Shell Prelude it appears has inherited the North Sea chronic disease of loss of containment

By Bill Campbell

On 22 January past the Regulator wrote to Shell Australia with a direction, a mandatory notice requiring action by the Owner, because staff on Prelude FLNG were carrying out activities the risks of which were not being reduced to levels as low as reasonably practicable and thus there was a significant risk to the Health and Safety of persons on the facility.

In issuance of this direction, they took cognisance of three previous dangerous occurrences all resulting in a loss of containment, namely

(1) On 18th Sept 2019 a loss of hydrocarbons from a marine loading arm being prepared for maintenance and inspection activated coincidental gas detection causing an Emergency Shutdown of the facility.

(2) This was followed on 10th December 2019 with loss of containment of high pressure liquid from equipment that had not been correctly isolated.

(3) The final straw it appears came on the 9th of January last when operators broke into equipment to reinstate a relief valve causing gas detectors to activate with the subsequent General Platform Alarm causing persons to go to their muster stations.

The directive, well written and comprehensive and superior in my humble opinion to an HSE improvement or prohibition notice, in summary prohibits Shell from conducting any more intrusive activities into plant and equipment where the loss of containment as a result of such an activity could result in unacceptable risks to the Health and Safety of persons at or near the facility, the latter I assume will refer to persons on any vessels docked against the side of Prelude.

They consider the Prelude Safety Management System (SMS) as written defective wrt to the safe isolation of plant and equipment and this needs to be improved and after it is approved by the Regulator and reissued offshore the Regulator will sample that they have implemented all the provisions of the directive for a period of 90 days thereafter.

Quite a slap on the wrist for a Company like RDS that prides itself on its standards, procedures and competence and wasn’t backward in publicly being critical of BP re the Deepwater Horizon, Vosser alluded to the fact that the well would not have been in the condition it was if installed and supervised to Shell standards.

Was it not Mr Jager that said words to the effect that operations on the FLNG would be so routine, so uneventful such that boredom would set in.  Doesn’t look like it to date, but nevertheless wish them well getting over what we could kindly refer to as teething problems.

PS:

Sadly, unless things improve, Prelude it appears has inherited the North Sea chronic disease of loss of containment and for a remote offshore installation that is also a complex hazardous substances plant, a plant that does not in any way shape or form meet the post Soveso requirements that would be applied to an onshore LNG plant, this must be a worry, especially its inability to demonstrate that it is inherently safe both in design and operation as EU directives would require an onshore hazardous substances plant to do, a standard also similar to that applied in Australian onshore LNG plants no doubt.

Bill Campbell

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PSS

John, this is a summary of the webpages obtained by (*XXXXXXXXXX) today from the NOPSEMA site, all I have done is summarise the findings.  I wouldn’t rabbit on about this subject if I didn’t think it was important, perhaps in some small way your pages influence others to see something of the bigger picture, use as you see fit and perhaps the Regulator would appreciate the comments from someone who used to be critical of the ability of the then Regulator during my many visits to Woodside Energy.

BILL CAMPBELL COMMENTS END

COMMENT BY JOHN DONOVAN: I have *redacted the name of a former senior Shell colleague of Mr Campbell with whom Bill has collaborated on most if not all of his published Shell Prelude comments on this website. The comments were originally triggered in response to the allegations of a whistleblower.

Extract from the whistleblower article I published at the time.

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