INFORMATION SUPPLIED TO SHELL AND THE SCOTTISH POLICE

ROYAL DUTCH SHELL PLC (COMPANY SEC MICHIEL BRANDJES) AND THE SCOTTISH POLICE (CHIEF SUPT. BILLY GORDON) HAVE HAD ADVANCE SIGHT OF THIS EMAIL AND ATTACHED INFORMATION FROM BILL CAMPBELL, RETIRED HSE GROUP AUDITOR, SHELL INTERNATIONAL

From: Cambell
Subject: Articles
Date: 25 September 2013 12:33:02 GMT+01:00
To: [email protected]
Cc: [email protected], [email protected]

John
 
I want to keep up the pressure on Shell by the publication of these two additional articles that cover the hardware faults taken from Shell’s own data.
 
The Chairman wrote to me some time ago saying he agreed with the 2006 press releases, I understand his defence now is that he was misled at the time by Malcolm Brinded and his legal counsel Keith Ruddock.
 
I want to use the fact that the Chairman has not raised, and will not raise, any legal objection to these articles in this correspondence copied to the police, and the previous article re behaviours, in future correspondence with the HSE and the judiciary.
 
I will pass to all the bundles of evidence supporting these articles in due course
 
Bill

CONTENT OF FIRST ATTACHMENT: DANGEROUS RISK LEVELS DOC.

The Shell Chairman accepts that many Offshore Installations operated at dangerously high risk levels over a prolonged period prior to a fatal accident

 

Introduction

 

The evidence referred to in this article relates to temporary repairs on pipes, 214 in all, of which 73 were in hydrocarbon service.  None of the repairs were approved by a technical authority in breach of Safety Case commitments.  The evidence is held by the police and Shell accepts that this data is authentic.  Shell has raised no objections to this publication on legal or other grounds

_______________________________________________________________________

 

In 1999 a combination of surface corrosion and internal erosion was eating away like a cancer at offshore pipe work.  It was a complete shambles.  An Audit carried out at that time reported on the ageing assets offshore there was increasing use of temporary clamps, due to pipe-work reaching minimum acceptable wall thickness causing loss of containment.  The audit found that no person at any level in the Aberdeen organisation appeared to have a concise overview of the technical integrity status of offshore installations e.g. the collective picture of loss of containment risks due to fitting temporary clamps, and the amount of thin wall pipes at any moment in time.

 

Directors accepted these findings and plans were put in place to recover the situation.  Despite this the situation deteriorated drastically.  A pipe repair was being fitted every three days somewhere in the oilfield.  The number of these repairs was unknown because they were not being recorded; there was no register of these repairs.  In panic and confusion the Production Director asked his operators to walk every line, the more they looked, the more they found.

 

In total by the time of the fatalities in 2003 some 472 temporary repairs had been carried out, one on average every 3 days, with 214 such repairs carried out, one every 7 days or so, were not approved, of which 73 in hydrocarbon service, and of which 9 were found to be materially defective including the repair that initiated the accident in September 2003. 

 

These 214 non approved repairs equates to 214 breaches of Shell commitments in its Safety Cases where no changes to plant or equipment were to be allowed without the prior consent and approval of a competent person.  The public Inquiry in 2006 established that a significant factor in the growth of unapproved repairs was the lack of resources, inadequate competent persons to deal with the backlog, such that Asset Managers simply ignored their own mandatory policy to get prior approval.

 

The repairs were being carried out because of loss of containment, and such a loss from an oil or gas pipe is reported under Government guidelines as a dangerous occurrence because of the potential of creating a flammable atmosphere.

 

If we consider the 73 repairs to hydrocarbon carrying pipes, every 3 weeks or so, a dangerous occurrence would develop when pipes with hydrocarbons and with paper thin walls leaked, it appears that many of these events, which by Law require to be reported, it is after all the principal key performance indicator, reported in HSE statistics, were not reported.  These leaks were then repaired, the repair was not registered, no one knew exactly how many there were offshore, and where they were, and no prior approval of the repair was sought from a technical authority.

 

From the viewpoint of the risk analyst, the mean time between dangerous occurrences offshore was circa 3 weeks, and yet Shell told the world in 2006 that it absolutely refutes the allegation that it operated installations with dangerously high risk levels. 

 

The commitments accepted by Directors in 1999 to get to grips with the situation, register these repairs, have in place sufficient competent persons to approve the repairs or otherwise, just simply failed to get done.

 

The end result was the double fatality in September 2003, which the public Inquiry determined, could have been avoided if the repair to the pipe on Brent Bravo had not been materially defective.  So here again Directors actions, or more appropriately inactions, contributed to the deaths.

 

This statement was endorsed by the then Lord Advocate Angolini who replied to parliament that the haphazard management of such repairs, over a prolonged period, had contributed to the deaths in her opinion.

 

For a Company that has within its Business Principles compliance with the Law, here is an organisation in Aberdeen breaking the Law every 7 days or so.

 

Culpable homicide charges in Scotland have been historically difficult to prove against the marker of beyond reasonable doubt.  Directors defend their position by the argument that they were not personally aware of what was going on.  They are often shielded by layers of bureaucracy they say. 

 

So the question is, did the Shell Directors accountable for these matters know about these defects, and if so, what actions did they take to rectify the situation?  The answer to this is in the uncontested Shell evidence that Directors were made aware, but took no appropriate action to prevent the deaths, and were therefore culpable. 

 

After the fatalities operators were instructed by the Production Director to walk every line.  The more they looked the more they found.  Over 400 repairs most of them unknown about and just like the statement made in 1999, no single person had an overview of the risks associated with all this mess.  It took till November to tally up the number of repairs, 8 of which were in the same defective condition as the repair that caused the fatalities. 

 

Shell are on public record as having some £1.5 billion to recover the situation over the 8 years or so after the fatalities.

 

Bill Campbell

CONTENT OF THE SECOND ATTACHMENT: REMEMBERING PIPER ALPHA

The Shell Chairman accepts that the failure of his Directors to act contributed to offshore deaths in an accident that was a potential Piper Alpha look alike

 

Introduction

 

The evidence referred to in this article is related to emergency shutdown valves (ESDV) and their associated fire and gas detection systems.  The evidence is held by the police and Shell accepts that this data is authentic.  Shell has raised no objections to this publication on legal or other grounds.

———————————————————————————————————–

Remembering Piper Alpha

 

Gas is the great killer and gas explosions specifically cause the significant majority of industrial deaths worldwide.  On Piper Alpha human failure in the working of the permit to work system allowed the nightshift to start a gas compressor whose pipe flanges had not been secured.  The gas cloud ignited resulting in a massive explosion.  The situation however was recoverable if only the gas supply could have been isolated to restrict the heat energy from the burning gas. This enormous heat energy quickly weakened the steel structure till it turned plastic and in this state was unable to maintain any load bearing.  We have all seen the pictures of that night in July a quarter of a century ago, who can forget them.  The gas could not be isolated; there was no ESDV on the incoming gas riser.  Even if the sending end platform some miles away had shutdown its process to stop the gas flow to Piper immediately it would have made little difference.  The entrapped volume of gas in the sub-sea pipeline, operating at many times atmospheric pressure, was more than sufficient to destroy the structure, with temperatures of around 2000 degrees Celsius, when the gas accelerated unhindered towards the open ended pipe-work at Piper. So it was that a major offshore installation was destroyed in some 22 minutes with the loss of 167 lives.

 

So ESDV and their maintenance in good repair is vital, that was the appalling lesson from 25 years ago.  This was the justification for introduction of prescriptive legislation

 

Given this importance and before the Safety Cases were prepared, prescriptive legislation was brought forward to install ESDV on all incoming and outgoing oil and gas risers.  So the importance of ESDV, and their maintenance in good order, can not be overemphasised.  This was enacted under the Pipelines Safety Regulations supported by the Prevention of Fire and Explosion Regulations.  The latter legislation was to ensure, by independent verification, that Fire and Gas detection systems were installed that could cause the automatic activation of ESDV.  The law made it an offence to operate with ESDV or fire and gas detection systems that were not in a good state of repair.

 

But 15 years later the Brent Bravo accident was a potential Piper Alpha because ESDV were inoperable due to neglect

 

In Sept 2003 two men entered the enclosed column on Brent Bravo to repair a temporary clamp on a pipeline going from the oil and gas process into the massive concrete storage cells.  The clamp was not approved and as the public inquiry determined was mechanically defective.  They did not have a permit to work.  The clamp failed when they were working on it.  But instead of water escaping, water with minute quantities of oil of around 30 parts per million in solution, a massive quantity of gas escaped from the temporary clamp and flooded the enclosed space.  It did not ignite, but caused death by creating a hydrocarbon rich and oxygen deficient atmosphere.  It did not ignite because the gas escaped in such volumes that the atmosphere would have gone through the explosion range for methane/air mixtures in seconds.  During those seconds no ignition source was present.  ESDV installed to isolate the gas flow in an emergency failed to operate. In total the inquiry found that some 15 ESDV were known to be defective or degraded including the main riser ESDV prior to the accident.

 

The gas did not ignite so the potential of a look alike Piper Alpha was avoided, if a spark had been present many more casualties would have resulted as there was significant doubt that the cellar deck, the weak point, the transition zone, where steel meets the concrete column, could have withstood the instantaneous overpressure.  Concerned about this The Sheriff at the public inquiry recommended a more general inquiry into the failure of the ESDV on that day and the effects such failures could have had on the installation structure. An explosion had the potential of causing a partial or complete collapse of the installation. No such inquiry was held with no explanation of why from the Crown Prosecution Service.

 

How can Directors be linked to the deaths in 2003?

 

On 20 October 1999 the Shell Internal Audit Manager in Aberdeen wrote directly to his Directors with serious concerns that ESDV were failing but had had their test results falsified.  He also complained about the delay in doing anything about the situation. 

 

On 22 October 1999, in an Audit presentation to the complete Aberdeen leadership team, including the Directors Chris Finlayson and Tom Botts, these concerns were repeated with recommendations to rectify the situation.  Later the recommendations were put in an implementation plan.  So Directors had accepted the serious concerns, their duty then was to insure that the rectification work including the behavioural aspects were followed through. 

 

In October 2001 an HSE Principal Inspector writes to Shell asking that Directors be made aware of what he describes as unacceptable delays in follow up to Improvement Notices.  These notices relate to failure to verify that Fire and Gas Detection systems across the field are functioning.  The Inspector says Shell have been out of compliance for 18 months. So Directors were again warned from a different source.

 

In 2003 failure of a number of ESDV contributed to the deaths according to the public Inquiry.  In addition, the Brent Bravo riser ESDV was in the same degraded condition that it was in 4 years earlier.  Clearly the implementation actions were not completed and the behavioural aspects remained unaltered also.  The inquiry specifically confirms that the defects on the ESDV were known about prior to the accident

 

In November 2003 the Production Director presented information on the status of ESDV across the field to the HSE in Aberdeen.  This information was from the post fatalities technical review and is summarised below.  The authenticity of this information is not contested by Shell.

 

On the Anasuria FPSO there had been repeated ESDV valve failures.  The ESDV was purposefully inhibited from operation but production continued.  In addition 60 fire and gas detection systems were in a fail to danger condition. On Fulmar there were failed ESDV with no follow up identified. In addition 434 fire and gas detection systems were also in a fail to danger condition. On Brent Charlie ESDV failures were not being corrected when identified.  In addition 30 fire and gas detection systems were also in a fail to danger condition.  On Brent Alpha ESDV had failed their leak-off tests but corrective maintenance work orders to rectify had been cancelled.  In addition 20 fire and gas detection systems were also in a fail to danger condition

 

Brent Delta had a failed ESDV but corrective work orders had been cancelled.  In addition 35 fire and gas detection systems were also in a fail to danger condition.  On Tern the fact that ESDV were not meeting the required standard was known about by the Asset Manager. In addition 18 fire and gas detection systems were also in a fail to danger condition. On Gannet there had been repeated ESDV failures but this data had not been recorded.  In addition 317 fire and gas detection systems were also in a fail to danger condition.  On Dunlin ESDV tests were being signed off as successful even when failure noted. In addition 6 fire and gas detection systems were also in a fail to danger condition. On Cormorant Alpha sticking ESDV identified during tests in 2002 but remedial actions not undertaken.  In addition 10 fire and gas detection systems were also in a fail to danger condition.

 

Not surprisingly, the Shell Internal investigation which reported to the CEO in July 2005 into the conduct of Directors in 1999, found no evidence that the actions to reduce risks in 1999 had ever been undertaken.  Rather the criminal neglect of ESDV maintenance had worsened considerably.  To operate knowingly with failed ESDV had become just the normal way of doing things.

 

Culpable homicide charges in Scotland have been historically difficult to prove against the marker of beyond reasonable doubt.  Directors defend their position by the argument that they were not personally aware of what was going on.  They are often shielded by layers of bureaucracy they say.  So the question is, did the Shell Directors accountable for these matters know about these defects, and if so, what actions did they take to rectify the situation?  The answer to this is in the uncontested Shell evidence that Directors were made aware, but took no appropriate action to prevent the deaths, and were therefore culpable. 

 

They were also clearly culpable by allowing offshore installations to operate with principal ESDV known to be in a failed condition, with no plans at all to do anything about it.  The Production Director was clearly aware of this when he presented this data to HSE in November 2003 but took no action to shutdown nine offshore installations with ESDV either in a failed state, or with functionality degraded, and continued to operate 14 offshore installations with 1278 unreliable fire and gas detection systems.  These were serious breaches of prescriptive legislation enacted as a result of Piper Alpha.  This was criminal neglect on an industrial scale.

 

Even if an ESDV is in good working order, and they seemed to be on some installations, the ESDV will not operate, doing nothing in an emergency, unless it receives a signal from the Fire and Gas detection system.  But 1278 such systems, according to Shell data, were unreliable, with the probability that they would not have actuated the installation ESDV on detecting fire or gas.

 

All this should be viewed against the Shell press releases in 2006 that their Directors  had vigorously responded to the defects witnessed in 1999 and claimed that significant improvements had been made across al their facilities.  They absolutely refuted that they operated installations at dangerously high risk levels and threatened to sue the BBC for this suggestion.  All lies of course, and now accepted as such by the non executive Shell Chairman and his legal counsel

 

The Scottish TV programme Frontline Scotland had short tenure after these threats and the Director left the BBC to go freelance, and the Producer left to join ITN/Channel 4, such is the power that Shell can apply.  These were just two of the many victims of this criminal abuse of power.

 

 

Bill Campbell

 

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