I am today publishing four documents relating to the safety of the proposed Corrib gas pipeline.
The first is the final report from the consultants appointed to undertake the safety review, Advantica. The second is a report to me from my Corrib Technical Advisory Group, making recommendations to me which I have accepted and will implement. The third is a report on inspection and monitoring issues, while the fourth is a short note which sets out in tabular form the recommendations of the Advantica Report, the TAG Report and TAG’s recommendations on inspection and monitoring, showing relationships where appropriate and identifying the parties responsible for their implementation.
I requested these reports because of the concerns relating to the safety of the onshore, upstream section of the pipeline expressed by people living in the community close to the proposed pipeline route. I have always accepted that these concerns were genuinely held, and I took them seriously.
I established TAG as an expert group, independent of the Petroleum Affairs Division within the Department, to assist and advise me in relation to engaging the best possible experts to undertake the safety review and also to make recommendations to me following completion of the review.
The first two reports were completed in the second half of January. I have not published them until now because I needed time to consider them, and because I had in addition asked TAG to come up with proposals for an appropriate inspection and monitoring regime to cover, not just construction of the Corrib project, but also its ongoing operation and maintenance. If there is one thing that has clearly emerged from this exercise, it is that, no matter how well something may be designed and built, there must be regular, effective maintenance to keep it in good condition, and there must be ongoing independent oversight of this to prove that this is happening. TAG has now reported back to me on this. I will comment further on this later.
Advantica’s final report is detailed and presents the results of months of very thorough investigation and analysis. I commend Advantica for this and I hope that everyone with an interest in this project takes time to give the report the consideration it deserves. I also thank everyone who contributed to the evolution of the report, particularly those who made submissions during the initial consultation phase and in response to Advantica’s draft report published in early December. Those submissions have shaped some of the work that was done – I would in particular identify work on peat dynamics which was undertaken in response to some helpful local observations.
Those who have studied the draft report will observe that there are many similarities between this final report and the earlier draft, and many of the recommendations made in the earlier report remain in the final report. However, in Appendices to the final report, Advantica set out their analysis of the report written by Richard Kuprewicz and also pipeline hazard calculations submitted by Dr Dave Aldridge. In fact, Advantica examined their material point by point and responded in detail to each. In many cases, Advantica had already identified the same points in their draft report. The detailed responses are set out in Appendices G and F respectively. Elsewhere in their report, Advantica deal with other concerns such as appropriate design codes and proximity distances.
I will not here set out in full Advantica’s conclusions and recommendations or attempt to paraphrase them – they are helpfully set out in a couple of pages at the front of their report. However, I will quote from two of them:
Proper consideration was given to safety issues in the selection process for the preferred design option and the locations of the landfall, pipeline route and terminal.
Provided that the recommendations are followed, we believe that the pipeline will be constructed to an appropriate standard and will be “fit for purpose”.
One of the recommendations that Advantica make is that steps should be taken to ensure that the pressure in the onshore section of the pipeline can never exceed 144 bar. It is their conclusion that this measure, taken together with the very thick pipe wall diameter, will deliver a very safe pipeline. Advantica conclude their report by saying:
Provided that it can be demonstrated that the pressure in the onshore pipeline will be limited effectively, and that the recommendations made elsewhere in this report are followed, we believe that there will be a substantial safety margin in the pipeline design, and the pipeline design and proposed route should be accepted as meeting or exceeding international standards in terms of the acceptability of risk and international best practice for high pressure pipelines.
The second report published today is from the Technical Advisory Group. TAG has accepted all the Advantica recommendations and has, in turn, recommended to me that they all be adopted. TAG has also made some recommendations, in particular one in relation to redesign of the landfall isolation valve to incorporate a further stage of pressure limitation over and above Shell’s current design proposals. The effect of this is to demonstrably guarantee that Advantica’s recommendation on limiting the pressure is achieved in practice.
I am today announcing that I accept the advice of my Technical Advisory Group and will be implementing those measures within my power – specifically requesting Shell to undertake the additional technical measures and provide the particular documentation detailed in the Advantica and TAG reports before further consents can be given. I expect Shell to comply.
TAG has recommended that operational maintenance and inspection of the onshore section of the pipeline should be in accordance with the guidance given in the Irish Standard IS 328. I would add that this will bring the Corrib pipeline into line with the same approach as BGE use for their gas transmission pipelines, which I know will be welcomed by many.
In the short term, TAG will act as the monitoring authority on my behalf. TAG will contract such specialist services to complement its own expertise as may be required from time to time. However, I intend to take powers through imminent legislation to place responsibility for gas safety on upstream installations with the Commission for Energy Regulation. CER is currently assuming responsibility for downstream gas safety matters. As with the application of the same monitoring codes to upstream and downstream pipelines, it makes sense to unify the responsible authorities for both.
In view of the lessons learned from the entire safety review process, I am having work undertaken on the Commercial Handbook which the Petroleum Affairs Division currently makes available to prospective developers. The updated Handbook will have a new section on safety issues which will make explicit the requirements in the area of safety that future projects will have to fulfil.
In conclusion, this combination of developments deals very comprehensively with the concerns about safety that some people earnestly held. I now call on all parties to engage constructively on the other issues relating to this project.
Copies of all Reports can be found on our website at
http://www.dcmnr.gov.ie/TAG/Technical+Advisory+Group.htm
ENDS
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