2 July, 1997

Mr. A P Dawson
Manager Foinaven Business Unit
BP Exploration Operating Company Ltd
Britoil plc
Golar Nor House Howe Moss Drive
Kirkhill Industrial Estate
Dyce
Aberdeen AB21 0GL


Dear Andrew,

Further to my letter dated 26th June 1997, I have received additional information/reports raising further questions to which I would be grateful for your response.

I have heard that problems have occurred due to unpredictable underwater currents. Information Greenpeace has received suggests that the problem with West of Shetland is not the maximum current velocity on the slope but the fact that it is not constant. For some reason the currents appear to oscillate. According to this information, this has caused a problem (somewhat akin to that suspension bridge disaster in the States many years back) where drill strings start to oscillate with increasing amplitude until they simply break. I understand that a number of drill strings have been lost in this way. This raises additional concerns with regard to the flexible risers carrying oil to the FPSO and whether or not they are likely to suffer from the same problem.

Furthermore, I understand that because of the lack of knowledge of the hydrography of the area, and the unexpected strength and variation in the currents, BP are having difficulty predicting the dispersal dynamics of operational discharges such as drilling cuttings and contaminated water and/or produced water.

With regard to problems reported with the manifold, the following information has been published. The European Offshore Petroleum Newsletter 14th May 1997 reported that:

"..engineers working on the prestigious FOINAVEN project have decided to retrieve a subsea manifold from Drill Centre 1 (DC1) for the second time.."

"..the decision to lift the DC1 manifold from its subsea site was taken last Friday night- because BP is not confident enough in the subsea equipment.."

"..five Xmas trees supplied by Cooper Cameron will be retrieved for inspection at the same time.."

The European Offshore Petroleum Newsletter 18th June 1997 reported that:

"..the second FOINAVEN manifold has been pulled up and taken onshore following a leakage problem similar to that of the first which also had to be removed from the seabed for onshore remedial work.."

".. BP spokesperson confirmed that the manifold had been lifted on 5th May and taken to Invergordon, Scotland by the following weekend. So far, the operator has not set a target date for getting the manifold repaired and back on location.."

It has also been mentioned that the extreme cold - as low as minus four degrees C - reportedly makes the oil sticky and restricts flow through pipes connecting the wells to the ship. This is reportedly the reason that some of the Xmas trees have had to be brought to the surface as they were clogged up.

If this information is accurate, it would appear, in this instance, that an Environmental Assessment would not only have benefited the environment, but also your work programme.

On a related safety issue the European Offshore Petroleum Newsletter 28th May 1997 further reports:

"..a new escape tunnel is to be fitted to BP's floating production Vessel for the Schiehallion field which will break new ground for a safety system.."

"..the makers say it can remain in operation after exposure to 500mbar blast overpressure, and will maintain an internal temperature below 50C during an emergency.."

Mr Peter Hayman of Mech-Tool Engineering went onto say: "There was a risk the industry might not require as high a specification as we were able to provide, and competitors would gain orders at our expense..", "..But we believe BP has shown other FPSO operators the way forward by ordering our technologically advanced tunnel".

It is my understanding that the tunnel is designed to allow safe passage from one area of the ship to the other and also safe access to production areas. Furthermore, due to the design of the Schiehallion FPSO, with the helideck at the stern of the ship and the accommodation at the bow, the tunnel is needed as an escape route. Accepting that the layout of the Schiehallion is different to the Foinaven, but also recognising that the tunnel is not solely used for evacuation purposes, I would like to know if any similar system has been fitted to the Foinaven FPSO.

Additionally, I am further concerned about the events that lead to the change in design with regard to moving the helideck to the rear of the vessel. It has been extensively reported that the reasons for this are that in bad weather, landing on the Foinaven helideck is very difficult. One crewman is quoted in the Shetland News on 15th March this year saying:

"this boat moves like a rocking horse in a storm and we've had to wait up to four days for weather so the crew change chopper could land"

I have summarised the main questions below, although it may be that the text of what I have written raises some additional questions that you feel require an answer.

1) Has the problem of oscillating currents been encountered and to what extent.

2) What precautions have been taken in respect of this causing damage and/or breakage to the flexible risers.

3) Considering the varying and unpredictable currents, is BP able to predict or asses the impact that operational discharges will have. This question is specifically aimed at contaminated drill cuttings disposal.

4) Could you please advise as to the situation with the manifold installation and whether or not there has been any leakage of oil.

5) Could you please advise us of the situation with the Xmas trees, if clogging has occurred has this lead to any further problems and/or leakage of oil.

6) Does the Foinaven FPSO have any safety tunnel system, which would allow safe access to different parts of the ship, in the event of an accident.

7) What evacuation procedures exist in the event of an accident in rough weather, where landing of a helicopter is difficult due to movement of the ship. This question is relevant to both individual evacuations and large scale mass evacuations.

I look forward to hearing from you at your earliest convenience.

Yours sincerely

Sarah Burton
Director, Campaign for Sane Energy
GREENPEACE UK

cc: John Browne