News Release – Issued by Shell to Sea – Oct 1st, 2017 – For immediate release
— Shell to Sea has cumulative knowledge of the Shell/Corrib project, and is capable and willing to put hard questions to CER and EPA. —
The latest fiasco in the Shell refinery at Bellanaboy resulted in as yet unspecified volumes of un-odourised gas entering the national gas grid and as yet unknown quantities of toxins released to land, sea and air in Erris, north Mayo. Shell to Sea has produced a list of specific questions for CER (recently renamed to the Commission for Regulation of Utilities) and EPA, the two statutory bodies charged with investigating this most recent lapse in Shell’s ‘global technical expertise’. [1, 2]
The list of 22 questions (copied below) is not exhaustive; it may evolve to include other questions and, depending on the accuracy of the answers received from CER and EPA may include follow-up questions.
Spokesperson Terence Conway said “Terry Nolan of Shell said in 2006 that ‘We use terminology that is not accessible to everyone’ – he was very wrong to imply that Shell to Sea did not understand that terminology”.
Spokesperson Maura Harrington stated ‘Shell to Sea know this project; we know the questions to ask and we will keep going until we get proper answers’.
List of questions regarding un-odourised gas from Bellanaboy refinery entering the national gas grid
1. How was it possible for un-odourised gas – in any quantity – to leave Bellanaboy refinery and enter the national grid?
2. Given that the ‘information’ provided to the public by the operator Shell and distributor GNI does not appear to Shell to Sea to be rational – specify the timeline of this fiasco?
(i) when was the entry of mercaptan-less gas from the refinery into the national grid first noted
(ii) By whom and where was (i) above recorded
3. From the inception of this fiasco and through its duration, detail the measures taken by the operator in relation to the production pipeline from well-head into and within the installation.
4. State precise time reverse-flow from Craughwell to Bellanaboy was initiated.
5. Specify volume of mercaptan-less gas which entered the ring-main from Craughwell. Should reply to foregoing point be in the negative provide coherent assurance outlining checks and balances which are in place to support such an assurance.
6. State total volume of gas from production pipeline and reverse-flow from Craughwell which was cold vented prior to and following the intensive, prolonged emergency flaring.
7. Can a definitive assurance be given that there have been no previous non-odourisation incidents at the installation? – to that end, provide a comparison table of gas produced and volume of mercapton delivered where from any deviations could indicate unreported non-odourisation events
8. State whether the operator Shell is/is not in breach of any EPA, CER, Plan of Development and/or other consents and if not, why not?
9. Why/how could the EPA state – and by whom it was stated – on or before 1.00 pm on Friday 22 September 2017 that the flaring at Bellanaboy ‘was not a regulatory breach’
10. State the total volume of gas released to the atmosphere through cold venting and flaring and calculation of CO2 emissions there from.
11. State definitively who is liable for the cost of said CO2 emissions.
12. Provide breakdown of total toxicity released to land, air and water; show deposited range of toxicity in relation to prevailing weather conditions.
13. State compatibility in law – EU legislation as transposed into Irish law – between the EU Habitats Directive and EPA/CER legislation relative to dealing with emergencies such as recent one.
14. As statutory bodies, are CER and/or EPA solely reliant on data provided by Shell; if not, outline the independent checks and balances which exist.
15. State when Bellanaboy refinery recommenced supplying gas to the national grid?
16. When did the EPA/CER learned of the cause for un-odourised gas entering the national grid?
17. What guarantees can the EPA/CER give that the placing of un-odourised gas onto the national grid won’t reoccur?
18. Had an incident occurred with the un-odourised gas on the national grid causing injury or damage, who would have been liable?
19. Was the flaring of the gas at Bellanaboy agreed with CER/EPA before it was commenced with?
20. What are the potential penalties that are open to CER/EPA to follow on the operator for placing un-odourised gas on the national network?
21. Would any potential fines be allowed to be written off against tax as a operating cost by the operator?
22. Do CER/EPA retain confidence in the operators of Bellanaboy refinery to extract gas and provide gas to the national grid in a safe manner?
 Crux of Corrib problem is a lack of real dialogue – Terry Nolan, Ex-MD of Shell E&P Ireland – Irish Times