At the public consultation hearing at Marsaxlokk last month and ever since I have expressed the view that precisely because the project has changed radically from its pre-election two land-based tanks of 30,000 cubic metres (cm) to a floating storage unit (FSU ) of 126,000cm in the middle of Marsaxlokk Bay, Mepa should not even consider the project without first conducting a maritime impact assessment.
How would this FSU in the middle of a high-traffic, geographically restricted navigational waterway seeing around 9,000 vessels a year excluding the fishing fleet, affect the job generation maritime enterprises based at this location?
How would it affect the thousands of manoeuvres carried out by the pilots who, with great skill, pilot vessels through this already congested waterway? How will the additional refuelling tanker of equal proportions adjacent to the FSU affect these activities?
Will the navigational space inside the harbour become too restricted for the larger vessels currently using Freeport? Would the turning circle for these vessels be affected? Will it increase waiting time for such vessels? Would it mean the harbour would at times be effectively closed?
What effect will various sea conditions have on the FSU and on the refuelling tanker and on discharging procedure? Would there be a higher risk of a collision occurring between vessels using the harbour and the FSU or its refuelling ship?
If the chances of such a collision are greater, by how much would the risk increase? In the eventuality of a collision between, say, a container ship and the FSU or the refuelling vessel, what would be the result?
How would this affect the population, the environment, businesses, power station, Freeport, bunkering operations, aquaculture site and the fishing vessels? Would Marsaxlokk port be closed to traffic pending investigations, security and safety checks, and possible wreck removal efforts? If so, for how long?
This is what I meant by a maritime impact assessment. I was told this would be done in due course. No such assessment has been carried out and the application is up for a decision on March 24.
But last week we were told that the Occupational Health and Safety Authority had reviewed a ‘study’ by George Papadakis. The OHSA CEO wrote to Mepa’s CEO saying it “is endorsing the consultation zones as drawn up by Dr Papadakis”.
A summary of the study’s results has now been issued after a public outcry that all that was published was this letter. In fact, the full study has still not been published.
From its heading, even the study appears to be “preliminary”, so one asks when will the full study be available? Surely, it should be available before the Mepa hearing?
One would also assume that the impact assessment has been carried out as part of this preliminary study, and any concerns, as previously explained, eradicated. In fact, although the summary describes a study which appears to have dealt with numerous issues, there is no mention whatsoever of a maritime impact assessment addressing any of the questions I have made.
This is not about politics or being negative
Page 21 of the study describes a number of worst case scenarios and says “the release of LNG to the sea from the tanker after collision of vessel with the tanker and hole opening in the LNG tank bottom and walls and development of LNG pool on the sea surface, LNG evaporation and development and dispersion of gas cloud”.
I thought it had dealt with my main concern. Sadly, it didn’t – quite the opposite. On pages 22 and 24, the summary goes out of its way to underline “that the immediate ignition of releases is a remote probability, assuming that the areas within the boundaries of the… FSU location including loading/unloading, are ignition free”.
And, “the generated natural gas cloud is assumed not to be immediately ignited, since the examined release points and areas within the boundaries of the FSU location are assumed to be ignition free”. Immediate ignition is not considered in the study and possible jet fires at the release source are not examined!
Are they serious? This means the report does not consider what would happen if there is an ignition source close to area where the gas is released. We do not need a report to tell us that the chances of a fire are remote if the ignition source is not next to such an area. We need a report that tells us what would happen if the ignition source is right next to the area. If two vessels collide, the potential ignition source would be precisely in the area where gas has been released, but that has been specifically excluded.
Mepa needs to demand that this report deals precisely with the effect of the release of gas in an area that is not ignition free. Mepa needs to demand a full maritime impact assessment. This is not about politics or being negative. This is about highlighting this hugely cavalier attitude towards safety, security and good maritime practice.
Unfortunately, I have seen this attitude before in a number of maritime casualties, with the end result being extensive damages and profound heartache, but it is often too late then. Who, exactly, will be responsible for the damages that will occur in the eventuality that things go horribly wrong? The applicant, Enemalta, the Cabinet, the owners of the FSU, OHSA?
Interesting times ahead.
Ann Fenech is a maritime lawyer and the president of the executive committee of the Nationalist Party.