Delimara Power Station Renewal & Variation Pubic Consultation Power... · Delimara Power Station Renewal & Variation Pubic Consultation 19 October to 27 November 2016 Ref # Date Received

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Delimara Power Station Renewal & Variation Pubic Consultation

19 October to 27 November 2016

Ref # Date

Received Name,

Surname1

E-mail / Letter / meeting

Date Acknowledged Comment Response

by Response

Marsaxlokk Local Council, Triq il-Port Ruman Residents` Association, Local Councils Association - meeting of 25 October 2016

1 25.10.16 Ing. Arthur Ciantar

Meeting Not Applicable

With reference to the presentation given by Enemalta on generating capacity the following comments were made:

a) It was mentioned that without the interconnector there would be shortfall of 55MW. In actual fact these could be temporary covered by Delimara 2B.

b) Although there is a shortfall this can be covered by the spare capacity.

Enemalta There is enough fuel for the gas turbines to be operated prior to switching on the Marsa Power Station (MPS) in view that it would take time to switch on the gas turbines at MPS.

Further to the reply provided during the meeting, Enemalta have provided the following clarification:

Presently, there is sufficient fuel for the D2A gas turbines to be operated for the time necessary to switch on the Marsa Power Station (MPS) in view that it would take time to switch on the boilers at MPS.

- Enemalta is working towards ensuring compliance with both current and future NECs limits, which would see the switching off of highly inefficient MPS plants and DPS Phase 1 plant operating on HFO

D2B is being considered in the 55MW shortfall. The D2B turbines are highly inefficient and are therefore considered emergency plants only. Although newer than D1, D2B is still considered past its lifetime and has low efficiency.

2 25.10.16 Janice Chetcuti

Meeting Not Applicable

With reference to the presentation given by iAS on the Enemalta IPPC application the following comments were made:

a) Whether with respect to waste management is there a difference from how it was used to be before.

b) What will happen with regards to discharges to seawater?

c) What happens to the oily water?

D3PG

Enemalta

a) iAS indicated that this is an extract of what has been presented and Enemalta noted that overall there will be a reduction in waste generation.

b) Enemalta explained that no wastes are disposed of in the marine environment. The same water which is pumped from Marsaxlokk Bay is disposed of at Hofra z-Zghira.

c) Enemalta indicated that such oily wastes are not disposed of at sea and explained that wherever there is a potential for generation of effluent which can be contaminated, there are the bunds which are kept closed, When these are then drained, they go through a series of interceptors. This is treated up to 5 microsiemens and then the clean water goes to the sea. There are alarms in case the limit is not achieved. Interceptors are designed in such a way that only the water will flow out. Enemlata also indicated that a large amount of waste is collected from the Marsaxlokk and trapped into the screenings.

Further to the reply provided during the meeting, Enemalta have provided the following clarification:

a) Overall, waste generated by ENE operations shall reduce. Waste streams still being generated by ENE, as described in the IPPC application, shall be managed as per current procedures. Enemalta explained that sea water is not disposed of at il-Hofra iz-Zghira, but used in the condensing units then discharged. Discharges to seawater shall be limited by the same composition, temperature and flow requirements currently enforced.

b) Oil water discharges are not disposed of at sea. Wherever there is a potential for generation of effluent, areas are bunded and drained through a series of interceptors. Discharges to sea are treated up to 5 microsiemens. Oily wastes retained in interceptors is collected by licenced waste contractors.

1 Included unless a request for confidentiality has been made.

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3 25.10.16 Ing Arthur Ciantar

Meeting Not Applicable a) Reference was made to the notice to mariners which will be issued by

TM and enquired whether there will be any restrictions to navigations and whether such restrictions will also extend to other boats entering the Marsaxlokk Harbour.

b) Request for a confirmation that access to fisherman is not restricted and that they have uncompromised access.

Electrogas Malta (EGM)

Transport Malta (TM)

a) EGM indicated that restrictions will apply during ship to ship transfers at the Delimara quay and the Has Saptan dolphin. TM indicated that although there is an exclusion zone there is a navigational channel from where other vessels can pass as usual. The notice to mariners will be published on TM’s website and communicated to the fisherman cooperatives. Even while the FSU is at the storm mooring position, a channel of 50-70m for passage of vessel will be retained.

b) This was confirmed by TM.


Meeting Not Applicable While the FSU is at storm mooring will the tanker still be in the harbour. This was questioned in view of recent articles in the media which indicated that the tanker will have to leave the harbour during storms.

EGM

EGM indicated that in the event of a one in 100 year storm, the FSU can still be kept in the harbour. If a greater storm is forecasted EGM shall be taking a conservative approach and FSU will be taken out of the harbour. However, the storm mooring is designed on the basis of very extreme weather conditions. Further to the reply provided during the meeting, EGM have clarified the following: EGM assumes that the tanker in question is the delivery LNG carrier vessel which shall bring LNG to the FSU to be filled. The LNGC / tanker will not be in the harbour when the FSU is at the storm mooring.


Meeting Not Applicable a) Reference was made to the nautical risk assessment report which takes into account grounding of the LNG carrier and questioned what scenarios are considered for this to happen.

b) Can grounding take place at the jetty? What is the required depth of the fairway?

c) What effect will the chains lying on the fairway (which will be tensioned to pull out the vessel out of the jetty) have on the fairway? what happens when they are under tension in view that they are on outside of vessel?

BUMI

EGM

a) Such grounding was considered in terms of the vessel movements in and out of the port.

b) Groundings cannot take place at the jetty. Regarding the depth of the fairway and the draft of the vessel the depth of water 17m and the draft is 11.4m.

c) The chains lined at the bottom of the seabed are not obstructing the fairway and are always connected by being kept slack. When these are under tension these will come up between the vessel and the sea and the LNG carrier cannot berth beside it. However it is important to note that when such tensioning will only happen when the vessel at the storm mooring and therefore no ship no ship transfers will be carried out at the time.


Meeting Not Applicable With reference to the presentation by EGM on the Safety Studies, the following questions were made:

a) Vaccari did not exclude the potential for ignition, was this included in the report? These translate into a possible number of fatalities if the incident occur.

b) Although the studies are trying to measure the possibility of something occurring, in reality, we need see what is the reality and practicality of this. Despite that safety measures are implemented in design, accidents still occur. This is possibly a point of disagreement with the operator. If operators are willing to work in such an environment not everyone is willing to live in this environment and not all residents are comfortable with this situation. This appeared in the social impact assessment (SIA) carried out as part of this project. This SIA indicated that 91% of Marsaxlokk respondents and 86% of Birzebbuga residents would have liked the vessel to be retained outside port. The situation is that we have

EGM

Dr George Papadakis

a) This was not excluded in the studies as will be shown later on. The risk contours and fatalities associated with each one depict these fatalities.

Further to the reply provided during the meeting, EGM have clarified that: The potential for ignition has been included in the EGM Safety Report dated Oct. 2016. The Consequence Analysis has addressed the maximum extents for cloud dispersion, flash fire, explosion and jet/pool fire scenarios. In the Risk Assessment, the frequency of these scenarios included the probability of ignition, and the severity depends on the possible number of fatalities. The probabilities range from less than one in one hundred thousand years to one in one million years.

b) A huge conversion has been carried out on the FSU and there has been thorough inspection which will enable certification by Bureau Veritas (BV). If this conversion was not carried out as required, then BV would not have signed to it. Concerns raised by Ing Ciantar are acknowledged.

c) These scenarios are from the FSU in case of major release that was considered such as full bore rupture between ship to ship transfer and major leaks on the FSU tanks. Although these have a very low probability they

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a 30 year old vessel in port.

c) One of the safety reports shows a number of worst case conditions falling under the e5 risk contour. What can one say about these? Although these are not probable their effect is catastrophic and an indication of what these scenarios are is to be provided.

d) Was there consideration for placing the LNG tanker outside the harbour. The frequency is 1 in 1million but for people it is a constant reminder. What would have been the difference if the tanker was placed outside the harbour? Regarding the social impact assessment carried out as part of the 2013 EIA consultation: How would the operator compare the consequences of the tanker in port and the tanker outside the port? If the tanker was outside port the local risk would be significantly less? The local population have a say as to where this should be located. This is undeniable. The residents of both Marsaxlokk and Birzebbuga have an undeniable right to state their intentions and make them noted in the decision making process which should take into account the interest of the population. Unfortunately although several representations (Birzebbuga local Council, AC and Perit Cacopardo) were made on this point, it seems that these were not taken note of. Now we are at the IPPC stage and what does this change? This was stated independently in an EIS in the social impact assessment. How come we have to go through the process of going through a serious of lectures trying to convince us of this study and queried what value has this study been given.

e) This is where we are not agreeing and I am waiting for a consultation process not an information process.

ERA

have been considered nonetheless.

There are actually 5 such scenarios and the others are related to flash fire. There was an extra study called the ALARP assessment study during which the companies have identified further safeguards to decrease the risks and found that they are on the lower acceptable limit and can be regarded as broadly acceptable. Further to the reply provided during the meeting, EGM clarified the following: There are actually 7 such scenarios, related to flash fire (combustion of vapour/gas cloud in open air) and large pool fire (direct ignition of LNG pool on water). An additional study, called the ALARP assessment, has been carried out with the FSU operator in order to re-examine the existing safeguards and identify any necessary additional safeguards to decrease the risks as much as possible. It was concluded that even in the case of a safeguard failure, the risks remain in the E5 level.

d) The process required under the legal requirement is being carried out. What is being claimed was raised by residents in 2013. The decision for it to be in the port has been taken and this decision is not related to this issue. This does not mean that under Aarhus and IPPC we are not following the required procedures. ERA shall be taking note of what is being said now and if required a separate meeting can be held to discuss such concerns further. The intention is for the information to be presented. This consultation is part of the process and what is required by law is being carried. The Social Impact Assessment was under consideration in a separate process for which a decision has already been taken.

e) The consultation process started now. The consultation starts before a decision takes place. The consultation being carried out at this point is being carried out before the operation whilst the decision for the design was carried out and there was a separate consultation process.


Meeting Not Applicable a) As a resident forming part of those 91%, if out opinion was requested why wasn’t it not answered and considered. Why was the study requested if it was not considered?

b) If this risk remains the same in terms of frequency, the consequences will be different if the FSU is outside harbour. My role is to explain this to the public and this answer has to be given to other residents.

c) The question at that time was twofold: first whether the storage would be on land or the FSU and then whether it was in harbour or outside

ERA

Enemalta

a) The authority is not here to evaluate the proposal and this has already been done. The public consultation process being referred to goes beyond the process currently being evaluated. The plant being proposed is ready in terms of development permits and is now being looked at in terms of the operation.

Further to the reply provided during the meeting, the following was clarified by the EIA coordinator: The reference to the ‘91% of all the respondents …’ refers to an inaccurate reading of the EIS and the SIA. This point was made clearly during the MEPA Board meeting which determined the original development applications.

b) The process being undertaken at the moment is for considering the operational aspect is safe. This study was taken into consideration. If such questions are raised, and there is a concern about safety we need to be assured that what is proposed is safe for residents but not our role to consider if FSU is outside port or not. The SIA was carried out as part of the EIA in 2013 which triggered other risk studies. Therefore Enemalta continued with the proposal for FSU to be in port and is now examining what are the associated risks and how they can be mitigated.

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Dr George Papadakis

At that time the Risk Assessment was not carried out in full. Further to the reply provided during the meeting, the following was clarified by the Enemalta with regards to point b) above: It is to be noted that the frequencies and consequences being referenced from the EIA risk assessment have been updated in the IPPC Application to reflect the details of the final design

c) Why should people be worried if the worst case scenarios show that the residents will not be effected.

8 25.10.16 Horace Gauci

Meeting Not Applicable There is a government commitment for the plant to be done and this was confirmed in 2013 and 2014.

ERA

Discussions should not be reduced to a political level. The scope of these meetings is to get feedback on how the operators are proposing the best solutions for their operations. If there are comments which you would like to put forward these can be sent to ERA. Even in a separate meeting ERA can do that.

9 25.10.16 Local Council

Meeting Not Applicable If this meeting was held before much of the worries would not have been raised.

EGM

Dr George Papadakis

It is important that this is seen now. We are explaining what the waste case scenarios are. All the concerns and results of the opinion of the people are taken into consideration and companies have put in the safest possible installation and authorities assessed the results and concluded that there is no risk to the people.

10 25.10.16 Ing. Arthur Ciantar

Meeting Not Applicable With reference to the presentation by AIS (on behalf of Delimara 3 Power Generation Ltd) the following questions was made:

a) the emissions after abatement on HFO and when using diesel as fuel the emissions are higher.

b) clarification on the status of conversion of the diesel engines in view that only four engines have been converted up to now.

c) the last presentation shows what everyday people are affected about – less emissions.

D3PG Ltd.

ERA

Enemalta

a) The abatement technology for the Particulate Matter will be removed. The diesel will only be used as emergency and the expected limits are still within the acceptable levels.

These emissions will be in line with the limits in the IPPC permit

b) This conversion and phasing forms part Enemalta’s generation plan. Due to security of supply the conversion is being done in two stages. The first four engines have being converted to operate on dual fuel (LNG and Diesel Oil). Once the necessary security of supply is established the remaining four engines will be converted to operate solely on NG.

c) These emissions will be in line with the limits in the IPPC permit.


Meeting Not Applicable a) Will there be any presentations from CPD on the External Emergency Plan. The report, although not long has a good coverage but have some questions on specific areas. Chain of information in case of accident is long. Dispersion rate depends on wind etc. process involves contacting a lot of people. Sirens are not reported here.

b) Regarding the evacuation of residents which is mentioned in the report, access to Marsaxlokk is restricted. Is possible to evacuate people in the required time?

CPD

EGM

CPD

a) The report presented cannot show the full operations in view of security issues. It makes reference to the information to the public document. An external consultant was engaged to produce these document .. All information is in case that an emergency escalates.

The emergency instructions to the public, are the same as they are for the current operational structure with Enemalta.

b) A fire station will be placed at Delimara in addition to Hal Far and Kordin stations.

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Birzebbuga Local Council, Birzebbuga Environment Action Group - meeting of 27 October 2016

12 27.10.16 Herman Schiavone

Meeting Not Applicable a) How will the interconnector be operated in view of the new generation plan?

b) What happened when in two problems occurred in the interconnector and what is the probability of this happening.

ENE a) Operating the OCGT is expensive due to the cost of gas oil and low generating efficiency of the plant in question. Should problems arise with the interconnector it might take time to bring back in service. With the submarine interconnector there are several potential malfunctions which might arise, that may require a substantial time for the necessary remedial works to be carried out; e.g. there are only two ships which can retrieve the cable from underwater to be able to fix it. Therefore, it could take months to resolve some issues which can occur. Some small issues can be resolved quicker’’ however a more appropriate response has been provided. b) These problems were not related to major incidents but related to protection trip and shutdown following prevention. Although Enemalta built a good interconnector and it is very unlikely to have problems, but if these occur it could take more than days to be rectified. Regarding the capacity of the interconnector, there would now be other sources which can be put into operation. Further to the replies provided during the meeting, Enemalta provided the following clarifications to each of the replies above: The Interconnector will form part of Enemalta’s new energy mix, consisting of low-emission, high-efficiency sources, which are combined to meet the ever changing electricity demand. The mix is optimized on a daily basis by a specialized team of engineers using custom-made innovative software, to ensure that Enemalta obtains the most sustainable mix on a daily basis.

The problems being referenced in question(b) were not related to major incidents but related to protection trip and preventive switching off. Although the interconnector has been constructed to the necessary specifications, factoring all foreseeable risks, incidents may occur which could take more than a few days to rectify. Following the completion of D4’s commissioning, any lost capacity due to unavailability of the interconnector may be replaced by other sources which can be put into operation.

13 27.10.16 Carmel Cacopardo

Meeting Not Applicable While this is interesting and very useful the most worrying aspect is the safety issue and the limited time should focus on this. Through a large number of meetings we are aware of a large number of information even at development stage. The information is still missing and the major worry is related to safety issues and we are not convinced that there is enough action in place regarding this issue. It would be useful to make good use of the time available to focus on this issue. Any other plans would be a waste of time. How do you tend to be in line with the requirements of the Seveso III directive?

ERA The aim of public meeting is how to go through the application. The intention was to have a presentation from each operator. Everyone present must agree on this suggestion if we should focus solely on the issues of safety of each operation through the presentation. ERA would then be criticised that not all the information is presented. Each operator can be given time to give his presentation and focus in detail on safety. Safety nautical and risk assessment are all presented in the coming presentation. Following consultation with all attendees it was decided that the process of going through each presentation shall follow.

14 27.10.16 John Grech

Meeting Not Applicable a) The public is lead to believe that the MPS is to be decommissioning completely. Is that correct? What about the decommissioning of Delimara 1 and 2?

b) Does the generation data include the use of renewable?

c) Considering the annual increase in electrical demand, how long will it last before we need another power station.

Enemalta

a) The MPS will be decommissioned once project is operation. Part of MPS is on cold standby once there is the N-1 facility. Once the new system is in place there will be an application for surrender of Delimara 1. Decommissioning of MPS is being done in 5 stages. Part is on cold stand by and will be fully decommissioned before new power station is in operation. The decommissioning of Delimara 1 will be part of another variation once the new system is in place. Delimara 2 will be kept as an emergency supply. part of the development permit for this application enforces that once D4 is operational Enemalta is to start dismantling of DPS1 and the MPS. Pulling down of D1 will then start. Tender evaluation is currently being carried out and the demolition is expected in the first half of 2017.

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ERA

Enemalta

Further to the response given during the meeting Enemalta provided the following update:

Decommissioning of MPS currently being undertaken and shall be completed in 5 stages. Remaining parts shall be decommissioned subject to the operation of the EGM plant. MPS would be in a position to be fully decommissioned only once the gas project is fully operational. Part of MPS is on cold standby which will remain so until the new plant is commissioned and Enemalta has an N-1 generation capability. Once the new EGM plant is operational, Enemalta will submit an application for surrender of Delimara 1. The decommissioning of Delimara 1 will be part of another variation of the DPS IPPC permit once the EGM plant is operational. Delimara 2 will be kept as an emergency generation source. Part of the development permit for this application enforces that once D4 is operational Enemalta is to start dismantling of DPS1 and finish dismantling MPS. The MPS has an IPPC permit for partial surrender. Enemalta will have to apply for full surrender to dismantle the rest of the plant. Regarding DPS once this permit is granted Enemalta will apply for another partial surrender for dismantle DPS 1. DPS 2A and 2B will be kept as an emergency back-up.

b) The generation presented is all from the Delimara plant. The energy from renewable energy is not considered in this presentation. About 45MW were generated in August. What is presented is the generation from the Delimara plant. The projection is that there is always an increase in renewables. The problem with renewables is when there is cloud cover. Further to the response given during the meeting Enemalta provided the following update: The generation presented is all from the Delimara plant. When calculating peak demand the energy from renewable energy is was considered. About 45MW from renewables were generated in August. The projection is that there is always an increase in renewable, however these cannot be considered as base load their generating capacity is dependent on weather conditions, in particular the unpredictability of cloud cover

c) The percentage increase is projected at 4-5% per year so it will have to be evaluated but not in the foreseeable future to have another plant.


Meeting Not Applicable Regarding the presentation given by iAS on the Enemalta IPPC application, the following question was raised: In view that there are a number of common services, what provisions are there to ensure that one accident with one operator does not spill over to the other operator

Enemalta An individual safety report was carried out highlighting different scenarios, the domino effects were considered and then based on the likelihood of the incident arising and any effect on adjacent operations was considered. Final contours assess the effects of all operators. In emergency response plan the operator considered there operations and depending on the situation there are procedures of communication as escalation will taken place as required. Further to the response given during the meeting Enemalta provided the following update: Individual safety studies were carried out by each operator, namely the Safety Report (SR), Safety Management System (SMS) and Internal Emergency Response Plan (ERP). These documents were reviewed by all operators to define potential domino effects with respect to risk as well as common systems and procedures

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which would require coordination. To assess potential effects of the multiple operators a Coordinated SR was carried out. In order to document any systems and procedure requiring action to be taken by more than one operator a Coordinated SMS was prepared. To ensure coordination between internal Emergency Response Plans a coordinated ERP was prepared.


Meeting Not Applicable How is one expected to prepare for this meeting if we have all these documents to analyse in such a short time and how would I know at which appendix to look at.

Enemalta

ERA

The sections which are most important are highlighted in the presentation. The documents have been divided into sections to allow the reader to focus on areas of particular interest. It is also to be noted that the IPPC process in an onerous process and the size of documents presented reflect the requirements of such an application.

The scope of the meeting is to guide the local councils. This presentation is aimed towards guiding the public to the presentation. The way the documents are structured on ERAs website guide the public towards the documents.

17 27.10.16 Daniel Grech

Meeting Not Applicable Will the continuous air monitoring be available for stakeholders involved in real-time and is there an objection for this data to be available.

EGM

ERA

This data will be available in real time.

The real time monitoring is already a requirement in the current permit and this will be retained.

18 27.10.16 Edwin Ebejer

Meeting Not Applicable What will happen if the cooling system fails and the pressure increases drastically.

EGM There are no coolers and the gas is actually liquefied by cooling it. Liquid is continuously boiling off so the liquid is always cold. It is cold by its same nature. The pressure goes up but the gas is taken away by transferring it to shore. The LNG remains cold and the system is making use of the natural properties of the gas.

19 27.10.16 BEAG Meeting Not Applicable Will there be the introduction of an odorising agents in the system. Will there be detectors at Birzebbuga and Marsaxlokk? Is there any objection in the introduction of such smelling agents.

EGM

Gas detectors will be present on site which can detect even very small quantities of gas and are activated accordingly. There will be no gas reaching the residents which would have not already caused the system to shut down. Gas detection systems are present to detect even small quantities of flammable gases. There will be alarms and trips of the plant in case many alarms are triggered. This is not required for LNG as opposed to LPG. An odourising agent will not be added.


Meeting Not Applicable How high would a bleve be? EGM

The effect of this has never been seen with LNG and the gas will raise and disperse. All these questions form part of the Safety presentation. Further to the reply given during the meeting, EGM have provided the following feedback: A BLEVE (boiling-liquid expanding-vapor explosion) occurs when a tank containing liquefied gas ruptures, resulting in the instantaneous release of the vapor, boiling liquid, and blast wave. The most common type of the BLEVE is caused when the external wall of the tank is exposed to a fire. The continuous heat transfer from the fire to the tank wall increases the temperature and pressure inside the tank, until the tank fails. This sudden failure of the tank results in an explosive vaporization of its contents. LNG is stored at -160°C and close to atmospheric pressure. The FSU tanks are not pressure equipment. In the very unlikely event of an engulfed fire, the tank would rupture without any boiling liquid. Actually, this would lead to a LNG spillage into the sea, as studied in the Safety Report. Conditions for the BLEVE occurrence are detailed in the Safety Report/Consequence Analysis and were presented by Dr Papadakis during the public hearing. LNG should not be confused with LPG (composed of propane and butane stored

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under pressure). LPG tanks present a potential for BLEVE.


Meeting Not Applicable Regarding the presentation given by EGM on the Safety Presentation, the following question was raised:

a) Is LNG is corrosive?

b) Is there any danger on low flying aircrIaft in the case of release of gas and is the use of aircraft for visuals considered? Has the airport has been made aware of this?

EGM

EGM

Enemalta

TM

a) This is not toxic and not corrosive.

b) The study looked at aircraft routes. There is restriction and they will be reminded not to fly over the plant. Enemalta have contacts from TM to enforce if someone is seen flying with a low flying aircraft. Enemalta are working hand in hand with TM to ensure that no fly zones over critical infrastructure such as the DPS is enforced. In the coming days TM shall issue a notice along these lines.

Presently there is already a restriction that it is not legally permitted to fly over power stations and that this is already in place. On the sea side, TM will be imposing an exclusion zone and restriction. There will be a minimum distance prohibiting movement close to the vessel during ship to ship transfers (sts) will be applied. There will be a notice to mariners which will be issued defining the navigational channel through which other vessels can pass through. It will be ensured that there is a channel from passage to the port but there will be a restriction through which vessels (whether recreational or not) cannot go close to during such operations. It is not that something will happen if one goes close to the vessel but safety measures are being introduced together with standard practices for this type of operation. What TM is also deciding as the port authority for the comfort of everyone is discussions with Enemed and Enemalta, the former being responsible for the importation of all fuels and Enemalta may be required to import fuel oil/gas oil in the existing plants. These need to collaborate since other tankers have to wait so two simultaneous operations will not be allowed. It is important to have international practices in view that this is one of the largest ports in the Mediterranean with several operators and so these should be maintained. This is in the interest of public as additional precautions.


Meeting Not applicable a) Is there any other port which sends LNG continuously to shore and exposed to the elements like this one? The main concern locally is the protection from the elements and that the port presented is an all weather port and not exposed to the elements. It would have been safer if it was out of the harbour.

b) What is the situation with regards to the fireworks and will they be allowed to let off.

c) in the reports there could be a situation where residents would have to be evacuated. Which scenarios are these? how will the residents know that they need to evacuate?

EGM

ERA

EGM

a) The La Spezia and Lithuania cases are presented. There are about 23 FSRU/FSU in the world. In many situations they are more difficult cases of a regas plant on board. The situation in Lithuania is that the regas is on board the vessel. In the Marasxlokk port, if the prevailing winds are from the south then the vessel has a system whereby it will move onto the storm-mooring system. What is being shown is the worst case scenarios.

There are specific presentations on how and when the storm-mooring works.

b) A reply from the Authorities on the issue shall be forthcoming.

c) The work of the individual operators is highlighted in the internal emergency plan and these will feed into the external emergency plan.

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CPD

ERA

CPD

From reports seen and analysed by the operators’ experts and CPDs experts it seems that there will never be situations where the residents need to be evacuated. However in view of a precautionary principle which must always be adopted the information was included for the residents to be aware and these are included in the manual. The Information to the Public document (which was presented to the attendees) will be distributed to the residents and simple instructions are included. These are very simple instructions which must be followed. With respect to the External Emergency Plan, the document is made up of two parts: Part 1 which include the general information and part 2 of the report is the restricted information as to how the CPD will act in case of emergencies and which cannot be shared with everyone as it might jeopardise the operations of the CPD.


Meeting Not applicable What is the scope of having a public consultation with something which is not available to the public? This is a public consultation exercise and in respect of the Civil protection document we are expected to be involved in this exercise when half of the document is blanked out. This is a farse. Although I read the document the explanation provided is not acceptable

CPD This part is a very technical procedure which details how CPD tackle fires, and include internal procedures of the CPD as to how they fit in with the operators. Such internal plans have not even been published in view that such information can be used for sabotage. The general public is being given complex fire fighting procedures and the Public Emergency Plan gives clear and simple instructions. The plant has all the infrastructural and safety internal procedures for the operators to tackle an emergency on their own. However, if this fails, the CPD will step in aiding or taking over depending on what the situation is. If the CPD takes over, the EEP starts to function. If evacuation is required this will happen at a very late stage and only if control of the situation may be lost. However, the safety reports show that the gas cloud does not reach Marsaxlokk. Confusion is being made between LPG and LNG and while LPG is compressed, LNG is different and is kept cold in order to be transported. The FSU is insulated and is continuously being kept cold through the release of the boil off gas. LNG is kept below -161oC. Once it absorbs heat energy it starts to evaporate. Contrary to LPG which if released will go down and is ignited with an ignition source e.g. a lighter, LNG upon exposure to the atmosphere will vaporise. CPD have been trained on firefighting procedures for LNG and have been purposely exposed to LNG and were not harmed in view that it is non-toxic. As part of the exercise, CPD was even trained on extinguishing large pools of LNG fires. This is being explained in view that they are well trained to deal with such situations. If there is a fire or there is a leak, Marsaxlokk and Birzebbuga will not be affected. However, as a precaution, evacuation procedures are being included and these are being made as simple as possible. CPD is willing to answer any questions made in this regard. Half of the document is an operational procedure and such information cannot be disclosed. Knowledge of this information can be used against the CPD and against the public. If for example, there is a particular collection point, anyone can prepare something to block CPD from doing their duty.


Meeting Not applicable Will personnel from CPD be located close to the area? CPD There are three fire stations which will response to any emergency, two located in Hal Far and one in Kordin. However, in view that this is critical infrastructure another fire station will be located outside the Delimara gate. In the case of an accident the CPD will not be act immediately but will be in communication with the operators and evaluate the accident and its intervention accordingly.

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Meeting Not applicable a) The major concern for the public is a terroristic attack and the gas tanker is a target in any terrorist fight, so what happens if there is a shooting aimed at it.

b) What would happen in that situation: an explosion, a gas leak?

c) If things are so safe wouldn’t this information be more alarming to the public.

CPD

EGM

TM

EGM

Enemalta

a) This is specifically why half of the operational part of the document was not published.

You need a very big missile and airplane to reach in the tanks in view that the tanks are very strongly built and this is not easy. Further to the reply provided for during the meeting, EGM have clarified the following: In the Safety Report/Hazard Identification, a terrorist attack was considered as an external cause which could lead to a large leak in the FSU tanks. This is the scenario presented in the safety presentation leading to a large pool of LNG. Therefore, EGM have reviewed this scenario and the worst consequences arising there from.

To put things in the right perspective if someone had such bad intentions it would be on a much smaller vessel discharging aviation fuel in this port, so the risk has to be comparative. If there was someone with malicious intent to cause this there are much worse and smaller vessels to target.

b) In that situation the scenario related to the pool fire would be applicable. There is CCTV and security to avoid this.

There have never been an accident in which the outer hulls have been penetrated in view that it is very strongly built and this scenario is extremely unlikely.

The previous Information-to-the-Public document has been updated to reflect the proposed changes at the DPS site due to the new plant and its fuel sources. Whilst the principle content of the document has been retained, people are being re-informed and reminded of its content. The previous document had been circulated to the public and is now being redistributed as a refresher and for new residents/commercial activities which were not provided this document before.


Meeting Not applicable With reference to the presentation on the Nautical Risk Assessment: a) The talk was based on forecasted internet conditions. There were freak

storms during which vessel at Freeport were vessels were almost completely disloged.

b) How would this affect the operation of the powerstation?

EGM

EGM

a) They looked at worst case scenarios and there are emergency releases and decoupling from jetty so if the FSU goes out there are PERCs. The hoses will disconnect by themselves and its an automatic system and release. If this happens there will be no spill and the vessel can be moved out to a safe position.

b) When the FSU leaves from jetty there will be a shutdown of D4 and Enemalta will move onto their alternative generation. The operation of the FSU is going to be based on conservative weather forecasting estimates and decision will be taken early on predictions. They will not wait for the 2m wave prior to disconnection. There is a specific communication procedure on how the disconnection procedure is to be carried out.


Meeting Not applicable Is there the possibility that a reservoir on land will be built?

EGM

There are no plans for this but the process for Enemalta to look at the energy mix and they have done this. In any power station there is any amount of downtime. In the first presentation and the N-1 scenario explains that even if the largest source

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Enemalta is not available distribution of the necessary power will still be taking place. There are many situations under which such requirements may arise e.g. maintenance. Therefore it is important to have the N-1 availability to deal with such maintenance or malfunctions. Further to the response given during the meeting, Enemalta have provided the following clarification: There will be sufficient generating capacity not to necessitate the construction of land based gas storage.


Meeting Not applicable a) What about the fireworks issue? Based on this reply, can the fireworks enthusiasts still let off fireworks? Who will answer such questions?

b) There is a fireworks factory in Delimara and also Birzebbuga and Marsaxlokk enthusiasts are in the vicinity and therefore can they let off fireworks from where they are now. That is the question.

c) The question is as to whether they can be allowed to let off fireworks from their current place.

d) As far as ERA is concerned will there be any instructions given to the police not to issue the permits?

e) What will be ERA’s recommendation to the Police? f) A reply was not being given in the meeting and cannot give a reply to

fireworks enthusiasts.

g) As of today no guarantee can be given to people as to whether fireworks can be let off.

EGM

Dr George Papadakis

ERA

Dr George Papadakis

OHSA

a) There is no significant risk. It is not up to the operator to provide such a reply.

b) The fireworks factory is not an ignition point but you must have an ignition source in such a place. When you have the fireworks you have ignition in the other areas which could act like an ignition point.

c) The authority issuing permits for letting off of fireworks is the police so ERA cannot reply on their behalf. However, the police will be consulting with the necessary Authorities on this and if required no permit will be issued for letting off fireworks from that point. Although the risk assessments did not highlight a problem with regards to the risk of fireworks, this does not mean that the Authority responsible for this permit cannot adopt additional measures..

d) ERA is not the competent authority and cannot speak on their behalf but can give a recommendation to the police and this will be done.

e) When there is a request for letting of fireworks, the Authorities will be making a recommendation in this regard.

f) A response will be given later and replies will be published even during the public hearing.

g) If the present Authorities had the authority to give such a reply they would, but it is not the case and such a reply cannot be given. Queries are being noted and a reply will be given.

In the past it seems that such issues were not raised despite having a gasoline and LPG site close by and other operations. Further to the replies given during the meeting, OHSA has provided the following update: According to the analyses carried out by COMAH CA’s consultant, fireworks can still be let off from the same area which is normally authorized for such purpose by the police authorities. According to the Explosives ordinance and subsidiary legislation, it is the Commissioner of Police who issues authorizations to let off fireworks, subject to any

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conditions that the Commissioner deems fit. In fact the Commissioner is not legally obliged to consults any other legal entity; any authorizations or withholding thereof are issued under the Commissioner’s sole responsibility. In a meeting held between the OHSA and the Commissioner of Police, OHSA on behalf of the COMAH CA, offered to give its recommendations should the Commissioner consider it necessary to seek advice.


Meeting

Not applicable a) The issue here is whether the IPPC permit should address the area within which fireworks cannot be carried out.

ERA The IPPC permit is issued on the operations of the plant and does not look at issues outside the installation. The comment is being taken note of and shall be discussed with the concerned Authorities.

30 27.10.16 BBuga Local Council

Meeting Not applicable In the case of the fireworks the issue is simply a relocation of the point from where these are let off, which can be moved to another area. In the area within Birzebbuga from where fireworks are let off, there are Has Saptan, 31st March installation and Oil Tanking close by so why is the issue being raised on this specific case and thus making a political issue out of it? Once again such activities can be moved and that this is a national project. In the case of Birzebbuga the issue was not raised. One shouldn’t make statements where it is indicated that because of this project, fireworks cannot be let off. Why do navigational issues fall under the competence of TM whilst in the case of other activities the decision is being left up to the decision of another Authority?

ERA This point applies to all other developments as indicated with reference to the sea uses. This does not only apply when dealing with fireworks, however, any type of land use has to go through a process of determining whether such activities are compatible. Therefore any land use which will fall in the area has to go through such a process in accordance with the relevant Authorities. There are other Authorities which we have a remit on land uses and which fall under the COMAH competent authorities. Therefore when it comes to the land uses there is a procedure as to which activities can be carried out so this will be sorted prior to the issue of the permit.

31 27.10.16 BEAG Meeting Not applicable It is being felt that a number of excuses are being made. In the same way that there is a navigational safety zone, the same should be applied for fireworks ERA A clear answer was given. The fireworks issues will be discussed between the

Authorities Subsequently to the risk assessment and the zones presented in these studies may be updated as deemed necessary by the relevant authorities.


Meeting Not applicable What is the method of construction of the jetty e.g. hollow pipes? How come they are not filled with concrete to make it more sturdy? Will they take the weight of the FSU?

EGM The jetty consists of hollow pipes which are driven into the bedrock. These are designed and constructed of materials with sufficient strength and thickness to make the piles and jetty stable. and confirmed that this will take the weight of the jetty. Further to the reply provided during the meeting, EGM clarified the following: . Please note that Bureau Veritas, as a third party certifier, have carried out a structural design appraisal of the jetty and associated mooring and breasting dolphins and have issued the corresponding certification.

33 27.10.16 BEAG Meeting Not applicable With reference to the presentation made by AIS on the D3PG presentation the following questions were raised:

a) Regarding the seawater contamination, at the moment the EIA reported that there is heavy pollution of heavy metals in the Marsaxlokk harbour. What is/has been done to assess the present situation and ensure that this contamination won’t be augmented in the future?

b) Regarding rainwater and oilywater, how will it be ensured that this doesn’t end up at sea?

c) Are the interceptors for heavy metals or only for oil? Is there any preventive action can be taken in the IPPC?

d) The Hofra z-Zghira is biologically dead. This was reported in the EIA. What is being done to restore biological life in the Hofra z-Zghira. Earlier

Enemalta

a) At the Marsaxlokk power plant does not release any waters so the power plant takes seawater from Marsaxlokk and discharges at Hofra z-Zghira so what is carried out is periodic monitoring of Il-Hofra z-Zghira and the inlet to be able to see what the impact of the operations on this area is in view that there is no impact on Marsaxlokk. When the seawater goes in the condensers it is filtered and every week 3 skips of plastic and garbage is collected.

Discharges to Hofra z-Zghira are periodically monitored as requested by the current IPPC permit.These results are compared to the inlet results at Marsaxlokk Harbour to assess the impact of DPS’s operations is on this area. One should note that prior to the seawater entering the condensers, sea water is filtered and every week 3 skips of plastic and waste is collected. With regards to heavy metals in the Marsaxlokk harbour, these are not attributed to the DPS. It is important to keep in mind that Marsaxlokk is an operating port.

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considerations from stakeholder where not considered in view that it was previously requested that the pipe is extended out from the Hofra z-Zghira in order to reduce the concentration. In the monitoring of the Hofra z-Zghira it is not explained why this area is biologically dead.

e) What will happen if the limits are not adhered to as shown in some studies?

f) Are these considered as part of the IPPC?

ERA

D3PG Ltd.

ERA

D3PG Ltd

EIA coordinator

b) Rainwater goes in interceptors and all water discharged to sea goes in a

series of interceptors which have alarms.

Potentially contaminated rainwater is passed through oily-water interceptors to ensure the removal potential contaminants before it goes out into the sea.

c) Emission Limit Values set out in the IPPC permit are extracted from EU

legislation for discharge to the marine environment. Therefore all discharges from the power station into Marsaxlokk are mostly related to treated rainwater or bund water which would have passed through the necessary treatment to allow the discharge into the port. The studies which were being referred to earlier in the discussion as part of EIA are studies carried out to asses the status of the water at the moment but Enemalta have no contribution when it comes to heavy metals towards Marsaxlokk bay. There are monitoring requirements which will look at this contribution and if levels are exceeded corrective actions need to be taken by the operator.

d) AIS carried out such studies as part of the current permit. Under the permit Enemalta are required to carry out chemical and biological studies at Hofra Z-Zghira which required Enemalta to engage a consultant to carry out a scientific diving survey to asses whether over the period of one year there were any changes. This is the fifth year that the survey is being carried out. A comparison with previous years is to be carried out. As part of the EIA covering the BWSC plant habitat mapping was also carried out at Hofra z-Zghira and a thermal dispersion modelling exercise was carried out in view of the protected species Pocedonia oceanica. Thus this exercise is to be carried out every year to map the seabed and determine whether conditions have remained the same by ensuring that the temperature of the effluent is within the temperature range stipulated in the IPPC permit and to ensure that the habitat is not being degraded or displaced in view of the emitted effluent. These surveys are available. As part of the obligations of the permit there is an Annual Environment Report to ensure that the data is reported and that the levels indicated in the permit are being monitored and within the required limits.

e) This is not the case and the current study is being evaluated and there are other species which are to be monitored in the upcoming study. Should there be signs of habitat degredation, then additional measures by the Authority regarding the operations of the outflow will be required.

f) These studies are part of the current IPPC and the application will be varied but these studies will be reflected in the upcoming permit. The temperature difference is the reason why the marine habitat doesn’t degrade. If the monitoring and the temperature difference were not carried out as required, the condition of the sea would have shown impacts, which is not the case.

Further to the responses provided in the meeting, the EIA coordinator clarified the following:

The 2013 EIA, the 2016 Addendum, and the 2016 Public Hearing presentation discuss the manners in which different types of waste waters disposal and/or

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treatment would be carried out. All waters discharged to the sea would be treated, and bilge water and boiler blow-out waters would be collected for treatment by licensed waste collectors.


Meeting Not applicable Are there any timeframes as to when the power station will be operational? ERA ERA is following the required legal procedure under IPPC in which there is public consultation and then there is time for taking on board comments from the public to determine whether these will be reflected in the permit or replied to. Following this, the conditions of the permit will be discussed and the permit will be presented for a decision. After the public consultation there are no specific timeframes. The IPPC regulations specify that the consultation period should be that of 30 days which has now been extended to 40 days.


Meeting Not applicable The 40 days public consultation are not enough in related to the volume of information which has been presented, not even 4 months would be enough. The meetings are focused on where the Authority deems fit to focus. Given that there are 270 pdfs it is impossible to read through all of them. This is not being carried out appropriately in view that the timeframe must be relative to the amount of information being presented which is not the case. Moreover especially when the information has been available at the Authority for a number of months and this was not issued for public consultation beforehand. The issue of the public consultation should have been organic in view that the information should have been issued once this was available. The consequence of not doing this is that it cannot be carried out well. The period of public consultation does not correspond to the amount of information available. CPD went beyond this and did not disclose information to give less material to the public

ERA The scope of these specific discussions is to offer help on how to navigate through the documentation. The aim of these meetings is to facilitate the process. The necessary expertise is also required to go through certain information. The information was not withheld. And the process involves discussion with the operations and development of the documentation. Should the information have been presented beforehand it would not have been complete. As can be seen in ERA’s review of the IPPC application the process takes several reviews prior to achieving the required level of information for public consultation..

NGOs: Din l-Art Helwa, Malta Organic and Agriculture Movement, Youth for the Environment - meeting of 28 October 2016

36 28.10.16 Dr Petra Caruana Dingli (Din L-Art Helwa)

Meeting Not applicable Regarding the presentation given by Enemalta on the generation capacity the following queries were raised:

a) What are the different options (do nothing options) and other options such as use of diesel in terms of emissions.

b) Regarding the Cost Benefit Analyses (CBA) we are expecting an update of the CBA which was carried out for the previous variation. In 2013 it has been indicated that this will be carried out. In view that there was commitment for this, it should have been done.

Enemalta

a) Diesel oil will be used. In the previous variation requested by Enemalta, the CBA was requested for the BWSC plant in view of the use of the HFO and its related emissions. In the current scenario the use of gas has overriding benefits. In the NEC report carried out by Enemalta, the worst case scenarios were analysed.

37 28.10.16 George Camilleri (Din L-Art Helwa)

Meeting Not applicable a) What happens when there is an N-1 situation when there is a situation that there is no gas.

b) If we are generating 450MW what are the emissions going to be? With the interconnector the emissions will be lower.

Enemalta

ERA

a) In this case, four of the engines will be operated on diesel.

b) This is dependent on the energy mix. All emissions are lower than those on operations on HFO.

Further to the response given during the meeting, Enemalta provided further information to point a) and b) above:

There is a shortfall D2B can also be started up. Considering an N-1 situation with the absence of LNG means there is sufficient alternative capacity through other sources, including D3 operating on gasoil, the Interconnector and D2B also operating on gasoil.This is dependent on the energy mix. all envisioned energy mix combinations using the new plants are significantly lower than existing situation with energy mix dependant on HFO. The Interconnector will continue to feature in the energy mix as well.

All emissions will need to abide by the Emission Limit values in the IPPC

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permit.

38 28.10.16 Dr Petra Caruana Dingli (Din L-Art Helwa)

Meeting Not applicable Regarding the nautical risk assessment presentation the following questions were made:

a) What are the navigational restrictions and what will be the safety zones around the FSU?

b) Will maps be produced?

c) If its all so safe what advantages would the gas pipeline have? The CBA would have addressed these issues.

d) Is the safety zone not included in the study?

TM

EWA

Dr George Papadakis

TM

a) A safety zone has been designated while vessel is berthed, at storm mooring and during STS. Movements of vessel will be unrestricted and operational restrictions at Dolphin and jetty during sts.

b) These may be requested through ERA for a visual of the safety zone. These will be issued through a notice to mariners, on the website and through the local council.

c) The pipeline will offer a natural gas supply not lng. One will have a more reliable supply sources and not dependent on lngc. To do such a project (155km pipeline) more time will be required. FSU is a good interim solution. Getting the basic design, identifying route and preparing document for determining process is a long process.

In terms of safety these cannot be compared since they are designed to be safe. It is a decision depending on economical and political decision.

d) TM took into account the studies by the operator and Dr Papadakis is to produce the safety zone. All local councils of concern have been notified and once NTM is issued it will be published and a request can be sent to ERA.

39 28.10.16 Dr Petra Caruana Dingli (Din l-Art Helwa)

Meeting Not Applicable With regards to the presentation by AIS on the operations of D3PG the following questions were made:

a) What are the predicted emissions in 2016 when compared what it will be happen once the proposed design is in operation.

b) How will the energy mix be decided to better emissions. Estimate of 2016 with future years is requested.

ERA a) As part of the current permit operators will be required to continue with the

submission of the AER which includes loads of emissions

b) This information shall be provided.

40 28.10.16 Mario Salerno (Malta Organic and Agriculture Movement)

Meeting Not Applicable a) Regarding negative externalities was any program done to quantify negative externalities before the investments was introduced not only on the soil but also on the health affect e.g. asthma

b) With regards to visual is it possible on the front to have tamarisk trees this would enhance the scenario? Regarding risk is there any plan to introduce improvements which the risk can be reduced.

c) How quickly can it be changed from gas to diesel?

Enemalta

EGM

D3PG

a) There are several environmental improvements which the project will bring upon such as the reduction in particulate matter, SOx emissions and removal of generation of flyash which currently is being exported.

b) All safeguards to reduce risk are put in place.

c) This can be done instantaneously

Other comments received via email, written submission or during the public hearing (as specified in the respective row)

41

20.10.16 Klaus Pedersen

Email 20.10.16 1. Visually - The views of the cliffs of Delimara, which was a sight to behold in the evening sun light, are now blotted out, as is the recently restored picturesque lighthouse at the top. In the nighttime, the light pollution is phenomenal. All in all, Marsaxlokk has become an uglier place.

2. Environmentally - We can no longer enjoy the shore leading out to Delimara point. This was a popular place for small boats to go to swim and fish and a place which could be reached, even with a small dinghy. This

EIA coordinator

1. The points raised by Mr Pederson have been discussed in substantial detail in the 2013 EIS, the 2016 Addendum, and the 2016 public hearing presentations. In the view of the EIA Coordinator the whole of the Power Station Site and the area around the Site should have been rendered out-of-bounds for the public at least as soon as the excavation works commenced. With regards to the light pollution issue, please note that the project is currently in the commissioning stage with significant activities being carried

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entire area is now closed to access and our ability to enjoy nature in this area has been cut off.

3. Safety - As a father of two and with a wife working all day at the seafront, I naturally worry about the safety implications of a possible leak and the risk of ignition of a gas cloud.

4. Economically - The project will impact us negatively in two ways. Firstly, through the fall in property values due to the above mentioned reasons. And secondly, in the longer run, there is no doubt that it will diminish M’xlokk’s attractiveness as a tourist destination, which in turn will have a negative impact on the restaurant business, where both my wife and my son work.

TM

EGM

Ministry for Energy

out for the first time over the whole of the 24hours and high lux levels are required on the jetty and associated mooring and breasting dolphins. EGM are in discussions with the Planning Authority regarding lighting levels to ensure they are compliant with the authority’s directions and relevant standards and codes for safe working. EGM will review, among other solutions, directional lighting, in the event that this is required.

2. TM: the “sea area” indicated has to be a restricted area for safety and security reasons. This is standard practice for such installation. EGM has a contractual obligation to manage and maintain the area.

3. Major accident scenarios were addressed in the Safety Report, including Hazard Identification, Consequence Analysis and Risk Assessment. Safeguards have been implemented to prevent the occurrence of such accident. In the unlikely event of a LNG or Natural Gas leak, the maximum extent of the gas cloud will not affect the village / seafront of Marsaxlokk as the cloud will warm up and quickly dissipate. Furthermore, there are ignition sources close to any potential source of gas or LNG which could escape which would prevent travel. Finally, the whole plant is covered with gas detection and fire suppression systems along with emergency shut down processes to safely isolate and contain the LNG away from leaks or fires. EGM has complied with Seveso, COMAH and any relevant safety regulations in installing a compliant safe plant for operations.

4. It is at this stage not possible to ascribe any causal relationship between the undertaking of the D4 project and real estate prices in the area. It is however understood that real estate prices in the area have been increasing, following the national trends in this respect. Thus, the undertaking of the project did not inhibit from real estate appreciation in the surrounding area during the past two years.

Similar comments can be made with respect to the hotels and restaurant business, whereby a number of establishments have opened in the area or refurbished their activities. Tourist visitors also remained sustained in terms of levels and growth, in line with national average developments.

Any negative effects in the long run will furthermore be minimised through the establishment of the gas pipeline to replace the floating storage vessel. The economic benefits of the power station running on natural gas are to affect Marsaxlokk residents, other residents within the vicinity as well as the wider society. The most relevant externality effects are those related to the reduction in emissions from the production of electricity. These benefits include the reduction in the impact of emissions on human health, the ecosystem, impact on buildings and materials as well as the impact on agricultural crops. It is estimated that the development of the power station running on gas is expected to result in a drop in externality costs of about 41%

42 23.10.16 Michael Trapani

Email 25.10.16 Currently we have ongoing debate on suitability of floating gas storage system. Was deep sea gas storage system considered? Reference link to such system is below http://www.google.com.gt/patents/US7654279

This has various advantages over floating storage, it is safe and underwater not

ERA

The application for the variation of the IPPC permit is specifically for an FSU. The consideration of the alternatives was carried out at design stage. The suggestion being made will be referred to the respective entities who are already looking into the proposal for the gas pipeline.

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exposed to ignition sources. It will also remove the visual impact on Marsaxlokk harbour.

43 29.10.16 Dr Petra Caruana Dingli obo Din l-Art Helwa

Submission sent by email following stakeholder meeting

03.11.16 1. Copy of Presentations - The presentations were helpful but also very detailed to absorb in one meeting, therefore please can you make a copy of all the presentations shown yesterday available to us to be able to view again, as soon as possible.

2. Comparative Table - It was agreed at the meeting that a comparative table would be provided, listing estimated total national air emissions from power generation in 2016, 2017, 2018, and clearly distinguishing between the various power sources utilised. Please can you make this available as soon as possible.

3. Details of Safety zones, including visual images - It was agreed at the meeting that a report/notice by Transport Malta would be uploaded without delay, to be included with the rest of the IPPC consultation documents on the ERA website, providing visual images of the three safety zones for mariners described during the presentation on the nautical risk assessment yesterday, for three scenarios:

i. during normal operations with FSU moored at jetty

ii. during periodic deliveries made by LNG carrier

iii. during times when FSU is on storm moorings In this document

Transport Malta was to also provide information on the fairways which will be open to any other vessels using the bay during these three scenarios, as well as on the coordination of other vessels engaged in delivery operations when the LNG carrier is in the port, as outlined in the presentation. Please can you give a definite indication of when these documents will be made available to the public.

4. Similar LNG Installations - The presentations at the meeting featured two LNG installations overseas which were compared to the new Delimara FSU set up. I believe these were one at La Spezia and the other in Lithuania. Please can you confirm which two installations were being referred to?

Reply sent by ERA with feedback from Enemalta and Transport Malta.

1. Copy of Presentations – All presentations have been sent via We Transfer on 7 November 2016.

2. Comparative Table - Please find below a comparative table as requested showing the emissions loads of the various pollutants emitted during 2014, 2015 and 2016 as well as the projected emissions with the various energy mix scenarios for 2016 and 2017 (see end of response for table).

3. Details of Safety zones, including visual images - On the above request, Transport Malta have provided feedback in that the Notice to Mariners will only be issued prior to the vessel receiving her first LNG parcel. Transport Malta has confirmed once again to Din l-Art Helwa, that they will be ensuring that an unrestricted fairway is established, thus ensuring there are no restrictions relating to fishing vessels and recreational craft.

4. Similar LNG Facilities - With regards to similar LNG facilities which were mentioned in one of the presentations please find below more information of these two installations:

La Spezia: The installation is operated by GNL Italia and consists of an LNG storage and regasification system. The LNG is discharged on shore via LNG carriers but is stored in two storage tanks with a capacity of 50,000m3 each. The load capacity of the LNG carriers varies from 25,000 cubic metres up to 65,000/70,000 cubic metres. Further information is available at the following link: http://www.gnlitalia.it/en/activities/Infrastructures

Lithuania: The installation is an LNG terminal in the port of Klaipėda in Lithuania. It is operated by Klaipėdos Nafta. The installation comprises of a liquefied natural gas floating storage and regasification unit (FSRU) (FSRU 1 Independence)with a capacity of 170,000 cubic metres. The LNG is interconnected to the grid as an LNG supply to the market of the Baltic State

Actual or Projected Demand (MWh)

Energy Mix Nox (tonne

s)

SO2 (tonne

s)

Dust (tonne

s)

Ammonia

(tonnes)

2014

2,227,821

D1, D2, D3, MPS and PVs 2,786.

0 4,566.

4 405.8 15.7

2015

2,304,061

D1, D2, D3, MPS, Interconnector and

PVs 1,541.

6 1,999.

7 129.6 5.4

2016

2,301,465

D1, D2, D3, Interconnector and

PVs 1,029.

8 1,434.

8 78.8 4.6

2017 2,457,467

D3, D4, Interconnector and

PVs 422.0 35.1 18.3 1.8

2018 2,514,8

D3, D4, Interconnector and 423.5 35.3 18.7 1.8

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81 PVs

Further to the reply above, EGM have noted that the LNG tanker fleet consists of 450 vessels at the start of 2016 (including 24 FRSUs)

44 28.11.16 Philip Mercieca obo Din l-Art Helwa

Email (requests are linked to the email submission in Ref#43)

1. ALTERNATIVES

The permanent presence of such a large LNG storage tanker, together with a regular supply ship of the same size, poses risks to the power station, the Freeport, fishing boats and other vessels, and the safety of people in the vicinity. Before taking any decisions, detailed studies should have been undertaken to consider all alternatives with more safety distance and less traffic movements.

Other suggestions for a new gas-fired power station included an offshore platform, a gas pipeline, or basing the gas storage on land. Detailed studies on the various options were not published. The government has now stated that it will eventually replace the FSU with a gas pipeline, however no studies or details have been presented comparing this option to the scenario now being implemented. The advantages and disadvantages of both FSU and gas pipeline should have been studied and compared in detail BEFORE any decisions were taken.

During the EIS hearing it was claimed that mooring outside the bay is not possible, yet offshore platforms exist which survive harsh weather conditions in the North Sea and elsewhere. More details about this option should have been provided before any decisions on the LNG storage option was decided.

2. UTILISATION RATES AND EMISSIONS

The EIS had not provided an adequate answer to the following query which was made by Din l-Art Helwa in relation to the draft EIS:

“The Project Description Statement states that the Delimara3 extension (when converted to gas) is only expected to have a utilisation rate of 50% once the proposed CCGT plant is operational. What are the expected utilisation rates of the proposed CCGT plant, the Interconnector, and the rest of the Delimara plants, from 2015 to 2020? What will be the “default pecking order” of the various power plants and the Interconnector? This analysis must be included in the EIS.”

The EIS coordinator response was as follows:

“The EIS covers an application for a new CCGT and assumes that such CCGT will be utilised to satisfy base load requirements. Other considerations such as making more use of the interconnector and reducing the use of the proposed CCGT may result in less environmental impact, but such a decision is not only taken on the environmental impact but on a range of other considerations including but not limited to economic issues. Such considerations are being dealt with in the CBA which will form part of the IPPC permit as requested by MEPA.”

The EIS response noted that the Cost Benefit Analysis is being undertaken as part of the IPPC permit, however has not been published.

The EIS coordinator had also stated that “making more use of the

1. Enemalta

2. Enemalta

1. The potential risks associated with the LNG tanker have been assessed for comparability with the surroundings, according to the criteria specified by COMAH. The assessment of possible alternatives was not the scope of the IPPC application.

2. In view of the fact that multiple operators are involved, it is important to note that information regarding utilisation rates are of a commercially sensitive nature. Also, expected utilisation rates shall be dependent on several factors (financial, environmental, availability, etc.). As such Enemalta has ensured that even under the expected worst-case operational conditions all emission requirements stipulated by the relative Directive and local legislation are abided by.

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interconnector and reducing the use of the proposed CCGT may result in less environmental impact”.

Din l-Art Helwa’s earlier request, submitted in relation to the draft EIS, to outline the proposed utilisation rates of the proposed CCGT plant, the interconnector and the rest of the Delimara plants, should have be answered in the EIS which should have addressed all environmental considerations and scenarios. No satisfactory answer was provided to this question at that stage, which has environmental implications.

During the IPPC consultation meeting on 28th October 2016, Din l-Art Helwa repeated this request but was only later provided with the chart below, which is unsatisfactory as it does not in fact outline the proposed utilisation rates of the various power sources, which will affect the total emissions:

Actual or Projected Demand (MWh)

Energy Mix Nox (tonne

s)

SO2 (tonne

s)

Dust (tonne

s)

Ammonia

(tonnes)

2014

2,227,821

D1, D2, D3, MPS and

PVs 2,786.

0 4,566.

4 405.8 15.7

2015

2,304,061

D1, D2, D3, MPS,

Interconnector and PVs

1,541.6

1,999.7 129.6 5.4

2016

2,301,465

D1, D2, D3, Interconnector and PVs

1,029.8

1,434.8 78.8 4.6

2017

2,457,467

D3, D4, Interconnector and PVs 422.0 35.1 18.3 1.8

2018

2,514,881

D3, D4, Interconnector and PVs 423.5 35.3 18.7 1.8

3. DETAILS OF SAFETY ZONES FOR MARINERS, INCLUDING VISUAL IMAGES

It was verbally agreed at the IPPC consultation meeting held in Delimara on 28th October 2016 which Din l-Art Helwa attended, that a report/notice by Transport Malta would be uploaded without delay, to be included with the rest of the IPPC consultation documents on the ERA website, providing visual images of the three safety zones for mariners described during the presentation on the nautical risk assessment yesterday, for three scenarios:

i. during normal operations with FSU moored at jetty

ii. during periodic deliveries made by LNG carrier

iii. during times when FSU is on storm moorings

In this document Transport Malta was to also provide information on the fairways which will be open to any other vessels using the bay during these

3. TM

3. Details of safety zones and maintaining a fairway: As per chartlets include in the PPT presentation for the 3 scenarios

Please refer to Document Ref#44 – Nautical Safety Zones on webpage

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three scenarios, as well as on the coordination of other vessels engaged in delivery operations when the LNG carrier is in the port, as outlined in the presentation.

However on 7th November, Din l-Art Helwa was informed by ERA that:

“On the above request, Transport Malta have provided feedback in that the Notice to Mariners will only be issued prior to the vessel receiving her first LNG parcel. Transport Malta has confirmed once again to Din l-Art Helwa, that they will be ensuring that an unrestricted fairway is established, thus ensuring there are no restrictions relating to fishing vessels and recreational craft.”

Din l-Art Helwa maintains that this information, including visual images of the safety zones for mariners, should be provided to the ERA board as well as the public BEFORE a decision on this permit is taken.

4. SIMILAR LNG FACILITIES

During the public consultation meeting held on 28th October 2016, two similar LNG facilities were mentioned in the presentations. Din l-Art Helwa requested further information from ERA on these two facilities, and was presented with the details below, however neither of these two installations seem directly comparable to the FSU scenario being constructed at Delimara:

a. La Spezia: The installation is operated by GNL Italia and consists of an LNG storage and regasification system. The LNG is discharged on shore via LNG carriers but is stored in two storage tanks with a capacity of 50,000m3 each. The load capacity of the LNG carriers varies from 25,000 cubic metres up to 65,000/70,000 cubic metres. Further information is available at the following link: http://www.gnlitalia.it/en/activities/Infrastructures/

b. Lithuania: The installation is an LNG terminal in the port of Klaipeda in Lithuania. It is operated by Klaipedos Nafta. The installation comprises of a liquefied natural gas floating storage and regasification unit (FSRU) (FSRU Independence) with a capacity of 170,000 cubic metres. The LNG is interconnected to the grid as an LNG supply to the market of the Baltic State

4. EGM

4. EGM notes that the examples given in the presentation were suggested as similar in nature in that they were LNG terminals new to existing communities/residential areas. The proximity to these residential areas is possible due to safety in design and operations.

45 14.11.16 Pierre Bianchi

Email 15.11.16 Dear Sirs,

I would like to register my interest as a resident in Triq Alfons Maria Galea, Birzebbugia, most particularly regarding the lights being used to illuminate the floating storage facility and its newly constructed mooring.

As can be seen from the images attached one feels that the lights are excessively bright as the illumination is not controlled to focus simply on the working areas but bleeds out onto the surrounding bay and cliff faces. This could be simply an issue of orientation of the spot lights.

Recommendations

• Re-Orient spotlights to be less intrusive across the bay and on the surroundings.

• Curtail the brightness depending on the how essential the areas are to the functioning of the facility.

EGM

Planning Authority

Please reference response to Q 41 item 1 above. EGM shall endeavor to find a long term solution in line with Planning Authority recommendations, applicable codes and safe working and which is acceptable.

The Planning Directorate is still discussing the external lighting with applicant so that it is kept to a minimum and at the same time all safety measures required are adhere to. All mitigation measures to minimise any impacts are being discussed and prior to issue any compliance certificate, a lighting plan will be submitted to the Planning Authority for approval.

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• Covers could be installed to avoid bleeding of the light in unnecessary directions.

As I understand the necessity for lighting to monitor the facility at night one would appreciate the consideration of screening and/or controlling solutions that could mitigate the diffusion and orientation of light throughout the bay.

Furthermore, I would like to register my attendance for the public hearing on 18th November 2016, Primary School, St. Thomas More College, Marsaxlokk at 3.30pm.

46 19.11.16 Edwin Ebejer

Email 20.11.16 With reference to the subject in caption and the public consultation regarding the LNG Gas Tanker, I appreciate the Government initiative to provide us with cleaner air. Unfortunately, the LNG still carries a low probability of a serious hazard, which can be prevented with rigorous safety, planning and uncompromising enforcement. It is important that once the safety buffers are established, they are not infringed for the sake of some fireworks enthusiasts or anything of the sort.

Moreover once we get cleaner air, I hope the authorities do not allow some other polluting project to be set up. It is unfair on the residents to have their quality of life eroded. Public consultations should be encouraged but the ordinary citizen does not necessarily have the expertise to be aware of the risks associated with the proposed projects. It is evident that this fact was exploited in the gradual development of the West Key, which intruded in our homes with unbearable noises and other inconveniences having an adverse effect on our health and pockets.

ERA The Delimara Power Station is a National Infrastructure and all entities should be made aware of the risk zones for this installation. The permit procedures normally required for any major installation normally requires the competent authorities to inform and consult the public.

47 25.11.16 Carmela Cacopardo obo Alternattiva Demokratika

Email 28.11.16 Alternattiva Demokratika qed tillimita s-sottomissjonijiet tagħha għar-rapport tad-Dipartiment tal-Protezzjoni Ċivili u dan minħabba li minkejja li kien hemm estensjoni ta’ żmien f’din il-konsultazzjoni pubblika, l-ammont ta’ dokumentazzjoni rilaxxjata kien wieħed voluminuż u ma kienx hemm ħin biżżejjed biex din tkun eżaminata bir-reqqa meħtieġa.

Ir-rapport intitolat External Emergency Plan imħejji mid-Dipartiment tal-Protezzjoni Ċivili għandu parti minnu nieqsa. Fil- paġna 21 ta’ dan ir-rapport hemm it-titlu tas-sezzjoni : Section B Operational. Imbagħad fil-paġna immedjatament warajha hemm nota li tinfurmana illi l-kumplament tas-sezzjoni hi nieqsa minħabba illi kieku din l-informazzjoni kellha tkun ippubblikata, din il-pubblikazzjoni tkun ta’ theddida għas-siġurtà nazzjonali. Hu sottomess li d-Direttiva tal-Unjoni Ewropeja magħrufa bħala Seveso III u intitolata “Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of major-accident hazards involving dangerous substances, amending and subsequently repealing Council Directive 96/82/EC” kif anke implimentata fil-leġislazzjoni Maltija permezz tar-Regolamenti tal-2015 dwar il-Kontroll ta’ Perikli ta’ Inċidenti Kbar [avviz legali 179/15] jobbligaw li jkun hemm konsultazzjoni fuq il-pjan estern ta’ emerġenza dwar l-impjant taħt konsiderazzjoni.

Dan il-pjan esterna ta’ emergenza , skond l-iskeda IV u l-iskeda V tar-Regolamenti tal-2015 dwar il-Kontroll ta’ Perikli ta’ Inċidenti Kbar [avviż legali 179/15] jeħtieġ li jkun fih bosta dettalji inkluż dwar x’inhu mistenni kemm mill-pubbliku kif ukoll mill-komunita kummerċjali.

Il-konsultazzjoni meħtieġa ma saritx u ma tistax issir u dan minħabba illi l-informazzjoni essenzjali għal din il- konsultazzjoni ġiet mużmuma milli tkun

CPD The Civil Protection Department has published the External Emergency Plan of which part B (Operational) was detained from publication as it has been classified Secret given that the information contained within if made public would be a threat to National Security. In our view, the external emergency plan as published contains sufficient information to satisfy legal notice 179/15 and Council Directive 2012/18/EU.

Several sessions were held as part of the IPPC Application Public Consultation and feedback on the External Emergency plan was given including several presentations and replies to submitted questions. The general public has been informed on what to do in an emergency through the information booklet that was distributed in each and every household in the area.

In view of this it is important to note the following;

As indicated from the information made available by the Operator in the Safety Reports and consultancy provided by international consultants, even in the worst case scenario, the general public living in Brizebbugia and Marsaxlokk will not be affected.

Notwithstanding the above the CPD has still prepared an evacuation plan for Marsaxlokk and Birzebbugia given that there are other Seveso class sites within the vicinity.

The external emergency plan will kick in if the Operator cannot handle the emergency and requires CPD assistance. CPD will kick in the external emergency only in the event of a major accident and this does not imply that evacuation is needed. Evacuation will only be required if CPD is not in a

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ippubblikata u dan kontra dak li jipprovdu r-regolamenti hawn fuq ċitati. Imkien, fl-imsemmija Direttiva jew regolamenti, ma hemm awtorizzazzjoni jew referenza għal xi ċirkustanzi li a bażi tagħhom l- informazzjoni meħtieġa tista’ tkun miżmuma mill-pubblikazzjoni.

Huwa essenzjali li l-pubbliku jkun infurmat bil-miżuri ppjanati għall-ħarsien tiegħu f’kaz li jseħħ inċident bħala riżultat tal-operazzjoni tal-impjant. Huwa biss billi jkun infurmat b’dawn il-miżuri li l-pubbliku jista’ jipparteċipa fl-eżerċiżżji dwar l-implimentazzjoni eventwali tagħhom u b’hekk tkun assigurata l-possibilita li l-pjan ta’ emergenza jkun wieħed fattibbli.

Għaldaqstant hu sottomess illi għandha tkun ippubblikata mingħajr dewmien l-informazzjoni nieqsa biex tkun tista’ issir il-konsultazzjoni pubblika meħtieġa.

position to contain the incident, and as stated earlier, from the safety reports and international consultancy acquired, this will not be the case where LNG is concerned.

CPD will be in a position to instruct the public appropriately only once the accident has occurred and not before as there are certain factors, such as weather conditions, which will determine the type of action required.

CPD actually has two years to draw up the external emergency plan, which period commences from the submission of the safety report and internal emergency plan by the operator. Furthermore the Operator and CPD are also obliged to conduct exercises in the plant at least once every three years from the start of operations.

48 27.10.16 John Grech obo Birzebbuga Environment Action Group

Email 28.10.16 1. Continual Monitoring and remedial Measures for any arising Noise pollution

1.1. Following an extended Malta Freeport Noise Survey, as carried out by ADI, as a direct result of the existing Malta Freeport Environmental Permit, it was recently confirmed that the Birzebbuga residents are currently being adversely affected through dBs well above the established WHO limit values, especially for the night.

1.2. Moreover, it was additionally confirmed that in the absence of any local legislation, the Survey followed a set of obsolete WHO guidelines; and had it followed more updated WHO standards, the resulting conclusions would have given an even worse scenario.

1.3. The 2016 Addendum to the 2013 EIS, Doc B, Statement on Environmental Impact Statement, Appendix One, prepared by ERSLI Consultants, and dated 22 September, 2016, Technical Statement, P 11, Noise Features, ElectroGas Report Reference Number 097.16, for May 2016, gave the following estimated Noise Readings at the Company's (EneMalta DPC) fence:

CCGT 85 dB (A)

Generator 112.00 dB m2

FSRU re Gas 109.85 dB m2

FSU/FSRU Deck areas 75.61 dB m2

Vaporisers 74.80/Unit

1.4. Considering the Seawater Noise amplification, it is estimated that these high dB levels from the Delimara Power Station upgrade would be adversely affecting the Birzebbuga various suburbs and their residents, through this cumulative additional specific Noise Pollution.

1.5. Under the circumstances, BEAG is soliciting ERA to include a number of B’Buga suburbs in any eventual Noise Surveys as arising from the Combined Cycle Gas Turbine, Liquefied Natural Gas Receiving, Storage and re-gasification facilities, immediately on commissioning and start of operations.

1.6. Moreover, such Noise Surveys should be followed up at interim intervals, and that ERA imposes remedial measures at source, as and when required.

1. EIA coordinator

1. Noise Pollution

The ‘WHO guidelines’ are never used in the assessment of ambient conditions during processes leading to the issue of development and/or operations consents, both where EIA and the IPPC processes are concerned. They should be referred to as guidelines for possible reference to the limits on grounds of public health. They are mostly guidelines for policy makers.

The declared scope of WHO’s efforts is to consolidate actual scientific knowledge on health impacts rather than to set standards that might be applicable to given situations and those that do otherwise do so at their own risk. In most cases if it is applied to projects’ environmental permitting, it short changes both the community and the developer.

The comment “followed a set of obsolete WHO guidelines; and had it followed more updated WHO standards, the resulting conclusions would have given an even worse scenario” is not understood as the levels stipulated in the guidelines have never changed since the issue of the first document Environmental Health Criteria - 12 Noise (WHO, 1980), neither in the follow-up document published by Berglund & Lindvall, on behalf of WHO in the 1995 Community Noise.

The guideline-suggested levels are better presented in Table 4.1 in Guidelines for Community Noise 1999. This document and Night Noise Guidelines for Europe 2009 are the only presently valid documents from WHO. These are however not used to evaluate environmental or legal situations. If that were the case, both Electrogas and Enemalta would not have gone through the process of all the noise control design process presented in the EIA and IPPC documents as the otherwise resulting levels would have been within those ‘guideline values’. This would however have not meant that the community would not have been adversely affected. Currently, it is the Malta Freeport that affects areas of Marsaxlokk (Kavallerizza, upper parts of Marsaxlokk) and the Delimara peninsula. At present the Freeport can still be heard above the LNG carrier/ FSU.

Note: It is Environmental Health Criteria - 12 Noise, WHO, 1980 that was used to establish the planning design indoor levels in BS 8233 and could be used if it is necessary to consider noise levels within buildings. These criteria and limits are primarily intended to guide the design of new or refurbished buildings, rather than to assess the effects of changes in external noise level. The criteria and limits given are therefore of limited relevance to IPPC or waste management licensing situations.

With regards to comment 1.3, the values being brought forward are not the values at the fence but are equipment sound power levels. Sound POWER levels are not sound PRESSURE levels and are not something determined with the ‘usual’ noise

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2. Sewage Contamination from Delimara Power Station Must be rectified

2.1. Chapter 3 “Re-assessing Impacts of Identified Discharges on Marine Quality” of the Statement on Environment Impact Statement, Delimara Gas and Power, combined Cycle Gas Turbine and Liquefied Natural Gas Receiving , Storage and re-gasification facilities, Appendix One, dated 22 September 2016, has reported on page 8

“Axiaq (2013) also indicated that the rest of the waters within the bay, were exposed to chronic pollution by sewage. These include the waters along the DPS.” .

2.2. Such blatant shortfalls in the DPS must be rectified without further delay, through permitting conditioning and enforcement, including an established time-frame for the investigation and remedial measures, including certification by an independent warranted engineer.

2.3. Moreover, in view of the above, and as integral part of this IPPC-Environmental permitting, the Re-gas Sanitary Wastewaters (vide Technical Statement Report Reference No. 084 – 16, dated 25 July, 2016, Table 1 (page 8), should not be collected in a common cesspit, as proposed, as this may and will be liable to lead to further sewerage contamination and abuse.

2.4. As an integral part of the IPPC permitting conditions, any and all regas Sanitary Wastewaters should be made to flow into a free standing PVC or metal tanker, placed in an empty cistern that allows, apart from regular emptying, for initial and subsequent yearly inspection and certification by an independent warranted engineer.

2. EIA coordinator

level meters. It is important to point out that there are many types of ‘dB’s and that the indices tied to them are the descriptors. This same mistake is done when quoting the WHO guidelines as all the levels within those documents are over a period of 8 or 16 hours and not in samples of five minutes or one hour.

With regards to comment 1.4, no ‘seawater noise amplification’ exists, but lack of attenuation for particular body-of-water conditions. ALL the predictions within the EIA consider this lack of attenuation. ALL predictions are in accordance with ISO 1996-2 and hence consider the worst conditions possible versus the receiver (there are circa 2 million of them in those evaluations).

With regards to comment 1.5, with the line of comment of BEAG, the predicted values for contributions from Delimara are substantially below the WHO’s suggested night noise guidelines values way before they reach the part of Marsaxlokk that is in line with Birzebbuga. Actually, the predicted values are substantially below any possibility of having any impact a good 700 meters before the first Birzebbuga residence in line with Delimara. As previously described, it is Birzebbuga that affects Marsaxlokk and not the other way round. Any suggestions of noise surveys in Birzebbuga with regards to Delimara power station would be technically inconclusive and nonconducive towards any evaluation of DPS’s operation.

With regards to comment 1.6, a series of remedial measures were implemented. In many cases a complete redesign of some major components was done by Siemens and Electrogas to fit within parameters set in the initial EIA documents. The series of Siemens reports and suggestions in due course of the construction are included in the EIA documents to represent this process as transparently as possible for evaluators of the documents.

2. Contamination

Reference should be made to the Addendum to the 2013 EIS and the two Technical Statements prepared by Dr Joseph A Borg (the assessments in which supersede previous the ones in previous ‘sea-water quality’ reports prepared for the EIA and its 2016 Addendum) dated 1-8-16 and 13-9-16: These statements indicate that no sewage will be discharged to the marine environment. The matter was also referred to in the EIA Coordinator’s presentation during the 2016 Public Hearing.

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3. Creation of an Environment Management Committee for the Delimara Power Station

3.1. BEAG strongly recommends that as an integral part of the relative IPPC permitting, ERA creates an Environment Monitoring Committee, similar to the one created for the Malta Freeport Terminals Ltd, which registered continual cooperation amongst all stakeholders, and smoothened up a number of potential misunderstandings, and other environmental hazards as arising from potential incidents and accidents. The Terms of Reference should also be similar to those established for the Malta Freeport Terminals committee.

3.2. Such a Committee should be made up from representatives of the Marsaxlokk, Birzebbuga and Zejtun Local Councils, and other established Environmental NGOs already established and catering for these self-same localities. It should additionally include other interested stakeholders such as representatives from Transport Malta, the Civil Protection and EneMalta, with representatives of the ERA to act as Committee Chairman and Secretary. Meetings should be held at least once every quarter.

3.3. Enemalta and its main shareholders should bear the financial burden for such a Committee with annual contributions to the stakeholders localities, and other expenditure for technical expertise, as an when required by each stakeholder.

4. The Continuous Emission Monitoring Systems

4.1. All the reports and feedback from the various emission monitoring systems should be made available on the Enemalta and ERA websites in real time, 24 X 7.

4.2. Any technical failures in the systems’ monitoring and reporting should be covered by thorough technical explanations from the relative management, and in any case there should not be a shortfall covering more than 10 man days in any one calendar year.

4.3. The Websites should additionally provide the results for all other relative environmental monitoring, sampling and technical reporting, including those pertaining to ISO.

5. Objection to the Proposed Hull Cleaning Process for the FSU.

5.1. It was reported in the updated EIS documentation that the FSU would not be drydocking for 18 years. One understands that continual monitoring of the hull is essential, but BEAG objects to any irresponsible hull cleaning, as this further pollutes the Marsaxlokk Bay.

5.2. Hull Cleaning and Propeller Polishing were similarly objected to at the Malta Freeport Terminals, as MEPA’s then environmental protection for this item left much to be desired on environmental grounds, where a seabed net was officially proposed.

3. ERA

4. ERA

5. ERA

3. Creation of an Environment Management Committee

ERA shall be addressing the potential creation of an environment management committee as part of the IPPC permit.

4. Continuous Emission Monitoring Systems:

The requirements for continuous emission monitoring and data provisions will be included as part of the IPPC permit. The operators will be required to provide real time data for emissions to air.

5. Hull Cleaning Process for the FSU Any requests for hull cleaning shall be made to the Authority in line with the required permitting procedures. Conditions in this regard will be included as part of the IPPC permit.

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6. Protecting the Birzebbuga bathers and the two area official bathing bays in the Marsaxlokk Bay through enforced continual independent monitoring and official reporting.

6.1. According to Doc B, 2016 Addendum to the 2013 EIS, Statement on Environmental Impact Statement, Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas Receiving, Storage and re-gasification facilities, Chapter 3, Pages 7-8 (re-Assessing Impacts of Identified Discharges on Marine Quality): -

“There are two officially designated bathing waters within Marsaxlokk Bay: Pretty Bay and St George’s Bay. Both are located in the western half of the bay, and are from 2.1 to 2.5 km away from DPS.”

6.2. It was moreover alleged that these two bays will be more exposed to anthropogenic pressures arising from Birzebbuga area, especially from the Malta Freeport

6.3. It was additionally reported that these bays are free from sewerage contamination, at least on date of the EIS reporting.

6.4. In Chapter 3.4. “Water Pollution/Chemical Pollution in Marsaxlokk Bay”, one notes that

“It is important to note, however, that aromatic and petroleum hydrocarbons, which are carcinogenic, are currently already found to be measurable at elevated levels in the bay. This is to be expected due to the harbour activities on a daily basis in the location. As a mitigation effort (!!!??? –BEAG), following information gathered from this assessment, efforts should be made to notify any prospective swimmers on the polluted nature of the bay and advise them o swim elsewhere as a precaution.

6.5. The above seems to infer that the Marsaxlokk Bay, including Pretty Bay and St George’s Bay (let alone the Qajjenza and Wied il Buni Areas) are currently ‘beyond hope’ due to the “circa 2,000 vessels entering the harbour every year”

6.6. Somehow, this would have been acceptable, had not both DPS and the Malta Freeport Terminals been already subjected to official (MEPA-ERA) environmental permitting and regular sea water monitoring.

6.7. Similarly BEAG expects and demands that the Authorities that be, rise to their inherent responsibilities, and take the initiative to finally protect the Birzebbuga residents, through feedback and other pro-active remedial measures at the responsible culprit areas.

6.8. Similarly, “Heavy metals such as cadmium and chromium have also been found in the superficial marine sediments at the bottom of the bay. These chemicals have carcinogenic effects upon long-term exposure, along with other effects associated with heavy metals deposition such as liver disease.”

6.9. “In the case of Cadmium, elevated levels were found that seem to point to the DPS activities being the primary source.”

6.10. Para 3.4.2. Detection of Mercury in Marsaxlokk Bay:-

“During investigations that were conducted for the Water Quality Assessment, mercury levels, well exceeding the maximum amount allowed

6. EIA coordinator

6. Comments 6.1 – 6.11 refer to the general situation of water and sediment quality within Marsaxlokk Bay existing prior to the 2013 EIS.

While the concerns expressed in comments 6.1 - 6.11 are appreciated; it is up to the pertinent authorities to tackle the monitoring and actions proposed as part of these comments. Regarding Comment 6.12; reference should be made to the above-mentioned reports prepared by Dr Joseph A Borg (dated 1-8-16 and 13-9-16): These statements indicate clearly that while no sewage will be discharged to the marine environment, wastewaters from the DPS will be treated, hence rendering potential contamination of marine waters negligible. During the 2016 Public Hearing Presentation reference was also made to the manners in which bilge and boiler blow-out waters would be disposed; i.e. through a licensed contractor. None of these waters would be discharged into Marsaxlokk Harbour.

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by AA-EQS water quality guidelines, were detected in over 12 out of 18 samples. This assessment was carried out over 9 months, so this is not a one off scenario.

“Mercury is highly toxic, especially as it accumulates in the filter feeding fauna of the Bay, and ultimately bio-accumulates higher up in the food chain. Any elevated levels should be taken very seriously. For both environmental and health concerns, this detection of mercury should be investigated and any sources discovered ought to be dealt with as soon as possible.

6.11. The above is all part of the official EIS submissions, and BEAG demands that ERA rises up to the challenges officially made, by enforcing further continual monitoring by independent bodies, and taking immediate pro-active remedial reporting to all stakeholders (including the Birzebbuga residents), and other immediate remedial enforcement measures as and when required.

6.12. This is more so when one considers that in other parts of the DPS EIS, e.g. Para 4.4. @Effects on Human Populations, F, Water Pollution, paras 4.4.2. 26 to 28.

“Water pollution can occur due to the discharge of several substances in the effluent waste of any power plantg. This discharge varies considerably with time, and can have diverse health impacts both direct (e.g with substantial heavy metal discharge), or indirect…..

Process wastewater may include contaminated wastewater from utility operations, storm water and sanitary sewage. A number of cleaning agents are used to restore the machinery and in combustion processes of thermal power plants. Most of these have their own hazard profile at toxic levels. Referred for your consideration

49 26.10.16 Alfred Falzon

Feedback sent through online form www.konsultazzjoni.gov.mt

Irrespective of whether an LNG is dangerous or not- a matter which should be decided upon by experts - I am against the mooring of this huge ship at Mxlokk Bay. The main reason for this is that this ship is damaging the environmental state of the area. Whereas I used to see the Delimara peninsula from my roof top, now I can only see this ship. Of course this is not my sole idea, but that of most of the residents at Marsaxlokk. The same could probably be said of residents at Birzebbugia. While on this subject, I would like to enquire whether the coastline between the Lighthouse and the Power Station would be available for the public.

EIA Coordinato

r

TM

The 2013 EIS, the 2016 Addendum, and the presentation made in the 2016 Public Hearing have discussed the issues raised Mr Falzon in detail.

As is noted above, this EIA Coordinator submits that the whole of the Power Station Site and the area around the Site should have been rendered out-of-bounds for the public at least as soon as the excavation works commenced.

The coastline, but to be more specific the adjoining sea area, will not be restricted to navigation, falling outside the safety zone or EGM sea area. This is marked with a green line in the attachment below.

Please refer to Document Ref#49 – Coastline Zones on webpage

With regards to access from the land side, this falls outside TM’s remit. Apart from any access restrictions for the AFM outpost, private residences etc, this is public land.


Public meeting

External Emergency plan: CPD

Taken into consideration the fact that in summer there are a lot of swimmers.

The part of the island referred to in the external emergency plan is the Delimara

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Following CPD Report what part of the island will be evacuated? Peninsula. The Civil Protection Department has also drafted a plan for the evacuation of such a peninsula given that in Summer there are a lot of swimmers who frequent the area on the other side of the Peninsula

Where will all the evacuated people be held? What will be the exact procedure? And how much long will evacuation take per se in relation to the persons? How will the local council be informed if the accident happens during the night? CPD

There is an evacuation plan in place that cannot be published due to national security. There is a maximum ten hour evacuation plan. There will be the alarm, upon which people shall return to their homes and await further instructions from the media. This is in accordance with European models and the FALC Netherlands

SEVESO directive Clause 16, Clause 19 -where is the effective public participation and consultation (Aarhus Convention)?

CPD

SEVESO Tests will be carried out.

Further to the response given during the Public Hearing, OHSA have clarified that the requirement of public consultation on the External Emergency Plan is being met through the ERA’s public consultation on the IPPC application.

Clause 16 mentions that plans shall be reviewed and tested. Residents were never consulted or asked their opinion about the emergency plans.

The External Emergency Plan has been issued for Public Consultation as part of the Public Consultation for the IPPC Application. CPD actually has two years to draw up the external emergency plan, which period commences from the submission of the safety report and internal emergency plan by the operator. Furthermore the Operator and CPD are also obliged to conduct exercises in the plant at least once every three years from the start of operations.

No one knows how the alarm will be heard; or how the people will be evacuated; or how the people will behave,; no one knows the routes that will be taken to avoid clashed with emergency vehicles during the evacuation drills. No information pamphlet or documentation has been distributed to those concerned, such as, restaurants, schools, homes and other public places. Where are the assembly points?

Refer to previous reply from CPD above.

CPD is not equipped enough and is refusing the responsibility as for the marine responses; TM is refusing this responsibility as well. Who is responsible?

CPD

The data regarding the gas cloud was analysed by FALC. As for the mentioned Times of Malta Article, this had been replied to including the preparedness of the CPD,

As regards to incidents originating from the marine side, CPD will request the assistance of Marine Tugs which are all equipped with firefighting capabilities and co-ordinate response accordingly as with any other maritime incident. In the event that the incident is on the jetty side the Incident Commander CPD will determine whether the intervention is to be made by CPD from the land side or co-ordinate the use of tugs or both.


Letter and email submission linked to Ref#50

28.11.16 Response to the External Emergency Plan

1.0 Qualification for the application of Directive 2012/18/EU - SEVESO III Directive.

The ARMADALNGMEDITERRANA ( ex-Wakaba Marn) IMO 8125868, gas tanker, built in 1985, now planned to be used as a Floating Storage Unit (FSU) by Electrogas at Delimara Power Station has the capacity to carry a cargo of 125,582 m3 of liquefied natural gas at -162° Celsius.

This capacity exceeds the qualifying quantity of200 tonnes detailed in Column 3 of part 2 of Annex 1 (Item 18-Liquefied flammable gases, Category 1or2 including LPG and natural gas).

Therefore by virtue of clause 3 of Article 3 of Directive 2012118/EU, the Electrogas FSU is classified as an 'upper-tier' installation.

EGM

Due to the large amount of LNG stored and handled (> 200 tonnes), ElectroGas’ new plant will be an “upper tier” establishment as defined by the Control of Major Accident Hazards (COMAH) Regulations that implement the Seveso Directive (2012/18/EU). The Directive has been transposed into Maltese law through the Control of Major Accident Hazards (COMAH) Regulations - LN 179 2015.

EGM has produced a safety report as required by Article 10 of the Seveso III Directive.

EGM has drawn up an internal emergency plan for the measures to be taken inside the establishment, supplying the necessary information to the competent authority, to enable the latter to draw up external emergency plans, as required by Article 12 of the Seveso III Directive.

EGM together with Competent Authority have produced an Emergency procedures booklet so that all persons likely to be affected by a major accident receive clear and

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The ARMADALNGMEDITERRAN is currently moored near Delimara Power Station.

OHSA

intelligible information on safety measures and requisite behaviour in the event of a major accident, as required by Article 14 of the Seveso III Directive.

This booklet has been distributed and can be downloaded on EGM web site: http://www.electrogas.com.mt/downloadable-material/

The FSU is classified as an upper tier site under the Control of Major Accident Hazards (COMAH) regulations, L.N. 179/2015

2.0 SEVESO Ill Directive Stipulations regarding Emergency Plans and related Information.

The SEVESO III Directive stipulates a number of principles and measures that are to be undertaken to prevent major accidents. Arising from the motivation of the Seveso III Directive, are the following; Clause 16. To prepare for emergencies, in the case of establishments where dangerous substances are present in significant quantities, it is necessary to establish internal and external emergency plans and to establish procedures to ensure that those plans are tested and revised as necessary and implemented in the event of a major accident or the likelihood thereof. . . . . And the public concerned should have the opportunity to give its opinion on the external emergency plan. Clause 19. .. .. In particular persons likely to be affected by a major accident should be given sufficient information on the correct action to be taken in that event. Member states should make information available on where to find information on the rights of persons affected by a major accident. Information disseminated to the public should be worded clearly and intelligibly. In addition to providing information in an active way, without the public having to submit a request, and without precluding other forms of dissemination, it should also be made available permanently and kept up to date electronically. Clause 21. In line with the Aarhus Convention effective public participation in decision-making is necessary to enable the public concerned to express, and the decision maker to take account of, opinions and concerns that may be relevant to those decisions, thereby increasing the accountability and transparency of the decision-making process and contributing to public awareness of environmental issues and support for the decisions taken Clearly the thrust of the SEVESO III Directive is:

• External Emergency Plans have to be established and more importantly tested. • That the public is to receive detailed information on the correct

action to be taken in an emergency without having to ask for it. • To have the public effectively participate in the decision making

EGM

OHSA

On the EGM site, internal tests are in process currently as we now move from our construction plans towards commissioning and operational plans.

EGM and TM have already tested removing the FSU without propulsion from the bay, and moving to the spread mooring system.

EGM has, in line with the Seveso directive, along with the other operators at Delimara and CPD, produced and posted to neighboring towns an updated safety pamphlet. This is also downloadable from our website and was freely available at the public hearing. All of this was, as required of the directive, without need for public request. The pamphlet confirms that the existing and previous recommendations in case of an emergency to our neighbors is unchanged. The description of the siren (tested annually) is included along with what to do in the event of the siren sounding.

Regarding the extent of impact and required public response, EGM understands that CPD safety report scenarios confirm EGM’s own scenarios which do not impact on the towns of Marsaxlokk and Birzebugga.

EGM also pursued a public communications process via the media of TV and print/newspapers, online, and at five of the nearby towns and localities, where EGM staff were on hand to discuss the public’s issues and provide information about LNG. A separate pamphlet was issued at these communication days, which is also downloadable from our website. This process was not required of the directive, but supplementary. Re clause 19: “…at the same time there should be appropriate confidentiality safeguards to address security related concerns, among others”

Re clause 21: Article 22 of the Seveso Directive deals with access to information and confidentiality

Emergency Plans submitted:

Internal Emergency Plan (IEP) by Enemalta

Internal Emergency Plan (IEP) by Electrogas

Internal Emergency Plan (IEP) by D3PG

A separate coordinated IEP for the whole site has also been submitted by Enemalta.

The External Emergency Plan (EEP) drawn up by CPD-

(COMAH Regulation 10(5) states that the EEP has to be drawn up ‘within two years following receipt of the necessary information from the operator’. CPD has already

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process - the Directive specifically uses the term "effective public participation" that is the public is to have an active part in the decision making process and not just be informed.

• The decision maker is to take account of the opinions and concerns relevant to the decision making process.

Direct and effective participation of the public means none other than the public being directly involved in the decision making process , to protect their interests, and not decisions being taken for them by others.

The SEVESO III Directive continues to detail and amplify on the principles involving direct and effective public participation in the decision making process as follows; 2.1 Directive Article 12 – Emergency Plans – Information and Alarms

Clause 5 states - Member States shall ensure that the public concerned is given early opportunity to give its opinion on external emergency plans when thev are being established or substantially modified.. The public concerned - (as defined by the Aahrus Convention meaning amongst others the residents of Marsaxlokk) should have been actively involved in the formulation of the External Emergency Plans when they were being established. Marsaxlokk residents were never consulted at any time prior to the publication of the External Emergency Plan. The majority of the residents are not even aware that an External Emergency Plan exists let alone its contents. The public should have been consulted in this respect before the external emergency plans were published not now that everything is set. Clause 6. - Member states shall ensure that internal and external emergency plans are reviewed, tested, and where necessary updated by the operators and designated authorities respectively at suitable intervals no longer than three years. The review shall take into account changes occurring in the establishments concerned or within the emergency services concerned, new technical knowledge, and knowledge concerning the response to major accidents. The keyword here is - TESTED. - No emergency simulations to test the responses in the case of an accident concerning the new LNG plant have ever been carried out.

Nobody actually knows how an alarm will be sounded and the actions to be taken and routes to be followed in the event of an evacuation.

CPD

prepared the EEP, much earlier than the statutory timeframe.

As required by the COMAH regulations, (regulation 10 (6)) the emergency plans will be tested once every three years once the plant is operational.

Regulation 10 of the COMAH Regulations stipulates that the “the CPD shall ensure that the public concerned is given early opportunity to give its opinion on the external emergency plans when they are being established or substantially modified. This has been done during the consultation period held in connection with the IPPC permitting process.

Regarding clause 19, an information booklet has already been distributed to the public concerned and posted on Electrogas’ website.

Clause 21 is a recital from the Seveso III Directive. The public consultation is referring to the decision making process regarding the siting of Seveso establishments, and is not related to operational requirements. In particular Article 13 of the Seveso III Directive has not been incorporated into the local COMAH regulations but is covered by the Supplementary Planning Guidance issued by the PA. The emergency plans will be tested once every three years as required by COMAH

regulation 10(6) once the plant is operational. Safety reports and emergency plans have been published. Information to the

public is available in printed version and posted on Electrogas’ website All reports have been published during the public consultation exercise by ERA OHSA/ the COMAH CA are not the decision makers regarding the siting of Seveso

establishments and article 13 of the Seveso Directive has been published under the PA’s Supplementary Planning Guidance. Article 15(7) of Seveso III states that ’the detailed arrangements for informing and consulting the public concerned shall be determined by the MS’, and no process is prescribed under the Directive.

In the Seveso III Directive ‘effective opportunities to participate’ is mentioned in Article 15(6) referring to article 15 (1)(a) and (c) regarding the siting of establishments. EEP was published for consultation In the COMAH regulations there is no mention of the public being ‘actively involved in the formulation’. Regulation 10(5) in the COMAH regulations states that the ‘public concerned is given early opportunity to give its opinion on external emergency plans when they are being established’. This was done in the public consultation period. Article 13(4) of the Seveso III Directive states that ‘ Member States may provide for coordinated or joint procedures in order to fulfil the requirements of this Article and the requirements of that legislation, inter alia , to avoid duplication of assessment or consultations’.

The Civil Protection Department refers to reply to comment Ref No. 47. has published the External emergency plan of which part B (Operational) was detained from publication as it has been classified Secret given that the information contained within if made public would be a threat to National Security.In our view, the external

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None of the procedures that may be contemplated in the External Emergency Plan particularly those involving the residents of Marsaxlokk were ever tested. Clause 7. Member states shall ensure that emergency plans are put into effect without delay by the operator, and if necessary by the competent authority designated for this purpose when a major accident occurs, or when an uncontrolled event occurs which by its nature could reasonably be expected to lead to a major accident.

The External Emergency Plan is lacking in this respect. It describes a whole chain of communication links but completely and utterly fails to address the public concerned. Nowhere is there any mention on the document of how the public will be warned, and what immediate action may be necessary. Article 12-3 states that- Emergency plans shall contain the information set out in Annex IV amongst which clause 2 b clearly states that the external emergency plans shall include for " Arrangements for receiving early warning of incidents, and alert and call out procedures." What alarm will be raised if an incident or an abnormal condition arises that may lead to a major accident occurs especially more so late at night or during the early morning hours when many residents would be asleep? Marsaxlokk residents are not even aware of the sound of the respective alarm. Indeed this cases vane calls for repeater alarms distributed in the town to ensure that they are clearly audible and unmistakable, at any hour day or night. The operator must inform the public on how the public concerned will be warned as stipulated in Article 14 which is very clear;

Article 14-1 Member States shall ensure that the information referred to in Annex Vis permanently available to the public, including electronically. The information shall be kept updated, where necessary, including in the event of modifications covered by Article 11.

Article 14-2a For upper-tier establishments Member States shall also ensure that:

All persons likely to be affected by a major accident receive regularly and in the most appropriate form, without having to request it, clear and intelligible information on safety measures and requisite behavior in the event of a major accident.

The information shall include at least the information referred to in Annex V. That information shall likewise be supplied to all buildings and areas of public use, including schools and hospitals, and to all neighbouring establishments in the case of establishments covered by Article 9.

Annex V Part 1, point 5 states;

emergency plan as published contains sufficient information to satisfy legal notice 179/15 and Council Directive 2012/18/EU. Several sessions were held as part of the Public Consultation and feedback on the External Emergency plan was given including several presentations and replies to submitted questions. The general public has been informed on what to do in an emergency through the information booklet that was distributed in each and every household in the area. In view of this it is important to note the following;

As indicated from the information made available by the Operator in the Safety Reports and consultancy provided by international consultants, even in the worst case scenario, the general public will living in Brizebbugia and Marsaxlokk will not be affected.


The external emergency plan will kick in if the Operator cannot handle the emergency and requires CPD assistance. CPD will kick in the external emergency only in the event of a major accident and this does not imply that evacuation is needed. Evacuation will only be required if CPD is not in a position to contain the incident, and as stated earlier, from the safety reports and international consultancy acquired, this will not be the case where LNG is concerned.

CPD will be in a position to instruct the public appropriately only once the accident has occurred and not before as there certain factors, such as weather conditions, which will determine the type of action required.

The CPD actually has two years to draw up the external emergency plan, which period commences from the submission of the safety report and internal emergency plan by the operator. Furthermore the Operator and CPD are also obliged to conduct exercises in the plant at least once every three years from the start of operations.

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General information about how the public concerned will be warned, if necessary; adequate information about the appropriate behaviour in the event of a major accident or indication of where that information can be accessed electronically.

Absolutely no information in this respect including details of the evacuation, have been published.

3.0 - Evacuation and emergency procedures. The External Emergency Plan published by the Civil Protection Department mentions under Article 4.3 – Evacuation that:

“If the situation warrants it the decision may be taken to evacuate not only the non-essential people in the facility but also part of the island residents.”

This obviously gives rise to the following question: What is the extent of the part of the Island that is being considered from which residents will be evacuated??

It is obvious that this is not limited to Marsaxlokk or Birzebbuga only, but a wider region is under consideration. The public concerned especially those that may be subject to evacuation should have already been informed and consulted as stipulated by SEVESO III and not kept in the dark on this very important matter! Furthermore the External Emergency Plan under Part 6 - Advice to the public, delivers in a scant manner, a basic notion of the emergency action that may be taken.

Quoting; "In the event of a Major Emergency at the "Delimara gas and power/ Receiving, floating storage and regasification facilities" it is the responsibility of the CPD and DOI to inform the residents of the island that an incident has occurred

In the event of a major emergency the CPD will inform the community of the incident and the requested actions to be taken by them.

The CPD will inform the local community through the Local Council Contact.

How this may be done effectively during the day and more so during the night, in an emergency situation with limited reaction times requires detailed clarification. The operators representative, ElectroGas Malta Ltd, will distribute an Emergency information card to all households of the local community on behalf of themselves and the authorities.

This information has not been distributed neither to the household, nor any

CPD The part of the island that is being referred to is the Delimara Peninsula. Refer to previous response by CPD. In the event of a major accident the public is being asked to refer to the information booklet that was provided and the Civil Protection Department will provide the necessary information on the media. Local council representatives will also be contacted and informed on the matter and advised on ongoing operations.

The Office of the Prime Minister will be advised on ongoing operations given that it is the ministry in charge of energy and because in any major operation as indicated in the Civil Protection Act and Emergency Powers act the Department of Information is to be involved. This is normal procedure in any major emergency. Any emergency in a Seveso site is considered to be a major emergency and therefore information to OPM is to be provided. The ultimate decision to evacuate or not lies with the Incident Commander of the Civil Protection Department who is on site. Once again from the data available in the safety reports and international consultancy received, even in the worst case scenario any release from the FSU will not require the evacuation of Marsaxlokk and Birzebbugia but notwithstanding the Civil Protection Department has still prepared evacuation plans for both given that both towns lie within the immediate vicinity of other Seveso sites.

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of the establishments many of which are restaurants, nor to the school.

This important information should have been prepared in consultation with the local community and in any case and should also be available online!!

When will the card be delivered ? , after the IPPC process has been approved?, another fait accompli!

After all that has been said to scale down the hazard, members of the public living in that part of the Island, that in the event of an emergency may be evacuated, will surely be surprised to learn that the risks to which they may be exposed are not so minimal as being presented by Electrogas.

The Emergency Card will list the requested (should be requisite) actions to be taken in an emergency and replicate the instructions to be received on the automated phone messaging system.

The public concerned should have been consulted on the requisite actions, and thereafter should have been published long before the tanker was brought into port.

The CPD will take the decision as to whether or not an evacuation of the resident population will take place in consultation with the operator and the OPM

Why should the Office of the Prime Minister be involved in the decision to evacuate the resident population more so when in such urgent situations delays could cause a significant increase in fatalities.

This clearly states that no precise, established and tested procedures on the actions to be taken in such an event have been prepared. The Office of the Prime Minister should be informed that an emergency procedure is being executed, but the decision to execute that procedure should lie with the Civil Protection Department only. An official of the Civil Protection Department who is empowered to raise the alarm is to be stationed permanently at Delimara Power Station.

Furthermore there is no mention of: • The alarms to be sounded in the event of an emergency. • The action to be taken immediately by the residents especially in

an evacuation. • Testing of the external emergency procedures as required by

the Seveso ill Directive., ie Public Evacuation Drills. • Where information can be accessed electronically. • Any prior consultation of the public concerned, more so

when the procedures are being established, as required by the Seveso III and Aahrus Convention.

• The evacuation routes. • Civil Protection Department access routes.

Basically the public even more so the residents and other

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establishments in Marsaxlokk, have not been consulted, have not received any information, and not taken part in any drills to test the procedures, and most of all are being kept in the dark on this important matter.

4.0 Operational Section

The greatest deficiency however has been reserved to the end of the document where it is being claimed that, quote; "The information in the Operational Section (Section B) of this

document is being withheld from publication on grounds of National Security" It is incomprehensible that while the SEVESO ill Directive stipulates that the public should :

• Be involved effectively at an early stage when the establishment

of the External Emergency Plans • Receive detailed information on the external emergency

plans and that these should be available and updated electronically.

• That all establishments in Marsaxlokk, including also the public school should be informed on the details of the External Emergency Plan and the requisite action to be taken in an emergency.

• Be informed of the appropriate alarms when sounded. • Be involved in testing the External Emergency Plan especially

more so in this case in the evacuation procedures mentioned in the report publish by the Civil Protection Department,

all of the above information is being withheld from the public on the basis of National Security On the contrary it is in the interest of National Security that this section should have been published.

In this state of affairs there remains only a few conclusions to be drawn namely: Should the procedures and evacuation plans be made public as stipulated by the SEVESO III Directive , especially those plans concerning the evacuation of part of the Island mentioned in the CPD report, then these would without any doubt give the public concerned a precise picture of the danger to which the public is in fact being exposed.

CPD

The Civil Protection Department has published the External emergency plan of which part B (Operational) was detained from publication as it has been classified Secret given that the information contained within if made public would be a threat to National Security.In our view, the external emergency plan as published contains sufficient information to satisfy legal notice 179/15 and Council Directive 2012/18/EU.

Several sessions were held as part of the Public Consultation and feedback on the External Emergency plan was given including several presentations and replies to submitted questions. The general public has been informed on what to do in an emergency through the information booklet that was distributed in each and every household in the area.







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The scale of the evacuation is proportional to the scale of the hazard and its extent in the event of an incident. This cannot be contradicted.

Furthermore to withhold information of such a nature, to withhold information that regards the safety of the public, against the stipulations of the SEVESO lI1 Directive adopted into the Laws of Malta, is in itself unlawful.

5.0 The present position of the Civil Protection Department on this matter In a report carried in the media most notably in the edition of Saturday the 29th October 2016 of the Times of Malta, the Civil Protection Department had declared that:

• It does not yet have the necessary equipment to tackle a major

accident related to the LNG: high- and low- expansion foam, LNG detection equipment aexplosion proofradios.

• It is insisting on specific training for its personnel. • It would not be held responsible for accidents relating

to the LNG tanker itself specifically quoting " the CPD will not take care of the marine side of the projects, which include the jetty via which gas will be transferred from the storage tanker that will be stored there for the next 18 years.

• As it stands today the CPD lacks the expertise, assets and resources to tackle the emergency response from the marine side.

The report continues that in the event of an emergency the CPD will still take on its role of coordinating emergency response with other stake holders such as Transport Malta. However even Transport Malta took exception and refused to assume responsibility in case of an accident involving gas.

The Civil Protection Department stated that although some improvements have been made, the CPD still lacks the expertise and marine equipment, basically sea fire engines, and will not be able to tackle any fire or explosion on the LNG tanker itself or the jetty

This report on the state of preparedness of the CPD at this very late stage is alarming and exposes serious deficiencies as follows:

• The CPD does not have any equipment to tackle an incident from the marine side. • The CPD lacks the technical expertise necessary to tackle the

emergency response from the marine side.

CPD Confirmed that that was the position of the Civil Protection Department did not have the necessary knowledge and equipment to tackle LNG borne incident when the quoted e-mail was sent. Since then approximately 2 million euro worth of equipment have been dedicated to this issue and now the Civil Protection Department is ready and able to tackle any LNG related incident.



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• The CPD refuses to assume responsibility to tackle accidents from the marine side of the project including the tanker and jetty.

• Transport Malta also refuses to assume responsibility. • At present the CPD is not prepared to tackle any fire or

explosion on the LNG tanker or the jetty. This state of affairs leads to other important conclusions as follows:

• That the CPD has to date not carried out testing of any procedures it may have prepared to tackle a fire or explosion as reported either on the tanker or the jetty, in line with the requisites of the SEVESO III Directive.

• In the present state the operator is in no position at all to

activate an emergency response in the event of an accident as required by the SEVESO III Directive.

Neither the Civil Protection Department nor Transport Malta will

assume responsibilities in the event of an incident on the Tanker or Jetty.

This situation is probably the explanation as to why Section B - the Operational Section was not published. In a situation where the Authorities are unable to assume their responsibilities in the event of an incident it is not that difficult to assume that this section may in fact be void. The statement that the information is being withheld on ground of National Security in the light that both the Civil Protection Department and Transport Malta refuse to assume their responsibilities in the event of an accident on the LNG tanker or the jetty, is unacceptable and the details of the Operational Section (Section B), if available, should be published entirely without any further delay.

6.0 CONCLUSIONS

1. The External Emergency Plan prepared by the Civil Protection Department is in effect no plan at all. It may at best be described as a collection of some basic ideas that may contribute in some way to the formulation of a plan.

2. The Plan presented ignored the basic stipulations of the SEVESO III Directive

No consultation with the public concerned was carried out even at the early stages of the formulation of the plan.

CPD

The Civil Protection Department has published the External emergency plan of which part B (Operational) was detained from publication as it has been classified Secret given that the information contained within if made public would be a threat to National Security.In our view, the external emergency plan as published contains sufficient information to satisfy legal notice 179/15 and Council Directive 2012/18/EU.

Several sessions were held as part of the Public Consultation and feedback on the External Emergency plan was given including several presentations and replies to submitted questions. The general public has been informed on what to do in an emergency through the information booklet that was distributed in each and every household in the area.

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There has been no effective public participation, that is the public is to have an active part in the decision making process and not just be informed.

No information about how the public concerned will be warned is available.

No information on the appropriate behaviour especially during an evacuation as is being considered by the Civil Protection Department is available.

No testing of the emergency procedures to be taken by the public concerned in the event of a major accident has taken place.

No emergency evacuation exercise has ever taken place..

No information on the procedures to be followed in the event of a major emergency, including evacuation has been distributed to all establishments and public places including the School.

Indeed the greatest deficiency is that the operation section (Section B) of the document has been withheld from publication on the grounds of National Security, a reason that specifically runs counter to the stipulations of the SEVESO ill Directive.

3. The report exposes serious deficiencies as follows:

The CPD does not have any equipment to tackle an incident from the marine side.

• The CPD lacks the technical expertise necessary to tackle the emergency response from the marine side.

• The CPD refuses to assume responsibility to tackle accidents from the marine side of the project including the tanker and jetty.

• Transport Malta also refuses to assume responsibility.

• At present the CPD is not prepared to tackle any fire or explosion on the LNG tanker or the jetty.

4. This state of affairs leads to other important conclusions as follows:

That the CPD has to date not carried out testing of any procedures it may have prepared to tackle a fire or explosion as reported either on the tanker or the jetty, in line with the requisites of the SEVESO III Directive.

In the present state the operator is in no position at all to activate an emergency response in the event of an accident as required by the SEVESO III Directive.

Neither the Civil Protection Department nor Transport Malta will assume responsibilities in the event of an incident on the Tanker or Jetty.

5. The plan does not consider the following possible scenarios

OHSA






The CPD actually has two years to draw up the external emergency plan, which period commences from the submission of the safety report and internal emergency plan by the operator. Furthermore the Operator and CPD are also obliged to conduct exercises in the plant at least once every three years from the start of operations

1. The process adopted is in line with the COMAH regulations L.N. 179/2015 (and the Seveso III Directive)

As required by the COMAH regulations, the EEP was prepared by the CPD and issued for public consultation.

This is a subjective opinion – the public, including through the respective Local Councils was given every opportunity to be involved in the process. This is included in the information leaflet published

This is included in the information leaflet published

This is included in the information leaflet published

The emergency plans will be tested once every three years as required by COMAH regulation 10(6) once the plant is operational.

EGM to start evacuation drills for plant employees during the 2nd week of December

This is included in the information leaflet published.

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A major accident during ship to ship transfer in port, when the supply vessel the LNG carrier is in port to replenish supplies to the floating storage unit FSU already moored to the Jetty.

Consideration should be given to the situation where an accident occurs during disconnection of the vessels in the manoeuvring that will be necessary to move possibly both vessels to their storm positions or outside the port of Marsaxlokk.

A major accident as a result of a determined attack on the FSU or the FSU and LNG Carrier combination during a refuelling operation.

6. Notwithstanding the conclusions mentioned in points 1 to 5 above, the residents of Marsaxlokk have been, and continue to be, held in the dark on a matter that exposes them to risks that realistically considered will be fatal.

Indeed the COMAH report has identified scenarios to be of category E5 i.e. having a low portability but being catastrophic and extreme with a relatively high number of fatalities/deaths.

The residents of Marsaxlokk and other members of the public concerned are being exposed to risks about which they are neither informed nor counselled on the appropriate action to be taken in a major emergency. Moreover when the same Civil Protection Department charged with safeguarding human lives and property refuses to assume responsibility in the event of a major accident than a permit to operate the plant should not be issued. The report as presented by the Civil Protection Department should have been accepted for consideration by the Environment and Resources Authority in the first instance, as it specifically runs counter to the stipulations of the SEVESO III Directive and is clearly in breach of the same. In these circumstances and taking into consideration the several serious deficiencies uncovered in this report than a permit to operate the plan should not be issued by ERA. This responsibility of a decision to uphold the stipulations of the SEVESO III Directive, and to safeguards the population now lies with the Environment and Resources Authority only.

Withholding of any information by the CPD on the grounds of national security is wholly permissible under the Seveso III directive and the COMAH Regulations.

The plant is not yet operational – any references in the Seveso Directive and the COMAH Regulations to emergency plans (and anything ancillary to them)refers to a site which is already operational.

According to the Civil Protection Act and the COMAH Regulations, CPD is the competent authority with regards to emergency preparedness, and is the entity entrusted with preparing the EEP. ERA has no role in this regard.


Public Meeting

Nautical Quantitative Risk Assessment

Nautical QRA does not cover on shore hazards. Nautical activity in the bay of M’Xlokk was not treated in this report. Acceptance criteria used in this report were cut off values acceptable to Dutch Authorities etc and no reference to Malta has been done EGM

This is not the latest QRA. Updates have followed and plans have been re-designed for the storm mooring system. The design of 1 in 100 year on mooring system now show sdifferent results from the original. The activities of every single ship, vessel and boat have been recorded for the year 2013

Further to the reply given during the public meeting EGM have clarified the following:

Correction: This is the latest nautical QRA (during the hearing it was assumed the speaker was referencing the preliminary QRA for the development permit)

In the absence of Maltese cut-off values, limits or codes in general, other applicable European or respected equivalents have been applied in consultation with and by agreement with the COMAH competent authorities

Mooring System – with a 2.5 m wave the mooring line will not resist even if this is a chain and hence the pressure will be on the other 7 lines. Will these EGM

The vessel designed for 1 in 100 year event and the actual significant data based upon 20 knots of wind and 3.41m of wave height inside the bay. Safety factors for equipment have been provided and BV certification shows that if 1 line fails, the rest

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withstand? Or they will start succumbing one after the other? There is this possibility. The shallow waters of M’Xlokk have also been mentioned as inadequate for a mooring system.

of the lines will withhold the vessel into position. Line no 8 is the worst line but if this fails, the rest will be there to hold.

Further to the reply given during the public meeting EGM have clarified the following:

This response is a comprehensive reply to the spread mooring system timeline, design and operations.

DESIGN:

The scope of Marin in relation to mooring of the FSU was to review:

the mooring of the FSU at the jetty,

the mooring of the FSU and LNG carrier vessel alongside, at the jetty,

and finally the FSU in the spread mooring position.

Marin undertook the marine studies for the project analysing the wind and wave data. The jetty and the spread mooring system design were based on the Marin reports.

Further to the various studies and due to jetty mooring operational weather limits, the FSU will need to disconnect from its jetty moorings as the weather escalates beyond the operational thresholds and before the storm approaches the operation site. During storm, it is intended that the FSU is moored through the use of a spread mooring system.

2014/2015: Marin began to review the concept of spread mooring which was at preliminary design stage from the EGM tender submission. However the response was not acceptable for holding the FSU in the conditions required and thus EGM and FSU owner, Bumi Armada, considered alternative options themselves.

2015: EGM (via Bumi Armada and subcontractors) initially investigated three storm moorings:

Option 1: Conventional Buoy Mooring - The conventional buoy mooring system comprised of four clusters of three catenary legs that are connected to the seabed by drag anchors. At the top, there are hawsers and intermediate mooring buoys for each line. The connection between the buoy and the anchor leg is via two segments of mooring chain: a top section of single chain and a lower section of double chain to add to the restoring characteristics of the mooring system and to reduce uplift.

Option 2: Taut Mooring System - The taut mooring system comprised of four clusters of three taut legs connected to the seabed through the use of piles.

Option 3: Mooring Tower - Each mooring tower comprised of a surface buoy that is connected to the seabed through the use of a single highly tensioned polyester rope and anchor pile. The twelve mooring towers are grouped into four sets of three and are connected to the vessel fairleads using polyester hawser lines.

The concept designs were issued to Tug Malta, Malta Pilots and TM for their review and comments.

The feedback received from the above mentioned authorities was that surface buoys would cause an obstruction and be in the way of other traffic. For these reasons EGM did not develop any of the above options further which required surface buoys.

In development of the taut mooring system, a sturdier option, which would cover the requirements of the local conditions was refined. This option is a spread mooring

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system for FSU that consisted of a 4 X 2 configuration. Each of the mooring line is made up of combination of 152mm ORQ chain, 95mm R4 chain and clump weights with tubular piles as anchors.

In order to develop this option further and undertake the detail design of the system additional data and runs had to take place. The detail design required more results from the original analysis undertaken by Marin. This is the only reason there is a difference in date between the original reports and then updated version with the additional data.

In parallel to EGM and their Contractors developing the above mentioned option, discussions with a global leading company on storm mooring solutions were commenced to develop a more environmentally friendly and optimised option for the storm mooring system. This company was Ocean Installer Inc. The design basis for Ocean Installer was the same as the piled option however without the use of piles which would require lengthy and disruptive installation works in the harbour.

This spread mooring system meets all the criteria set by the Authorities, the standards and guidelines that had to be followed and is certified by a competent third party classification society.

The final system consists of over 2Km of chains and anchors:

Pulling Chain: 64 mm Studlink pulling chains 952m length

Top Chain: 95 mm Studless top chains, 556m length

Ground Chain: 140 mm Studless ground chains, 399m length

Triplates: Lower Triplates (8 off) and Upper Triplates (8 off)

Triple Chain: 133 mm Stud link Outer Chains and 127 mm Studless Middle Chains. The outer chain is 65.4m in length and the middle chain is 64.5m in length

Stevshark Mk5 anchors

Stevpris Mk6 anchors

Shackles and connecting links

The analysis methodology was based on industry standards as well as the Bureau Veritas requirements.

All environmental parameters were based on the Marin reports (including the additional data). In addition, wind and wave loads were modelled as per SIGTTO guidelines

156 wind and wave load cases were run to find out the impact of local extreme forces on the FSU.

The 1 in 100 year event results in a 3.14m significant wave height and wind of 25.4m/s.

SIGNIFICANT WAVE HEIGHT:

The significant wave height is a value to characterise a “sea state”. The significant wave height is defined as the mean of the highest one third of the waves,

In a sea state that lasts 3 hours, there can be 1000 – 1500 individual waves, depending on the mean period. The maximum wave during that 3 hour sea state will be much larger and can be 1.8 – 2 times the significant wave height (as per guidelines). So during a sea state characterized by a significant wave height of 3.14

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m, the maximum wave height can be 5.65-6.28 meters.

As explained above, the system is designed for the 1 in 100 year event. Additional safety factors have been applied for mooring line components for the intact condition of the system, ballast and loaded draft, offsets calculated for the intact condition of the system at maximum line tension position, which means that the system can withstand conditions greater than the 1 in 100 year event.

Single line failure analysis and anchor capacity calculations were undertaken and the results showed that even if one line breaks completely the remaining SMS can withstand the forces and stay intact. In addition, sensitivity checks on the system were performed.

OPERATIONAL USE OF THE SPREAD MOORING SYSTEM:

A notification system will be in place between EGM, the FSU operators and TM along with notification to Enemalta and other affected parties.

An agreed weather forecasting tool is being used by EGM and the FSU operator which shall form the basis for agreed decision making between them. This tool provides 6-hourly forecasts which will be subsequently compared with actual weather data recorded by the weather station on the EGM jetty to improve the forecasting accuracy over time

Internal discussions between EGM and the FSU master will initially take place based on the forecasted weather.

A 5 day weather forecast of severe weather will be received and trigger first analysis internally within EGM and the FSU Operator.

Then at 3 days ahead of a severe weather forecast EGM will hold discussions with TM, pre-notifying them of a risk of either using the spread mooring system and/or if there is a risk of disconnection from the spread mooring and potentially leaving the harbour.

24 hours ahead of using the Spread mooring system or disconnection from the spread mooring system, the weather shall be reviewed and a decision taken based on the forecast of the agreed weather forecasting data. This will allow the FSU to move before the sea state goes above the operational limits of the tugs (2m).

Weather permitted the FSU will remain on the storm mooring system, unless the forecast is above the limits of th 1 in 100 year storm or in any case if the Harbour Master requests the vessel to leave the bay.

Additional to the planned disconnection procedure described above, the FSU operator is able to disconnect quickly from the chains of the spread mooring system. This is not a preferred operation and is limited to when the FSU is requested to leave immediately by the Harbour master, presumably on account of potential security or safety issues.

FSU and regasification unit shall be located outside the port and this is an alternative that shall be considered. ERA What is being considered is the proposal as presented by the operators and

approved from a development aspect.

Cloud Dispersion – What is the national acceptance criteria for deaths? As Malta has no such acceptances, is this legal?

EGM

Since the development permit all calculations have been re-run with up to date data to the location and which do not refer to the preliminary QRA.

Further to the reply provided during the public hearing EGM have provided the following clarification:

In the Safety Report/Risk Assessment, the proposed risk acceptability criteria was discussed and agreed with the Competent Authority and their independent

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Dr George

Papadakis

consultant, and compared to risk criteria acceptance applied in other EU countries. Actually, the risk ranking matrix is similar to the one applied in France for major accident scenarios at Seveso sites..

With regards to cloud dispersion, as a conservative approach, it was considered 100% fatalities for people exposed within the LFL contours, without any consideration for wind direction.

Since the preliminary QRA produced at the development permit stage, all the calculation carried out in the Safety Report have been re-run with up-to-date data from the project, including release source flowrates and maximum consequence distances.

Dr Papadackis stated that the preliminary QRA is not up to date and not taken into account for the operational permit. This preliminary QRA formed part of the 2013 EIS. For the purposes of the operational permit further studies were carried out to ensure that the latest information is considered for any required outcomes.


Letter and email submitted linked to Ref#52

26.11.16 Nautical Quantitative Risk Assessment (QRA) 1.0 Preamble This document is a response to document item 6: Nautical Quantitative Risk Assessment {QRA) Report No: 27689-6-MSCN-revl dated 18th December 2015.

This document is to be read in conjunction with Document ref B.01.03 dated the 24th January 2014 presented as part of the EIA process. 2.0 Introduction The time allowed to review the volume of documentation published carefully is clearly insufficient. This observation was already made at the EIA stage when similar detailed studies were published a short period before the Christmas festivities.

It is reasonable to expect that the time allowed for review should be proportional to the volume of documentation under study, so as to permit careful analysis and argumentation during the process that is due.

This is clearly not the case. This document again concentrates on the main priority, that is the main concern of the author and shared by the majority of residents, as attested by the Social Impact Assessment, i.e. the risk to life and property posed to the residents of Marsaxlokk by the Floating Storage Unit (FSU) and associated LNG delivery infrastructure both located at Delimara Power Station.

ERA

ERA is following the required legal procedure under IPPC in which there is public consultation and then there is time for taking on board comments from the public to determine whether these will be reflected in the permit or replied to. Following this, the conditions of the permit will be discussed and the permit will be presented for a decision. After the public consultation there are no specific timeframes. The IPPC regulations specify that the consultation period should be that of 30 days which has now been extended to 40 days.

3.0 Scope of the study.

Concisely stated the purpose of the Nautical Quantitative Risk Assessment( QRA) is to assess the probability and extent of;

• death and injury to people

• damage or destruction of buildings and equipment

as a result of a major incident either on the FSU the LNGC, or the jetty

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with its cryogenic shore connection.

4.0 Limitations.

The Quantitative Risk Assessment presented is qualified by conditions and limitations as follows: Existing Nautical Activity - Not included in QRA. The QRA presented by SGS states under clause 2.1 that

"any other onshore hazards related to the same project have already been addressed in a first approach in the preliminary QRA and must be addressed in detail in the safety report of the establishment."

The author Ms. Silva continues that

" Likewise any other hazards due to the already existing nautical activity in the port must be considered out of scope"

This last statement is surprising considering the number of daily ship movements in the port of Marsaxlokk and also movements by other tankers to Delimara Power Station and the Dolphin nearby.

That these activities and their impact on the LNG vessels and associated installation has been considered out of scope of the study is a serious shortcoming, because of the undeterminable increase of possible incident scenarios. Limitations

The study as presented is subject to a set of limitations {Pg12/79), one of which is of particular importance. This is quoted as follows

"Apart from these, another indirect limitation of the study is the result itself of cited nautical risk assessment [7] provided by MARIN which in turn is based on the acceptance of several limitations as specified in the reference. Additionally, MARIN report (ref [7]) shall be considered as part of this report in order to fully understand the nautical scenarios, their limitations, the manoeuvring considered the type of vessels considered, etc "

The Nautical Quantitative Risk Assessment (QRA) - Final Report, dated the 18th December 2015 is subject to the limitations in reference [7] ie MARIN report "Nautical and risk studies for the Delimara LNG Terminal in Marsaxlokk port, Malta item 5: Nautical risk assessment study (27689-5-MSCN), 2014 In addition the reports and memo published by Marin, after the reference document [7] was published in 2014 namely;

• MARIN item 3 Moored Ship Response Study Report 27689-

3PO dated the 18th December 2015 that concludes that serious limitations regarding mooring system exist.

• MARIN item 8 Additional moored ship response calculations Storm Mooring Report No: 27689-9-POdated July 2016 versionl.0. (Piles & Clumpweight System)

• Marin Memo Simulations and Results with modified Storm Mooring System dated the 3rd August 2016 (Anchors & Tri-Chains)

EGM The quoted sentence refers to the risks of other collisions not involving the FSU or LNGC such as between two container vessels. It is obvious from the report of the nautical risk study that the collisions of all other traffic with the LNGC are taken into account.

In relation to Marin mooring studies queries raised by this letter, please refer to answer to Q52 above

The Nautical QRA carried out by SGS focuses on the consequences of the release of LNG after a collision leading to damage of the tanks of the FSU or LNGC. The additional calculations for the spread mooring system were carried out after the nautical QRA by SGS as the design had not yet been finished. However, this is considered acceptable as there would be no revision or new scenario as the probability of collision is less (due to the limited time the FSU is at the spread mooring over the course of the year), and the outcome of the collision scenario would be the same or less in terms of the safety report worst case analysis. This was discussed with the external advisor to the COMAH competent authority.

The note regarding the 50 year condition criticality refers to a previous design of spread mooring system which is not developed and not the final chose design. The author of this letter should refer to the later sections of the report dealing with the actual design installed. This is further explained in our response to Q52.

Considering a probability of occurrence of 10·2/year together with a catastrophic event is not correct. It is not correct to say that a line will break every 50 or 100 years and the author is referring to incorrect spread mooring design as well as relating a catastrophic event directly to a one-line break.

Failure of one mooring line does not mean that the whole mooring system will fail. It is designed with safety margin even with one line broken as there is redundancy of n+1 on each leg of the system.

As part of the prevention measures, the jetty will be provided with a weather monitoring system. In the case of forecast severe weather conditions, beyond 1 in 100 year storm conditions, decision will be taken to tug the FSU out of the port, together with the operator and TM (see response to Q 52.).

Moreover, the FSU is provided with double hull strength and no major LNG spillage should be considered, even in the unlikely event of grounding. This has been proven from historical data on LNG carrier: they have been been run aground, suffered weather damage, been subjected to low suffered weather damage and been involved in serious collisions with other vessels, and no major LNG spillage occurred.

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were not included in the Nautical Quantitative Risk Assessment being presented ( 27689-6- MSCN-revl, dated is" December 2015). The QRA study presented therefore does not include the important limitations and deficiencies regarding both the jetty and storm mooring systems, that the reports published by MARIN after the 18th December 2015 bring to light.

This is another serious shortcoming, as the analysis presented in the report does not factor in the various scenarios that may develop as a result of a failure of the mooring system, which would have definite marked impact on the probability calculations, significantly increasing the uncertainty of the results of all the studies The effectiveness of the mooring system in itself is limited by the wind velocity (speed and direction) as well as the wave height. These are shown to be particularly critical under conditions that develop in 1 in 50 year storm events, ie having a probability of occurrence of 2 x 10·2 /year.

The probability of a failure of the mooring system is of a relatively much higher order. When added to the probabilities of the failures considered in the Qualitative Risk Assessment as well as to the probabilities of events that have not been considered, this has a strong overriding effect, raising the probability of an incident to the order of 2 x10·2/year. The studies also show clearly that the loading on line 8 will become critical in 1 in 100 year storm events, bringing the reliability of the whole mooring system in such conditions into question. The situation has a probability of occurrence of 10·2/year A probability of failure of 2 X 10·2 I year situation is unacceptable by any international standards. In such circumstances, a catastrophic incident will indeed likely to occur as shown in the Common Risk Matrix detailed in the COMAH report dated 18.10.2016 (pg23/51) It is incomprehensible that the limitations of the mooring system stated above, should have been left out of the QRA. This is a serious deficiency in the whole QRA, to the point that the whole of item 6 - Qualitative Risk Assessment, requires wholesale revision, on this point alone.

5.0 Risk Estimations & Gas Cloud Extensions The risk contours shown in Appendix A are circles centred on the jetty I FSU manifold. The fact that the contours are circular means that :

• the topography of the surrounding landscape was considered as being completely flat and wind can come from any direction. This is not the case. In fact the Delimara Ridge as well has the San Lucian promontory will effectively channel any cold, heavy and therefore low gas cloud dispersions either away from or worse still into the population centre of Marsaxlokk under appropriate meteorological conditions.

EGM

In the Safety Report, the Consequence Analysis was carried out by using PHAST 7.11 software, released by DNV GL. This software has been validated for application to LNG release scenarios.

It is true that PHAST is a 2D software tool, therefore effects of topography are not considered. Actually, the cloud dispersion calculation is reliable for wind direction towards the open sea side of the project. The topography would provide effective mitigation against dispersion of any cold cloud formed on LNG spills, as well as limitation to thermal effect of any large pool fire, towards the Delimara Peninsula. In this direction, the results may be conservative. This limitation in the extension of the cloud was also stated in the SGS Preliminary QRA.

During the public hearing, CPD presented the cloud dispersion results, using a 3D model which confirm the topographiy effect. And the maximum extent of the cloud

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The influences of wind and sea currents were not considered.

Considering the wind data included in the QRA, it is expected that the risk contours would be in the form of elongated ellipses, certainly not circular in form. This matter was already indicated during the EIA Consultation but seems to remain unchanged.

In fact to support this argument, in one of the cases considered by Dott. Vaccari in the QRA preliminary report presented by SGS. Dott. Vaccari calculated that a flammable gas cloud could develop, and would have a length of 2,306m and a width of 1,582m. The calculated time for the development of the cloud would be 794.96 seconds ie 13 minutes, too shortfor any emergency response.

Such a gas cloud has the potential under the appropriate meteorological conditions to travel over water without being ignited, and to cover the whole of Marsaxlokk. In a similar manner it could also cover most of Malta Freeport Terminal and Birzebbugia. This cloud will then definitely find a source of ignition when over the populated areas. The ignition of such a cloud having Maximum Explosive mass of 835,000kg or 835 Tonnes, as calculated by Vaccari in the preliminary QRA, will certainly have catastrophic consequences with a high number of fatalities well beyond the minimum of 40 indicated in the preliminary QRA FN curves and far greater than the 4 fatalities indicated in the current study(pg 69/79)

The data is tabulated on page E21 and E22 of E425 of the QRA Preliminary report.

Furthermore, in the considerations presented in the QRA Preliminary Report (pg69/75) it is stated that

" .. .it's easy to see how a flammable gas cloud can rapidly travel from the release point to some part of the Delimara peninsula or to the existing Delimara Power Station. Specially in the DPS, a large number of different ignition points would be present, so that ignition is almost certain "

This statement confirms that it is possible for a flammable gas cloud to rapidly reach the population centre in Marsaxlokk and find an ignition point there, with extreme consequences on the population.

In addition Vaccari concluded in the same Prelimary QRA Report (pg 70/75) that;

"The comparison between the three options using the extension of the gas cloud contour, clearly demonstrates that for the three options a flammable gas cloud can travel to the Delimara Power Station and easily find an ignition point, there with devastating effects on the Maltese power system"

Vaccari states in clear terms that a gas cloud that reaches

Enemalta

dispersion was similar with no major changes to the outer limits.

In the case of a vapour/gas dispersion, the cloud shape describes a “plume” in the downwind direction. In the Safety Report/Consequence Analysis, for each cloud dispersion scenario, the maximum extent was calculated and represented as a circle, without any consideration of wind direction and topography.

The most recent safety reports should be those which are referred to now. This includes the operator safety reports for Delimara (Enemalta, EGM and SEP), the report carried out independently by CPD and the report independently carried out by the COMAH competent authority’s external advisor..

Ignition source within the DPS area as well as domino effects between EGM and Enemalta have been considered in the Safety Report as well as in the coordinated Safety Report. There is no scenario which would have devastating effects on the whole power plant.

:

It is important to note that as one would expect, a number of risk assessments have been carried out from the onset of the project. Risk Assessments have been carried out at the various stages of the project, each time highlighting potential concerns so that the necessary actions may be taken and the effectiveness of those actions re-assessed in the next assessment. The information being extracted and quoted form part of the Preliminary Quantitative Risk Assessment dated August 2013. The purpose of this assessment was to evaluate floating and land based storage options, making conservative assumptions based on the information available at the time. This document was then updated in December 2013 to assess the potential risks of the floating storage option, and submitted as part of the EIA application.

The August 2013 assessment conclusions have been submitted as a reference document as requested by the IPPC process to reflect the works carried out during the EIA.

It is important to note however that since the preparation of the December 2013 report, the detailed design of the project was completed, including the incorporation of suggested safeguards allowing for an updated assessments to be performed. In conclusion the statements being referenced are based on a report that has been superseded. Therefore it is suggested that reference is made to the final safety report so a holistic view of the studies can be carried out.

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Delimara Power Station will definitely find an ignition point. This will result in a deflagration/ explosion that will cause a good number of fatalities (deaths) and result in serious injuries of station personnel, and also lead to the devastation (destruction) of the generating plant.

This situation will not only have catastrophic consequences on the Maltese Power System only but also on the Maltese economy as a whole

6.0 Vassilikos Power Station Disaster

The scenario presented above bears the same hallmarks of another serious incident that occurred in Cyprus.

On the 11th of July 2011 munitions and explosive material that had been held for 2 years at the Evangelos Floralis Naval Base in Cyprus exploded, and destroyed Vassilikos Power Station some distance away. Of the 700M facility only a mangled shell remained.

The loss of Vassilikos Power Station resulted in the Electricity Authority of Cyprus losing some 47% of its generating capacity in an instant, giving rise to long term rolling long duration blackouts.

The rebuilding of the lost capacity lost several months and was estimated to cost US$2.83 billion.

On the 20th of May 2016 a court in Cyprus found the Government of Cyprus to be guilty of criminal negligence for its role that led to the devastation of Vassilikos Power Station.

Dr Papadakis

The cause of the accident was the storage of munitions and other explosive material in an adjacent military site. No similar scenario exists in Malta.

7 .0 Consequences in the event of the loss of Delimara Power Station.

When compared to the damage suffered and caused by the Vassilikos Power Station accident, the scenario considered by Vaccari would have consequences that are even worse, as Delimara Power Station is the one and only power station that is operational in Malta.

The only source of power left will be the Sicily-Malta lnterconnector, that with a power capacity of 200MW will only cover about 45% of the national demand. A good proportion of this capacity will in such circumstances, be utilised to supply the reverse osmosis plants for the production of potable water.

Without the continuous production of potable water, the reserves available will be exhausted in 3 days, after which the country will face a serious water crisis.

Moreover as a result, severe electrical power supply restrictions, and rolling blackouts to industries businesses and homes, will have to be introduced to manage the severely limited power source available. The devastation of Delimara Power Station as mentioned by

EGM

Enemalta

Domino effects thresholds from a large pool fire from the FSU or at the Regasification do not affect the near diesel fuel tanks or Delimara plant.



It is important to note however that since the preparation of the December 2013 report, the detailed design of the project was completed, including the incorporation of suggested safeguards allowing for an updated assessments to be performed. In conclusion the statements being referenced are based on a report that has been superseded. Therefore it is suggested that reference is made to the final safety

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Vaccari would therefore cripple the whole economic sector.

The facts and resultant consequences of an incident devastating Delimara Power Station as described in the preliminary report by Vaccari, are being laid bare.

Dott. Vaccari specifically indicated the threat that the LNG FSU in Marsaxlokk Port poses to Delimara Power Station and also directly to the local population. As mentioned at the EIA stage, the LNG FSU should have been stationed outside the port of Marsaxlokk, to remove altogether the risk to the power station itself even if remote.

report so a holistic view of the studies can be carried out.

8.0 Other Scenarios

The SGS report does not consider domino effects as a result of escalation scenarios such as:

• A small leak of LNG, either by material failure or human error, and a subsequent fire remaining uncontrolled causing a larger leak e.g. by a boiling liquid expanding vapour explosion of a closed cryogenic pipeline.

• This may easily escalate further as LNG will embrittle and severely weaken steel including that of the vessel. Only the inner containment is able to resist the cryogenic liquid at -162°C.

• An intentional attack on the LNG FSU and Carrier during a refueling operation.

It is pertinent to indicate that Sandia National Laboratories were tasked by the U.S. Government, to undertake extensive studies into possible scenarios, particularly those that may develop as a result of intentional attack ( 2013 reports).

EGM

Enemalta

In the Safety Report as well as in the Coordinated Safety Report, the domino effects have been addressed, for explosion and jet/pool fire within the DPS area. Plus the safety report does look at LNG leaks.




9.0 Risk Evaluation – High Consequence events

The failure probability/scenario frequency values as used in the SGS reports could, as a result of such considerations be much higher.

In the case of a potentially large incident as mentioned above, the usual produce (consequence x probability) is ignored.

Many risk evaluation studies, not least the one published by the International Risk Governance Council (irgc.org/white paper, 2006, figures pages 37 and 38), indicate that the acceptable probability in case of potentially large consequences, is much lower than that based on the produce (consequence x

EGM

Enemalta

Major accident scenarios were identified and assessed in the Safety Report, including full bore rupture for pipeline and large leak/catastrophic rupture for vessels.

For each consequence, the risk was evaluated as the combination of the frequency and the severity. The frequency takes into account any possibility of domino effects.

It is important to note that as one would expect, a number of risk assessments have been carried out from the onset of the project. Risk Assessments have been carried out at the various stages of the project, each time highlighting potential concerns so that the necessary actions may be taken and the effectiveness of those actions re-assessed in the next assessment. The information being extracted and quoted form part of the Preliminary Quantitative

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probability). Risk Assessment dated August 2013. The purpose of this assessment was to evaluate floating and land based storage options, making conservative assumptions based on the information available at the time. This document was then updated in December 2013 to assess the potential risks of the floating storage option, and submitted as part of the EIA application.



10.0 QRA Conclusions – Acceptable fatalities

One of the conclusions of the Nautical Quantiative Risk Assessment is the following:

“Regarding the societal risk in the unlikely event of an accident, the number of fatalities is acceptable, if compared with the acceptance criteria used in other European Countries with a large tradition of quantitative risk assessment”

The following points arise from this statement. 1. A number of fatalities is to be expected in the event of an accident. 2. The number of fatalities or at least the order thereof, remains undisclosed.

3. The number of fatalities ( unknown) is acceptable when

compared to the acceptance criteria used in other European Countries not with the Maltese National Risk Acceptance Criteria.

The report is based on the following references mentioned in para. 1 of item 2.2 in the QRA Final Report:

1. PADHI- HSE’s land used planning methodology, http://www.hse.gov.uk/landuseplanning/padhi.pdf, 2008.

2. Health and Safety Authority (HSA), Policy & Approach of the Health & Safety Authority to COMAH Risk-based Land -use Planning, 07 September 2009.

3. RIVM Reference Manual BEVI Risk Assessment version 3.2, 2009

4. VROM, Publication Series in Dangerous Substances (PGS 3) - Guideline for quantitative risk assessment "purple book" CPR 18E., 2005

5. (Ph.D.) Vianello Chiara," Risk analysis of gas distribution network"

6. COMAH Regulations. Policy & Approach of the Health and Safety Authority to COMAH Risk Based Land-use Planning.

No reference is to be found of the Maltese National Risk

Planning Authority

The current Planning Guidelines regulating Major Hazardous installation and development within their midst is the Supplementary Planning Guidance on Major Accident Hazards and Hazardous Substances, of November 2004. (http://www.pa.org.mt/LpDocumentDetails?syskey=458)

.This Guidance sets out Planning Policy on development within the existing installation, new development of installation and development within the context of Hazardous Installations. The document includes the criteria for the assessment of proposed development within the consultation zones of Hazardous Installation including justification for allowing or not proposed development. The Annexes include the reasoning in terms of risk as a result of proposed development. The methodology was adopted from HSE of the UK.

Kindly note, that the installation as proposed for the operation permit has a Planning Development Permit as per PA21/14 and PA22/14.

The Authority is currently updating the Supplementary Planning Guidelines on Major Accident Hazards and Hazardous Substances of November 2004. This will also result in updating the risk zones of all existing COMAH sites where applicable.

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Acceptance Criteria in the report presented.

Furthermore no mention or reference to the Maltese National Risk Acceptance Crtieria was found in Maltese Law. This means that there is no legal basis to the claim that " the number of Fatalities is acceptable" as this is not founded on Maltese Law but on , as the author states " the acceptance criteria used in other European Countries with a large tradition of quantitative risk assessment".

It is to be mentioned that the Risk Acceptance Criteria differ from one EU Member State to the other. That is to say what may be acceptable in the UK may not be acceptable in France of Holland, or the Czech Republic, and certainly not in Germany. There exist no unified or harmonized Risk Acceptance Criteria in the EU covering Seveso III sites.

Clearly the author is referring to acceptance criteria used in other jurisdictions, but not the one applicable to Maltese Territory, bringing the whole study once more into question as it is not based on Maltese law. The question "what is the limit of fatalities that are considered to be acceptable in Malta" that is based on Maltese Law, remains to be established.

The conclusions drawn in the QRA report, if accepted would introduce a precedent that will surely be highly controversial namely:

That in Maltese Society human lives may under certain circumstances be considered to be expendable. That economic benefits for a few outweigh the value of lives that may be lost in an accident when the latter are exposed to an involuntary risk .

The profits of a private company will be given priority over the lives of Maltese Citizens.

This concept runs directly counter to the inalienable right of every citizen in this country Malta) to enjoy a peaceful existence in his own home with his family free from any threat or involuntary risks whatsoever. This concept is unacceptable especially more so when another much safer alternative exists - stationing the tanker outside the Port of Marsaxlokk.

In the present circumstances and in the light of the above the validity, and legality of any decision by ERA or the PA approving the operation of the LNG plant would be questionable, even more so in the knowledge that a suitable and much safer alternative is available that of locating the Gas Tanker at a suitable location outside Marsaxlokk Port exists. This would be similar to the installation of the “FSRU Toscana” 22km off Livorno, Italy.

11.0 Conclusions In the light of the facts presented by the Preliminary Quantitative Risk Assessment and furthermore the deficiencies of the Quantitative Risk Assessment- Final Report including:

EGM/

Response given by EGM

Kindly refer to previous individual answers

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That the Quantitative Risk Assessment (QRA) is deficient as it does not consider existing nautical activity in the port of Marsaxlokk at all.

That the QRA presented is deficient as it does not take into consideration the Moored Ship Response Studies and memo published by Marin in December 2015, July 2016 and August 2016, in which serious deficiencies and limitations of the mooring systems adopted were indicated.

• That relatively much higher probability an incident of the order of 2 x 10-2 / year exists, as a result of the higher probability of failure of the mooring system during 1 in 50 year storm events.

• That a risk probability of the order of 10·2 / year is not

acceptable by any international standard. • Other accident scenarios that may develop into major accidents,

including the threat of a direct attack on the FSU or FSU/LNG Carrier were not considered.

• That as indicated by Vaccari, a cold gas cloud at low wind speed

conditions can easily travel to the population centre in Marsaxlokk and Birzebbugia, which will ignite causing a significant number of fatalities (deaths) injuries and damage to property.

• That similarly a gas cloud can much more easily travel to

Delimara Power Station, easily find an ignition point there with devastating consequences on the Maltese Power System as stated by Vaccari.

• That in the event of the loss of Delimara Power Station the only

source of electrical power will be the Sicily - Malta interconnector limited to 200MW. In such a situation, the interconnector may be considered as a life-saver.

• That the consequent devastation of the Maltese Power System will

cripple the Maltese economy. Severe restrictions and long duration rolling blackouts will have to be imposed on industries, businesses and home to manage the limited supply available.

• That the devastation of the Maltese Power System will consequently

also disrupt the capacity to generate potable water from the reverse osmosisplants.

• That the supply of stored potable water is limited 3 days consumption. • That the study does not refer to any Maltese National Risk

Acceptance Criteria, but instead adopted references to Criteria used in other European member states.

The validity and legality of any decision that would allow the operation of the LNG plant as configured would be drawn into doubt, as it would not be based on the Maltese National Risk

Enemalta

Kindly refer to previous individual answers since it does consider this.

See above answer – it has been discussed that there would be no effect of new scenarios

Please note that this is a reference to a different spread system, not used

These are all considered in the Safety Report.. Author is guided to read these subsequent to the preliminary one.

As above

Domino effects thresholds from a large pool fire from the FSU or at the Regasification do not affect the near diesel fuel tanks or Delimara plant

Since the date of the Preliminary QRA a full Nautical Risk Assessment has been undertaken by EGM.

Document being mis-referenced has been superseded.

Document being mis-referenced has been superseded.

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Acceptance Crtieria.

That theacceptance of the QRA study directly implies the acceptance of the concept in which, human lives may be sacrificed in favour of the economic benefits and profits of a private company.

• That the inalienable right enjoyed by every Maltese citizen to enjoy a peaceful existence in his home together with his family free from any threat whatsoever especially involuntary risks would be violated.

• That the alternative to relocate the LNG FSU with the

regasification unit on board at a safe distance outside the port of Marsaxlokk exists, bringing only gaseous fuel onshore, thereby eliminating completely any threat both to the local populations , to Delimara Power Station, and consequently to Malta as a whole is possible, as demonstrated In Livorno, Italy.

• That as established in the Social Impact Assessment as

required by the SEVESO Ill Directive, 91% of respondents in Marsaxlokk and Birzebbugia want the tanker to be located outside the port of Marsaxlokk. This is the will of the people!!!

Than on the basis of the above facts, the Environment and Resources Authority (ERA) should not grant a permit to operate the Plant in its present configuration with the LNG FSU inside the Port of Marsaxlokk.


Email 27.11.16 Queries regarding the estimated fatalities, injuries and damage to property that may result in an accident. I refer to the Public Consultation by the Environment and Resources Authority in the process covering the variation and renewal of the Integrated Pollution Prevention and Control {IPPC} permit IP0002/07/E for Delimara Power Station. The Nautical Quantitative Risk Assessment (QRA) Report, Report No: 27689-6-MSCN-rev.1 states on page 70 of 79 , paragraph 4 ( Doc 1 attached) that:

"in the unlikely event of an accident, the number of fatalities is acceptable" Furthermore referring to the EGM COMAH Assessment Report page 36 of 51 paragraph 3 ( Doc 2 attached) states that:

"In order to evaluate whether the risk of each WSC (worst case scenario) is at acceptable, tolerable or unacceptable level, the Common Risk Matrix (Doc 3 attached) has been applied in the Safety Report, in which each and every scenario has been ranked according to the level of its risk."

Paragraph 4 on the same page, specifically details the following terms

EGM

1. In the Nautical Quantitative Risk Assessment, the isorisk contours and the FN-curve have been produced and are included in the report. Please also refer to page 33 and page 68 of the document which describe the method and the acceptable criteria for individual risk and societal risk.

2. In the safety report, for each scenario, the severity sheets are provided in the Safety Report/Risk Assessment/Appendix 2, with the estimated number of fatalities. The Author is requested to understand the complexity of these calculations which cannot be simplified into a single number as they depend on numerous factors and is thus best to review the appendix referenced.

In the Safety Report, the scenarios in the E5 risk level from:

FSU cargo tanks, Large leak, 250 mm, Flash Fire (F2), FS-011-250-FF (F2)

FSU cargo tanks, Large leak, 1000 mm, Pool Fire, FS-011-1000-PF

LNG liquid header, Full bore rupture, Ship-to-ship transfer, Flash Fire (F2), FS-021-FBR-FF (F2)

LNG liquid header, Full bore rupture, Ship-to-ship transfer, Flash Fire (D5),

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• Risk of an "unacceptable" level. • WCS are within the "broadly acceptable" risk area. • A large number of WSCs are within the intermediate risk area"

tolerable if ALARP risk area" • A limited number of FSU major-accident scenarios (WCSs) exhibit a

risk level of E-5 (E-5; disastrous consequences with remote probability) Question 1: May you please provide the estimated number of fatalities and injuries that are being considered to be:

1. Acceptable, as stated in the conclusion of the Nautical Quantitative Risk Assessment.

2. Unacceptable, broadly acceptable, and “tolerable if ALARP risk are” in each case, as stated in the EGM COMAH Report.

Question 2: With reference to the limited number of FSU major-accident scenarios (WCSs) that exhibit a risk level of E-5 identified in the EGM COMAH Report:

1. Please give specific details of the limited number of scenarios (WSCs) that have been identified in the COMAH Report.

2. Please state the estimated numbed of fatalities and injuries and the extent of damage to property without the additional safeguards that should be implemented.

3. Please details the safeguards that have actually been implemented and are in place today to reduce the risk to “tolerable if ALARP risk AREA” as stated in the COMAH report.

4. Please state the estimated number of fatalities and injuries, and the extent of damage to property, with the safeguards that have actually been implemented.

FS-021-FBR-FF (D5)

LNG liquid header, Full bore rupture, Transfer between tanks , Flash Fire (F2), FS-022-FBR-FF (F2)

LNG loading hoses, Full bore rupture, Ship-to-ship transfer, Flash Fire (F2), FS-051-FBR-FF (F2)

LNG loading hoses, Full bore rupture, Ship-to-ship transfer , Flash Fire (D5), FS-051-FBR-FF (D5)

For these scenarios, the severity sheets are provided in the Safety Report/Risk Assessment/Appendix 2, with the estimated number of fatalities.

And a further check has been applied to these scenario during the ALARP Assessment process, to identify whether they retain their frequency and remain in their initial risk level, if for each of them, the probability of failure of their risk control measures with the highest confidence level is set to 1.

With regards to the scenario FS-011-250-FF, considering that the safeguard “PSV Gx93/Gx94 (x=1 to 5, to atmosphere through Vent Mast 1-5) is rated at 100% capacity and full redundancy of each valve, it can be documented that level E remains for this scenario in case of failure of this safeguard.

The frequency of a large LNG leak in FSU (scenario FS-011-1000) has arbitrarily taken as 10-8 /year. In case of this event, both internal and external emergency plans will be activated..

With regards to scenarios FS-021-FBR-FF, FS-021-FBR-FF and FS-022-FBR-FF, considering the additional safeguard “Preventive Management System”, it can be documented that level E remains for this scenario in case of failure of this safeguard.

With regards to scenarios FS-051-FBR-FF FS-011-250-FF, the ship-to-ship transfer manual is to be considered as Safety Critical procedure.

The intend of these safeguards is to reduce the frequency for these worst case scenarios.


Email 27.11.16 Query on Malta National Risk Acceptance Criteria

I refer to the Nautical Quantitative Risk Assessment (QRA) Report, Report No: 27689-6-MSCN-rev.1 dated December 18,2015 submitted to the Environment and Resources Authority in the process covering the variation and renewal of the Integrated Pollution Prevention and Control (IPPC) permit IP0002/07/E for Delimara Power Station.

The Nautical Quantitative Risk Assessment makes reference and compares the results of the study to National Risk Acceptance Criteria applicable in other foreign states.

Absolutely no mention is made in the Quantitative Risk Assessment of the Maltese National Risk Acceptance Criteria, applicable to Maltese jurisdiction.

Research on this matter on my part yielded no results.

Planning Authority

The current Planning Guidelines regulating Major Hazardous installation and development within their midst is the Supplementary Planning Guidance on Major Accident Hazards and Hazardous Substances, of November 2004. (http://www.pa.org.mt/LpDocumentDetails?syskey=458)

.This Guidance sets out Planning Policy on development within the existing installation, new development of installation and development within the context of Hazardous Installations. The document includes the criteria for the assessment of proposed development within the consultation zones of Hazardous Installation including justification for allowing or not proposed development. The Annexes include the reasoning in terms of risk as a result of proposed development. The methodology was adopted from HSE of the UK.

Kindly note, that the installation as proposed for the operation permit has a Planning Development Permit as per PA21/14 and PA22/14.

The Authority is currently updating the Supplementary Planning Guidelines on Major

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May you therefore please provide details, and a copy (pdf) of the Legal Notice stipulating the Maltese National Risk Acceptance Criteria.

Accident Hazards and Hazardous Substances of November 2004. This will also result in updating the risk zones of all existing COMAH sites where applicable.

56 18.11.16 Dr. Ann Fenech

Public Meeting

The report Wave Climate Studies and the Wave Penetration Studies dated December 2015 are the latest reports? EGM Yes

Reports were based on information from the Ocean Weather Inc. There were no real wave buoy studies. Where is the real time data of the wave buoy data analysis?

EGM

No real buoy data analysis available. Ocean Weather Inc is a global company which is very reliable with the data they provide, that’s why data was taken from there.

Further to the feedback provided during the meeting, EGM have indicated the following:

As per the Marin Wave Climate study, in total 33 years of offshore wind and wave data were obtained from the OCEANWEATHER Global Reanalysis of Ocean Waves Fine Mediterranean (GROW-FINE MED) hindcast at offshore location (35°45'N, 14°37'30''E), see Figure 2-1 of the report. The time resolution of the time series is 1hr.

Ocean Weather Inc is a global company which is very reliable with the data they provide, that’s why data was purchased from there.

Marin response 6th Dec 2016:

“The Oceanweather data used as basis for the study are not from ship observations. These are from a so-called ‘hindcast’ study in which 30 years of historic weather data have been reanalyzed. The results of this re-analysis is a consistent dataset of wind and air pressure for the Mediterranean. These wind fields are the input for numerical wave models that calculate the waves on a grid covering the entire Mediterranean. Satellite observations and buoy measurements are used to verify and calibrate the model results. The use of such data as basis for the design of structures is common practice in civil engineering and offshore industry. Oceanweather Inc is considered to be one of the leading institutes/firms in this work. Historic wave buoy measurements near the port entrance or inside the port from a period also covered by the wave hindcast would have been valuable for validation of the methodology, but these were unfortunately not available”.

“The last version of the [wave study] report was issued in December 2015 upon completion of all study items, but the first draft was issued in October 2014. The draft final was issued in January 2015”

Last paragraph of the report based on the Ocean Weather Inc indicates that the wave height in the bay of M’Xlokk might be higher than that predicted in this study. Results of the study should be treated with caution when designs are made

EGM Real buoy data would require a long time in order to gather the required measurements. Marine reports were originally developed to be submitted to the Authorities and to do the preliminary design. The reason is that the real design required additional data, additional runs and not because the original was not valid, but because we needed more information and more numbers for the population of the software

Marin response 6th Dec 2016

“Note that the wave heights given in the reports are generally the “significant wave height”. This is a kind of mean wave height used to characterize the waves during a sea state; typically a 3 hour period. About 13.5% of the waves in a sea state are higher than the significant wave height. The maximum wave height in such a sea state can be much larger; in the order of 1.8 – 2 times the significant wave height. Estimating a wave height in extreme conditions is not easy; the height of the largest

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waves may be related to some structure, but it is impossible to estimate the significant wave height visually with a degree of accuracy”

“The additional analysis is a reanalysis of the same data as the wave climate studies. In the wave climate studies the wind and waves were analysed independently to find the values for selected return periods for the individual parameters wind speed and wave height. The probability that 100-year wind speed and the 100-year wave height occur at the same moment is smaller. In the additional metocean analysis the wave height expected to occur simultaneously with the 100-year wind was determined and vice versa (wind associated with the 100-year wave height).

Whether waves increase or decrease when approaching the coast or a port entrance depends largely on the situation. Generally the wave height decreases due to processes such as wave breaking and bottom friction, but locally the wave height may increase due to focussing of waves due to the seabed or reflection from structures. The latter occurs in the Marsaxlokk entrance where waves reflected from the breakwater in combination with the incoming waves increase the wave height in the approach. Note that this is taken into account in the wave modelling.

The additional metocean analysis was carried out because the results were not only used for a verification of operational limits, as initially expected, but also for the design of the storm mooring of the FSU.”

Report No 7 re: Metocian analysis; Why were the offshore results applied to the port whilst the near shore results were applied to the bow of the vessel. This is complete distortion of the studies.

If this is an industry practice, this shall be produced.

EGM

It’s common practice to take off shore data thru software and take them to the near shore, and then take the near shore data and take them to the location of the jetty or the structure and whichever that is. That’s why we followed that industry practice to calculate wave and wind forces.

Kindly refer to previous Marin responses above.

In report No 4: maneuvering of the LNG as it approaches the FSU. The report is recommending real life data. Why wasn’t real life data done?

EGM Data has been taken from ships that had visited the port of M’Xlokk. Simulation was carried out to make it as real as possible.

Further to the reply provided during the hearing, EGM have provided the following response:

Real life data is being used, for LNG carrier approaches, from the weather station and monitoring fixed on the EGM jetty.

The simulation.data has been taken from all the ships that come in and out of the port of M’Xlokk. Ship schedule for an entire year (2013) was provided to us and used this real life traffic in the simulation.

The simulations where carried in Malta using the state of the art facilities of the Malta Maritime Pilots. They were carried out in conjunction with the actual pilots who will be assisting in the actual operations of manoeuvring the LNG Carriers to and from the terminal. They were carried out using the specific available tugs that will be used within the harbour and also carried out in conjunction with Tug Malta who will be providing these tug services. The simulation was carried out to make it as real as possible.

Is there an off shore buoy? Since the report indicates that the data was gathered from the Ocean Weather Inc.

EGM There is a buoy on ocean weather Inc. We used the buoy because there is a long history which can actually be put into a model to get the best real data results as we could. However, there will be our own weather station.

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Further to the reply provided during the hearing, EGM have provided the following response:

There is no physical buoy but there is a data point. As per the Marin Wave Climate study, in total 33 years of offshore wind and wave data were obtained from the OCEANWEATHER Global Reanalysis of Ocean Waves Fine Mediterranean (GROW-FINE MED) hindcast at offshore location (35°45'N, 14°37'30''E), see Figure 2-1. The time resolution of the time series is 1hr.

How far out is that buoy?

During the sitting the EGM had indicated that a buoy had been utilized..

Further to the reply provided during the hearing, EGM have provided the following clarification:

Marin response 6th Dec 2016:

“The Oceanweather data used as basis for the study are not from ship observations. These are from a so-called ‘hindcast’ study in which 33 years of historic weather data have been reanalyzed. The results of this re-analysis is a consistent dataset of wind and air pressure for the Mediterranean. These wind fields are the input for numerical wave models that calculate the waves on a grid covering the entire Mediterranean. Satellite observations and buoy measurements are used to verify and calibrate the model results. The use of such data as basis for the design of structures is common practice in civil engineering and offshore industry. Oceanweather Inc is considered to be one of the leading institutes/firms in this work. Historic wave buoy measurements near the port entrance or inside the port from a period also covered by the wave hindcast would have been valuable for validation of the methodology, but these were unfortunately not available.

As per the Marin Wave Climate study, in total 33 years of offshore wind and wave data were obtained from the OCEANWEATHER Global Reanalysis of Ocean Waves Fine Mediterranean (GROW-FINE MED) hindcast at offshore location (35°45'N, 14°37'30''E), see Figure 2-1

The offshore data point is just over 10 km SE (direction 138°N) from Marsaxlokk breakwater head.

No other buoy has been used any closer to Malta? EGM No.

Jetty Classification: Report No 3 – Moored ship response study concludes that at 2.5m wave height and above, the mooring lines will not resist. The safe working load of the mooring line on the FSU will be exceeded. Spread mooring system which have been analysesd that have been analyzed are challenging. The jetty needs confirmation from the BV. In the nautical report here is no certification for the jetty. Is there certification from BV? What did BV Verify?

EGM

Transport Matla

There is certification for the jetty and it’s a fact. And it verifies a 2.5m wave height.

Further to the reply provided during the public hearing, EGM have indicated the following:

The Marin reports analysed the ship responses and the operational limits at the jetty.

The Marin studies have been used to undertake the detail design of the jetty and the storm mooring system.

In addition, please see response to item 52 above.

BV have reviewed and run independent analysis which resulted in BV certification for the following:

- The jetty structure

- The FSU

- The storm mooring system

To date there is no certification from BV for the jetty

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EGM

There is BV certification that will be submitted to the authorities. In the interim there is certification from JPA and AECOM

The vessel can stay alongside the jetty at 2.5m high wave? EGM

Yes

Further to the reply provided during the public hearing EGM have provided the following:

The significant wave height is a value to characterise a “sea state”. The significant wave height is defined as the mean of the highest one third of the waves,

In a sea state that lasts 3 hours, there can be 1000 – 1500 individual waves, depending on the mean period. The maximum wave during that 3 hour sea state will be much larger and can be 1.8 – 2 times the significant wave height (as per guidelines). So during a sea state characterized by a significant wave height of 3.14 m, the maximum wave height can be 5.65-6.28 meters. Please see response on Q52.

Potential failure of storm mooring system Report No 8 July 2016. Why is it that Electrogas opted for the shallow spread mooring system, notwithstanding the warning (report No 3) which said that this challenging?

EGM

We have to deal with shallow water because there is shallow water.

We now have a system which is a 1-100year storm design and is going to be BV certified and will also do dive surveys in the coming days. There is a time lag between the initial studies and the final design. This is classed by an international reputable authority.

Further to the reply provided during the public hearing EGM have provided the following:

EGM has engaged a world leading company on storm mooring systems. We now have a system which is a 1-100year storm design and is going to be BV certified. There was a time lag between the initial studies and the final design.

Please see item 52 above and previous comment (58-10) for more details on the operational limits and wave height information.

The design is a chain lying on the seabed with clamps and the anchor attaches to an anchor pile. An anchor pile is bored in the bedrock and filled with cement and steel. In a month the plan changed thru a memo. Why Electrogas compromises its position and not use piles which is obviously much more secure to an anchor and try chain system>

EGM

In the background we were still discussing this system. We were investigating other options within the exact same parameters with a far lesser impact and which is completely reversible, and one which can be maintained easily. Clamp weights are very difficult to install. The impact to the environment is far less reduced and more in line with the EIA. These have the exact same parameters with minimal impact design.

What kind of reinforcement the vessel had to go through in order that the bollard can withstand up to 600 tons?

EGM Exact details cannot be given, however special winches that are not bollards – chains that are attached to the winches have been specially built.

Further to the response provided during the hearing, EGM have provided the following reply:

All deck steel replacement and strengthening, along with under-deck stiffening, have been completed in accordance with BV rules for steel ships, which is standard practice. Some 500t of new steel has been added in the storm mooring system including chutes, chain-stoppers and deck reinforcements.

And what about what holds the anchor to the vessel? EGM

The deck has been strengthened to take these forces. The design of the mooring system is from the anchor right up to the deck and to the chain locker on board the FSU. The whole system will be BV certified.

Further to the reply provided during the public hearing, EGM have provided the following information:

The SMS system consists of over 2Km of chains and anchors:

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- Pulling Chain: 64 mm Studlink pulling chains 952m length

- Top Chain: 95 mm Studless top chains, 556m length

- Ground Chain: 140 mm Studless ground chains, 399m length

- Triplates: Lower Triplates (8 off) and Upper Triplates (8 off)

- Triple Chain: 133 mm Stud link Outer Chains and 127 mm Studless Middle Chains The outer chain is 65.4m in length and the middle chain is 64.5m in length

- Stevshark Mk5 anchors

- Stevpris Mk6 anchors

- Shackles and connecting links

Letter issued by TM 14 Sept. Has class approvals for the storm mooring been obtained yet?

EGM

Notification is prepared and we are awaiting visibility on the bay to carry out the inspections

Further to the response given during the public hearing EGM have indicated that BV certification of the storm mooring system has been received.

Can electrogas advise what would have happened if there is a storm like the 29th Oct 2016 storm with 7 m high waves at the mouth of the bay. What would have been the effect?

EGM

The design of 1 in 100 year storm parameter is in place. If the design is going to be exceeded the FSU will be safely removed from the harbor.

Further to the response given during the public hearing EGM have indicated the following:

Apart from the fact that the wave height quoted is anecdotal, by the time this particular wave reaches the jetty or the port its energy would be dissipated and will inevitably become a smaller wave.

Please see point 52 and point 58-10 above for more details on the SMS operating limits

Has the vessel been equipped with quick release hooks as per SIGTTO guidelines? Is there a quick release hook mechanism as obliged to install? All mooring points shall be equipped with quick release hooks. When the ship need to get off its mooring, how are going to get the mooring line go?

EGM

The vessel has special winches specifically built for this mooring system. The ship has quick release hooks for the LNG. These have been installed.

The vessel has and can quick release hooks to disconnect from the jetty. The storm mooring is a safety protection devise for the FSU and it has as well.

Further to the response given during the public hearing EGM have indicated the following:

SIGTTO guidelines do not cover nor require Quick Release Hooks for storm mooring systems. Please refer to answer on Q52 for operational details.

How is the link going to be removed during a 3m height wave?

EGM

The whole system is based on predictions. We shall take predictive conservative action. There is a procedure to have a planned control move out of the harbour if there are predictions.

Please refer to answer on Q52 for operational details.

How can the vessel be taken out when it’s a dead ship in storm conditions? How are you going out of the M’Xlokk Bay from her storm mooring when the engines have been removed?

EGM We already practiced with TM. The ship will be disconnected and tugged out by the tug boats before the storm happens as per simulations. Since all this is based on predictive weather, the ship will be taken out before the storm arrives.

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At what significant wave height will the ship be taken out from M’Xlokk when this is a dead ship? EGM

TM

Since this is based on predictive weather, we shall be moving out ahead of the storm. Please see response to Q52.

Further to the response given during the public hearing, EGM have provided the following reply:

BV has already certified the storm mooring system. The FSU will be detached from its storm moorings and once released this will be tugged out by 4 tug boats. This will be completed before the sea state reaches the 2m limitations of the tug boats and is based on a forecast exceeding the operational limits of the spread mooring or on an instruction from the Harbour Master.

Please also see point 52 above

Electrogas are still in the process of certifying the storm mooring system. The FSU will be detached from its storm moorings and once released this will be tugged out by 4 tug boats with 2 persons aboard. All this depends on the crew competence, and the particular conditions.

At what significant wave height can the tugs connect to a vessel? TM It depends on crew competence, the weather conditions etc but ultimately its 2m wave height and above this, we do not normally secure to a ship.

If at 2.5m significant wave height the vessel is going to be shifted to the storm mooring and at 2m significant wave height you can’t really have tugs passing a line- exactly how the ship will get out?

EGM

System designed for a 1 in 100 year storm will be adopted. The storm mooring was designed for 1 in 100 year event with a 3.14 m wave height. Actual SMDD have got safety factors for actual chains and equipment. The system can actually withhold more than it is actually designed for. This is a joint decision between the forecasted weather, the Captain of the vessel, Transport Malta and the Tug Boats. We shall not wait for the storm to happen or have a 4m wave height. There is a simple procedure and we will simply go by the book.

Further to the response given during the public hearing, EGM have provided the following reply:

Please note the decision is taken before the sea state reaches the limit of the tugs. However we do not need tug assistance to go on to the spread mooring and therefore if the weather will not exceed the 1 in 100 year storm conditions (which will be the case most of the time) then we shall remain on the jetty until we need to leave for operational reasons to the spread mooring (i.e. significant wave height = 2.5m).

ERA to take note of the serious fact that we have not been informed that the vessel needs to move away from the port at 2.5m wave height, and still have not informed us of the actual wave height in writing.

EGM All waves heights and vessel parameters are included in the reports submitted to the Authorities

The report has 12 empty pages. Why? Electrogas has not published its emergency plan for what happens when there is a fire at the vessel, jetty and the FSU. Hence it’s a breach of the SEVESO Convention.

EGM

The report has these empty pages which will be populated in the coming days with results and data. There are 43 scenarios for the FSU, LNG and the jetty.

Further to the response given during the public hearing, EGM have provided the following clarification

Upon review EGM confirms these belong to the confidential report. This report has been issued to the relevant authorities. However for security reasons we cannot share publicly and this was agreed with the Authorities.. Please note the inclusion of the headings was to inform the public that these scenarios are indeed considered and planning has been done.:

As a citizen I would like to know. What is the emergency plan? Who is going to deal with it? And be responsible? CPD will not be taking care of the marine side ERA

This email refered to the regulatory consultation process. In the meantime and after that, discussions have been carried out between TM and CPD and the remit has been resolved.

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of the project and neither will TM. Whos is going to be in charge of the marine side? Reference to e-mail dated 17 June 2016. Responsibility for the marine side shall be clearly written down.

SEVESO 3. How can you say that this is in line with SEVESO 3 when every single rule in terms of public consultation has been broken; it is necessary to establish emergency plans; which have not been published and no public consultation whatsoever carried out. Plans that have been prepared and not published are useless.

Dr George

Papadakis

ERA

Access to the safety reports. All the information have been received and we have sufficient information for any type of scenario so as to prevent any further scenarios to occur. I can clearly state that these were assessed and were found to be adequate and credible. With regards to other information, it is up to the company to decide what can be disclosed or not. But emergency plans are complete, even the external emergency plan. There is a lot of information so external emergency plan has to be tested and revised but ultimately we are satisfied.

Consultation required in line with the SEVESO guidelines is being carried out as this is a public consultation meeting.

Emergency Plan has been published. The unpublished part is the part where the evacuation plans are involved for the purpose of confidentiality and is in line with the regulations.

SEVESO DIRECTIVE- These reports tell you what an emergency plan shall have. From the marine side, the report mentions nothing with regards to any collisions or grounding that might occur/happen.

Geological Considerations. Appendix 2 Vol 6 EIA. This does not consider the area of the jetty or the FSU nor the part where accidentally in July 2015 a big rock fell. This site is directly behind the jetty and the FSU. What are the consequences of a similar accident?

The, EIA coordinator has provided the following information:

Plate 1: View of the cliff from the south (note chimney of the DPS in the background). Steep cliff slopes to the west. There is no overhang.

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Plate 2 (2013 Photo) View of the cliff face from the north. Fort Delimara is in the distance. A knick and cliff overhang can be seen at the coastline beneath the fort. This explains the recent 2015 rock fall. The geological/geomorphological conditions at the fort are different from those of the cliff close to the jetty.

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Plate 3: close- up View of the overhang at the toe of the cliff face at Fort Delimara the cause of cliff failure

The recent rock fall

1. The cliff face behind the Jetty is mostly Upper Globigerina Limestone with a well established vegetation cover. It has no overhang (see Plates 1 to 3) and therefore no chance of the cliff collapsing

2. The unstable area “close” to the jetty is over 250m away from it.

3. Now that the overhanging cliff has failed, it will not fail again as the overhang is gone.

The geo-technical test results There is nothing wrong with the geo-technical tests results. Both the Delimara cores (2013) and the ones tested by MEPA collected from Mqabba and Zurrieq (1996) were tested in the approved manner.

Although the rock samples tested at both sites belong to the Middle Globigerina Limestone Member, the physical and geological conditions of the terrain at the two sites are entirely different.

a. Delimara marks the depocentre of Middle Globigerina Limestone with an exceptional development of this rock unit while the same

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rock unit outcropping between Mqabba and Zurrieq would be located on the margin away from the depocentre and hence less developed. The tested Zurrieq beds Zurrieq are totally different to the Delimara ones.

b. the levels tested from the two sites are not equivalent.

c. beds in the exposure at Zurrieq are subject to seasonal changes in saturation while those at Delimara lie below sea level and are under constant saturation conditions.

d. the Middle Globigerina Limestone at Delimara is capped by a thick Upper Globigerina Limestone Member while that at Zurrieq has been mostly eroded and only about 10m of the basal beds are preserved. This implies that while the Zurrieq samples came from the base of the Middle Globigerina Limestone, Delimara ones would come from the upper and middle beds of the same unit.

There is nothing in the reports with regards to compensation given in case of damages or personal injuries. Who is responsible to pay? Will the persons responsible be utilizing the liability issue? And if yes, if damages are higher, who will be covering the other part of damages in monies?

EGM

The subject of compensation would be a matter for the law/courts according the circumstances following any incident causing injury death or property damage to third parties. The Electrogas construction insurance programme provide coverage for Electrogas’s liabilities to third parties at law following an incident causing and this will be continued with coverage for the operational facility.

57 18.11.16 Dr Ann Fenech

Document submitted during the Public Hearing

21.11.16 Summary of the covering letter submitted by Dr Fenech

We refer in particular to the 15,000 pages of documentation which were put up on Authority’s website on Wednesday 19th October 2016 first with a request to have any objections, representations and comments within 30 days and then as subsequently amended, within 40 days after a request for an extension was made by Dr. Simon Busuttil.

Neither the original 30 days nor the subsequent 40 days are anywhere near sufficient for the general public to download, consider, review, analyze and study the 350 document provided. This is not “effective public consultation” as per the Aarhus Convention and Seveso III Directive. It is of great concern that ERA has failed to adopt both the literal wording and spirit of these two legislations intended to safeguard the interests of the citizens.

The Nationalist Party has in time available focused on identifying serious critical failures in aspects of the project relating to the presence of the LNG carrier, used as a FSU alongside a jetty in Marsaxlokk which is not an “All weather port” and how these serious critical failures may affect the health and safety of the population.

There are significant failures which compromise unnecessarily the health and safety of the residents and commercial operations in the area. The failures render the project as it stands in breach of the Seveso III Directive and flies in the face of good practice and recommendation as established by the International Gas Tanker and Terminal Operators Ltd (“SIGTTO”).

We strongly believe that the ERA is obliged to reject the application before it.

ERA ERA has taken note of the contents of the submission. It is ERA’s opinion that the whole process of the Public consultation is in line with theat stipulated in the IPPC and Seveso regulations. All the information submitted within this process will be taken into consideration in the formulation of the recommendation to the ERA Board.

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58 18.11.16 Dr Ann Fenech

Document submitted during the Public Hearing

21.11.16 Preliminary Report on the Significant Failures and Deficiencies in the Risk & Safety Studies justifying the presence of the LNG Floating Storage Unit (FSU) in M’Xlokk.

1.Wave studies a. The wave climate and wave penetration studies related to Marsaxlokk

were not conducted on the basis of real and actual wave buoy readings but on the basis of statistical extrapolation from weather sites.

b. The same reports themselves contain a critical caution and state in the concluding remarks that pilot observations and storm videos indicate that the wave height inside Marsaxlokk bay may be higher than predicted in the study. They admit that the lack of available site measurements makes it impossible to properly deal with such information and increase the reliability of the study.

c. The same reports state that the results of the study should be treated with caution during the design. This makes no sense at all when you consider that the report are dated 18 December 2018 when the jetty had not only been already designed but already installed.

d. The seriousness of the failure to base the reports on real wave data is emphasised in another report which talks about the manoeuvring of the LNGC, the other vessel which is needed to refill the FSU, alongside the FSU. This report states “To allow implementation of the above operational mentioned limits, actual information regarding wind, waves and current is indispensable. Installation of a wind meter and a wave current station at a suitable location in the approach (eg a buoy or mounted on a pile) with continuous transmission of the measurements (eg every 10 minutes) is highly recommended. The measured wind and wave data can be used as an unambiguous reference to decide whether the manoeuvre can be safely carried out or not, which the current information allows a pilot to anticipate on the actual conditions in the approach.”

e. So for the purposes of the second LNGC actual information is considered crucial and for the permanent berthing of an FSU inside an unprotected harbour it is not.

f. This failure in gathering real live actual data and the admission that the wave heights are actually much greater than indicated in the reports, makes these reports critically flawed and these are the reports on which the design for the jetty, the design for the FSU alongside the jetty and the design of the storm moorings and the Quantitative Risk Analysis were presumably based.

EGM 1. a. please see answer in Q56

b. please see Q56

c. assuming date should be Dec 2015? Jetty was under construction and not yet completed. Jetty has been designed and installed according to rigorous standards and BV certified structurally taking into account the Marin study.

d. this is not correct. Please reference response to Q56. The report advises us to have real time monitoring when we are in operations and the LNG carrier is approaching. This is in place.

e. again this is not correct. The modelling has been based on an interpolation of real data gathered data point as described in Q56. This was the sole method by which we could reliably design and install the facilities which are BV certified. The use of real time for LNG carriers is an operational mitigation.

f. please see explanation on significant wave height in Q52 and Q56. This allegation is therefore not correct. The use of modelling and the methods for interpreting data, are confirmed by Marin, a leading expert in this field to be reliable and standard industry. practice

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2. Jetty Classification

a. Report 3 dated 18th December states that a significant wave height of 2.5metres the FSU will break her moorings. This is a force 5. It also states that it was challenging to construct a successful spread mooring system in shallow water and recommended a multi-buoy system. In fact no multi buoy system was used and the current storm mooring system is a spread mooring system.

b. Transport Malta has insisted that the jetty be classed by Bureau Veritas. This had to be done by August 2016.

c. There is no record in the documentation of such classification.

d. Why hasn’t the jetty yet been classed?

e. What is the maximum wave height which Bureau Venus are prepared to class?

EGM

TM

Two separate topics are covered under point 2 – jetty classification. and the spread mooring system. The spread mooring system is irrelevant to the jetty classification.

Please see point 52 above for more details on the storm mooring system.

With regards operational limitation on the jetty, the author is kindly referred back to the note on significant wave height above.

EGM has received BV classification for the jetty structural design. EGM will subsequently add operational limits to this BV certification. In the interim, EGM is satisfied that the operational limits have been analyzed and checked by Marin, a mutual contractor used by both EGM and TM because of their experience in this field,.

BV has certified the jetty according to the EPC2 detail design. The wind and wave data incorporated in the design was based on the Marin reports.

A Bureau Veritas Structural Design Appraisal Certificate and the associated Design Approval report has been provided. This is deemed sufficient for our end in respect of the IPPC process. Certain tests and verifications need to be conducted during the commissioning tests. Further conditions will be included as part of the IPPC permit requesting the Operator for submission of full certification.

3. Potential failure of storm mooring system

a. Report 3 dated 18th December commented on the permitted wave height at the jetty and the deficiencies of a spread mooring system.

b. Report 8 dated July 2016, stated that the results in Report 3 were “not satisfactory or conclusive” and yet it still proposed a spread storm mooring system 70 meters offshore. This is a system of 8 chains divided between 4 points attached to an anchor pinned to the sea bed by clumps and anchor piles. Piles would be bored down to and into the seabed with steel and concrete and then vertically and horizontally tested.

c. In a subsequent memo dated 3rd August 2016, the anchor pile method is discarded and another system adopted, that of an anchor simply placed on the sea bed attached to a try chain system which then leads on to two chains attached to the vessel was adopted.

d. The safety and integrity of the mooring is as good as the strength of the bollard holding the chains on the vessel, the immobility of the anchor and the integrity of the chains. Why was the more secure pile system which effectively attaches the anchor to the solid rock beneath the sea bed replaced by the tri chain system?

e. What will be the effect on the FSU if the anchors drift, if the chains are compromised or if the bollard on the vessel to which these chains are attached becomes compromised by giving way from the vessel?

f. Why haven’t the storm moorings been classed yet as demanded by Transport Malta?

EGM

TM

3. Please see information provided in point 52 and 56 above

A BV Certificate of Class with a POSA notification has been provided. The POSA certification covers also the storm mooring system. The detailed conditions are being prepared by BV and are being requested prior to commissioning. These will be in line with the operating limits as indicated in the Marin Report. In this respect, the documentation submitted to date is deemed as sufficient. Further conditions will be included as part of the IPPC permit requesting the Operator to submit full certification prior to the commissioning of the installation. .

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g. What will be the effect on the storm mowing system if there is a storm blowing into Marsaxlokk bay with the same force as the storm over Malta in the weekend of which was blowing from the North East.

4. Absence of quick release hooks on Vessels

a. Report 3, Report 4, Report 8 and the Aecom report all state that the vessel Wakabu Maru was going to be converted into an FSU and will be fitted with “Quick Release Hooks.”

b. Quick Release Hooks on vessels are essential to ensure the quick release of moorings.

c. In the present scenario there needs to be the facility in an emergency for the immediate release of the vessel from the Jetty or from the LNGC which will be alongside her or from her storm moorings.

d. The vessel has not been fitted with quick release hooks which means that if she wants to leave from her storm moorings in an emergency she cannot and she needs to rely on specialised tugs which will have to lift the 8 chains on to the deck of the tug and remove the shackles. This is totally contra indicated in an emergency situation.

e. This will lead to:

Severe difficulties and delay in the release of the vessel in challenging weather conditions. Severe difficulties and delay for the tug engaged to assist.

Severe difficulties for the crews of tugs engaged to assist.

Serious possibility of a disengagement not being done.

Serious possibility of the dragging of anchors in the event that it is not possible to disengage anchors.

Serious possibility of grounding

EGM

TM

The FSU has been fitted with quick release hooks for jetty side and for ship-to-ship alongside mooring.

Please see point 56 above.

SIGTTO guidelines do not cover nor require QRHs for storm mooring systems.

4(e) these outcomes are not proven or correct in relation to the actual operations of the storm mooring which is addressed above

.

A manual describing in detail the procedures has been provided. This includes a quick release procedure to be carried out by ship’s personnel under the direction of the Master. Operating conditions relate to the MARIN study, therefore, same procedures will be considered finalised on receipt of Operating Conditions as issued by Bureau Veritas, in line with the “Classification of Mooring Systems for Permanent and Mobile Offshore Unit – Rule Note NR 493 DT R03 E”. Conditions will be included as part of the IPPC permit requesting the Operator for a revision of the procedures to include BV operating conditions prior to commissioning.

5. When and how will vessel be taken out of Marsaxlokk in an emergency a. Reports state that after one year the vessel’s engines will be demobilised

and thereafter the vessel will be effectively a dead ship with no self-propulsion.

b. In the event that the vessel is on her storm moorings and needs to be taken out of Marsaxlokk in an emergency how will this be done?

c. Such an event would presumably mean severe weather conditions producing wave heights well in excess of 3 meters.

d. Since locally available tugs find it challenging to pass a line in anything

EGM

TM

Please also see Q52 above

In an emergency the FSU will adopt the quick release procedure as described above.

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more than 2 meter significant wave height, how are tugs going to give immediate assistance to get an effectively disabled vessel away from her storm moorings?

e. Since this produces great risks why it is that the plan to remove the engines and to disable the vessel been maintained?

f. What tugs are going to be deployed to tow a dead vessel of that size and displacement?

6. Collision permutations

a. When talking about the refuelling LNGC being alongside the FSU states page 6 of report 5 states that “In this case no other ships are allowed to pass the moored carrier to visit MX Dolphin or MX Power. Only the ships visiting the terminal or the oil tanking facilities are allowed in the port.”

b. Is the reference here to the LNG Terminal or to Malta Freeport Terminal? If it is Malta Freeport does this mean that the Freeport is going to be closed for 3 days whilst the vessel enters, discharges and departs?

c. Does this also mean that no fishing boats will be permitted to enter or leave Marsaxlokk whilst the LNGC is entering or departing or whilst it is along side the FSU?

d. Whilst it seems that the probability of a collision resulting from navigational errors has been assessed there does not appear to be the equivalent assessment regarding collision arising out of technical failures.

e. The reports state that the model that has been adopted is the one used for LNG transport to ports. Here we are not merely talking about the Transport of LNG to ports but about the permanent presence of an FSU in what is not an all-weather port.

f. The report is based on 2013 traffic inside Marsaxlokk. This has increased considerably and the report does not consider this increase at all.

g. The report does not consider the risk of collision between other vessels and the FSU when the FSU is not alongside the jetty but on her storm moorings. This is of concern particularly since the anchors of the storm moorings appear to be placed within the turning circle of ships leaving and entering Freeport.

h. There is also no reference whatsoever to the safety zone or exclusion zone. Has Transport Malta published this?

EGM Response from Marin 6th Dec 2016:

“As far as we have understood and used in our studies:

1. no other large commercial ships will be entering or leaving the port or manoeuvring in the vicinity of the LNGC route when an LNGC is entering or leaving. This is a common risk mitigation measure taken for LNG operations. This means an adequate safety distance for a vessel entering after the LNGC (also allowing for delays when manoeuvring).

2. no commercial vessels will be allowed to Has Saptan Terminal or the Delimara quay when the LNGC is alongside the FSU.

3. When calculating the probability of a collision, a small fraction of the traffic is assumed to disobey the rules. The probabilities of a collision are not nil; the probabilities that a collision causes damage to the tanks is nil in several cases. The author seems to confuse these two.

4. The reference is to Malta Freeport Terminal. See also 1 above.

5. Small vessels such as fishing boats have sufficient space to pass and do not pose a risk for penetration of the tank due their small size. We have understood these will be permitted to pass when the LNGC is alongside. I would expect they need to wait when the LNGC is manoeuvring in the port. I expect Transport Malta will be further detailing the regulations together with the pilots. The VTS can inform fishing vessels whether passing is permitted or not.

6. Technical failures are also considered. See section 2.3.2 of the report.

7. Information on the traffic calling at Marsaxlokk has been received from Transport Malta and analysed as input for the study. The traffic is split up in type and sizes of vessels. Probabilities of failures are not the same for all classes of traffic.

8. The effects of a hole in the containment system is considered in the study item carried out by SGS.

9. Page 8 of the report states also: “The program has also been used in safety assessment studies for offshore platforms, offshore wind farms and for the new traffic separation scheme in the approach to Rotterdam. Further the model was used to assess the required capacity for SAR, salvage and oil spill response operation in the Dutch Continental Shelf.”

The model is a general model to assess risks related to nautical operations. The permanent presence of the FSU in the port has been included in the calculation of the collision probabilities.

The FSU is considered to be permanently in the port. The probability that other vessels collide with the FSU is not significantly different if the FSU is on the jetty or at

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the storm mooring. If the wave height at the jetty is over Hs = 2.5 m, I would expect that no other traffic (large commercial vessels) will be entering, as the wave heights in the approach just before the port entrance are too high to operate with the tugs. Most vessels that were moored in the port may have left already if such conditions occur. Pilots may have more detailed information.”

7. Failure to producing emergency plans marine side

a. If the vessel breaks her moorings alongside the jetty, if she breaks her storm moorings, if she drags her anchors, if there is a collision, if there is a grounding, if there is a terrorist attack, if there are difficulties removing the vessel from the harbour, these are emergency situations which need an emergency plan marine side.

b. No emergency marine plan has been divulged in the Electroas Emergency plans. This is unacceptable. They have 15 blank pages when dealing with the Emergency plans marine side for:

LNG Spill, Gas Releases and Fire Scenarios at the FSU

LNG Spill, Gas Releases and Fire Scenarios at the Jetty and

Collision

c. Furthermore correspondence exchange between CPD and Transport Malta show that neither one nor the other wants to take responsibility for the Emergency plan marine side. “CPD will not be taking care of the marine side of the projects. As things stand today, CPD lacks the expertise, assets and resources to tackle the emergency response from the marine side, however in the event of an emergency CPD will still take on its role of coordinating emergency response with other stakeholders such as Transport Malta in this case” In its response Transport Malta says: “Whilst TM would assist as required in the event of a marine related incident the respective competencies have to be clearly defined and in line with the applicable legal provisions.”

d. Questions being raised are:

1. What is the situation in the case of a casualty incident marine side?

2. What is the situation in case the vessel breaks her moorings?

3. What is the situation if there is a collision?

4. Who is in charge of such emergency response marine side?

5. Who is going to take responsibility for this?

6. What is the emergency plan marine side?

EGM

CPD

7(b) Please refer to response to question response to Q56

The External Emergency Plan has considerations for such eventualities that may arise from the marine side. In such an eventuality the Incident Commander will make use of Marine Vessel Tugs to direct and contain the incident as is normal in any marine emergency.

Confirmed that the quote was the position of the Civil Protection Department did not have the necessary knowledge and equipment to tackle LNG borne incident when the quoted e-mail was sent. Since then approximately 2 million euro worth of equipment have been dedicated to this issue and now the Civil Protection Department is ready and able to tackle any LNG related incident.


The CPD actually has two years to draw up the external emergency plan, which period commences from the submission of the safety report and internal emergency plan by the operator. Furthermore the Operator and CPD are also obliged to conduct exercises in the plant at least once every three years from the start of operations. In the case of an emergency that is beyond the Operator’s Capabilities CPD will always be in charge.

8. CPD External Emergency Report

a. The Electrogas Internal Emergency plan specifically states that: “If there

CPD The Civil Protection Department has published the External emergency plan of which part B (Operational) was detained from publication as it has been classified Secret given that the information contained within if made public would be a threat to

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is a threat to the public an evacuation of the local community may be initialised in accordance the External Emergency Plan”.

b. Yet if one goes through the External Emergency plan that part of the report which needs to specifically deal with the mechanics of the emergency plan itself are left blank and in the Operational Section one sees the following: “ Information on the operational section (Section B) of this document is being withheld from publication on grounds of National Security”

c. Notwithstanding that there are 22 pages there is no plan whatsoever as to what the residents need to do in case of emergency and more importantly what they need to do in an evacuation which is considered as a possibility in the same report which states “If the situation warrants, the decision may be taken to evacuate not only the non-essential people in the facility but also part of the island residents”

d. On the other hand the report states that in the event of an emergency the CPD however is obliged to take decisions as to whether or not an evacuation of the resident population will take place, in consultation with the operator and the OPM. The CPD is the ultimate guardian of the health and wellbeing of the citizens which must be taken objectively and in the interests of the general public totally independent of any political considerations.

e. The External Emergency plan is directly contrary to what is demanded by the Seveso Ill Convention which “underlines the need to ensure that appropriate precautionary a action is taken to ensure a high level of protection throughout the Union for citizens, communities and the environment”

f. The plan does not satisfy the requirements of Seveso III because:

a. It does not provide any actual emergency plans particularly in the case of an evacuation

b. It does not provide for the plans and the procedures for them to be tested.

c. Persons likely to be affected are not being given sufficient information on the correct action to be taken without them having to ask for it.

d. There has been no effective public consultation in the decision making necessary.

g. The information available is too little too late. Even the Non-Technical Summary Safety report published by Electrogas, states: “The safety report must be submitted, in case of a new establishment a reasonable period of time prior to the start of construction or operation. Regarding the Electro Gas project the submission of safety report is expected 6

National Security.In our view, the external emergency plan as published contains sufficient information to satisfy legal notice 179/15 and Council Directive 2012/18/EU. Several sessions were held as part of the Public Consultation and feedback on the External Emergency plan was given including several presentations and replies to submitted questions. The general public has been informed on what to do in an emergency through the information booklet that was distributed in each and every household in the area. In view of this it is important to note the following;





The CPD actually has two years to draw up the external emergency plan, which period commences from the submission of the safety report and internal emergency plan by the operator. Furthermore the Operator and CPD are also obliged to conduct exercises in the plant at least once every three years from the start of operations

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months before start of operation.”

9. Serious omissions in Electrogas Safety Reports

a. The safety reports admit that they are not considering certain risks including high wind and waves. “Such scenarios can be discarded front risk assessment al they are managed by the normal design process.”

b. Equally “Scenario’s related to FSU cargo tanks at the Storm Mooring system are discarded as their frequencies are below 10 -9 per year.”

c. So what kind of safety report is it if it is not going to double check the design process? These am huge flaws meaning that we have no assessment of the effect of a failure in the storm mooring system. The question what will happen if there is a failure in the storm mooring system has not been addressed.

d. The report states that “Safety distance kept from FSU (to be defined by port authorities” We have been unable to find such safety distances anywhere. Shouldn’t these have been published as part of the Safety Plan?

EGM (a) From Safety Report/Hazard Identification/Extreme Weather : “High winds and waves may also cause damage to process equipment and structures. Main hazard may be the rupture of the mooring lines which may cause displacement/drift of the FSU, as well as damage to the unloading facility and the jetty structure under efforts. These environmental loads are taken into account in the project design, as described in chapter Safety of the Installations.”

Scenarios related to lightning, soil subsidence and seismic activity have be discarded from Risk Assessment as they are taken into account for the project design.

b. Scenarios related to FSU cargo tanks at the Storm Mooring System, due to equipment failure, process deviation, external hazard (ship collision, terrorism attack) are discarded as their frequencies are below 10-9 /year. This was by agreement with the relevant Competent Authorities.

c. The spread mooring system is designed to have double legs on each corner, and to withstand line breakage. The FSU maintains both of her anchors in any case. As mentioned above, if the forecast is that the weather will exceed the operational design then the FSU shall be taken out of the harbour in advance..

d. As explained during the public hearing, TM will communicate with mariners on Safety distances from FSU.

10. Quantitative Risk Assessment

a. The Quantitative risk assessment starts with a disclaimer stating the information contained therein reflects the company’s findings at the time of its intervention only.

b. The Quantitative Risk Assessment should therefore be thrown out on the basis that the wind and wave reports admit that they had no real data and because the entire mooring system with all its deficiencies highlighted in this report were finalised AFTER the date of the Quantitative Risk Assessment. This QRA is based on a report which was considered later “not to be satisfactory and inconclusive.”

c. This is a very serious omission when one considers that the loads on the mooring lines are higher in a one in 50 year storm than they are in a one in 100 year storm and as shown in the Common Risk Matrix of the COMAH report I in 50 occurrence is shown in the Common Risk Matrix as “Likely” and as having an effect which could range from “Moderate” to “Catastrophic” and “Disastrous”.

d. The QRA like the Electrogas Safety report retains as out of scope” other hazards due to the already existing nautical activity. How can all the other very substantial nautical activities in the port which must impact substantially on the presence of the FSU in port plus the continuous arrivals and departures of the LNGC be considered as out of the scope

EGM 10(a) Marin response 6th Dec 2016: “This seems to be a standard phrase in SGS reports, but is in fact valid for any study by any consultant.

10(b)

EGM refer back to answer 56

Marin response 6th Dec 2016: “The Nautical QRA carried out by SGS focuses on the consequences of the release of LNG after a collision leading to damage of the tanks of the FSU or LNGC. The additional metocean analysis has no direct relation with this study”.

“The additional calculations for the storm mooring system were indeed carried out after the NQRA by SGS as the design of the storm mooring had not yet been finished.

As mentioned above, the QRA by SGS deals with the consequences of collisions and groundings and does not evaluate the mooring system”.

The probability that other vessels collide with the FSU is not significantly different if the FSU is on the jetty or at the storm mooring. If these remarks refer to possible failures of the mooring systems (either jetty or storm mooring), I expect that in case of a complete failure of the mooring and drifting and grounding of the FSU the speeds with which the FSU may ground or collide with a dolphin will be so small that damage to the tanks is not likely”.

10(c) It is true that for the 60°N direction the line loads for the 50 year case are marginally higher than for the 100 year case and both are well below the Safe Working Load of the mooring lines. However this direction is not the governing case for the design. For all other wind directions, including the governing direction the 100

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of a QRA?

e. This QRA report does not address the concerns raised in the first QRA report dated July 11th 2013 wherein Prof Vaccari stated: PGE 69: It is easy to see how a flammable gas cloud can rapidly travel from the release point to some pan of the Delimara peninsula or to the existing Delimara Power Station. Specially in the Delimara Power station a large number of different ignition points would be present so that ignition is almost certain.

And on page 82 when talking about the options available but always with a vessel in Marsaxlokk bay, “A flammable gas cloud can travel to the Delimara Power Station and easily find ass ignition point there with devastating effects on the Maltese power system.”

f. Finally the report concludes that “Regarding the societal risk, in the unlikely event of an accident, the number of fatalities is acceptable if compared with the acceptance criteria used in other European Countries with a large tradition of quantitative risk assessment”

1. How many fatalities exactly is this report identifying and why should any fatalities be acceptable when there is such an acceptable alternative which eliminates the chances of the fatalities altogether? AND: 2. In which other country in the world is there a similar project of an FSU in unprotected bays for which a QRA has been carried out?

year case is more onerous than the 50 year case. As we have designed for the most onerous wind direction we have designed for the 100 year case.

10(d) Marin response 6th Dec 2016 “The last sentence of the quote in 7. refers to the risks of other collisions not involving the FSU or LNGC such as between two container vessels. It is obvious from the report of the nautical risk study that the collisions of all other traffic with the LNGC are taken into account”.

“The FSU is considered to be permanently in the port. The probability that other vessels collide with the FSU is not significantly different if the FSU is on the jetty or at the storm mooring”

10(e) the Preliminary QRA is superseded by the safety report not the Nautical QRA. Therefore these topics are addressed within the safety report.

10(f) Marin response 6th Dec 2016 “the graph to which this sentence refers shows that the estimated risk levels are much lower (several orders) when compared to acceptance levels used in other countries in QRAs.”.

Please refer to Q53 above.

11. Missing important geological considerations

a. The fact that the cliff face directly behind a. the jetty at Delimara is very soft Middle Globigedna Limestone which collapses regularly has not been taken into account.

b. The “area of influence” considered in the report covering Geology, Hydrology and Hydrogeology excludes completely this area very close indeed to the jetty which collapsed as recently as July2015 causing damage and injury to persons.

c. This unstable area prone to collapse is dangerously close to the jetty against which the FSU will be moored permanently and was not considered.

EIA

Coordinator

See the answer in question 56 above

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d. What precisely will be the effect of further cliff failures on the jetty carrying LNG piping and on the jetty against which the FSU is moored?

e. Furthermore the results of the samples testing the strength of the Middle Globigerina limestone into which the piles for the jetty were bored are completely different to the results conducted in a study for the Planning Authority in 1996. The results are very high showing an average compressive strength of the cores of 13.5 MPa and a range of 6.2 to 20.6. These results are fundamentally different to the results for Middle Globigerina Limestone between Zurrieq and Mqabba which show an average compressive strength of 4.65 MPa. The fact that the results in the reports show the limestone to be 3 times stronger than in previous reports suggests there is something wrong with these results.

f. It is vital to establish whether there is indeed an error in the results of the Delimara cores because the construction of the piles supporting the Jetty was carried out on the basis of the purported strength of the Middle Globigerina Limestone as represented by these cores which appear to show the material to be three times stronger than it actually is.

g. This could lead to a totally dangerously compromising situation for the Jetty housing the piping carrying the LNG as well as for the FSU moored against the Jetty.

12. Third Party Liability Insurance

a. No information is available on the compensation available to third parties in the case of injury, death or property damage.

b. How and by whom will the residents and those with commercial interests in the area or in any area affected by an accident or casualty be compensated?

c. Who and which is, or are the insurance entities covering the substantial risks to third parties associated with the project?

d. Will the vessel’s protection and indemnity club be covering the damages which will be caused in the event of a gas leak caused at the manifold, during a ship to ship transfer or as a result of a rupture of the vessel’s tanks caused by collision or grounding?

e. If not who will cover the damages?

f. In the event that the vessel will be entitled to limit its liability in line with the Limitation of Liability Convention who will pay the difference between the damages caused and the maximum limit?

EGM a. The subject of compensation would be a matter for law/courts according to the circumstances following an incident causing injury death or property damage to third parties. The Electrogas construction insurance programme provides coverage for Electrogas’s liabilities to third parties at law following an incident causing and this will be continued with coverage for the operational facility.

b. See reply in a. above in view that the same coverage applies for such third party liabilities at law.

c. The insurers for primary and excess liability are major rated global insurers including Lloyd’s syndicates.

d. The vessel has mutual P&I in place which will respond to any liability incurred by Bumi as owner/operator of the vessel, including pollution.

e. Not applicable.

f. The right to limit liability is waived.

13. Flight path – Aviation Enemalta Enemalta are working hand in hand with TM to ensure that no fly zones over critical

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a. The Non-Technical Summary of the Electrogas Safety Report states that since the new facilities are out of the landing / take off approach routes for the airport, no specific design requirement has been implemented for any aircraft impact.

b. It is not true that the facilities are out of the approach routes for the airport.

c. Only last week Transport Malta issued for the first time ever an urgent announcement that the previously available approach route over the LNG Tanker has been rerouted, and one of four orbit zones available for flying schools to use over the Delimara peninsula has been eliminated. The email explained that this has to be done in the shortest possible time.

d. For the first time ever a Prohibitive Flying zone has been created covering a 1.5 km radius from the LNG tanker.

e. Whilst of course Transport Malta had no option but to ensure a re-routing in light of the actual dangers, it is unacceptable that the only reason why there are no safety considerations related to aviation in the reports is not because there was no need for them as things stand, but because landing routes and orbiting zones have either been redesigned or eliminated completely to ensure that there are no planes whatsoever flying within 1.5 km radius of the FSU

infrastructure such as the DPS is enforced. In the coming days TM shall issue a notice along these lines.

59 18.11.16 Joe Camilleri

Public meeting

If accidentally during the storm itself the tanker is struck by a lightning? What will happen? If there is any mechanical failure in the pipes whilst gas is being passed?

EGM

The design has taken into consideration both storms and seismic occurrences. Seismic designs have been taken into account EN 1493 and the jetty has been designed taking into consideration any earthquakes. Design is according to seismic loads. All pipes have been designed to withstand any damages as mentioned.

60 18.11.16 Saviour Camilleri

Public meeting

Why have we brought the tanker when the gas pipes to Sicily could have been used? What happens if accidentally an aeroplane falls hitting the tanker? These are realities.

EGM

Airplane accident is at remote probability, such as ship collision and terrorism attack. However, the consequence would be a large pool fire as presented in the Safety Report/Consequence Analysis.

61 18.11.16 Anglu Caruana

Public meeting

The area where the jetty is being proposed has been a recreational area for a lot of fisherman who used to go with their families or to do some work there. CPD has stopped us from coming in that particular area lately. We were told by the Minister that the area in question will not be closed.

CPD/TM

The area in particular has been closed for boats for security purposes.

62 18.11.16 Major, M’Xlokk LC

Public meeting

The air monitoring unit above the LC will keep on functioning? ERA

Yes

Documents

Delimara Power Station Renewal & Variation Pubic Consultation Power... · Delimara Power Station Renewal & Variation Pubic Consultation 19 October to 27 November 2016 Ref # Date Received