Ymddiheuriadau. Dim ond yn y Saesneg mae datganiadau i'r wasg Cyfeillion y Ddaear i'w cael. Am ragor o wybodaeth gweler ein Cynllun yr Iaith Gymraeg.
The two proposed LNG terminals at Milford Haven would pose an unacceptable threat to the local population and should be called in by the Welsh Assembly. This is the message that Friends of the Earth Cymru have given to the Assembly's Planning Minister, Carwyn
Jones, in a letter written on the day that Prime Minister Tony Blair gave a stark warning of the ongoing threat posed by terrorists (see Letter copied below). A Council meeting to be held this Wednesday (10th March) may make a decision on the proposed Exxon LNG terminal after being deferred twice.
The campaigning organisation point to recent recommendations from the USA that these terminals should be sited away from populated areas because of the particular hazards posed by this fuel. A tanker fire, which could be caused by collision in the narrow waterway or by terrorist activity, could result in a 'pool' fire that could cause second-degree burns at a distance of two miles.
The FoE Cymru letter quotes from a study by a Californian energy company that states that "LNG plants and tankers contain such huge amounts of highly inflammable and explosive fuel that they are considered ideal terrorist targets".
A USA government's General Accounting Office report to the US Senate and independent experts has recommended the siting of these facilities away from populated areas. As a result of this advice and local opposition, the two proposed LNG terminals in the USA are likely to have offshore locations.
FoE Cymru are recommending that an emergency planning exercise should be undertaken in the Haven to test the response to a credible major fire. As responsibility for emergency planning and fire services is to be devolved to the Welsh Assembly this year, FoE believes that the Minister should authorise such an exercise to ensure that only safe LNG terminals are permitted.
FoE Cymru spokesperson, Gordon James, said:
"Both LNG proposals would pose major public safety risks and raise issues of national security. As such, they ought to be called in by the Assembly for further consideration. We believe that we should follow the recommended practices in the USA and only allow these terminals to be sited away from populated areas."
FoE Cymru has also written to the two local Assembly Members, Christine Gwyther and Tamsin Dunwoody-Kneafsey, to ask them to support their request for the proposals to be called in.
'Assessment of Potential Risk Associated with Location of LNG Receiving Terminal Adjacent to Bajamr and Feasible Alternative Locations' by Power Engineering of San Diego (June 30th 2003)
March 5th 2004
Minister for Environment, Planning and the Countryside
The National Assembly for Wales
Dear Mr Jones,
Friends of the Earth Cymru is requesting that the Welsh Assembly Government calls in both the Exxon Mobile LNG terminal application and the Petroplus LNG terminal permission in the Milford Haven waterway. Both LNG operations would be strategic in scale and would pose major public safety risks and raise issues of national security. As such, we believe that the final decisions should be the Welsh Assembly Government's. We understand that the Petroplus application has been approved by the Health and Safety Executive (HSE) on an 'interim' risk analysis possibly pending further risk analysis (1).
An LNG tanker contains an enormous amount of energy. A tanker fire could be caused by a ship collision in the narrow busy waterway or by terrorist activity. Both are very credible emergency planning scenarios, especially since 9/11. The 'Bajamar' report, prepared by Powers Engineering of San Diego , California on behalf of Bajamar Real Estate Services, Baja , California [see attached], states that:
"LNG baseload plants and LNG tankers contain such huge amounts of highly flammable and potentially explosive fuel that these plants and tankers are considered ideal terrorist targets".
Two or more LNG tankers would access the terminal every week negotiating the Haven along with oil tankers, passenger ferries and other vessels. A retired Milford Haven pilot with 27 years' experience of working in the port, Mike Leney, has voiced serious concerns about safety aspects of the proposal. He has written to the Department of Transport warning that the safety margins are not sufficient to ensure safe passage without the unacceptable risk of accident or collision. An accident of this nature could have catastrophic consequences.
A tanker fire resulting in a 'pool' fire (gas on water) is probably the most dangerous type of event according to US experts, such as Jerry Havens, professor of chemical engineering at Arkansas University , and James Fay of the Massachusetts Institute of Technology. A test 10,000 gallon LNG pool fire resulted in a cylindrical fire 50ft diameter and 250ft high. Each tank/hold on a typical LNG tanker would be about 6.5 million gallons (ie. 650 times bigger than the test fire) and there are usually five or six tanks/holds on a LNG ship totaling 33 million gallons (ie. 3,300 times bigger than the test fire). And the fire would be more intense than a petrol fire. These, and other details, can be found in the article, ' Destination Humbolt Bay : The LNG Debate Heats Up', from the North Coast Journal (see www.northcoastjournal.com/110603/cover1106.html).
According to an authoritative US government 'General Accounting Office' (GAO) report (see LNG Bajamar pdf attached), a tanker fire would cause second-degree burns within one minute at a distance of two miles (3km). The Petroplus terminal is approximately only one mile from Pembroke Dock, Milford Haven town and two large oil refineries. The proposed Exxon terminal is only one mile west of Milford Haven town, and the waterway shore to shore is only one mile wide. LNG tankers entering Boston harbour have strictly enforced moving two-mile exclusion zones around them due to collision and terrorist risk.
Windblown gas plume fires may present a safety hazard at even greater distances. The paper for the HSE Panel meeting, on 2 nd September 2003 , about the Petroplus terminal (ref: Petroplus-C2339-PP-Aug) stated on page 14 para. 4:
"It is clear that such plumes, cantered on the jetty, are capable of engulfing the densely populated developments of Milford Haven (town), Neyland or Pembroke Dock. But without PCAG Guidance on the frequency to be assigned to the release, an ignition probability analysis cannot be undertaken to determine their significance in risk terms '.
Consequently Friends of the Earth Cymru consider that both terminals and associated LNG storage facilities pose a major safety hazard to the residents in Milford Haven town, Pembroke Dock, Neyland and people in the surrounding communities, oil refineries and gas facilities. The outlying population is around 28,000 inhabitants.
The two LNG terminals in Milford Haven would be the first in possibly a number of schemes in ports around the UK . Due to the serious fire risk onshore, LNG terminals have been successfully opposed in Italy in 2001 and the only two LNG terminals currently proposed for the US are offshore installations. The recent GAO report to the US Senate committee on Commerce stated that "remote siting is the primary factor in safety" because of "the vulnerability of the facilities to natural phenomena and sabotage, the public can be best protected by placing these facilities away from densely populated areas" (see LNG Bajamar pdf page 11). And Professor Jerry Havens has stated that LNG terminals should be located, at a minimum, two to three miles from populated areas.
LNG facilities are potentially very easy targets for terrorist attack, which should now be included in risk analysis and emergency-planning scenarios. An emergency planning exercise codenamed 'damaged dragon' based on a nuclear release was stage in Wrexham recently.
Presumably MI5 and the Ministry of Defence have been notified of these proposals. Indeed, an American owned/Republican-friendly oil company (Exxon), with a potentially indefensible highly-volatile, strategic energy facility located in a US friendly state (UK) and supplied gas from the middle East (Qatar) might be regarded as a globally prime target for some terrorist cells.
Friends of the Earth Cymru believes an offshore terminal is an option to be considered but even then the Haven may not be a safe location. An emergency planning exercise in the Haven could test responses to a credible major fire and would inform decision makers and the public about the proposals. An emergency planning exercise was staged in the Swansea area recently and another based on a marine oil spill in Cemmaes Bay , Anglesey last week. As emergency planning and fire services are to be devolved to Wales this year, we consider it reasonable, for safety reasons, that the Assembly Government ensures that only safe LNG terminals are permitted and a credible worst case emergency planning exercise is carried out before any LNG proposal is considered.
We note from the Notes (see footnote 2) presented to the HSE Panel on January 5th 2004 (ref: Exxon-C2436-PP5) that those involved in safety and risk discussions did not consider that they had enough official guidance or data to determine the risk posed by the terminals.' Interim' zones were set instead and a decision to support an 'advise against' was made which appears to have been subsequently overturned after meetings with the local authorities and the company. It would be instructive to know if the authorities and company were fully aware of the details in US studies and if they had considered terrorist risk. It appears that if they did not realise the scale of safety hazard then the economic benefits and local job creation may have been influential in determining the application. If so, this could prove to be a disastrous oversight that can still be averted by the Welsh Assembly Government.
We were also concerned to learn that Pembrokeshire County Council approved the South Hook LNG's hazardous substances consent application without obtaining a copy of the HSE's full risk assessment. The Milford Mercury newspaper reported, on the 26th February, that the County Council had not requested nor received the risk assessment. This malpractice fuels suspicion that safety issues are not being adequately addressed and adds weight to our request for a call-in.
Today, the Prime Minister gave a stark warning about the threat posed by terrorism pointing out that "it is a challenge of a different nature from anything the world has faced before". Allowing these two LNG proposals to proceed within a populated area would offer a target for terrorists and present an unacceptable threat to local people. We urge you to call-in these applications as they pose major public safety risks and raise issues of national security (see Planning Policy Wales, Section 4.12), and to follow the recommended practices in the USA of permitting them only if they are sited away from populated areas.
We look forward to hearing from you. If you respond by e-mail please reply to firstname.lastname@example.org
Friends of the Earth Cymru
33 The Balcony
1.The HSE's papers for the Panel meeting on 24th November 2003 (Ref: Exxon-C2436-PP3) state, on page 6 para 1, "The calculation for these events in the assessment of the Petroplus proposal, presented to Panel on 2nd September 2003 in paper C2339/02, are relevant also to this proposal.Panel ruled however, that hazard-based (flashfire) zones based on 6.54 km to LFL and 6.84 km to half-LFL should not be used. Rather it was agreed to postpone consideration of flashfire risks from ship releases until policy for ship releases had been clarified and until additional information on release frequencies and ignition probabilities were available. Until such time LUP contours would be described as 'interim'".
2. "Following Panel's decision to support an 'advise against' response, meetings have been held with the two local authorities concerned and with the company. Panel is asked to note that, taking its past discussions into account, the circumstances now allow an in-section 'not advise against' decision."
8th March 2004
Friends of the Earth Cymru
Last modified: 16.3.04