worded conclusion HSL say “The Lloyd’s Register study has not raised any issues that appear, at this stage, incapable of being addressed by suitable concept selection, detailed design and the use of international good practice standards and procedures. This note does not preclude the results of more detailed QRA and assessment which may be possible subsequently”. What they do not say is that the possibility of an incident can be reduced to nothing or that the consequences of a release of LNG can be mitigated. In the locations that Government is proposing to site LNG facilities, the GSD demand no less than risk elimination and this is not possible.
What is incredible is how little, other than what appears to be some preliminary scoping work, the Government has done to obtain safety assurance for this project, despite already awarding the contract for a power station. That the safety assurance will be provided by those who are bidding for the contract to build the LNG terminal creates even more doubt about the Government’s judgment. The GSD will continue to work solely for what is in the interest of the safety of our community.
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