"The Government have clearly sent the message to Shell, ‘you can do whatever you want’. Fortunately due to protest, the refinery remains unconnected to the gas field. If, as Shell planned, gas had been flowing by now, we would potentially all be dealing with a gas leak and explosion.”
Letter to The Western People
Wednesday, January 24, 2007 There are many flaws in Corrib gas project SIR - Having (with some success) pursued Shell’s application to the EPA for a pollution (IPPC) license for the past two years, I wish to comment on the above as follows: AIR QUALITY: - The Ballinaboy site is set within a cluster of seven protected areas (SACs), hence the pristine air quality. As there are no air quality surveys available for rural Ireland, Shell justified comparing the pristine air quality in Ballinaboy to three areas in the U.K. - all near major motorways - and one in the most industrialised area in the U.K. The gas turbine alone will emit over 200,000,000 cu. ft. of emissions daily. These engines do not conform to the Gotenburg Protocol for Nox emissions, yet they expect the EPA to violate their own regulations and accept their use. Tank filling alone will emit 12,000 kg of VOC’s annually.
Shell applied for and got planning permission to use condensate as fuel (i.e. unrefined oil from the gas field), even though they had an abundance of free gas. Only belatedly has this changed, due mainly to protesters pointing out that Shell were effectively incinerating the waste oil surreptitiously. Shell repeatedly gave false information regarding the amount of condensate produced i.e. 17 barrels per day) instead of 177 barrels. Likewise emissions to the environment of carbon dioxide were to run at over 1,000 tonnes per week until protesters forced a re-think.
Cold venting of gas (the release of gas into the environment) was not in the EIS presented to Mayo County Council and Bord Pleanala for planning permission - a breach of the EIA directive. Consequently, the HSA could not assess the toxic effects of gas in their report to the planning authority. As this is a SEVESO site (a site where large volumes of dangerous substances are stored) the HSA is responsible for the health and safety of the public.
Shell only revealed their intention to cold vent gas when applying to the EPA for an IPPC licence long after getting planning permission from Mayo County Council. Since an application is assessed on the information contained in the EIS the information received by the EPA was at variance with that in the EIS.
This violated Section 14 of the EPA regulations so the EPA requested Shell to ‘amend’ their EIS. Shell issued an ‘Addendum’ which fundamentally-changed parts of the original EIS, as presented to Mayo County Council for planning permission. Were this allowed, any company could get planning permission based on an incomplete EIS and so by-pass statutory requirements.
Furthermore, Shell state in this ‘Addendum’ that “the decision to cold vent was made on the basis of consultation during the planning application process with the community and planning authority” This is untrue and there are 200 signatures from residents within 5 miles of this proposed refinery to prove it. It is also irrelevant as consultation cannot confer permission.
Any release of gas in this SEVESO site is a fire hazard (as admitted by Shell) and requires planning permission. Between 200,000 and 300,000 kg pa of gas (incl. 7,000 kg each month at the start up of the compressor) will be released into the local environment already charged with up to 300 million cu. Ft. of emissions per day at 500 deg. C. This is an area subject to atmospheric inversion, as vividly demonstrated at the Oral Hearing, so emissions will settle at such times. Contrary to what Shell state, gas flaring will occur routinely. In answer to EPA (Item Ef), it is clearly stated that the maintenance flare will be used every 3 months. The plant will be shut down for annual maintenance and will require 100,000kg of gas to be flared off.
This does not take into account any of the dozens of listed malfunctions which could result in major flaring of gas - including full pipeline de-pressuring which would amount to 3 million kg. of gas.
Annual usage of methanol was put at 1,825 tonnes (IPPC licence application, p.239) This turns out to be untrue as further information revealed annual usage is 3,100 tonnes. Shell claim methanol is recycled and re-injected, implying none is lost. Where then does the annual usage of 3,100 tonnes disappear to? Further information also revealed that “there is no reliable on-line measurement device for direct measurement of methanol in Corrib produced water” and in effect that it accounts for most of the contaminants going out into Broadhaven Bay - dumped at sea through the outfall pipe.
Methanol is a fatal poison if ingested and serious skin contact causes blindness yet it is proposed to store 4,000 tonnes of it at the refinery site. The Inspector of An Bord Pleanala went meticulously through all tie-back operations worldwide, larger, smaller and similar to Corrib - and showed that glycol (which is safer) not methanol was the most common hydrate inhibitor in use.
Broadhaven Bay is a protected EU site. Shell have consistently tried to downgrade it. A desk-top survey in Shell’s EIS, exaggerated trace metals of copper in the bay twentyfold, other metals by between 100% to 700% as highlighted by three Marine Institute surveys carried out in 2004/2005. Furthermore, there is no planning permission for the outfall pipe bringing contaminants from the proposed refinery into this protected bay. It was not included in the planning application to Mayo County Council and Minister Fahey of DCMNR wrongly gave consent ultra vires for this outfall pipe. It is not in any way part of the upstream pipeline but is entirely part of the proposed refinery, as such Shell must obtain planning permission from Mayo County Council and this has not been done.
Finally, Carrowmore Lake, another site under EU protection and funded by the EU, is the regional water supply for the entire region yet it will receive the runoff water from the proposed refinery site. Inspector Des Johnson of An Bord Pleanala warned that it could turn Carramore Lake “into a giant settlement pond from which it might never recover”. Are these the standards we have to accept from giant multi-national corporations in return for the billions of euros worth of our resources which have been signed over to them by our government scot free?
Yours sincerely, Imelda Moran Chapel Street, Belmullet.