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Retired Shell Global Safety Consultant says concerns expressed by Australian Regulator (NOSPEMA) about Shell Prelude fully justified

Please read in conjunction with the recent comments made by Bill Campbell in the article Alarming warning to the Australian National Offshore Petroleum and Environmental Management Authority about Shell Prelude Project

By Bill Campbell

Hydrocarbon leaks an ever-present danger – the argument with respect to inevitability

HSE started in 1992 to record and classify dangerous occurrences including hydrocarbon releases. This was adopted as their principal technical integrity measure. In the circa quarter of a century from 1992 to 2015, for example, there were 4656 hydrocarbon releases on average 194 per annum. The latest data available is for 2018 where the number of releases was recorded at 96 per annum, so there has been a trend downwards but this should not be understood to be a significant improvement because the population number of installations in 1992 was larger than the number in 2018 due to installations being abandoned at end of life. In any case, the reality is that over the period 1992 to 2015 there was between 3 to 4 hydrocarbon releases per week and in 2018 there was approaching two hydrocarbon releases per week. This can not be viewed as a significant reduction in risk because hydrocarbon loss into the atmosphere, whether it be minor significant or major, are all classified as dangerous occurrences because of the potential of these incidents.

On the basis of this historical data, it is reasonable to conclude that despite a quarter of a century of sustained effort the industry appears unable to prevent frequent loss of containment of hydrocarbons on its offshore installations.

Why close attention should be given to the Australian Regulator concerns re Prelude FLNG is that the risk of loss of containment increases if intrusive entry into pipes or vessels takes place if this equipment has not been properly isolated and made safe. Again, analysis of approaching 30 years of data gives us information on the causes of these incidents and the causes of particular interest to us re Prelude are –

(A) – Non-compliance with isolation and permit to work procedures is the most widespread operational cause of hydrocarbon leaks that Is explicitly stated followed by deficient procedures (1)
(B) – Most releases occur during normal production operations mode followed by during start-up and reinstatement (1)

Both A and B seem to align with the Regulators concerns re what has been going on on Prelude and fully justify their concerns.

(1) Offshore Statistics & Regulatory Activity Report 2018 and an Analysis of Offshore Hydrocarbon Releases by the Health and Safety Laboratory, Buxton



Prelude Rumours: Rumour has it is that the problems are due to malfunctioning valves that are being replaced hence the intrusive entry into plant, a very unusual and unwelcome occurrence it seems causing the operators to make short cuts, begs the question If shortcuts are being taken elsewhere? if this type of behaviour is prevalent and not discouraged in one area it can be contagious, no idea what valves and where in the process but likely to be a factor in the underperformance of the plant reference design outputs.

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.


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