From the silent voice of death come the soundest lessons in life

Last Update: August 2008  (Author Andrea Madeley - VOID Founder)



How was it that a company awaiting prosecution for breaching their legal responsibility in Occupational Health and Safety AND Dangerous Substances legislation can be eligible to enter the awards program - and WIN?

Not only did they take out the top safety award on offer at the South Australian SafeWork SA awards in 2007 - ‘Employer of the Year’ - but also collected a host of others through the private insurers SISA 2007 Safety Awards.  Not bad for a company that has been flat out finding a hole in the word-of-law to get around answering some tough questions about their safety practices.

To date Santos has been unsuccessful in convincing the South Australian Industrial Relations Court or that of the Full Court.  Nor was this argument successful before the South Australian Supreme Court.  Not satisfied with these decisions made against them, Santos Ltd and Diemould Tooling Services lodged a special leave of appeal in the final hour with the Australian High Court on August 29th 2008.  So – its pretty clear they’re not taking no for an answer and prepared to sink a ton of money into this tech-hitch.  

Of course, these avenues of side stepping the courts is their legal right…and that legal right is not in question.  The question of whether they are guilty or innocent is not the issue here either.  Rather, the question here is whether the decisions of this corporate giant portrays the kind of mind-set or culture that identifies genuine leadership in Occupational Health and Safety.

In my very humble, actually scrap that, there’s nothing humble about my opinion on this matter,  I am as angry as a cut snake.  This wealthy company has opted to clog up an already over burdened legal system with its tenacious stance on this matter portraying an attitude that falls well short of praise.  The fact that they finally invested some money into ‘safety’ should be seen as a step in the right direction (of course) but clearly it was well overdue and more to the point I question the motive.  Is this truly a change of attitude or is this about polishing a tarnished image?  

Why would the same Government departments that poured so taxpayer resources into ensuring a solid case was mounted for prosecution be now holding a polishing cloth to help restore that image?  Let’s not forget the ongoing costs associated with this ‘legal argument’ and the notion that the Crown funds its argument via taxpayer’s money also.  This has been going on for years and that suits those who prefer their misadventure becomes a distant memory.  It probably makes good business sense to put a few years between the dark cloud (that would the the cloud that went BOOM) and the court room - in the hope that all this will be old news and anything too incriminating will sneak by without so much as a sniff from the media.

On the flip side, the downside to running a legal challenge like this means that information that would normally not be available to the general public is.  Published court documents allow us to easily identify what the charges entail.  Couple that with on-line media documents - and the picture starts to take shape pretty quickly.  

This all unfolded in the early hours of January 1st 2004 at the Santos Moomba facility.  The charges laid against Santos relate to a rather nasty mercury leak in the Liquids Recovery Plant (LRP) that created a large vapor cloud that ultimately ignited and exploded.  By the grace of God the plant was in maintenance shut down and was operating with a low number of personnel.  Thankfully no one was killed as they all managed to get away.  Had this catastrophe occurred when the plant was in full operation, one could easily imagine a very different outcome.  

From what I can gather, after gleaning through the media reports – it would seem the priority issue arising from the January 1st explosion was the concern of an ongoing gas supply.  Sadly safety gets little mention.  With the LRP plant out of action, the ripple effect of that affected many industry users that relied on gas for production.  Oops…did I read the word ‘litigation’?  Okay so now more of the picture takes shape - because now its clear that there are many millions of dollars in liability hinged on this matter.

I’ve spent countless hours delving deeply into the incident that occurred on January 1st in 2004.  In querying some archived reports it was rather intriguing to see how this all unfolded.

Going back a few years beyond 2004, there was certainly the impression that all was not well at the Moomba plant.  The unions had been begging for better safety at the Moomba facility.  Several news reports after the event suggested Santos was running a cowboy operation.  There had also been convictions against the company in 2003 where a worker was killed and another seriously burned.  Not a good wonder they wanted to polish their image!

Construction of the Moomba facility began 40 years ago in 1968 so the plant effectively was ageing.  It would appear from my humble research that it wasn’t really until the appointment of John Ellice-Flint in 2000 that some meaningful dollars were being spent on maintenance and upgrades at Moomba.  That leaves many decades of plant fatigue and neglect.  Ellice-Flint had one heck of a job to do - under his watch he’d inherited a run down plant and somehow he had to keep the shareholders happy AND pour money into something that doesn’t actually offer a huge return.  Oh and he’s not there anymore by the way.  How interesting.

Back to the issue at hand – the 2004 boom!  

Immediately after the incident, Santos was reporting that a ‘faulty inlet nozzle’ caused the catastrophic explosion.  The word ‘faulty’ lures those of us with normal English skills to assume the nozzle had failed due to an inherent deficiency…but that assumption turns out to be not quite right.

A few months later, in March 2004 reports began to emerge with a different story.  The mercury element and the term LME or ‘liquid metal embrittlement’ began to materialise.  

“LME is a rare instantaneous phenomenon. It is a complex metal fracture mechanism that occurs without warning. It is understood that, to date, the Moomba incident is the first known occurrence of a gas release and fire due to LME. While LME occurs with aluminium, it does not occur with steel and therefore does not affect the strength of steel pipes and valves. At the Moomba Plant, the cold box is the only major piece of aluminium equipment. The remainder of the processing equipment is predominantly constructed of steel. (READ FULL ARTICLE)

How interesting - read below...this is information I found relating to LME and offers some time lines as to when it first became a topic of interest within the gas processing industry.  

The implication of the effect of mercury in natural gas was not reported until 1973, when a catastrophic failure of aluminum heat exchangers occurred at Skikda liquefied natural gas plant in Algeria. It was found that the corrosion of the aluminum tubes (constructed of aluminum alloy 6061) was caused by a combination of mercury and water at temperatures around 0.0ºC, which prompted a number of research studies into this phenomenon. (READ FULL ARTICLE)

1973 - that was 35 years ago and just a few years into the Moomba plant construction.  

Here is another extract taken from from a website GasChem.com1 and specifically the link is on the company’s pages on ‘Mercury’ (or for those more scientific minds, Hg).  Again there are quotes here that suggest this issue has been a concern to the gas processing industry for decades.

Hg forms amalgams with a variety of metals, including aluminum, copper, brass, zinc, chromium, iron, and nickel. When these amalgams form with metal components of processing equipment, corrosion of the equipment results, because either the amalgams are weaker than the mercury-free metal (Leeper, 1980; Bingham, 1990), or, as is the case with the aluminum amalgam, the amalgam reacts with moisture to form a metal oxide plus free mercury, which then can continue the corrosion process (Crippen and Chao, 1997).  Specific examples include corrosion of aluminum in cryogenic heat exchangers, gates and stems of wellhead valves.  Such mercury-induced corrosion of aluminum heat exchangers resulted in catastrophic failure of exchangers at the Skikda LNG plant in Algeria (Kinney, 1975).

I clearly need a dictionary so that I can refresh my understanding of the word unforeseeable.  It would appear to a relatively non-scientific mind that a few simple searches on trusty ‘google’ will bring up hundreds of articles published in relation to the reactive nature of mercury and aluminium but also some pretty horrific facts about the effects mercury has on humans who come into contact with it.  

Further to that, there is just as much information relating to the use of mercury control and removal / recovery units.   It seems reasonable to assume then that there has been quite some work done over the years to address the threat of deadly mercury vapour and explosions.  

Looking into the PIRSA website, it’s evident from various (Fit For Purpose) reports that a mercury removal system was installed AFTER the 2004 explosion - up until that time LME or any discussion on mercury seemed to be missing from these reports.  So, let me get this straight.  Here we have at least 30 years of information out there on mercury and its substantial consequences... and it rates not one mention in their reporting?

Now - I did find this kind of thing all over the place - the reference to EML and the Liquid Recovery Plant - Santos 2001 Fit For Purpose Report.

Based on the recent reliability performance of the Santos facilities and the most recent independent risk assessment reviews, the areas identified as having the greatest collective potential to impact on the security of supply of natural gas, or the environment, have been grouped as follows:

1. Failures associated with the Moomba Plant utility systems.

2. Critical pipeline failures. These lines are the Toolachee – Strezlecki, Dullingari to Moomba and Tirrawarra to Moomba lines.

3. Corrosion induced environmental incidents.

**4. An Estimated Maximum Loss (EML) incident involving a vapour cloud explosion (VCE) in the Liquids Recovery Plant (LRP).

Hmm and what do we make of that?  The old run down Liquid Recovery Plant - aged and neglected for decades while the company recorded massive profits and growth.  

EMPLOYER OF THE YEAR?  Really?  This was the best the South Australian government could find in its endeavor to set an example?  Hell I’d think the local corner deli would serve us better as Employer of the Year than this self serving, potbellied hypocritical rubbish.


1st July 2011

After more than 7 years it would appear SANTOS are finally answering to the charges laid against the company in the South Australian Industrial Relations Court.  Also interesting is both companies involved in that lengthy and failed legal arguments both ultimately entered a guilty plea once their respective matters went back to the courts.

We note in the AdelaideNow article;

     “Mr Edwardson said the incident was serious, but could have been worse”

Yes indeed but for the grace of God this plant was in maintenance shut down when many hundreds of workers were not there at the time of the explosion. Don’t be hanging your hat on that though Mr. Edwardson - the plant was neglected and run down.  I shudder to think of the devastation had that white cloud shown itself when the plant was in full swing.  The incident was earthshaking, but could so easily have been catastrophic.