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PUBLIC ENQUIRY PRESENTATION
BY GEORGE WHATLEY
Chairman of People Against Methane (PAM)
Oct-Nov 2007
OPENING ADDRESS
My name is George Whatley I have lived on Canvey Island at 35 Limburg Road since 1964
In late November of 2005 I was elected by a gathering of like minded people to be the Chairman of a group called “People Against Methane” (PAM)
“People Against Methane” (PAM) is an organisation of ordinary people formed because of the major concerns by the ordinary people, of the planning application by the Calor Gas Consortium to site in its “TOP TIER COMAHH” site 120, 000 tons of Liquid gas next door to them on Canvey Island
There is little or limited access off the Island in the event of an emergency, therefore creating the implication of an increase in their “Societal Risk” as all traffic must pass through one roundabout which becomes compromised particularly at commuter times
There is also limited access and egress infrastructure for the hundred of thousands of people in the wider area of Castle Point and South-East Essex in the event of an emergency involving an incident leading to a serious accident with this Liquid Gas
Canvey Island people are unique when paralleled to other communities in the south east of England; it is a very friendly population where neighbours talk to one another discussing their community.
The unique community of Canvey Island is often related by generations of family connections and are a very close knit community unlike some areas where you can live next door to someone for ten years and not know their name
There are good Commuting facilities to London by rail and Castle Point is a sought after area for 1st time home buyers, families and retired people alike
The People Against Methane (PAM) committee, our M.P. Dr Bob Spink, individual Councillors and County Councillors, the Castle Point Council and all the Political Parties as a whole have all united behind the people against this proposal
They and the people have expressed they cannot help but feel that, the “Calor Gas Company” backed by the rest of the consortium comprising of “Centrica” (ex British Gas) “Osaka Gas” “LNG Japan” and the partners of “Sojitz Corporation” and the “Sumitomo Corporation” has not convinced the people that the Planning proposal for this site is imperative and solely in the National Economic Interest
Therefore this proposal should be refused
10,000 people signed a petition which was raised by the local “Independent” party
We understand a “Petition” even with 10,000 names on counts as 1 letter of objection and give an indication of the feelings of the people on any particular issue and can be presented by an MP in Parliament
A “Referendum” of a majority of the voting population of Canvey Island was carried out by the “People Against Methane”
A “Referendum” whilst much stronger, cannot be for procedural reasons be presented at Parliament, but it can be presented to Government Departments, or as in this case it can be counted as a true account by the amount of votes recorded.
In this case 8,425 recorded objections
Even though the very same people The Calor Consortium want to be good neighbours with, have said a resounding NO in that referendum it seems the “Calor Consortium” still want to impose this terminal upon them against their will
In that properly adjudicated referendum 68% of the voting population of Canvey Island voted (an average Election vote is between 22% and 32%)
(Letter from Ray Howard - Appendices 1)
The “Calor Gas” Depot declined to be part of that Referendum
(Letter from “Calor Gas” – Appendices -2)
The Referendum count, was on the 6th December 2006 and the result of that count was 99.5% of Canvey Island’s voting population that voted on this referendum, said No to the Calor Gas proposals because they fear for their safety and the safety of their loved ones
There were 34 voted for the gas terminal and 8,425 voted against the terminal
(Box with Referendum slips)
When we carried out the referendum the people told us of their fears and how emotionally they feel about this terminal being sited so close to them
We were able to gauge the depth of feeling of the people and their determination to oppose this terminal I believe additionally 1,900 families also took the trouble to write letters to the planning inspectorate expressing their fears about the siting of these tanks so close to them
The people worry about the web of hazardous industry already sited on their doorstep surrounding them with no knowledge of any adequate escape route out of the area or any instructions as to what to do in the event of an accident involving any of the “TOP TIER COMAH” industries
(Letters Appendices 3)
The people have voiced the opinion that they feel that Canvey Island is being used as a dumping ground and that they are expendable
Do not consider the population of Castle Point have a “NIMBY” (Not in My Back Yard) attitude in this instance
Look at what dangers are already in our back yard:
(Maps of the Thameside installations – Appendices 4)
- The dangers of Flooding (Canvey is on a flood plain and flooded in 1953 with devastating consequences)
- Existing “TOP TIER” COMAH site of LNG at the Isle of Grain (Which has expanded from its original planning application)
- Sunken 2nd World War Ammunition ship “The Richard Montgomery” (in the Thames Estuary)
- The dangers of a Shipping incident affecting the sea wall (In the past an Ammunition ship has rammed the sea wall at Canvey also there have been other collisions) and we feel the river Thames is a floating COMAH site in it’s own right overseen by the PLA
- There are COMAH sites of Oil Refineries on both sides of the River Thames near Canvey Island
- TOP TIER COMAH site of the “Oikas” Storage Depot next door to the TOP TIER COMAH site of the Calor Gas terminal
- LPG already stored at the TOP TIER COMAH site of the “Calor Gas Terminal”
And now we are threatened with the introduction of more TOP TIER LNG COMAH products at the Calor Gas terminal
The skyline plumbing of these proposed tanks will dominate the landscape and will be seen for miles from Canvey Island, changing the visual impression of Canvey Island from a residential area with a bit of industry, to the visual impression of Canvey Island being a Gas Tank Farm with housing around it
There is the danger of an Incident leading to an Accident with LPG and or LNG that would involve using what in our opinion is an inadequate Off- Site Emergency Plan
This is also without the threat of a Terrorist attack
There is the possibility of an incident leading to an accident at any of the TOP TIER COMAH installations that might cause a Domino Effect disaster
We have all of this and we have only one access point off the Island in the event of an incident leading to an accident as all roads off Canvey Island converge at the one roundabout at Waterside Farm
There has been no information relayed the people and especially the vulnerable members in our society as to what to do in the event of an emergency at the Calor Gas terminal
ENOUGH IS ENOUGH
THIS COMMUNITY IS ALREADY DOING ITS BIT IN THE NATIONAL ECONOMIC INTEREST
We give up our time and effort and are here today because we feel that we care and are defending our way of life and the life of this community
We are not paid to be here to defend what we consider to be an indefensible profit making project
The Canvey Island people and the surrounding population resent being expected to take yet another risk at someone else’s gain in this case the Calor Gas Consortium
It is not up to the people of Canvey Island and the surrounding area to prove that the proposed planning application submitted by the Calor Gas Consortium is a HAZARDOUS site and threatens the wellbeing of the community from no matter where that threat may emanate from
It is for the Calor Consortium to prove to the people that their proposed installation or its operations will NOT put the community at risk or give the perception of risk to the community
At this point I would like to introduce Mr Paul Mobbs as a witness
THE PEOPLES CONCERNS ON THE CALOR GAS PLANS
Some of the main questions that have been posed by the people are:-
- What is in it for the “Calor Gas Company”?
- Does the site need to be cleared of existing Liquid Petroleum Gas (LPG) tanks and pipe work to be regenerated with a new large tank of LPG in the National Economic Interest?
- At the same time introducing and adding Liquid Natural Gas (LNG) tanks and pipe work and a new pipeline in the National Economic Interest?
- Has the Calor Gas site become a non-viable financial site because of its age and should close?
- Is the Calor Gas Consortium using the excuse it’s in the “National Economic Interest” as a way for the “Calor Consortium” to get a favourable consideration from the Government and therefore make a site that would become a financially non-viable into a financially viable site again?
- Therefore is the “Calor Consortium” making this Planning Application nothing to do with “National Economic Interest”?
- But a manipulation of that “National Economic Interest” for profit, by the Energy Consortiums involved in trying to get this Planning Application passed?
- Could it be they see this existing site, as a site that has passed its sell-by date and is in need of regeneration in the near future for their own profit?
- It would seem from the “Calor Gas Company” point of view the proposition of a new large LPG storage tank with the associated infrastructure offered as part of the deal that allowed LNG storage and new pipe pipelines as part of this site would seem too good to pass up?
The next question is what’s in it for “Centrica” and the remainder of the Consortium?
The publication “Our Energy Challenge” “Ofgem’s” response April 2006 page 46 Item 1.27 and 1.28 gives us some indication as to the answer to this question
(“Our Energy Challenge” Appendices 5)
- Item1.27 States that the value that the energy market places on these facilities (being LNG storage facilities) which provide high levels of deliverability on a few occasions per year, is apparent from the level of interest shown by the market participants in LNG storage capacity auctions.
- For the past 3 years all of the available LNG capacity has been sold at each of these facilities.
- In addition the amount that the market is willing to pay for this capacity has increased year on year and in a more recent auction the capacity was over subscribed
- Item1.28 In response to high gas prices a number of new LNG storage facilities are planned or under construction. The Canvey Calor Gas site being one of them, which is shown as expected to come on stream in the Ofgen response by 2010.
- There was a secret meeting at Downing Street on 10th November 2005 attended by Ministers, Industry representatives and Government officials. Following this meeting the government ordered an enquiry into whether there was going to be enough gas to keeps Britain going in the winter of that year. (Appendices 6 Ref Report )
- There was concern that the UK would run short of its gas supply in the event of a prolonged cold snap.
- Spot prices in the wholesale gas market virtually doubled within a few weeks as traders feared that there would not be sufficient capacity to meet demand.
- Reports were commissioned to look into the possibility for large industry and power stations to cut their gas consumption to safeguard domestic supplies.
- A further report would examine as to what effects on the economy would be as a consequence of a reduction in output.
- In its Winter outlook report the National Grid forecast that the UK should be able to withstand the kind of Siberian Winter experienced every 50 years or so, but in that case it said that the country’s 1,750 largest industrial users and gas fired power stations would need to halve their gas consumption.
Enquiries revealed that a number of factors caused a surge in gas prices over the previous weeks.
Firstly operators had begun to draw supplies from “Centrica’s” Rough gas storage facility in the North Sea unusually early.
This facility holds enough gas to supply one tenth of the country’s needs for three months.
Secondly shipments of LNG heading towards the Isle of Grain terminal had been diverted to the USA and Spain where they had attracted higher prices.
Thirdly there were technical problems (now resolved) that halved the capacity of the gas pipeline between Bacton on the east coast and Zeebrugge in Belgium which is used to import gas from the continent.
Clearly these sets of circumstances and the knowledge that the North Sea supply is diminishing has prompted the government to look at the storage of LNG as a solution to securing the Country’s supply.
Centrica Storage Ltd own and manage the largest Off-shore platform at Rough and its Easington terminal.
Rough is a significant provider of seasonal swing capacity, allowing gas suppliers to support varying levels of demand permitting producers to convert cheap summer gas into more valuable winter gas thus maintaining the nations supply at a profit?
The question then is why more storage facilities are not provided offshore in installations such as the Rough Platform safely away from societal risk?
Sadly the vulnerability of this option became apparent when in February 2006 an incident on the Bravo platform in Centrica’s Rough Field installation involving a fire, left 2 persons injured, causing the gas platform to be partially evacuated and a complete shutdown of this major gas supply.
(Ref: Appendices 7 Expedia Report)
London Reuters reported 16th February 2006 that the gas prices had jumped 50
Percent on news of the Rough Storage shutdown, thus increasing the value of the gas stored in the tanks at installations such as the one proposed at Canvey Island.
(Ref: Appendices 8 Tiscali report)
This again artificially manipulated the value of stored gas causing the consumer an increase in the price they would have to pay.
There seems to be a potential for a win-win situation should such circumstances as a shutdown of the Rough storage facility reoccur for whatever reason.
Is it in the Nations interest to allow energy suppliers the power to control gas prices in this way? Despite what controls Ofgem may impose.
(Ref: Appendices 9 Use it or lose it policy)
Is the Canvey proposal only money making venture where the Calor Gas consortium cannot lose? And is it controlled by the USE IT OR LOSE IT PROCESS if not is it in the National Interest to have huge gas tanks empty of gas?
WHY IS IT IN THE NATIONAL INTEREST FOR THE CANVEY STORAGE PROVISIONS TO GO AHEAD?
(Ref Appendices 10 Our Energy Challenge: Ofgem response)
‘Our Energy Challenge’ Ofgem’s response document shows a number of installations on tables
- 1.2 Current Storage Facilities
- 1.4 Future LNG Import Facilities (in which Canvey Island is given a status being IN THE INITIAL STAGES OF DEVELOPMENT
- 1.7 Future Storage Projects would be more than adequate storage for the country’s requirements for the foreseeable future and would be sufficient with Canvey Island being excluded from this list.
Thus avoiding additional societal risk to the Canvey Island residents over and above those with which they already have to contend.
So we contend that it becomes hugely financially viable for the Calor Gas Consortium when you consider what their web site states (quote Calor Gas web site)
“The final costing will be arrived at as part of the full project plan the partners have now committed to undertake but we anticipate it at between £150 and £200 million in addition to the two LNG storage tanks, this will include additional loading arms on the jetty, improvements to the gas pipeline connecting to the National Grid and a re-gasification plant on site”
With a turnover of £280m £18.3bn $8.6b 450b yen respectively and support of 50-50% investment from Sojitz Corporation and Sumitomo Corporation
The people believe it all comes down to “Profit and Loss”
Calor Gas Consortiums “Profit”
The peoples “Loss”
1-HEALTH & SAFETY / SECURITY
What is the substance we are talking about?
WHAT IS LNG?
Answer by Calor Gas (Quote Calor Gas web-site)
Liquefied Natural Gas (LNG) is simply gas in super cooled liquid form. Contrary to many perceptions, LNG is also not flammable in its liquid state and can be safely stored. It only becomes flammable when turned back into its gaseous form
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What is not said about Liquid Natural Gas (LNG)!
A) There are other aspects of this so called “Simply Gas in super cooled liquid form which does not burn in liquid state and can be safely stored”
B) It’s mostly “METHANE” GAS -- Super Cooled to below Minus 160 degrees Centigrade so it can be concentrated down 620 times from a gas state to a liquid state for economically viable storage and transportation
C) If there is a large spill of this super Cooled liquid Methane there is no way to contain it or stop it expanding 620 times from a liquid state to a gaseous state
D) If this should happen then the gas expands further into an Unconfined Vapour Cloud if this Unconfined Vapour Cloud finds an ignition source there could be an Unconfined Vapour Cloud Explosion over a highly populated area
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Under the Health & Safety at Work Act all companies must have a C.O.S.H.H. (Control of Substances Hazardous to Health) report on all substances used within there premises even down to the cleaning equipment used by cleaners
(Appendices -11- Data Safety Sheet for LNG)
1-1 C.O.S.H.H. Report on L.N.G. (Methane)
Respiratory Protection
For concentrations exceeding the recommended level use NIOSH
(National Institute of Safety and Health) approved air purifying respirator
If conditions are immediately dangerous to life or health exists use NIOSH self-contained breathing apparatus (SCBA)
Eye protection
Use safety glasses with side shields or face shields
Skin protection
Use rubber or impervious gloves/consult a qualified professional expert or industrial hygienist
Handling and storage precautions
Do not get liquid gas into eyes, on skin, or clothing
Do not breathe vapours, mist, fumes or dust
It may cause freeze burns upon direct contact
Keep away from any ignition source
Secure container from damage
Do not puncture container
Effects of exposure
Eyes
May cause irritation, pain, blurred vision, redness, tearing and superficial corneal turbidity as LNG will cause freeze burns on contact
Skin
May cause freeze burns upon direct contact
Inhalation
It will asphyxiate all living things
(LNG Continued)
May cause
Nausea/ Diarrhoea/ Loss of appetite/ Dizziness/ Disorientation/ Headache/ Rapid respiration/ Drowsiness/ Laboured breathing/ Anaesthesia and other central nervous systems affected/ Extreme exposure may cause rapid unconsciousness and respiratory arrest/ Liquefied gas may cause freeze burns to the mucous membranes and possible central nervous system depression
Appearance
Colourless liquefied gas
Odour
Odourless
Boiling point
-258F (-160C)
Fire and Explosion Data
Flash point
-292F (-180C)
Special Fire Fighting Procedure
Stop flow of Liquefied Gas if possible
Let fire burn until flow of liquid gas can be shut off
Evacuate area
Wear appropriate safety equipment for fire conditions including NIOSH Self-Contained Breathing Apparatus (SCBA)
(LNG continued)
Fire and Explosion Hazards
Very dangerous when exposed to heat or flame
Containers may explode violently in the heat of a fire
Vapours may travel to a source of ignition and flash back
Heated containers may rupture violently and suddenly without warning due to over-pressure “BLEVE” (Boiling Liquid Evaporation Vapour Explosion) or a UVCE an “Unconfined Vapour Cloud Explosion”
Fragmentation of the container should be anticipated
If a flame is against the container withdraw immediately
Spill Leak and Disposal Procedure
Evacuate the area
Shut off source
If possible contain spill
Protect from ignition
Keep out of water sources and sewers
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When Calor say LNG (Methane) in liquid form does not burn technically this is true but it is understood that in gaseous state it is highly flammable and burns 300 degrees hotter than petrol
It’s like saying petrol and diesel oil do not burn but the fumes do
With Liquid Natural Gas (Methane) once it escapes the confines of its containers (which to the layman are like giant metal and concrete thermos bottles) it’s like an evil genie escaping from its bottle can cause devastation for the surrounding area.
Once the genie is out of the bottle it cannot be put back
1-2
According to the Calor Gas Consortium the societal risk from the existing “Top Tier COMAH” installations in the Thames-side including
· The Isle Of Grain Terminal
· 2 “Top Tier COMAH” sites on Canvey Island next door to each other
· Other “Top Tier COMAH” sites on the Thames near Canvey Island
· The increased river traffic
· The expanding Thames Gateway
· The mind set of today’s terrorist
· Limited access and egress off Canvey Island in the event of an incident leading to an accident
· All this LPG and the reintroduction of storing and processing LNG
According to the “Calor Gas Company” is acceptable
To whom is this acceptable?
THIS IS NOT ACCEPTABLE TO THE PEOPLE OF CANVEY ISLAND
Acceptable translates to be of an insignificant risk?
Does the Calor Gas Company really want the people of Canvey Island to believe when you consider all the societal risk already in our vicinity plus what they want to impose on this society that all of this is of an INSIGNIFICANT RISK?
The people of Canvey Island do not want to be another accident statistic involving “VAPOUR CLOUDS” like “Cleveland” in Ohio, “Montreal” (Canada), and “Algeria”
The People know there have been a number of “UNCONFINED VAPOUR CLOUD EXLOSIONS” such as the ones at “Pernis” (1968)—Port Hudson (1970)—Flixborough (1974)—Buncefield (2005)
(Appendices -12- HSE Second Report. 13 table C)
Such clouds may start to burn around their envelopes and “lift off” to form fireballs, which are dangerous in the extreme.
When formed of hydrocarbons, they are luminous and radiate sufficient heat to cause fatal burns to bystanders, and to ignite wood and paper for example, they have been known to set fire to the interior of office blocks
As fireballs rise they produce mushroom clouds, in the stalks of which are formed violent upward convection currents which suck up and ignite debris and scatter burning brands over a wide area.
Such an occurrence can clearly cause damage far beyond the normal safety distances of what are termed conventional fires
This hazard has not been adequately investigated.
We recommend that there be further examination of such occurrences before the decision is made on this planning permission and the findings of that investigation made public and debated
(Appendices -13- Second Report Page 15 Paragraph 14)
Who pays the price for this type of scenario?
The people who live in the area, not just Canvey Island, but for miles around
The Off-site Emergency Plan dealing with a worst case scenario that Calor Gas should have in place, but is not readily available to the general public, should give a clear indication of as to the extent of the consequences of a major Incident leading to a major accident from this site, unfortunately this is still an issue with the people causing them the perception of extreme societal risk
1-3
The comment “Simply gas in super cooled liquid form” also makes light of the complicated process dealing with different qualities of LNG from various areas of the world suppliers
The basic qualities of the Liquid Natural Gas are 90% METHANE
Referring to different densities i.e.: heavier or lighter types of LNG that would be provided by Algeria or Nigeria or other parts of the world the terminal operators would likely need to handle differing qualities and densities of LNG concurrently enabling sourcing to be cost effective
The mixing of the different density in these gases within the same containers bring about stratification causing rollover or flashing within the containment and this has to be skilfully managed to prevent a hazardous situation
We understand in layman’s terms LNG from different parts of the world is of different density and quality
We understand it will be a lot cheaper buying in many different densities and qualities of LNG from different sources and being able to mix them than sourcing one density and quality of LNG from one supplier and the cost involved
Therefore the strength of tank required to enable the mixing of heavy and light LNG to avoid stratification and rollover needs to be made thicker
(Ref: Appendices 14 Stratisification – Advanced Liquid Natural Gas Storage Tank Management)
We contend that the design of the tanks are not for preventing outward attack or damage but to be able to control the effects of rollover and stratification causing an increase in internal pressure brought about by rising temperature causing expansion of the internal LNG into it’s gaseous form (LNG expands 620 times it’s size from liquid to gas)
Therefore the design of the tanks are for the profit margin being maintained and being able to mix and match different densities and qualities of LNG from different sources
Once again it is down to profit and loss
Calor Gas Profit our loss
1-4 TERRORISM
This new large installation would clearly be a major terrorist target?
Answer by Calor Gas (Ref Appendices 15 Calor Gas Doc)
There is actually no evidence that installations such as that proposed at Canvey would be a target for terrorist action. As we all know recent experiences have been tragically aimed at crowds / transport infrastructure in major cities.
However we do remain constantly vigilant and have excellent contacts through the intelligence community and our own extensive security measures on the site
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Since the 1st January 1993 E.U. Legislation on Health and Safety imposed additional responsibilities on employers relating to everyday safety of staff, visitors and persons that might be affected by their operations
The Legislation includes their safety when there is a threat of a terrorist act
It also requires employers to nominate a sufficient number of Competent persons to implement these procedures
Failure to anticipate risk and plan for its avoidance resulting in loss of life could lead to Corporate Manslaughter or Negligent charges
Whilst Management cannot prevent an attack, good planning can reduce the effects of an explosion and minimize disruption
Health and Safety at work Regulations 1992 oblige an employer to establish appropriate procedures to follow in the event of serious danger to staff, visitors and persons that might be affected by their operations to follow in the event of serious danger to them
This may include the threat of terrorist or other violent act
Calor report is to highlight that they do not consider their site to be as greater target than other terminals
If that is correct why were armed police required to protect the Easington Gas Terminal-owned by Centrica? (Ref: Appendices 16 BBC News Ref Armed Police)
Why was the Secretary of State concerned on 8th June 2007?
Ref: Appendices 17 The Secretary of States comments (news paper articles)
Terrorist threat has promoted the response of increase security measures around a large number sensitive energy sites
Security increase around other sensitive government sites in London has made other softer sites such as energy sites more vulnerable
What further off site security measures do Calor intend to install should the permission be granted?
In addition, to address terrorist risk, the Ship and Port Facility Security Code was adopted in 2003 by the member countries of the International Maritime Organization (IMO), an agency of the United Nations responsible for maritime matters concerning ship safety.
This code requires both ships and ports to conduct vulnerability assessments and to develop security plans. The PLA is very active in this arena and we have an excellent relationship with them to share intelligence and best practice
The police take the matter very seriously (Ref Appendices 18 Letter)
Anybody who has had anything to do with security will tell you that it is only a matter of when not if a terrorist decides to carry out an attack to further their cause
A free society cannot stop the most determined terrorist. All you can do is to make it very difficult for them
If you move the Target (in this case the Calor Gas Methane Terminal) to a location that is farther away from a residential area in the event of an attack the casualties are minimised to as low as reasonably practicable (this could be part of a future government structure plan for “TOP TIER COMAH” sites which we believe needs to be put in place)
The mind set of the terrorist today is more menacing with suicide bombings
As there is a trend of suicide bombings that are increasing today, the difficulty of stopping these terrorist activities increases
Now consider the Quote by the “Calor Consortium” on Terrorism
“There is actually no evidence that installations such as that proposed at Canvey Island would be a target for terrorist action
All known recent experiences have been tragically aimed at crowds/transport infrastructure in major cities”
(Ref: Appendices 19 Calor Gas Doc)
Under the section of being confident of getting there planning permission Calor Gas state “They would not progress with any development on the site that would increase the risk to the local community”
1-5
We find this statement quite strange as we believe although the LNG industry has enjoyed a history of relatively few safety incidents, there is no reason to believe that LNG industry would be a less attractive target to terrorist organizations than other infrastructure
Although intentionally creating the “perfect storm” of events necessary to cause a significant LNG incident would be challenging, it is not impossible
Therefore the placement of LNG facilities could increase or decrease the level of risk and the resulting consequences according to their siting
There was a bomb planted in the adjacent “Texaco” depot in 1979
I would like to draw your attention to the report of1980 U.R.L .Enquiry I refer to the various conclusions in section “G” of this report in which Sir Richard Ward, the inspector states: - (Ref: Appendices 20 1980 Report)
In the United Limited Refineries Enquiry Report of 1980 the conclusions on Paragraph 216“quote” by “Sir Richard Ward”
“There must be an element of risk from a terrorist attack since there was an I.R.A. attack in January 1979 which must be taken into account”
Consider the quote from “Usama bin Laden” following September 11 2001
WE LOVE DEATH – THE WEST LOVES LIFE
THAT IS THE DIFFERENCE BETWEEN US
Add to this the recent worrying figures given out by the government that they estimate there are 200 terror cells within the UK
(Ref: Appendices 21 News Paper Article)
If you look on the web sites you can down load “LNG Threat Analysis” this is a
160 page Security Risk Management Analysis which explains in detail how a terrorist can attack an LNG (Methane) terminal
(Ref: Appendices 22 “LNG Threat Analysis”)
(I have included the whole document under a separate file as evidence but have refrained from using it in total detail for security reasons and having a responsible attitude to this issue, but there are items out of this document I will be referring to because the issue of terrorism cannot be ignored)
If I, as a layman, can find this analysis then so can a terrorist
1-6
This analysis focuses on Security Risks Management involving intentional damage by a determined group; it does not address Safety Risk Management
Traditional risk management calculation methodologies are insufficient to deal effectively with the security risk now posed by terrorist groups.
Traditional risk management methodologies would have determined that the probability of terrorists employing hijacked commercial passenger aircraft to destroy the World Trade Centre was zero.
Pirates seizing a Gas Tanker in the Malacca Straits impossible
(Ref: Appendices 23 Pirates seizing Tanker Article)
A bomb being planted on a tank in a storage depot
The probability of a terrorist attack occurring can not be effectively measured, but it is now “a foreseeable risks”
There are two reasons why a terrorist would be interested in attacking an LNG tanker or facility such as the terminal proposed by Calor Gas for Canvey Island, both of which fit the Mod of Operations of al Qaeda for example
1) The potential to bring substantial damages to the energy infrastructure by creating a domino effect type disaster not only on Canvey Island but all along the Thames estuary and blighting the energy industry for years
2) High civilian casualties especially in high populated areas such as the Thames Estuary, with a population of 40 thousand or more people being close to the Calor Gas site
Whilst considerations and calculations involving probability of attack, a consideration for an alternative 5 part methodology for determining security risks and cost calculations could be considered
1) INTENT
Whether and to what extent terrorist groups have expressed interest in attacking a particular type of target or whether their overall ends and priorities would be served by such attacks
The Jihadist Terrorist network of al Qaeda and similar groups have articulated goals including
a) Killing large numbers of people
b) Conducting attacks on the western world
c) Damaging economy and infrastructure
d) Damage Oil and Gas Infrastructure
Terrorist have threatened the energy infrastructure of this country in the past, as previously mentioned a bomb was planted on an adjacent depot to the Calor Gas terminal on Canvey Island
2) CAPABILITY
Whether and to what extent terrorist groups have or could easily obtain the means necessary to conduct a significant attack against a class of facilities such as proposed by Calor Gas for Canvey Island
Since 9-11 terrorist groups such as Al Qaeda have demonstrated an ability to operate worldwide, they have the weapons and other capabilities needed to carry out an attack on an LNG Terminal like the one on Canvey Island,
The information required to carry out an attack on an LNG tanker can be easily obtained
3) VUNERABILITY
Whether and to what extent a class of facilities have inherent weakness to certain vectors of attack, with or without mitigation efforts
Both the proposed LNG Terminal and its operations and the LNG shipping transit to and from the proposed terminal at Canvey Island are vulnerable
Creating a destructive LNG incident through an intentional attack on an LNG facility such as the one proposed for Canvey Island could be achieved through several means:
Vaporized LNG
1) Using the gas in vapour form to cause to cause physical harm to surrounding population, it would be possible to have the gas spread bearing in mind LNG is a colourless and odourless gas
2) Using the gas in vapour form to ignite a fire
3) Using the gas in vapour form to cause an explosion
Liquefied Natural Gas
1) Using the liquid gas to physical harm surrounding population
2) Using the liquid gas to ignite a fire
3) Using the liquid gas to cause an explosion
The creation of permanent or temporary restricted flight areas around LNG facilities such as the one proposed on Canvey Island will not prevent high jacked or stolen aircraft being used as a weapon with no defence for that scenario
3) CONSEQUENCES
What is the range of damage from an attack on a certain class of facilities could be and to what extent the facility and the communities in which they reside have the capability to respond adequately to such circumstances
The consequences of a terrorist attack on an LNG Terminal such as the one proposed for Canvey Island or LNG Tanker would be catastrophic for the population in the surrounding area also the infrastructure if a “DOMINO EFFECT” occurred
The potential catastrophe that could ensue from an attack on an LNG tanker or LNG Terminal near a highly populated area such as Canvey Island and the surrounding area is unthinkable
4) RECOVERY
What is the timing and costs of various kinds would there be to restore essential services and infrastructure and compensate for damages after an attack
The financial cost of compensating victims and rebuilding damaged or destroyed facilities following a catastrophic attack on an LNG facility or Tanker would exceed any insurance carried by the owners and operators of the LNG facility or the tanker owners
Bearing in mind some of the off-site areas involved in the “Buncefield” incident have still yet to be concluded to a satisfactory end years after the incident
Whilst there is no adequate way in which to determine the probability of a terrorist attack on LNG facilities such as the one proposed for Canvey Island
There are adequate grounds to judge that such an attack would be consistent with terrorist’s that have demonstrated intent and capability
There is also a basis to judge that likely enhanced security measures would not significantly reduce the risk
There is significant ground to conclude that a high risk exists of catastrophic damage from these types of attacks that terrorists are capable of mounting
ALTERNATIVES:
We are of the opinion is that LNG Terminals should be sited away from residential areas as we believe that siting LNG terminals in non-urban areas would reduce the terrorist’s incentives to attack it as the impact of an attack would only involve product and not many lives
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In America the US Special Operation Forces use the “CARVER” threat assessment process
“CARVER” stands for Criticality / Accessibility / Recoverability / Vulnerability / Effect / Recognisability.
A) Criticality is the importance of a system / subsystem / complex / or component.
· A target is critical when its destruction or damage has a significant impact on the output of the targeted system / subsystem / or complex
B) Accessibility is the ease with which a target can be reached, either physically or by fire.
· A target is accessible when an action element can physically infiltrate the target, or the target can be hit by direct or indirect fire.
· Survivability of the attacker is usually most closely correlated to targets accessibility
C) Recoverability is the measure of time required to replace / repair / or bypass the destruction
D) Vulnerability is the element of damage that can be caused
E) Effect is the public reaction in the vicinity of the target
F) Recognizability is the degree to which a target can be recognized under varying weather and light
On page 56 of “LNG Threat Analysis” it tells of studies done on the characteristics of an LNG fire
The initial damage done to property and injuries to people will occur within 30 seconds of ignition
The damage would be done so quickly that the efficiency of evacuation procedures would be significantly curtailed
Steps incorporated into an emergency response plan will be of little use in the event of a large scale release and ignition of LNG
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Notification procedures, sirens and warning devices that are standard elements of emergency response scenarios, are useful in the event of a building fire or natural disaster, but would be rendered useless during a major LNG fire
Surely the Governments National Economic Interest policy does not put at risk large areas of population in favour profit for the Gas Energy Companies?
Or does it?
We are of the opinion if all alternative sites do cost more and the government do decide to proceed with the proposed urban location such as the Calor Gas Liquid Natural Gas Terminal at Canvey Island because of cost differential and the National Economic Interest
The cost trade off of the people of Canvey Island and the surrounding area can be measured precisely
The government in making the decision in favour of Calor Gas Consortium to site a TOP TIER COMAH LNG (Methane) Terminal on Canvey Island would have to consider:-
· That avoiding the financial burden to the Calor Gas LNG operator of a more secure location in a less populated area is more important than public policy and people of Canvey Island and the surrounding area’s lives
· Therefore being more financially important to the Calor Gas Consortium’s profit than avoiding the additional risk of a catastrophic attack by terrorists
· A terrorist attack of this nature would involve mass trauma and burn injuries to the people of Canvey Island and the surrounding area
· Therefore this dilemma does accompany this decision by the Government on the siting of this TOP TIER LNG COMAH (Methane) Terminal by the Calor Gas Consortium on Canvey Island
We believe people come before profit or Government energy policies and if there is a requirement for more gas in the National Interest there should be a Safe Siting Policy for these TOP TIER LNG COMAH Terminals
We believe TOP TIER LNG COMAH Terminals should be sited away from a highly populated residential area such as Canvey Island and the surrounding areas
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What would happen if the unthinkable does take place and the terminal developed a major leak/ was successfully breached through sabotage or tragic accident?
Answer by Calor Gas (Ref Appendices 24 Calor Gas Doc)
Firstly we cannot emphasise enough that the chances of this happening would be extremely remote but full contingency plans and emergency response actions will be in place for the LNG terminal just as they are now with the LPG installation.
In the case of a leak, remember that the 2 inch thick steel walls of the tanks are encased in two and a half feet of concrete with a 3 feet space in-between so it would be incredibly unlikely for this to happen.
Should it occur, sensors would detect it immediately and the operation would shut itself down automatically
The design of the Terminal dictates that there would be no sources of ignition within the vicinity of the tank. Onsite and offsite emergency plans would be invoked if there was a significant release
What is the plan?
Where are the existing procedures for societal evacuation?
Tanks designed for internal pressure created by mixing different qualities of LNG: - Stratification issues
Sensors failed at Buncefield at one time under previous ownership the high sensors were not working at the Canvey Island Terminal
How do these plans deal with the evacuation of Canvey Island and the surrounding area?
What are the proposals for the safe action to be taken?
Under COMAH regulations “Assessment of extent and severity of the consequences of identified Major Accidents including Maps / Images / or as Appropriate / Equivalent descriptions showing areas which are liable to be affected by such accidents arising from the Establishment and its operations
(Ref: Appendices 25 HSE Doc 2005 -1088)
Being a REMOTE possibility of an incident leading to an accident cannot give sufficient reassurance that alleviates people’s fears (the “Buncefield” incident was a remote possibility no doubt)
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INCIDENTS INVOLVING LNG
There have been many reported incidents worldwide involving LNG since 1965
(Ref: Appendices 26 list of incidents)
This does not include the 2 incidents at the terminal on Canvey Island one in 1965 the other in 1974
(Ref: Appendices 27 Incidents at the Canvey Terminal)
I am not saying the Gas Industry is a dangerous Industry the point I make is that the Gas Industry does not have the perfect safety record it would have us believe
The truth the Gas Companies do not want you to know
The Gas Companies are claiming there have never been any accidents or incidents involving LNG during the last 40years so as not to include the Devastation in
Cleveland OHIO in 1944
(Appendices 28 Cleveland incident)
At the Cleveland peak shaving plant a tank failed and spilled its contents into the street and storm sewer system. The resulting explosion and fire killed 128 people. The tank was built of steel alloy that had low-nickel content, which made the alloy brittle when exposed to the extreme cold of LNG
In their findings they also deliberately do not mention the explosion in an LNG plant in Algeria in 2004
(Ref: Appendices 29 Algeria incident)
LNG Incidents or accidents within the past 40 years
(Ref: Appendices 30 List of incidents)
1964 & 1965 Methane Progress Fire
Whilst loading LNG in Arzew, Algeria, in 1964 lightning struck a forward vent riser of the Methane Progress and ignited vapour which was being routinely vented through the ship venting system
A similar event happened early 1965 while the vessel was at sea shortly after leaving Arzew. In both cases, the flame was quickly extinguished by purging with nitrogen through a connection to the riser
1965 Methane Princess Spill
LNG discharging arms were disconnected prematurely before the lines had been completely drained, causing LNG to pass through a partially opened valve and onto a stainless steel drip pan placed underneath the arms. This caused a star-shaped fracture to appear in the deck plating in spite of the application of seawater
1965 May Jules Verne Spill
LNG liquid spill at Arzew, Algeria, caused by overflowing of a cargo tank that resulted in the fracture of the cover plating of the tank and adjacent deck plating
1969 January Canvey Island (England) Collision
Methane Princess strikes the Terminal jetty and suffers damage to steelwork. Repairs necessary to the jetty unloading arm and other parts, amounting to almost £3,000
1969 Portland Oregon Explosion
An explosion occurred in an LNG tank under construction. No LNG had ever been introduced into the tank. The cause of the accident was attributed to the accidental removal of blinds from natural gas pipelines which were connected to the tank. This led to the flow of natural gas into the tank while it was being constructed
1971 May Canvey Island (England) Incident
Liquid nitrogen loading line into LNG ship Methane Princess opens, spilling nitrogen through the combined vent line onto the foredeck, causing some cracking in the deck plating. Probable cause relief valve had been improperly reset to lower than the specified pressure at the annual survey
1971 August La Spezia (Italy) Rollover
This accident was caused by “Rollover” where two layers of LNG with different densities and heat content form. The sudden mixing of these two layers results in the release of large volumes of vapour. In this case, about 2,000 tons of LNG vapours discharge from the tank safety valves and vents over a period of a few hours, damaging the roof of the tank.
1971 Canvey Island (England) Incident
Methane Princess sustains serious cracks in inner hull, necessitating lengthy repairs
1972 January Montreal (Canada) Explosion in Liquefaction
A back flow of natural gas from the compressor to the nitrogen line occurred during defrosting operation at an LNG liquefaction and peak shaving plant. The valves on the nitrogen were not closed after completing the operation. This caused over-pressurization of the compressor and the natural gas entered the control room through the nitrogen header (where operators were allowed to smoke). An explosion occurred when an operator tried to light a cigarette
1972 Canvey Island (England) Incident
Methane Progress put out of service for repairs to the inner hull and cracks caused by LNG cold
1973 February Staten Island (New York USA) Incident
While repairing the interior of an empty tank, a fire started. The resulting increase in pressure inside the tank was so fast that the concrete dome on the tank lifted and then collapsed down inside the tank killing the 37 construction workers inside
1974 July Massachusetts Barge spill
After a power failure and the automatic closure of the main liquid line valves, 40 gallons of LNG leaked as it was being loaded on a barge. The LNG leaked from a one-inch nitrogen-purge globe valve on the vessels liquid header. This leak caused several fractures to the deck plates
1974 December Canvey Island (England) Collision
The coaster Tower Princess steaming way off course strikes the LNG ship Methane Progress while it was tied up at the LNG jetty, tearing a three-foot gash in its stern. No LNG is spilled (the ships cargo tanks were not located in that area) and there was no fire. The Tower Princess’s Captain was reportedly asleep below and the Tower Princess on auto-pilot when the accident happened
1976 May Canvey Island (England) Collision
Cypriot Oil Tanker Britt veers off course and ploughs into the LNG jetty at the Canvey LNG depot, coming to halt only yards away from the large-diameter ship-to-shore pipeline, which according to company officials is always kept filled with LNG. No damage occurred failure of the steering gear on the Britt was blamed
1977 September Bontang (Indonesia) Spill
During the filling of a cargo tank at Bontang, LNG overflowed through the vent mast serving that tank. The incident may have been caused by difficulties in the liquid level gauge system. The high-level alarm had been placed in the override mode to eliminate nuisance alarms
1978 March Das Island (UAE) Pipe Failure
An accident occurred due to the failure of a bottom pipe connection of an LNG tank. The tank had a double wall (a nine-percent nickel steel inner wall and a carbon steel outer wall) Vapour from the outer shell of the tank formed a large heavier-than-air cloud which did not ignite
1979 April Mostafa Ben Bouliad Spill
While discharging cargo at Cove Point, Maryland, a check valve in the piping system of the vessel failed releasing a small quantity of LNG. This resulted in minor fractures of the deck plating
1979 April Pollenger Spill
While the vessel was discharging LNG at a terminal in Everett, Massachusetts, (USA) LNG leaking from a valve gland apparently fractured one of the tanks cover plating
1979 October Cove Point (Maryland USA) LNG Leak
A natural gas leak caused an explosion killing one plant employee and seriously injuring another and causing about $3 million in damage
1983 April Bontang (Indonesia) Ruptured Heat Exchanger
A rupture in an LNG plant occurred as a result of over pressurization of the heat exchanger caused by a closed valve on a blow-down line. The exchanger was designed to operate at 25.5 psig. When the gas pressure reached 500psig, the exchanger failed and the explosion occurred
1987 August Nevada Ignition of LNG
An accidental ignition of an LNG vapour cloud occurred at the United States Department of Energy test site during large-scale tests involving spills of LNG. The cloud was accidentally ignited and damaged and propelled polyurethane pipe insulation outside the fence
1990 Bachir Chihani Cracking Hull
The ship sustained structural cracks allegedly caused by stressing and fatigue in inner hull
1993 Bontang (Indonesia) LNG leak
During a pipe modification a leak from open run-down pipeline caused LNG to enter an under ground concrete storm sewer system and underwent a Rapid Vapour Expansion that over-pressured and ruptured the sewer pipes. The sewer system was substantially damaged
2002 Off Gibraltar Collision with Submarine
LNG ship Norman Lady collided with the nuclear-powered attack submarine the USS Oklahoma City. In ballast condition. The ship suffered a leakage into the double hull bottom dry tank area The Submarine suffered periscope damage
2004 Jan Algeria Facility Explosion
A steam boiler that was part of an LNG production plant exploded, triggering a second, more massive vapour-cloud explosion and fire. The explosions and fire destroyed a portion of the LNG plant and caused death, injury, and material damage outside the plant’s boundaries
2004 June Trinidad LNG Turbine Explodes
Workers were evacuated after a gas turbine at Atlantic LNG, s Train 3 facility exploded
2004 July Ghislenghien (Belgium) Pipe-line Explosion
A pipeline carrying natural gas from the Belgium port of Zeebrugge to northern France exploded, resulting in 23 known fatalities. The cause of the accident is still under investigation but it appears that a contractor accidentally damaged the pipe
2004 September Norway LNG Tanker Adrift
A fully loaded tanker was adrift west of Fedje, on the west coast of Norway, North of Bergen, the ships engine had stopped and the anchors were useless in the stormy weather.
The Tug boats couldn’t get the tanker under tow until the ship was only 30 yards from the rocks
Preparations were made to evacuate the 800 persons living on the Island of Fedje for fear of the tanker exploding if it grounded
2005 Aug Nigeria LNG Pipeline explodes
28-Inch Liquid Natural Gas Underground pipeline exploded and in the 27 square Kilometres blast 11 people are feared missing and all aquatic life was completely destroyed
There has also been an incident involving the “Transco” facility at Bourne Valley in Dorset in 2000 (Appendices 31 “Bourn Valley Incident)
Between 1943 and 1978 there were 47 incidents worldwide involving LPG!
LPG is also stored at the Canvey Methane Terminal!
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SHIPPING
SHIPPING LNG AND THE PORT OF LONDON AUTHORITY
Within its responsibilities as a public trust the PLA must consider the needs and interests of all stakeholders from commercial ship and port operators through to leisure users, Local Authorities and residents along the river bank, as well as a responsibility to all its employees in their work places with particular issues to those that actually work on the river
The PLA is responsible for 95 miles of the River Thames from Teddington Lock in the west of London to the outer estuary.
Throughout that area there are more than 70 different terminals for cargo ships including several top tier COMAH sites.
The PLA manage the various and differing types of hazards transported in huge quantities throughout its navigational responsibilities.
Its top priorities therefore are navigational safety security and environmental issues whilst providing the right support to commercial shipping operators so that they can achieve efficient turnarounds and avoid unnecessarily expensive delays to their vessels.
The Thames and its mooring facilities could justifiably be viewed as a top tier COMAH site in its own right.
The PLA is responsible for co-ordinating the needs of more than 30000 vessel movements per year within its jurisdiction.
Consideration also has to be given to the increase that would be brought about by the new deep water port at the Shell Haven site.
There are proposed increased movements of petroleum products and of course consideration needs to be given to the LNG terminal at the Isle of Grain site when considering the hazardous nature of shipping on the Thames.
The PLA have invested heavily in technical advances to ensure safe movement of vessels on the Thames.
This new system works around the clock to co-ordinate movements of commercial shipping on the river so ensuring navigational safety and efficiency.
This will be presented no doubt to reassure us that the PLA have complete management of the potential hazards from the various industrial by products
I am sure however, that the PLA would agree that having communications and visual display facilities of vessels through their advanced computer system does not mean THAT THEY HAVE FULL CONTROL OVER THESE VESSELS .
The PLA are well aware of the proposal from the Calor Gas site to be turned into an LNG facility
They have taken an active role commissioned by the consortium behind this proposal in dealing with the natural environmental issues and we assume that they have taken risk assessments on behalf of their employees that identify the potential hazards and situations, presented by LNG shipping, receiving and vaporization facilities.
These risk assessments need to take in the worse case scenario hazards that may confront their employees with particular attention to the docking and mooring process of LNG vessels.
The risk assessment process should include emergency action plans and adequate protection facilities in the case of a spillage of LNG over water.
In the unlikely event of an LNG release from a carrier its contact with the water or any warmer substance such as air, would cause the LNG to evaporate very rapidly (vaporize) returning to its original gaseous state (we understand the expansion rate is 3 times faster on water than on land).
As the LNG vaporizes, a vapour cloud, resembling ground fog will form under relatively calm atmospheric conditions. The vapour cloud is initially heavier than air since it is so cold that it would cause skin burns.
As the LNG absorbs more heat it becomes lighter than air causing it to rise and travel with the wind.
LNG vapour clouds are flammable within the portion of the cloud where the concentration of natural gas is between five and fifteen percent by volume and mixture with air.
This will ignite when this proportion of vapour cloud comes into contact with an ignition source.
The PLA when considering and risk assessing for the safety of their personnel will have to include in their emergency action plan, detailing the actions to be taken for the events considered most likely to result in a significant release of LNG on water.
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Feasible situations as follows:-
1. An outbound vessel has collided with an inbound LNG tanker.
2. An inbound LNG tanker collides with its terminal jetty and structure causing damage to the containment of LNG
3. A vessel colliding with an LNG tanker whilst on its moorings at the terminal
4. Grounding of a tanker whilst on its moorings due to low tide or silt back fill causing the vessel to list either onto or away from its moorings whilst connected to the transportation infrastructure (pipe-work under pressure).
For the inspectorate to be satisfied that societal risk will not be compromised by LNG tankers delivering their cargoes, the PLA safety procedures will have to be suitable for purpose and be appropriately audited to identify that review and revise procedures will been undertaken.
Security measures will also need to be clearly defined within the risk assessment to ensure that intentional spillage of LNG through terrorist activities can be limited to as little as possible.
Risk assessments for the outcome of a large spillage of LNG over water can only be the subject of guesswork.
Currently the potential for an LNG cargo tank breech whether accidentally or intentionally is not fully understood, particularly with regard to the dynamics and dispersions of a large spill and its hazardous outcomes.
There are two primary reasons for this assumption,
- Firstly the combination of current LNG ship designs and safety management practices have to an extent prevented observations from historical or empirical information on the consequences of a large spill of LNG.
- Secondly the only experimental data on LNG and its dispersion over water to date deals with a relatively small amount of gas which does not reflect the possible outcome of an intentional or unintentional breech of containment.
The PLA within its risk assessment when considering the safety of its personnel would be wise to consider that an area such as Canvey Island which comes into contact with a large LNG spill would have dire consequences from the impact of thermal radiation creating a severe public safety and environmental hazard.
The nearby OIKOS (top tier COMAH site) should be of extreme concern as a consequence of its infrastructure being involved in such an impact would be catastrophic.
It is well known in 1974 the “YUYO MARU” A Gas ship travelling at less than 10 knots and the “PACIFIC ARES” travelling at 2 knots collided in the bay of Tokyo killing most of the crews on both vessels
The “YUYO MARU” exploded causing a pool fire that lasted for 19 days and eventually had to be towed out to sea and sunk as it was estimated that unless sunk it would burn for a further 5 months and there have been many other shipping incidents that are a matter of record including
The “Betelgeuse” at “Bantry Bay”
The “Energy Concentration” at “Rotterdam”
The “Rene 16” at “Landskrona in Sweden”
The “Esso Bernica” at “Sullom Voe Shetland”
The “Inca Tapuo” at “Louisiana USA”
The double hull safety claim for tankers put out by Gas Companies is for the naïve as in 2002 Yemen terrorist used a small boat and rammed a French Oil Tanker and pierced its double hull releasing 90,000 barrels of oil .
(Ref: Appendices 2-1 double hull safety claim)
If this had been a Gas Tanker the devastation would have been colossal
(Ref: Appendices 2-2 20 times greater)
For commercial reasons, ships load and discharge their cargoes very rapidly
As a consequence the pipes transferring the liquid cargo, flammable or toxic are large
The rates of flow are as high as practical for the terminals and shipping companies
In the event of a fracture of the loading system even if the automatic cut-off devices work properly, spillages of the order of tens of tonnes may still occur.
In the event of the failure of the cut-off devices spillages may be very much larger than tens of tonnes
We maintain there should be further studies into the interrelationship of the various regimes of control in ports and harbours in particular stowage, loading and discharging and planning controls in the vicinity of ports and harbours handling major hazard cargoes.
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At a recent meeting with the PLA who have the jurisdiction under the Dangerous Substances in Harbour Area Regulations 1987 and are also bound by the Port Marine Safety Code which is monitored by the Maritime and Coastguard Agency the Harbour Master “Captain Gordon Dickins” stated whilst great in-roads have been made in marine safety and the imposition of no movement allowed on the river Thames a mile in front and a mile behind a Gas ship travelling in certain parts of the River Thames within their jurisdiction,
That in a worst case scenario “It would a case of SEARCH AND RESCUE afterwards not a matter for evacuation”
In America (who have more freedom and access of information than we do in this country) “initial actions to take in the event of a worst case discharge of LNG”
Step Action 9999
1. ORDER THE EVACUATION OF ALL U.S.C.G.
(UNITED STATES COAST GUARD) PERSONEL FROM AFFECTED AREA
Would anybody call the United States Coast Guard alarmists?
(Ref: Appendices 2-3 Step Action 9999)
The tankers that transport LNG are typically more than 900 feet long, equipped with five 6-million gallon tanks filled with LNG, each ship carries enough natural gas to heat 30,000 homes for a year
If there was a large spill of LNG on water it would expand from liquid state to a gaseous state three times faster than if the large spill of LNG was on land also it has been estimated that if the spilt LNG escaped from a hole three feet wide, flammable vapours from the spill can travel 3.5 miles
There have been reports of estimates of IGNITABLE UNCONFINED VAPOUR CLOUDS ensuing from a large spill spreading 10s of miles
We believe there is a concern to scientists about an LNG spill is Rapid Phase Transition (RPT) as RPT is the natural gas instantaneous transition from its liquid phase to its vapour phase, and the associated pressure increases that result from the conversion,
Were LNG to be released from a tanker the liquid would pool on the surface of the water the warmer water would rapidly vaporize the LNG, the RPT occurs when a portion of the spilled LNG transitions from a liquid to a gas nearly instantaneously (Ref: Appendices 2-4 Rapid Phase Transition)
Remember there was a very small Rapid Phase Transition (RPT) at the Canvey Depot in 1973 (Ref: Appendices 2-5 Canvey RPT incident)
The pool fire scenario is the most likely event to cause major devastation from an LNG release on water.
The LNG would seep out of the breached tank and form a pool on the surface of the water.
As the pool forms, some of the liquid will evaporate as the warmer water condenses the colder LNG
If an ignition source is present, as it is likely would be in the case of a large-scale LNG spill a pool fire could result, that could potentially envelop the entire tanker
LNG fires cannot be extinguished by conventional fire-fighting techniques and will burn much more rapidly and at much greater intensities and levels of heat than crude oil or even gasoline fires
Is this a possible or probable scenario?
If we take the May 1976 Canvey Island incident involving the Cypriot Oil Tanker and its collision with the LNG Jetty and add a Methane Ship unloading as was the scenario when the coaster Tower Princess collided with the methane progress whilst she was tied up at the Canvey Island Jetty and instead of stopping short of the filled pipelines hit them and broke them the very possible following scenario could happen
Oil Tanker fractures pipe line
Residue of LNG in pipe spills onto the water (even after allowing for the emergency valves operated shutting off further LNG spilling) creating a Rapid Phase Transition (RPT) and exploding (if the 1st emergency valves fail is there a back-up valve further down the pipe if so how much LNG is in that pipe to escape)
The concussion from that Rapid Phase Transition (RPT) explosion creates damage to further pipe work and the Oil Tanker
This damage to further pipe work in turn that can create spills that create further Rapid Phase Transition (RPT) and an Unconfined Vapour Cloud
That Unconfined Vapour Cloud could be of LPG or LNG or even both
That UVC could spread over the highly populated area of Castle Point and even further when the edges of the UVC are at the right mixture of 15% - 5% Gas and 85% - 95% air if that cloud finds an ignition source it will explode creating a BLEVE or an Unconfined Vapour Cloud Explosion UVCE which in turn can create a DOMINO effect scenario if the Tanker catches fire it could be another Bantry Bay type Disaster
THIS IS ONE OF MANY NEAR MISS SCENARIO’S THAT HAVE OR COULD HAVE HAPPENED AND THERE IS NO GUARENTEE A WORST CASE SCENARIO INVOLVING LNG OR LPG WILL NOT HAPPEN AT THIS PROPOSED TERMINAL
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IS THIS AN ACCEPTABLE RISK?
Can you guarantee the safety of the residents in Canvey in case of an incident on site?
Answer by Calor Gas (Calor Gas Doc)
In the UK all construction and maintenance relating to so called hazardous installations come under the jurisdiction of the Health and Safety Executive.
This is a very powerful independent statutory body that assess risk in an objective and scientific way.
Our plans will be scrutinised by them in great detail and we are looking forward to a long dialogue with them to establish the integrity of our plans.
For the HSE to give their approval to the construction of an installation like this one, the risks would have to be calculated as ACCEPTABLE.
To whom are they Acceptable?
(Ref: Appendices 2-6 BS 8800:2004)
May I remind you that according to “BS 8800:2004 an Acceptable level of risk is regarded as INSIGNIFICANT and stands alone or as a result of Risk Controls?
How can the risks from this proposed terminal be considered as INSIGNIFICANT?
Calor Gas also says: - (Calor Gas Doc)
The partners in Canvey LNG are world leaders in their own right in their own particular disciplines within the international gas industry.
They have extensive experience in the construction and operation of gas facilities and are fully committed to safety during design, construction and operation.
Safety will always remain our top priority.
If safety is the top priority of Calor Gas and its partners how is it they want to put this type of Simply gas in super cooled liquid form so close to a residential area?
This simply gas in super cooled liquid form been explained in the LNG material data sheet and is not as safe as made out in previous chapter WHAT IS LNG
Are the dangers involving Storing / Transporting / Processing LNG on Canvey Island really “INSIGNIFICANT?”
Or is that the interpretation of the calculations of risk that the Calor Gas Terminal has carried out and wants everybody to believe?
(Ref Appendices 2-7 – Reducing risks, protecting people /HID’s Practicable (ALARP) decisions)
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SO WHAT ARE THE DANGERS INVOLVED IN THE TRANSHIPMENT AND STORING LNG (METHANE) CLOSE TO A RESIDENTIAL AREA?
The Calor Gas Consortium of Companies would have us believe that LNG does not burn (Calor Gas Doc)
Technically that is true but the fumes from LNG do burn
It’s like saying diesel oil does not burn (but the fumes do)
They also imply if spilt LNG would evaporate harmlessly upwards into the air
What is not said is that LNG will only start to evaporate upwards after it has risen in temperature from BELOW -160 C or -260 F to above ZERO degrees
(Ref Appendices 2-8 LNG Definition)
In the meanwhile the contention is that it will be an expanding white fog spreading outwards until it reaches an ignition source or dissipates upwards whichever is the soonest?
What is the timing factor of the speed of expansion from large spill of so called super cooled gas in liquid form to an unconfined vapour cloud?
THERE IS NO KNOWN WAY TO STOP A LARGE SPILL OF LNG
THERE IS NO KNOWN WAY TO STOP AN UNCONFINED VAPOUR CLOUD ENSUING FROM THAT SPILL
THERE IS NO KNOWN WAY TO STOP AN UNCONFINED VAPOUR CLOUD EXPLOSION IF THAT CLOUD FINDS AN IGNITION SOURCE
Because Liquid Natural Gas (LNG) when stored is concentrated down 620 times from gas state to a liquid state and stored in tanks (in layman’s terms like giant thermos bottles)
It is stored at a temperature of below Minus 160 C or Minus 260 F
If there is a spill or escape of LNG it would freeze everything in its path and boil off
It will evaporate and expand 620 times its size from a liquid state to a gaseous state
It will form an “UNCONFINED VAPOUR CLOUD” spreading outwards in a ground hugging cold white fog until it reaches above Zero degrees
When the “UNCONFINED VAPOUR CLOUD” reaches above Zero and the mixture is at between 85% to 95% air and between 15% to 5% gas it can be ignited by the slightest spark creating an “UNCONFINED VAPOUR CLOUD EXPLOSION”
How far that “UNCONFINED VAPOUR CLOUD” spreads before ignition is determined by many factors:-
Wind strength and Direction of the wind, Temperature, Daytime, Nightime, Season
As on a very hot day it would warm up quicker
As on a windy cold and frosty morning it would spread further
SEPARATION DISTANCES (Cordon Sanitaires)
Separation Distances or Cordon Sanitaires are important for protecting works personnel, surrounding areas and people living within the surrounding area should a release of L.N.G. or a fire occurs at an L.N.G. Facility.
Each onshore L.N.G. container or tank must be within a secondary dyke or impoundment area
The Regulations specify that each L.N.G. container and L.N.G. transfer system must have a “THERMAL RADIATION PROTECTION ZONE” beyond the impoundment area (the temperature is so high if L.N.G. is ignited there would be a HEAT SEAR “thermal radiation” a long way beyond the perimeter of the flame)
These thermal radiation exclusion zones must be large enough so that the heat from an L.N.G .fire does not exceed a specified limit for people and property
WE BELIEVE THAT UNDER UNITED STATES LEGISLATION
THE THERMAL EXCLUSION ZONE MUST BE OWNED OR CONTROLLED BY THE OPERATOR OF AN LNG FACILITY
IF THAT IS SO WHY CHANGE THE RULES FOR THIS COUNTRY?
SURELY THE DANGERS OF L.N.G. DO NOT CHANGE WHEN IT IS STORED AT A DIFFERENT LOCATION OR COUNTRY?
The “Calor consortium” does not own this area of land deemed a CORDON SANITAIRE beyond their perimeter fence nor do they control it
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In America to determine these thermal exclusion zones or “Cordon Sanitaires” I understand the Gas Research Institute (G.R.I.) computer model or a similar model should be used.
Wind speed, ambient temperature and relative humidity producing the maximum exclusion distances are to be applied subject to other detailed provision of the regulations.
Similar to the provision for THERMAL RADIATION PROTECTION (heat sear) The U.S. federal regulation 49 CFR Part 193 Specifies that each L.N.G, Container and L.N.G. transfers system must have a flammable vapour dispersion exclusion zone around the facility that is owned or controlled by the facility operator.
The Vapour dispersion zone must be large enough to encompass that part of the vapour cloud which could be flammable
The code also specifies how the flammable vapour dispersion distance is calculated for each L.N.G. Facility
In order to account for irregular mixing of the vapour cloud, the regulation designates the vapour cloud hazard area as the area where the average gas concentration in air is equal to or greater than 2.5 percent (half the lower flammability limit of methane)
This provides a significant margin of safety to account for irregular mixing.
The regulation also specifies other parameters including dispersion conditions should be used in computing dispersion distances
Do we in this country have these significant safety margins?
If not, why not?
If L.N.G. is spilled the resulting L.N.G. vapours (methane) will warm, eventually become lighter than air, disperse with the prevailing wind (cold L.N.G. vapour will appear as a white cloud) Expanding from liquid to gaseous state 620 times its size forming an unconfined vapour cloud.
When this unconfined vapour cloud expands to a concentration of 85%-95% air and 5%-15% gas the vapour cloud will burn and can be ignited by the slightest spark the vapour cloud will burn along a flame front towards the source of the fuel
To keep the public safe, vapour dispersion exclusion zones are calculated and plotted to determine how far L.N.G. vapours (methane) could possibly travel from a storage facility and still be flammable
Since this fire would burn with an intense heat, Thermal exclusion zones are also established to take into consideration of heat sear
Flammable vapour and thermal exclusion zones are determined to keep the public at a safe distance from L.N.G. facilities
As there is no known way to stop a large L.N.G. spill or an unconfined vapour cloud ensuing form that spill or the ignitions of that vapour cloud from a flame source
WE UNDERSTAND THESE ZONES MUST NOT REACH BEYOND THE PROPERTY LINE THAT CAN BE BUILT ON as the requirement is that the flammable and thermal exclusion zones must be owned by the operators
What area or Thermal exclusion zone does the Calor Consortium own outside the perimeter fence of their Terminal?
1-2-7
FIRE FIGHTING
Our Fire Brigade who are our first line of defence, in there duties they sometimes carry out the impossible, I understand that there is no way the Fire Brigade could fight or control a vapour cloud moving in the air at whatever speed or direction the wind carries it, so don’t expect them to perform miracles.
What happens in a worst case scenario?
Would the siren sound notifying everyone there is a problem in the terminal vicinity?
How long before the call goes out to the emergency services?
Are there Bunds or containment areas to contain any spill of LNG?
Are there any pits to catch LNG spills?
Have the Fire Brigade been consulted as to what equipment might be required on site such as enough foam or any equipment they might require in the event of an escape of LNG?
Are all our firemen fully trained in how to handle an LNG fire?
Who stores any fire dampening product?
Is there enough to cope?
What would happen if they meet an Unconfined Vapour Cloud waiting to ignite on their way to us?
Would it be like the twin towers in America, where even though the firemen knew they were going to certain death they still went in?
Was it just luck that the Buncefield fire was on a Sunday when there were only a few people around?
Will we be as lucky next time?
1-2-8
STATUTORY INSTRUMENT S.I. No. 476 of 2000
(Ref: Appendices 2-9 S.I.No 476of 2000)
European Community (Control of Major Accidents Hazards involving Dangerous Substances)
Regulations 2000 SEVESO II Directive
Regulation 8 (2) requires an establishment such as Calor Gas Company to provide such evidence (including documentation) to prove that they have
(a) Identified the major accident hazard.
(b) Taken all necessary measures to comply with these regulations.
Regulation 19 (1) (a) Information for the Safety of the Public
An Operator of an establishment shall inform persons (other than persons working at the establishment) who is likely to be habitually (we consider this to be the whole of Canvey Island) in the specified area of safety measures and the correct behaviour which should be adopted in the event of a major accident.
Regulation 19 (3) requires the operator shall ensure that the information referred to in paragraph 1 (a) is supplied without such persons i.e. occupiers and residents having to request it.
We believe that this has not been complied with and will be presenting evidence by way of letters from residents to support our findings.
We believe that there has never been sufficient assessment of the extent and severity of the consequences of a major accident involving LPG and now LNG with regards to the safety of the occupiers of Canvey Island.
European legislation is fundamentally linked to the Control of Major Accidents Hazards Regulations (COMAH) which aims to prevent and limit the consequences to people and the environment of any accident which may occur at a COMAH site.
Regulation 10 Offsite Emergency Plan
(Ref Appendices 2-10 Off-site plan)
The emergency plans objectives are detailed on page 50.
They are of particular interest to this application with regard to Canvey Island.
Local Authority is required to prepare an emergency plan (Off-site) in respect of establishments such as this.
However they cannot complete this task without obtaining the necessary information from the operators.
This information would not normally be the entire safety report.
The operator is obliged only to provide information which is relevant to preparing the Off-site Emergency Plan, such as details of accident consequences which should include information about the potential effects of a major accident at their sites, their likelihood, how far the effects might be felt, and how much harm might be caused to people in the event of such an incident.
Paragraph 260 identifies the issues of DOMINO sites.
These are sites where the likelihood or consequences of a major accident may be increased because of the location and proximity of other COMAH establishments with their associated dangerous substances.
This situation with regard to the Calor Gas Site needs special consideration in terms of emergency planning, and the testing of the Off-site response.
It is worth noting here that the situation of Canvey Island where it’s occupant’s evacuation would be a logistical nightmare
AT SOME ESTABLISHMENTS IMPACTS MAY BE TOO MANY AND VARIED FOR DEDICATED ARRANGEMENTS TO BE MADE IN ADVANCE FOR EVERY SCENARIO may well indicate that it isn’t possible to provide Canvey Island with a suitable and sufficient Off-site emergency plan for a vapour cloud explosion and therefore we should not be put to this risk at all.
In the case of the above off-site plans should go as far as arranging for sampling and analysis in order to assess actual impact in bringing together key stakeholders and resources to agree priorities for community clean-up and restoration. AN AFTER EVENT PROCESS.
Paragraph 252 deals with remedial measures which include removing dead animals.
If this proposal is accepted and there is such an event as a vapour cloud explosion, or an event which would normally cause evacuation of a large area you would need to add, as part of the remedial action the removal of HUMAN REMAINS.
It has been quoted by the HSE that some establishments are reluctant to provide a worse case scenario because this information would have to be made available to the public.
1-2-9 Guidance for Local Authorities for Dealing with Requests
under the Freedom of Information Act
(Ref Appendices 2-11 Guidance for local Authorities)
This document states that consideration of withholding information on the grounds of National Security is not intended to interfere with Companies complying with their legal obligation under relevant regulatory regimes to inform their employees and where required members of the public of actions to be taken in the event of an emergency situation.
It states that it is Government policy to inform the public of the robust measures that are in place to avoid or minimise the risk of incidents at Major Hazardous sites.
There is however a significant needs to maintain national security and public safety by minimising the risk of a successful attack on these sites.
This means that each request for information has to be considered on its merit, and the appropriateness of applying exemptions will depend on specific requests and the nature of the information.
Should the details to be taken in the event of an incident that affects individuals on an off-site basis not be readily available, then this would imply that it is being withheld on the GROUNDS OF NATIONAL SECURITY.
The types of information which it may be appropriate to withhold include
1 Detailed description of the site such as the precise location of storage tanks
2 Actual volumes of materials stored
3 Detailed information about pipelines and associated storage systems
4 Details of safety measures on site
5 Safety equipment and emergency response equipment
Unfortunately this information is already readily available on the Calor LNG website, linked the fact that it is well known that Canvey Island has not the infrastructure that would support a successful emergency evacuation for the forty to fifty thousand occupants, making this an extremely attractive and easy target for terrorism.
1-2-10
The Calor Gas Community Safety and Emergency Plans Document revised March 2005
This document does not promote confidence to the residents and occupants of Canvey Island for the following reasons
Section 9.19 Public Warning Provisions
There is no public warning system for Canvey Island although it is noted that the on-site siren can be heard off-site although the distance is quite limited.
15.1 identifies public consultation distance of 900 meters radius but the assessment for explosion effects is for 2km radius
This takes into the hazard area much greater residential and associated facilities such as schools shops old people’s homes and public buildings for which no off-site provisions have been made.
15.2 Prior Public Information.
Calor Gas declared that they send out public information letters approximately every three years to persons residing in the Public Information zone and beyond.
There appears to be no evidence of this being carried out
15.3 Potential Accident Scenario
When information was requested about this issue from the local authority it was withheld on the grounds of NATIONAL SECURITY
15.4 Potential impact to Persons Off-site
Again when information was requested it was withheld on the grounds of NATIONAL SECURITY
15.5 Impact to Adjoining Industry
We are told it is anticipated that off-site areas which could be affected by thermal radiation generated in a fire includes parts of the adjacent industrial site to the West. (This is the COMAH site OIKOS which would have a serious DOMINO effect. This has not been accounted for in this safety plan.) The sewage works to the East and the farmland to the North.
This fails to identify other areas that would be affected such as the Football Club, housing, retail, commercial and environmental areas
16.1 When will this plan be activated?
This plan will be activated in the event of a major incident at the Gas Terminal which has escalated off-site.
Such an incident is likely to result in public warnings being issued and emergency evacuation of residential and industrial premises.
The evacuation process in this document only provides for the evacuation to other parts of the Island.
We would suggest that for an incident of an LPG escape to have escalated to the extent of 2km this would result in a VAPOUR CLOUD EXPLOSION, and remaining on the Island may then not be appropriate.
1-2-11
OTHER DOCUMENTS DEALING WITH MAJOR INCIDENTS
Essex Resilience Forum Document COPE (Combined Operational Procedure for Essex)
Updated October 2006 (COPE & CASTLE POINT PLAN)
Castle Point Borough Council Emergency plan 2006 both fulfils the duties required by the Civil Contingencies Act 2004.
These are extensive documents making provisions for principally reacting to a major incident
Definition of Major Incident (Castle Point Emergency Plan Document 1.3)
Although the Civil Contingencies Act uses the term emergencies, the definition of a Major Incident is still relevant since it is used by the emergency services. It is defined as:-
Any event, happening with or without advanced warning causing death or injury, damage to property or the environment, or disruption to the community, which because of the scale of its effect cannot be dealt with by the emergency services and local authorities as part of their day to day responsibilities.
We can take great comfort that these documents through their reactive processes take care of our injuries, welfare and dead bodies.
There is no emergency action plan for the evacuation of Canvey Island.
Although not stated it would appear that logistical operation of evacuating 40 to 50 thousand people off of Canvey makes it impracticable.
The Calor Gas consortium has to understand that we cannot accept a situation which may cause devastation, even though it may be unlikely or unforeseen, to ever happen on Canvey Island.
We ask them to reconsider this application for a more suitable site.
The production of COMAH off-site plans are the responsibility of the County Council and are supposedly produced within the county of Essex, on a site by site basis by the Essex County Emergency Plans Unit.
Despite this there is no mention of this process or procedures to deal with an incident brought about by a COMAH site in the COPE document.
This could of course be the subject of National Security, however if this is the case then the security of Canvey Islanders would be better served by this proposal never going ahead.
1-2-12
Why should we feel concerned?
Look at what the Calor Gas Company say on their web-site when quoting “what is LNG”.
LNG is Liquefied Natural Gas is simply a gas in super-cooled liquid form.
Contrary to many perceptions LNG is also not flammable in its liquid state and can be safely stored. It only becomes flammable when turned back into its gaseous form.
This Gas in Super-cooled Liquid form is Liquid Natural Gas which is 90% Liquid Methane when spilled expands 620 times its size from liquid state to a gaseous state when mixed with the right consistencies of air and Methane is highly ignitable and burns hotter than Petrol
There is no known way at this moment to contain a large spill of this Liquid Gas in Super-cooled form or contain the Unconfined Vapour Cloud (UVC) or the Unconfined Vapour Cloud Explosion (UCVE) if this cloud finds an ignition source
LNG was stopped from being shipped to Canvey Island after 1990
(Ref: Appendices 2-12 Letter No similar storage)
Is Calor Gas suggesting that those who have the skills required to handle and process LNG have been put in a cupboard somewhere and are ready and waiting to be got out of that cupboard and are ready to be used
2-1
Facilities for LNG according to the Calor Gas web-site
(Calor Gas Doc)
A lot of the infrastructure normally associated with a new location is already in place’
This emphasises that this is a moneysaving option for the consortium. The HSE has
through documentation implied that some infrastructure of COMAH sites should
undergo a programme of regeneration. Could this be the case here?
Canvey could potentially receive a shipment every week
This is not encouraging due to the size of the proposed vessels planned to use this
site. The logistics of ship movement within this area must be clearly risk assessed
by the Port of London Authority documentation of should be provided before
planning is deemed acceptable. This along with environmental impact assessments
will attract several erroneous conditions. These conditions should be fully
implemented before planning approval is deemed acceptable.
The terminal would be operational for 50 years
This gives cause for concern in that the proposed safety systems and the structures being a new innovation may not have a life span of 50 years. This aspect should be fully investigated before planning permission is approved.
2-2
The truth of the safety record of the Canvey terminal since 1964
HISTORY OF THE CANVEY SITE-
In the past there has been LNG stored at the terminal on Canvey Island in in-ground tanks these were found to be uneconomical and were decommissioned as there was a great deal of concern about the permafrost causing widespread ground-heave
(Ref Appendices 2-13 how it should be / how it is)
Due to this permafrost creating ground heave fissures formed and interconnected the 4 in-ground tanks therefore making them unstable and uneconomical
The failed in-ground tanks due to permafrost were experimental at the time and without the benefits of modern safety procedures
There was an undertaking given to the people at a public meeting that Calor Gas would not develop LNG on Canvey Island when the site was purchased by “Calor Gas” from “British Gas” now “Centrica”
There have been 2 accidents involving LNG inside the Canvey LNG terminal.
Ref Appendices 2-14 Lloyds Register “Major LNG Incidents
1) In 1965 a man was seriously burned by LNG.
LNG spilled out of a storage tank being emptied, vaporizes and catches fire. The flames spread ten to fifteen feet high, damaging paint, parts of the tank exterior, and some piping. Fire-fighters cool the tank and the piping and allow the gas to burn itself out before extinguishing the blaze.
No deaths but one employee seriously burned and taken to hospital
2) In 1973 a small amount of LNG spilled Causing a Rapid Phase Transition (RPT)
On May 10 1973 at midnight loud explosions were heard from the Methane terminal the blasts did not involve LNG ignition. An investigation by British Gas Corporation determined that the explosions were caused when LNG spilled out of a tank as it was being unloaded. Splashing LNG on top of a puddle of water, and the resulting flameless vapour explosion, called a rapid phase transition (RPT), caused the explosion luckily no injuries resulted
2-3
There have been concerns raised in the past by another Planning Inspector attending and adjudicating at a previous Public Enquiry when this Methane Terminal was owned and operated by the then “British Gas” now known as “Centrica” which are one of the main partners in the consortium of this venture by Calor Gas
Referring to the United Refineries Limited (URL) Enquiry Report of 1980 Sir Richard Ward in his conclusions on LNG and LPG Quote:-
(Ref Appendices 2-15 URL enquiry report 1980)
Paragraph 175
British Gas does not come well out of this, Sir Bernard Brain’s evidence accusing them of evasion, concealment and bad management was not denied by their representatives or by the health and safety Executive
Paragraph 176
I trust that the managerial aspects would have been put right but my fears were not allayed after my visit to the Methane Terminal, This was the only installation which left an uneasy feeling in my mind, a view that was endorsed by my assessors. In the circumstances I would not be happy working there or living nearby
Sir Richard Ward ends with the quote in Paragraph 177:-
The Methane Terminal contributes no less than one third to the total risk of a serious accident from all the present and proposed installations in the scheduled area after all improvements have been made.
One possible incident, however remote the chance might be, could be the release of a large cloud of Methane Gas which could if not ignited on route reach out 10 kilometres from the terminal reaching Basildon in the Northwest to Southend –on -Sea in the Northeast, the direction of the prevailing wind.
If the cloud should be ignited there, the numbers at risk would be very large
And at the end of Paragraph 181
“It was suggested to me privately that the Gas terminal would provide about 2% of the United Kingdoms annual needs.
If this figure can be verified, I find it difficult to accept the retention of the Gas Terminal at Canvey Island when weighed against the risks to the local people”
We believe if Sir Richard Wards report, if compared to an M.O.T. inspection of a car, there was found to be defective steering and bad brakes
Defective steering: - British Gas has a bad history of bad steering in its management at this plant
Bad brakes: - British Gas failed to stop its operations in respect of the high level alarms that were not working (This scenario was part of the cause of the “Buncefield” accident years later) until after a notice was served on them by the H.S.E.
There have been a number of incidents involving LNG shipping at the Canvey Island Terminal
In 1969 January Canvey Island (England) Collision
Methane Princess strikes the Terminal Jetty and suffers damage to steelwork, Repairs necessary to the jetty unloading arm and other parts, amounting to almost £3,000
In 1971 May Canvey Island (England) Incident
Liquid Nitrogen loading line into LNG Methane Princess opens, spilling nitrogen through the combined vent line onto the foredeck, causing some cracking in the deck plating. Probable cause relief valve had been improperly reset to lower than the specified pressure at the annual survey
In 1972 Canvey Island (England) Incident
Methane Progress put out of service for repairs to inner hull and cracks caused by LNG cold
In 1974 December Canvey Island (England) Collision
The Coaster “Tower Princess” steaming way off coarse strikes the LNG ship “Methane Progress” while it was tied up at the LNG Jetty, tearing a three-foot gash in its stern. No LNG is spilled (the ships cargo tanks are not located in that area) and there was no fire
The “Tower Princess’s Captain” was reportedly asleep below and the “Tower Princess” on auto-pilot when the accident happened
In 1976 May Canvey Island (England) Collision
Cypriot Oil Tanker “Britt” veers off course and ploughs into the LNG jetty at the Canvey LNG Depot, coming to a halt only yards away from the large-diameter ship-to-shore pipeline, which according to company officials is always kept filled with LNG. No damage occurred; failure of the steering gear on the Britt was blamed
So much for “Not a single incident since 1964”
A safety record that the “Calor Consortium” wants to be associated with?
2-4
We are of the opinion not only are the dangers still there, but more so, because of the “TOP TIER LNG COMAH” Terminal at the Isle of Grain adding to the possibility of a Domino effect also the consideration of the change in the nature of the terrorist element
(Ref Appendices 2-16 National Grid)
Please note:- all the other 5 present “LNG” TOP TIER COMAH sites at “Glenn Mavis” - “Denevor Arms” - “Partlington” – “Avonmouth” and “The Isle of Grain” are sited in sparsely populated or low density population areas unlike Canvey Island and the surrounding area which is highly populated
Only the names of the Canvey LNG site owners have changed from “British Gas” to “Calor Gas”
“Centrica” (British Gas) is now a partner with “Calor Gas” as is “Osaka Gas” and “LNG Japan Corporation” with a 50-50 partnership between “Sojitz Corporation” and “Sumitomo Corporation”.
Therefore you can understand why the people have no faith in the Calor Consortium to consider the safety of the people over their own profit
Even though on their web site Calor Gas made the statement “We would not progress with any development on the site that would increase the risk to the local community”
Even a layman knows if you demolish an existing site that in an area that has been deemed as a “Just Tolerable Risk area” then if you:-
- Increase the amount of gas you store to that area
- Don’t increase the “Cordon Sanitaires”
- Don’t tell the people about the Emergency Evacuation Plan
- Don’t tell them the dangers of what they believe to be an inadequate untested off-site emergency plan and do not tell the nearby population what to do in an emergency,
You will increase the fear of risk to the surrounding population from “Just Tolerable” to a “Totally Unacceptable” risk
(Ref Appendices 2-17 BS 8800:2004 Doc Just tolerable)
How did the terminal reduce the risk from their site down from what was after the all the improvements imposed in light of the Canvey Island reports back in 1980s from Unacceptable to “Just Tolerable” have now we are to believe reduced the risks from their site from “JUST TOLERABLE” to “ACCEPTABLE” ?
An “acceptable risk” according to British Standards is an “Insignificant” risk
Who is this acceptable to?
The Calor Gas Consortium?
It certainly is not acceptable to the people of Canvey Island and the surrounding area and they are the ones that will have to live with this risk
According to “British Standards” 8800:2004 Just Tolerable risk falls in-between an Unacceptable risk and a Tolerable risk and below that level of risk is an Acceptable Risk
An Unacceptable Risk is a risk that cannot be accepted whatever the level of benefits gained from the activity giving rise to the risk
A Tolerable Risk is a risk at a level that can be accepted provided risk controls are implemented to reduce risk as low as is Reasonably Practicable i.e.:-
Reduced to the point where it can be shown that the costs (in terms of time, money and /or effort) of further risk reduction would be disproportionate to the further benefits
Note: - In UK law the words “grossly disproportionate” are used to define the test that should be applied
Acceptable Risk is a risk that is regarded as Insignificant either as it stands, or as a result of risk controls
Hazard is the source or situation with the potential for harm (in terms of human injury or ill health, or a combination of these)
Risk is a combination of the likelihood and consequence of a specified hazardous event
Note 1 A risk always has two elements:
-The likelihood of a hazardous event
-The consequence of the event (the severity of harm in terms of human injury or ill health)
Note 2 Particular in relation to hazards to health, the harm might arise not from one event, but from exposure over a period of time
Note 3 In some other sources it is alternatively defined as a statistical probability of a specified undesired event e.g. the probability of a fatality
Risk Assessment
Is a process of identifying hazards and evaluating the risks to health and safety arising from these hazards taking into account of the existing risk controls (or in the case of a new activity, the proposed risk controls)
Risk Controls
Are workplace precautions, for example, physical safeguards, containment of airborne contaminants and noise, safe systems of work, competency, and personal protective equipment (PPE?)
Risk Control Systems
Are arrangements that ensure that the workplace precautions are implemented and kept in place, for example, designation of responsibilities, training, supervision, work equipment maintenance, performance measurement, audit, and the selection, briefing and control of contractors?
2-5 RISK CONTROLS
In Health & Safety there are risk controls required by all companies
THEY SHOULD USE A GUIDE CALLED “HSE RISK CONTROL HIERARCHY”
1 ELIMINATE THE HAZARD AT SOURCE
2 REDUCE THE HAZARD AT SOURCE
3 REMOVE THE PEOPLE FROM THE HAZARD
4 CONTAIN THE HAZARD BY ENCLOSURE
5 REDUCE EXPOSURE
6 SAFE SYSTEM OF WORK
7 PROTECTIVE EQUIPMENT
SO INSTEAD OF WORKING UP THE RISK CONTROL HIERARCHY LADDER STARTING AT NO 7 AS THE PEOPLE BELIEVE IT IS DONE AT THE MOMENT IN FAVOR OF THE GAS COMPANIES WE BELIEVE IT SHOULD START AT NO 1
ELIMINATE THE HAZARD AT SOURCE AS THERE IS NO GOVERNMENT SAFE SITING POLICY OF THESE “TOP TIER LNG COMAH” SITES
REFUSE THE PLANNING PERMISION TO THE “CALOR GAS” AND YOU REMOVE THE HAZARD COMPLETELY TO THIS COMMUNITY
2-6
As the only Emergency Plan ever given to the residence as a whole is nearly 30 years old and that tells the schools what to do in the event of a vapour cloud is the “Advice to Householders Handbook”
(Appendices 2-18-Copy of Advice to Householders Hand book)
Also at the time the teachers were given instructions as what to do if they heard the “Gas Terminal Alarm Siren” in the Guide lines for Civil Emergencies
(Appendices 2-19- Guide lines for Civil Emergencies)
This “Gas Terminal Alarm Siren” which sounds exactly likes the “Flood Warning Siren” (with a possibility of total confusion at a high tide as Canvey Island is in a flood plain area)
The teachers were to go to the window and look to see if it was a high or low cloud
If it was a high cloud they were to get blankets and instruct the children to put the blankets over their heads and get under their desks
If it was a low cloud they were to instruct the children to put the blankets over their heads and stand on their desks
Apart from the dangers of flooding no further instructions on what to do in the event of a major Incident involving the “TOP TIER COMAH” sites within the area have ever been given to the majority of residence within the surrounding area of the Terminal on an annual basis
The last “What to do in an emergency instructions” involving “TOP TIER COMAH” sites was issued to all Canvey Island residence nearly 30 years ago to the people and has not been up-dated since
The people feel Calor Gas have demonstrated via a public meetings and their website Canvey LNG, inconsistencies bordering on contempt for the residents of Canvey Island and the surrounding area in regard to their safety and well being, subsequently losing their trust
The Calor Gas Consortium has lost the battle to win the hearts and minds of the people of Canvey Island and the surrounding area.
3-1 PLANNING
Are you confident of getting all the permissions?
Answer by Calor Gas: - (Calor Gas Doc)
Yes, we wouldn’t be progressing to this next stage if we hadn’t successfully completed a detailed feasibility study and risk assessment.
We have also received feedback that this development was very much in the National Interest.
We would not progress with any development on the site that would increase the risk to the local community
We consider this is treating the people with contempt because documentation clearly identifies that this proposal had already been started and in fact was included in the Ofgen report dated April 2006 on table 1.4 future LNG import facilities as providing storage facility before the planning application was adjudicated on in the following September 2006 thus losing the confidence of the people
(Ref Appendices 2-20 Our Energy Challenge)
This was clearly 6 months before the Adjudicated Castle Point Planning Authority had made its decision to reject the planning application and 18 months before the start of this enquiry into the same planning application which we understand is still to be determined
But according to the April 2006“Ofgem”report this terminal that we are having this Public Enquiry about today is not CONCEPTUAL or SEEKING PLANNING PERMISSION or at the PUBLIC ENQUIRY stage but in the “INITIAL STAGES OF DEVELOPMENT”
The feeling from the people is that their judicial rights and due process was being undermined and there had been a deal done
At the LNG presentation held at the Paddocks in January 2006 We were told by the Canvey LNG partners that they had submitted their detailed planning application together with an environmental assessment to Castle Point Borough council in late 2005 and that they were confident that the proposal would be approved having received feedback from the Government that this development was very much in the national interest.
When asked at that meeting would you appeal if this proposal was not given planning permission they said yes and subsequently duly did so on the last day for appeals to be submitted? (Showing not best integrity to the people of Canvey Island) having falsely given some of them the impression that this issue had been resolved and their anxiety was no longer valid.
The local community misguidedly believed the comment by the LNG consortium that they constantly state in all their communications that they would not progress with any development on this site that would increase the risk to the local community.
This statement of course highlighted the fact that there is a risk at this site that had gone unrecognised by the community for some time.
The consortium did not explain that their confidence of success for this project was founded upon Governmental intervention, this being substantiated by the inclusion of the Canvey Island Calor Gas project being in the initial stages of development in the document Our Energy Challenge table 1.4 future LNG imports Ofgem, s response April 2006
6 months before the decision was rejected at the Castle Point planning sessions.
3-2 HSE 1st Report Section 5 Planning Controls
(Ref: Appendices 2-21 HSE 1st Report)
Para: - 72
We hold very firmly to the view that siting of all industrial developments should remain a matter for planning authorities to determine since safety implications, however important, cannot be divorced from other planning considerations
Para: – 76
The hazard potential will largely determine the extent of the area around a notifiable installation
Topographic (physical features or locality), atmospheric (surround air) and demographic (life in the community of people) factors must be taken into account
So much depends on the precise nature of the development concerned
HSE 2nd Report
Section 4 the relationship of planning to major hazards
(Ref Appendices 2-22 HSE 2nd Report)
Para: - 80
Referring to decisions about potential hazardous developments should be taken by central government; however, this appears to us to give insufficient recognition to the fact that local authorities are well placed to take proper account of the full range of local factors, including safety issues, which are relevant to planning decisions
Para:-81
We emphasized in our 1st report that absolute safety was impossible to achieve
Para: - 91
We are of the opinion that the introduction of a notifiable hazard at an existing installation, or a change of use, should be capable of control so as to provide the local community with an opportunity of deciding whether they are prepared to accept the introduction of that hazard
Para:–109
The overall objectives should always be to reduce the number of people at risk, and in the case of people who unavoidably remain at risk, to reduce the likelihood and extent of harm if loss of control or of containment occurs
3-3
The planning issues in particular SOCIETAL RISK being at the forefront of the decision process.
It is generally believed that as a result of the Flixbough disaster the Health & Safety as it is known today was born and this investigation and the 1st investigation held involving the Thurrock and the Thameside industries was the first societal risk assessment carried out between high fire risk industries and the local population
This latter investigation focused on the Thameside industries at the time and the surrounding area, the installations included in this report were
Canvey Island Shell Haven
British Gas Corporation Shell UK Oil
Texaco Ltd
London and Coastal Oil Wharves Ltd
Occidental Refineries Ltd Stanford-le-hope
United Refineries Ltd
Fisons Ltd
Coryton General
Mobil Oil Co Ltd Transport of Hazardous materials
Calor Gas Ltd by river, rail and pipelines
3-4
Many of the accidents considered in this investigation could occur without causing any significant number of casualties to the general public.
However if the conditions at the time of the accident were sufficiently unfavourable to cause a significant number of deaths amongst the public, quite small changes in circumstances could cause the number of deaths to range from a few tens to a few hundred up to several thousands
The Methane Terminal was then and still is today considered to attribute one third of the totality of societal risk to this community as the report said, we have serious doubts whether British Gas Corporation should continue to store such large amounts of LNG and LPG at the Terminal in the light of the investigating team’s assessment
This is an historical issue that has confronted the residents of Canvey Island for some considerable time and it is the collective risk from various issues that cannot be discounted.
Where is the Societal Risk assessment?
3-5
HSE 1st Report
Chapter 2 Identifying major hazards and assessing risk
(Ref: Appendices 2-23 HSE 1st Report)
Para: - 10
We have begun by focusing our attention on certain of the more obvious threats to safety, those that arise from the escape of significant quantities of flammable and or toxic materials as a consequence of loss of plant integrity or loss of process control
Installations where such materials are present depend on proper containment for their ultimate safety and this is the heart of the problem
We must take vigorous action now with the aim of ensuring that large quantities of dangerous chemicals do not escape
Para: – 11
In the case of flammable materials, the greatest threat arises from the sudden massive escape of those volatile liquids, or gases, which produce a large cloud of flammable, possibly explosive, vapour.
If the cloud was ignited, the effects of combustion would depend on many factors including wind speeds and the extent the cloud is diluted with air
3-6
The worst consequences could be large numbers of casualties and wholesale damage on site and beyond its boundaries
An important feature of this threat is the small time between the initial escape and the fire or explosion, which could be LESS THAN A MINUTE.
Thus there is little time for the implementation of prepared emergency arrangements as is shown in the following report:
HSE 2nd Report
Chapter 1 Experience of major accidents and problems in evaluation of major hazards
Table “C” and Para: - 14 (Ref: Appendices 2-24 HSE 2nd report)
Also in the HSE 3rd Report
(Ref: Appendices 2-25 HSE 3rd Report)
Chapter 1 the overall problem
Para:-6
The point raised here is that people who are liable to be affected by a major hazard installation should have information made available to them on the hazards and the control measures
Para: – 10
Continued research into factors affecting major hazards is necessary
Chapter 2 Living with risk
Para: - 22
It seems inescapable to us that if the public are to be expected to live with risks from some industrial installations, however well controlled, they should be made aware of those risks
Para: – 23
The minimum information given should include
a) The nature of the hazard which might affect them if control measures fail
b) The emergency arrangements which have been made in advance
c) What they should do in a major incident
Para: – 24
Who should be told?
a) Employees and others on site
b) Local Planning authorities
c) Members of the Public who live in the vicinity of the hazardous installation
3-7
At the LNG presentation held at the Paddocks in January 2006
We were told by the Canvey LNG partners that they had submitted their detailed planning application together with an environmental assessment to Castle Point Borough council in Late 2005 and that they were confident that the proposal would be approved having received feedback from the Government that this development was very much in the national interest.
When asked would you appeal if this proposal was not given planning permission they said yes and subsequently did so on the last day for appeals to be submitted. (Showing not best integrity to the people of Canvey Island) having falsely given some of them the impression that this issue had been resolved and their anxiety was no longer valid.
The people foolishly believed the comment by the LNG consortium that they constantly state in all their communications that they would not progress with any development on this site that would increase the risk to the local community.
This statement of course highlighted the fact that there is a risk at this site that had gone unrecognised by the community for some time.
The consortium did not explain that their confidence of success for this project was founded upon Governmental intervention,
This intervention being substantiated by the inclusion of the Canvey Island Calor Gas project being in the initial stages of development in the document Our Energy Challenge table 1.4 future LNG imports Ofgem’s response April 2006 way before the decision was rejected at the Castle Point planning sessions.
It is clear in the DTI document Offshore Natural Gas Storage and Liquefied Natural Gas Import Facilities that the government are clearly concerned that they need to encourage gas suppliers to make investments to secure our energy supplies.
3-8
USING SALT CAVERNS FOR STORAGE OF LNG
There have been suggestions of storing LNG in salt caverns around the coast.
I understand the use of underground caverns in rock formations to store Natural Gas is long established and common around the world.
I believe in the U.K. the practice was first used in 1959 at the Saltholme brine field on Teesside
I believe the longest established site used for storing Natural Gas was commissioned in 1979 at Hornsea in East Yorkshire/ Seal Sands in Teesside / Holford in Cheshire/ Hole House, Cheshire.
3-9 (Ref Appendices 2-26 DTI Doc)
In the DTI document Meeting the Energy Challenge a white paper on energy May 2007 chapter 8 planning at page 255 talks of their concerns about uncertainty created by the planning process, although they list examples that may hold up the planning processes they do not consider societal risk to be an issue, but note that extensive delays can create a climate of uncertainty which often makes it difficult to secure capital or continue financing a project that may be delayed.
In other words a financial issue rather than a societal need issue.
It is noted on the footnote of page 255 of the above document that there are other projects that have been refused by their local authorities for whatever reasons.
Although we would note that this would give the government and appropriate departments serious cause for concern about their projected impact on gas supply infrastructures and projects
We must emphasise most vigorously that the Canvey Island issue should be assessed in its own merit and not be dragged along with the government strategy for future gas supplies.
Item 8.4 of the above document refers to the government’s improvements to the planning system in recent years both from decisions taken by local authorities and those taken by central government with regard to land use planning.
8.5 of this document refer to planning being consistently one of the top 6 concerns for inward investors in the UK.
New decision making body
(Ref: Appendices 2-27 Barker Review)
The Barker Review document on page 76 puts a case for a new decision making body to determine applications for major infrastructure in the context of the governments strategic priorities thereby removing the need for ministers to be involved at the end of the decision making process.
3-10
WE FULLY SUPPORT THIS NOTION for the following reasons:-
- It is proposed that the independent planning commission would be made up of a panel of well respected experts of considerable standing in their field.
- It promotes monitoring and auditing arrangements to be established to ensure
There is appropriate accountability and probity
- The commission would assess applications as they come forward in the context of declared national policy and ensure that developers have carried out appropriate consultations with the local communities as well as statutory consultee
- The report declares that it would be critical that the commission took appropriate account of local interests in its decision making even where NATIONAL NEED is clearly established. Local considerations would have to be taken into account and communities given the opportunity to express their views and concerns.
- 3.16 continues with the European Convention of Human Rights which is incorporated into UK law by the Human Rights Act of 1998 has enshrined the principles that everyone should have the right to a fair hearing in making decisions on planning whether at local or national level, this means the principles of natural justice must be applied and that parties to planning applications should be treated fairly and even handily.
- 3.16 states that it would also be important to ensure that the reason for the final decisions are properly explained to those effected at local level
- 3.17 states that the commission would have to act and be seen to act in a way that demonstrates that it had not pre judged the application it was considering. It would have to determine applications in full consideration of all the relevant issues including all relevant environmental issues. Even where National need was clearly established, local circumstances might indicate that the cost of granting planning permission outweighed the benefits. In that case the commission would have the powers to refuse the application it was determining.
The residents of Canvey Island feel that any decision that is made to this issue should be made by an independent planning commission and not by the Secretary of State.
3-11
Any decision to this application should be deferred until the following have been implemented
- That the notion of an independent planning commission is employed to adjudicate this application using the agenda highlighted above
- That any decision made should be deferred until the HSE have fully investigated the phenomenon of VAPOUR CLOUD EXPLOSION so that any safety elements can be fully appreciated and acted upon should this proposal go ahead.
The Barker Review Delivering Major Projects in the case for a new decision making body i.e. Independent Planning Commission lists a reason for support for this notion on page 77 as REMOVING SUGESTIONS OF BIAS.
It suggests that by taking ministers out of the decision making process would also remove from the planning process any suggestion of bias and unfairness for example
There could be concerns about particular political interests or high profile interest groups influencing decision making under the current system from which an independent planning commission would be comparatively free.
We fully support this notion in light of the Secretary of States decision detailed on the letter 10th May 2007 that stated that the appeal was to have been decided by an Inspector.
The Secretary of State considers that they should determine the appeal. The letter stated that Secretary of State hereby directs that they shall determine this appeal instead of an appointed person.
(Ref: Appendices 2-28 letter dated 10 May 2007)
This means that instead of a decision, the Inspector will prepare a report, which will be forwarded to the appropriate decision branch.
This issue in the view of the residents of Canvey Island has always been of grave concern being there is a suggestion of bias resulting from the numerous discussions and consultations between the government departments and the power suppliers.
3-12
In the Government response to public consultation of the D.T.I. offshore Natural Gas Storage and Liquefied Natural Gas Import facilities
The demands of the energy industry want a one-stop-shop
On paragraph 4.43 The Joint Nature Conservation Committee and Countryside Council for Wales commented that it would beneficial for all land and sea based infrastructure relating to individual developments to be simultaneously considered by consenting and assessment process
This view was supported by “Hoegh LNG” who requested a “one-stop-shop framework to cover both on-and offshore aspects of the project” they consider that this would “simplify procedures for all persons concerned in such activities”
We accept that there would be advantages to developers in one consenting authority considering all aspects of a project, even where a project may necessarily be split with onshore and offshore elements
However, under the existing Petroleum Act 1998 provisions, it is necessary to make a separate application, as appropriate, for any onshore aspects associated with the project.
The DTI does not propose to make any changes in this respect relating to these new provisions.
The Planning White Paper, due to be published by the Government in the spring 2007 will separately be making proposals for the reform of onshore planning processes
DTI has been active in the development of this Paper
The term of THIS IS A DONE DEAL was heard on many a doorstep
3-13
Where is the feasibility study? Of course it’s feasible you save a lot of money
What dates were they submitted?
Should there not have been a feasibility study and risk assessment in place on the existing site that stores LPG?
Where is this previous feasibility study and risk assessment or safety case?
Has it been kept up to date annually?
Who told Calor Gas, “It was very much in the National Interest” to have there site here on Canvey Island?
Where is the study that there is no increase in danger to the community with the proposal for 120,000ton of LNG and LPG where at the moment there is already stored an unacceptable amount of 35,000 tons of LPG that has been forced upon us?
Where is the Emergency off site Evacuation Plan that should have been in place since 2001 on the present site?
Have the people of Canvey Island been told of this “Off site safety plan”?
Have they been allowed to see a copy of this “off-site safety plan”?
The only way we could get a Partial view of this “off site safety plan” was to invoke the “freedom of information act” as a requirement for this enquiry
3-14 OFF-SITE PLANS FOR CALOR
(Ref: Appendices 2-29 Calor Gas Emergency Plan)
The “Calor Gas Terminal” is a “TOP TIER COMAH” Terminal that has to be considered as part of a “DOMINO” site with the other “Thames-side” COMAH INDUSTRIES
The site has the potential hazard of Fire and Explosion
The hazards are from Processing / Ship to Shore Transfer / Road Tanker Export / Pipeline Export
The Principle Risks are:-
Failure of a storage tank
Failure of ship to shore transfer pipe work
Failure of pressurised loading hose
Failure of pressurised road tanker
Failure of pipe work
Failure of Gas Holders
Events contributing to a major Accident
Jet Fire
Pool Fire
Vapour Cloud Explosion
Boiling Liquid Evaporating Vapour Explosion
There is No Public Warning System (on-site siren can be heard off-site)
When the off-site emergency plan is activated Calor Gas will contact the emergency services stating “we are a Top Tier COMAH site and we have an incident and are activating our off-site COMAH plan”
It will take time to activate these procedures unfortunately they are designed to be reactive and not active and the time factor between an incident leading to an accident is very quick
3-15
Whilst we believe the emergency services can perform the impossible it would be doubtful if the emergency services can react as fast as required bearing in mind according to the HSE 2nd report table “C” Sudden release of flammable gases or vapour the time from spill to ignition is very short in a lot of cases less than 10 minutes
Have the schools, disabled persons, playschools, and senior citizen establishments and local population been informed of the existence of an off-site Emergency Evacuation Plan that is required by a “TOP TIER LNG/LPG COMAH site? This should have been instigated by Calor Gas as a requirement as far back as 2001?
Has the existing off site emergency plan been tested?
Have there been exercises with the appropriate Authorities to test this “Off-site Emergency Plan?
If it has been carried out what was the outcome?
Was it a desk-top test or a fully integrated test?
All parts of risk assessment Refer to S.I. No 476 of 2000 for co-operation between other sites / Emergency action plan/ Local Authorities/ Fire Authorities/ Police / NHS
There is no suitable emergency plan for the evacuation of Canvey Island.
This should be made very clear to the people
The LNG project as a hazard should not be dealt with in isolation.
There are many other hazards in addition to day to day risks (e.g. crossing the road etc.) that Canvey Islanders are subjected to, i.e. LPG, Petrochemical storage and installations. Flooding, Shipping, Montgomery, an accumulation of COMAH sites.
The combination of which had been reduced down in the past from an “unacceptable level of societal risk” and was reduced to what is at the moment is regarded as a “Just Tolerable level of societal risk”.
Enough is enough, the very process of decommissioning and commissioning these types of installation is hazardous.
The constant reminder by way of size and bearing is unacceptable to the concept of residential area of the size of Canvey Island where its occupants have a greater level of risk above that of day to day living to contend with.
The people ask is Canvey Island already the most hazardous place to live in the country, even without LNG.
3-16
Does the UK need this facility?
Answer by Calor Gas
In all our discussions with Government officials and industry experts this question created complete consensus; the answer is yes.
The UK is already importing natural gas and in 2004 became a net importer. It is vital that there are a number of sources of natural gas available for UK natural gas customers to ensure security of supply.
The reliance on just one type of natural gas supply is no longer an option as we have seen in recent weeks. A number of strategically sited LNG terminals will play a crucial role in creating a secure and diverse source of natural gas in the decades to come.
If this is so why Canvey Island? The smallest of the sites?
Have Calor Gas added up the figures to suit their own scenario for example stating the capacity they can store 5.4 million tonnes per year at the proposed site and that equates to 5% of the gas used by the UK of 180 million tonnes therefore they can manipulate that figure to represent an argument that their 5.4 million tonnes that their site can hold is an urgently required 5.4 million tonnes required for the countries needs so what they propose is in the national economic interest?
Having undertaken extensive research there has not been any document found that refers to the Canvey Island Terminal as to be so essential for the National Interest for its gas supply.
There is still a need to show why this development should take place on Canvey Island.
Other than financial convenience for the Calor Consortium being Canvey Island project is a relative small site
The people of Castle Point have become very suspicious of the Energy Companies and we do not forget that Centrica (ex British Gas) is a partner in this venture and they have a monopoly on gas supplies in this country and if so inclined could hold this country to ransom if supplies of gas were manipulated
Centrica has brought about this situation because of the fire at the “ROUGH” platform shutting down gas supply from the countries largest storage facility causing a high rise in the gas supply, the people are asking why are we giving them the opportunity to effect the gas price by having storage outside the “ROUGH” facility- shut down for any reason therefore there will be an increase the value of the stored gas
Saving money –look at the proposed cost-to profits
The sole reason for Canvey Island is its unique location –coupled with the largest jetty in the Thames Estuary- shipping traffic to be increased from the new container terminal
The jetty is not large enough for their needs
Who are the Government officials and industry experts?
Is this a done deal?
Are the people of Castle Point expendable to the machinations of the Gas Industry?
3-17 TECHNICAL
How much gas will be stored at Canvey?
Answer by Calor Gas
We intend to seek permission to store 240,000m3(108,000 tonnes of LNG and 12,000 tonnes of LPG) at Canvey in 2 full-containment purpose built tanks where the inner tank is made of 2 inch thick steel plus 3 feet wide insulation to maintain the LNG at a temperature of -160 degrees C, while the outer tank is made of two and a half feet thick pre-stressed concrete. In the past the site has been authorised to store 246,000m3 (128,000 tonnes) of LNG.
Are Calor suggesting that because the terminal when it was owned by “British Gas” once stored 128,000 tonnes of LNG, it will be able to increase that storage of gas stored at the terminal in the future to128, 000 tonnes of LNG plus 12,000 tonnes of LPG, equating to 140,000 tonnes of gas stored at the Calor Gas site, and therefore use the National Economic Interest as the reason to expand their site, therefore increasing their profit?
Was not all this high volume capacity of LNG stored so close to a residential area given permission in the first place, before the birth of the Health & Safety and the concept of societal risk impact and if the same planning application that was put forward then was put forward today it would be doubtful as to whether permission would have been granted?
Was not Canvey Island made expendable in the National Economic Interest then and was it not made the guinea pig to test the use of LNG in-ground storage?
Are we to be used once again as the guinea pig in trying out these new tanks in the name of loss and profit?
Our loss, Calor consortiums profit!
4-1
SIGNIFICANT ADVERSE IMPACT
The Calor Gas consortium’s website refers to the historical consideration that exists with their site, it having been DISCREETLY LOCATED as being a consideration as to why Canvey residents should accept their proposal.
It is difficult to comprehend how the impact of this proposed development by reason of the height scale and mass of the storage tanks could ever be considered as being DISCREET.
Although the proposal, to make it sound acceptable offers us a lesser number of tanks that currently store LPG,
For economic reasons and constructional restrictions, in order to achieve the capacity that they desire, are asking us to accept storage facilities which have a height of 46.3 metres equal to 152 feet or over 14 storey, equivalent to 3 times the height of the existing tanks.
The proposed tanks will have a diameter of 83.6 metres equal to 274 ft 3 in and again almost three times the width of the existing tanks.
This is HARDLY DISCREET.
It will be Sky-line Plumbing and will look like a permanent giant Carbuncle threatening to burst sited on the landscape of Canvey Island
On the LNG website the question ‘How would the site look?’ is depicted by computer aided diagram which is at best misleading.
These describe the storage tanks as only being approximately 10 metres 32 ft 6in higher than the existing tanks.
It will totally change the landscape of Canvey Island because you will be able to see these proposed giant tanks tens of miles away
It will change the appearance of Canvey Island dramatically
It will give the impression that Canvey Island instead of being a seaside commuter residential area with a bit of industry
Canvey Island will be changed irrevocably into the appearance of being an industrial area with a lot of heavy dangerous industry in the middle of a large housing estate
In terms of the local impact of this proposal, it is considered that these new storage tanks, by reason of their size and appearance and over dominance, have a significant adverse impact to the residents of Canvey Island.
The consequences of this significant increase in scale of these proposed tanks will mean that this site as exists will turn from a relatively low impact feature (discreetly located), which while visible over a long distance is a least capable of being screened with some degree of success by trees into a substantial eyesore on the wider landscape.
The proposed tanks will be incapable of being successfully screened giving Canvey Island the legacy of appearing as a highly industrialised site.
The structures will dominate not only the area immediately adjacent to the site but from long distant views of the entire Island
Changing not only the character of the immediate area but also the perception of the Island from as far a field as Kent from where these 150ft Giant Thermos Bottle monstrosities will be easily seen.
This is completely at odds with the current recessive development of the site, and is unacceptable in terms of impact not only to the appearance of the site but also to the people of Canvey Island.
When asked ‘What impact will this have on local property prices?’
Via their website, the response of the LNG consortium was “As there has been a gas terminal at this exact location for over 40 years the vast majority of local residents have moved into the area after the terminal became operational.”
This is true but because the site was discreetly located it would not have been an obvious issue to most of the new residents.
It would not have been a discussion point with the Estate Agents concerned.
The website continued “If this proposal does not go ahead, there will still be a gas terminal on our site”
This is also true however because of the proposal of the Calor Gas consortium and as a result of a Public Inquiry; this has attracted high profile attention to this COMAH site, bringing about the perception and reality of societal risks from such sites.
We can justifiably be accused of complacency but rest assured this society will be paying particular attention to the Calor Gas site with regard to its working practices and off-site emergency procedures ensuring our own well being.
Calor Gas website states
‘We do not anticipate any impact on local property prices as a result of this proposal for a brand new terminal going ahead’
We can assure the Calor Gas consortium that the property prices on Canvey Island will not favourably increase as a result of their ‘brand new gas terminal going ahead’
4-2
GAS / VAPOUR FLAMMABILITY
We understand it is a function of a Process Hazard Analysis (PHA) to identify those inherent properties, conditions or equipment that could cause injury to personnel, the environment or facilities.
Gases and vapours have one property that can make them particularly problematic, they readily mix with air
This means that loss of containment incidents can quickly expose processes, company personnel and the general public to fire or explosion hazards if the gas or vapour is combustible and the result could be catastrophic
Because gases and vapours can quickly mix with air and this allows the gases and vapours to form ignitable mixtures with air this we believe can lead to flash fires, pool fires, jet fires, vapour cloud explosions and detonations
If the ignition of a gas / air or vapour / air cloud occurs rapid burning is initiated
Also several possible outcomes are possible, if the cloud is unconfined, a flash fire will occur; the high temperature flame and combustion pose a great danger.
If the flash fire is confined or if conditions are right for flame acceleration, then a vapour cloud explosion (VCE) will occur
An Unconfined Vapour Cloud can cause extensive damage and threaten personnel over a wide area as the vapours from a flammable liquid can flash back and ignite the liquid pool resulting in dangerous Thermal Radiation levels or Heat Sear therefore spreading the fire,
We also believe flammable liquid fires are very difficult to extinguish
The release of gases or vapours under pressure can cause jet fires as these fires are fuel rich they burn very hot and they pose an extreme hazard to nearby tanks if the tank is pressurized and contains a substance such as Liquid Petroleum Gas (LPG) and Propane it can result in a Boiling Liquid Expanding Vapour Explosion (BLEVE)
The effects of a BLEVE include missiles, blasts and if the contained material is combustible, a fireball with extreme Thermal Radiation or Heat Sear will occur
Also the contained material does not have to be flammable for a BLEVE to occur I understand it is the Rapid Phase Transition (RPT) that causes the physical damage
4-3
Given a worst case scenario whether the cause of an Unconfined Vapour Cloud Explosion (UVCE) or a Boiling Liquid Expansion Vapour Explosion (BLEVE) is Instantaneous, Catastrophic, Continuous or Transient the result can be extremely Hazardous to the surrounding area
It can cause Fireball Thermal Radiation that will have a catastrophic effect on the community of Canvey Island and the surrounding area with only a Search and Rescue Policy available
When ignited LNG burns at a much higher temperature than petroleum spirit
If we look at Table “C” Sudden releases of flammable gases or vapour it clearly states the different materials involved and please note the time to ignition in minutes are very short
An evacuation Policy is not possible for Canvey Island due to speed the events could occur and the lack of infrastructure to cope with this sort of scenario and there is only one access point off the island at the “Waterside Roundabout”
Therefore the people of Castle Point become expendable in the event of a worst case scenario
4-4
Is the tank design of two inch thick nickel steel inner hull and two and a half feet outer hull to protect the tank from outside forces or attack?
Is it to strengthen the tank from the inside because of being able to use different types of light and heavy LNG and being able to mix them and the strength from inner pressure is required because of wrong layering of different sources of LNG that are of different consistencies (some are heavy and some are light) that can cause a rollover, but being able to use different sources of LNG at different consistencies makes it more economical?
Is the real reason Calor are building these tanks 14 stories high because you can only go upwards on this site because of the foundations of previous tanks and you can-not build on those old foundations?
Will this be a peak shaving plant?
Will LNG be brought in cheaply stored until the price rises and then sold to the highest bidder?
Can Calor Gas prove is it part of required daily usage of the nation in the south east?
How does the Calor Gas Company quantify the figure of 5% of the gas annual demand?
Does Calor Gas infer that the annual need for the UK is 180,000 billion cubic meters therefore if we make the depot at Canvey Island capable of storing 5.4 billion cubic meters that equates too and represents 5% of the countries needs?
Are they just juggling the percentage figures to suit themselves?
Are Calor Gas guilty of trying to use a terminal that will be past its sell-by-date and will have to close, modify it, and use the National Economic Interest as a red herring in the name of profit for their own Consortium?
Why is the Consortium only spending £150 and £200m on this project when you and your consortium have an annual turnover of 450 bn.Yen / £280m / £18.3bn / $8.6bn respectively?
Has the Calor Gas Company ever been involved with the Transporting / Storing / and Processing of LNG in the past?
Is the Calor Gas Consortium just playing a game of profit and loss?
Calor Consortiums profit, the Peoples loss!
Are the people to believe that Calor Gas are pulling down 8 good storage tanks storing 35,000 tonnes LPG and replacing them with a brand new very big single tank storing 12,000 tonnes of LPG?
If the 8 old tanks were not passed there sell-by-date why are the Calor Gas Company pulling them down?
4-5
In the past British Gas (now Centrica a marketing partner of the Calor Gas Company) stored LNG in 4 EXPERIMENTAL in-ground tanks as a cheap way of storing LNG (I know its quite technical but in layman’s terms they cut 4 round holes in the ground next to one another, froze the ground, put the LNG in and put a lid on it)
These Experimental tanks became unstable and uneconomical due to the permafrost created by the freezing ground and the fissures between the 4 tanks caused by the permafrost
(Ref Appendices 2-13 how it should be / how it is)
Because this permafrost made the tanks interconnected by these fissures these tanks were decommissioned because concerns of safety and they were uneconomical?
Has the exact design of tank suggested by Calor Gas ever been used before or are they also Experimental?
In the past Canvey Island was the guinea pig for The British Gas Company (now Centrica a marketing partner of The Calor Gas Company) for their profit
When Calor acquired this site was it not muted that they would only store LPG and not LNG in the future?
Is the chance of a large profit at our expense overtaking that view?
Are the dates of getting this application passed and started being forced through quickly to suit the Calor Gas Consortium so that the terminal would not have to adhere to and would not have to come up to the standard required of the new safety proposals from the onset that are being suggested in the Health & Safety document CD 211?
The request by the Health & Safety of more studies into Unconfined Vapour Cloud Explosions in reference to “Proposals for revised policies for HSE advice on development control around large-scale petrol storage sites” document on page 32 of that report
4-6
(Ref Appendices 2-30 CD 211)
WIDER IMPLICATIONS FOR OTHER MAJOR HAZARD SITES
The implications of these changes for major hazard sites other than those like Buncefield need to be considered, but those are not an issue for this consultation exercise.
Clearly we have a poor scientific understanding of the mechanisms which led to the vapour cloud explosion at Buncefield, and we accept that installations storing other substances could present this type of hazard, for example bulk LPG storage, and other flammable liquid storage.
Assumptions about possible means of and time available for emergency action are equally applicable to such sites as they are to large-scale petrol storage depots.
Further scientific research should be undertaken to clarify our understanding of the conditions under which such explosions may occur, and thence how the risks from them may be controlled
Furthermore it is necessary to review some of the fundamental assumptions used in HSE’s risk assessments to rationalise issues about, for example:
The building design and construction;
The level of protection given to people from fire and toxic hazards, as well as from explosions; and
The varying capabilities of people at home and at work to respond effectively and escape from a “developing” major incident
6.3 The forthcoming Government consultation on societal risk will examine that issue in relation to all major hazard sites including petrol storage depots, so societal risk has not been covered in this exercise
Surely the planning application for storing LNG at the Canvey Island terminal should be refused until the HSE have completed their studies into Unconfined Vapour Cloud Explosions and the findings known and debated also the forthcoming Government consultation on societal risk has been carried out and debated by all parties?
Would it not be wiser to make a decision on this Calor Gas Planning application until after the HSE have completed their studies into “Unconfined Vapour Cloud Explosions”
The area of Castle Point is already at a Just Tolerable risk level without adding more and increasing the storage level of Liquid Natural Gas to the area and making a Just Tolerable level of risk into an Unacceptable level of risk
4-7
The following documents although historical, show great value in the fact that we still have lessons to be learnt
The “Advisory Committee on Major Hazards First Report”
The “Advisory Committee on Major Hazards Second Report”
The “Advisory Committee on Major Hazards Third Report”
4-8
There is also a “Revised land use planning arrangements around large scale petroleum depots RR511” under review and:
“RR512”Review of significance of societal risk for proposed revision to land use planning arrangements for large scale petroleum storage sites”
“CD211” Is a consultative document on proposals for revised policies for HSE advice on development and control around large-scale petrol storage depots.
4-9
WE FIND THE COMMENTS IN THE FOLLOWING REPORTS SIGNIFICANT
(Ref Appendices 2-31 Nature of the problem)
Advisory Committee on Major Hazard First Report
Chapter 1) the nature of the problem
Para 1
There are now many plants throughout the world where critical first mistake can result in disaster, such as major explosions and safety needs to be balanced because of the increase in the size of plant and the pace of development
1(6)
Whilst the probability that an individual worker will be involved in a fatal accident has notably fallen
The chances that a plant failure will involve many deaths have at the same time increased
The risk of involving the public at large in an industrial accident has become considerably greater and has rightly changed society’s attitude to manufacturing hazards
Surely this must lead to a need for new kinds of control for industry that whilst developments in manufacturing technology have raced ahead
The methods of ensuring safe operations, and the legal mechanisms for enforcement of safe standards, may not have kept pace and require a system of control that keeps pace with technological developments
(Ref Appendices 3-1 Identifying major hazards)
4-10 Chapter 2) Identifying major hazards and assessing risk
The more obvious threat to safety are those that arise from the escape of significant quantities of flammable and or toxic materials as a consequence of loss of plant integrity or loss of process control
In the case of flammable materials, the greatest threat arises from the sudden massive escape of volatile liquids or gases, which could produce a large cloud of flammable, possibly explosive, vapour
If the cloud were ignited, the effects of combustion would depend on many factors including wind speeds and the extent to which the cloud is diluted with air
The worst consequences could be large numbers of casualties and wholesale damage on site and beyond its boundaries
An important feature of this threat is the small time interval between the initial escape and the fire or explosion, which could be less than a minute. Thus there is little time for the implementation of prepared emergency arrangements
With toxic materials the sudden release of very large quantities, if windborne, could conceivably cause even larger numbers of casualties than a flammable escape in certain conditions produce lethal concentrations in places 20 miles from the point of release
The number of casualties would depend on population density in the path of the cloud
Some installations pose both types of threat also the possibility of creating a domino effect hence large numbers of people at risk if anything goes wrong
4-11
Chapter 3) Notifiable Installations
(Ref Appendices 3 -2 Notifiable Installations)
On the subject of notifiable installations the proposed terminal at Canvey Island would I understand come into this category
We believe past Health & Safety reports have confirmed in their analysis study what the people of the community have always believed the Calor Gas Terminal site is considered to be one third of the total risk of all the Essex side of the Thameside Industries
WE BELIEVE THERE IS TOO MUCH HAZARDOUS INDUSTRY BEING SITED TOO CLOSE TO RESIDENTIAL AREAS
The threat and the dangers to this community also the probability of the devaluation of there properties would not exist without the “Calor Consortiums” plans to site this “TOP TIER COMAH” LNG (Methane plant) so close to this residential area
4-12 Chapter 4) Application of controls to major hazard installations
(Ref Appendices 3-3 Application of controls)
For the Health & Safety to ensure the companies shoulder their responsibilities in a satisfactory manner there must be accountability
Management must manage the hazard and be ready to account for its performance at all times.
It should be made mandatory for a company which operates or proposes to operate an installation offering the highest risk and statutory responsibility being laid on the company to demonstrate it has in place
- Appropriate philosophy, technical and human resources implemented by “competent persons”
- A sound management system
- The responsibility being laid with senior management
- The production of codes of practice being implemented
It must be the responsibility of senior management to satisfy itself that its arrangements are adequate and that:
- Senior management appoint a senior person or a senior position in the company where that person or persons in that position takes full responsibility under vicarious liability
- If there is an incident or an accident resulting in injury or loss of life that is caused by a failure to carry out the duty of care through the actions or inactions of themselves or their staff
- That person should be clearly identified and would take full responsibility if the charges of corporate manslaughter were be brought to bear if that was proven
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