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Shell cannot say it was not warned about Prelude FLNG

Warning by Bill Campbell, retired HSE Group Auditor, Shell International: Hydrocarbon leaks on offshore installations are unavoidable!

The answer to the question, can offshore installations meet a zero tolerance standard for hydrocarbon leaks, is easily answered, they cannot! Keeping hydrocarbons in the box appears beyond the wit of man. The support for this rather pessimistic view is based on actual historic data from the North Sea. It should be noted that this key indicator is the number one, the foremost technical integrity measure recorded by the HSE offshore division in the UK. All operators also are required to have it as their top indicator and non-reporting of hydrocarbon leaks is an offence in Law. So there is a degree of confidence in the accuracy of this data. 
In short, despite prevention of leaks being the utmost priority, a leak occurs somewhere offshore in the North Sea, an arena along with Norway that is subject to sophisticated regulatory oversight, every other day.
Thankfully, the majority of leaks are minor but still there are a worrying number of significant and major leaks both of which have the potential to impair the installations Temporary Refuge, cause asset damage and risk to life and limb (ref HSE definition of major and significant).
The data is available on the HSE website but I have included a summary below. The published data covers an 11 year period 2005/6 till 2015/16, the latter is the latest year for published data.  
So on average over the 11 year period
Total Leaks = 1607 or if you like one every 2.5 days
Significant Leaks = 618 or if you like one every 6.5 days
Major Leaks = 70 or if you like one every 57 days
My opinion:
First some facts. Prelude is a hazardous substances plant occupying an area on average 22 times smaller than an equivalent onshore plant. It cannot and does not, Shell downstream experts cannot fail to concur, meet the inherently safe requirements (as defined by the HSE) of a post Seveso hazardous substances plant designed and constructed in Europe.
Therefore, to meet the current North Sea standard, which Shell claim they meet for Prelude, that is having Temporary Refuge impairment frequency no greater than once per 1000 years, Prelude during its operational life, simply cannot afford to have any leaks, particularly those classed as significant or major during its operational life.  
A leak, for example, of just one cubic metre of LNG on Prelude would convert quickly on contact with seawater to 600 cubic metres of methane gas, such a volume meeting the definition of a Major leak c.f. with the HSE UK definition.
Comment by John Donovan: We created the above graphic a few years ago. As can been seen from his recent articles, Bill Campbell has now concluded that it is not a case of “almost inevitable”, but instead, just a matter of time.


SFA (Say F All)
Reading Bill’s comments has inspired me to chime in. Ruthless cost cutting is leading to such HSE incidents. The sacking of skilled and experienced staff is taking place all over the place. The risk level is being seen as acceptable where there is heavy cost injection required to be on the safe side. Nobody dares question this due to the HR assassins that are currently patrolling the corridors looking for their next victims.
As much as I like some of Bill Campbell’s articles this latest one is just going a bit too far. there are so many variables which will change the prognosis here that its almost impossible to predict the leakage potential of Prelude. The major ones are location and hydrocarbon profile. I wonder what Bill Campbell would advocate as a solution? It almost appears as if he wants to be in a position to say “I told you so” and not in a supportive mode of “this is what you could do”. The safety cases for Prelude do of course look at spill scenarios and remediation is the key, none of us at Shell is naive enough to believe in the 100% carbon loss free situation but common sense, good engineering and good training will do a lot to combat what Bill sees as the inevitable. armchair criticism at its best.

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