Alarming warning to the Australian National Offshore Petroleum and Environmental Management Authority about Shell Prelude Project

Preamble 

Some 30 years of government statistics from some 200 installations in U.K. waters demonstrate that despite it being the Regulator and the industries highest safety priority a significant number of dangerous occurrences re the loss of hydrocarbons has continued over this prolonged period. No one will or could argue on this conclusion based not on supposition but on historic data that there is and continues to be a certain inevitability that hydrocarbons will leak into the atmosphere. Subsequent ignition of these leaking hydrocarbons has the potential of loss of life or threats to the structure of the installation.

All this not subjective, not emotional, just plain statistical fact.

Shell Australia certainly, not sure about RDS, must have felt so confident that FLNG hydrocarbon facilities could buck the leakage trends re loss of containment because although these installations have residual risks that are higher than the average North Sea facility, as previously explained in many articles appended to this website, the only way these Shell statements purporting best in class low risk levels for Prelude can possibly be justified is if Prelude FLNG will have during its operational life no losses of containment.
None whatsoever!

What is worrying about the Australian regulators concern is that intrusive entry into hydrocarbon containment areas has been going on for some time, possibly with operators under pressure to reduce outage periods, without proper isolation and de-pressurisation, as required by Shell’s own internal procedures.

In summary

The demands of the Regulator seems simply put to get Shell to be faithful to and fully comply with its own competent procedures for safe isolation of plant and process.

Past history is important, examples

Lest we forget, it was accidental failure, but failure nevertheless, to isolate a gas compressor in compliance with Occidental procedures and its Permit to Work that led to the deaths of 167 persons on Piper Alpha and the total destruction of the asset.

On Brent Bravo it was the failure of trainee operation technicians to comply with normal procedures to isolate the downcomer pipework on the hydrocarbon line to the storage cells prior to the repair of a leaking temporary patch that led to two deaths.  This incident also had the potential for the destruction of the installation with a loss of 156 persons if the huge gas cloud emitted as a result of loss of containment within the enclosed top sides support column had ignited, ref (1).

(1) Evidence given to the Sheriff in camera by HSE structural engineers and the Shell scientist at the the time of the public fatal accident inquiry into the deaths on Brent Bravo in 2006.

Bill Campbell

BILL CAMBELL ARTICLE ENDS

An email has been sent today to The Australian National Offshore Petroleum and Environmental Management Authority drawing this article to their attention. 

RELATED POSTING ON OUR SHELL BLOG 1st Feb 2020

Bogus Group: Having worked on LNG facilities and having seen the devastation of one going wrong, concerns posted on this blog about the risks posed with Prelude FLNG, were perfectly justified. But ‘as one would expect’, Shell would have considered and accounted for these risks! How else could they justify “Goal Zero ambition is to achieve no harm and no leaks across all of our operations”? However, ‘as some would know’, when costs are escalating, talk is cheap. Recent concerns raised by the Australian regulator that Shell has not ensured “best practice” for its isolation procedures on Prelude FLNG, must raise warning signs. But how can these concerns be warranted? In 2014 an article alluded to the role of Shell lawyers in collaboration with all aspects of the project, including safety regulation. If you believe the media, the acquisition of BG Group lawyers should enhance this type of collaboration. One such article centred on the responsibilities of Sarah Franklin (BG chief counsel), which included health and safety, who has inherited a new team that focuses on complex safety and environmental issues. There can be no more complex safety and environmental asset in the Shell portfolio than Prelude FLNG, yet there would appear to be a deficiency in a fundamental work control system, their isolation procedures. The article also noted her other skill sets, such as setting up BG’s first whistleblowing programme. Other’s will attest that this programme was unquestionably fallacious. As noted in a previous blog if you are a Shell employee with concerns, especially those with a safety connotation and you wish to engage with her………. beware.