A Galway-based structural engineer believes Shell's new plan for the Corrib gas terminal in north Co Mayo is hazardous following the Dooncarton landslide at Pollathomas.
Mr Brian Coyle, of Coyle Kennedy Ltd Consulting Engineers, also says he believes the company's proposed high-pressure, gas onshore pipeline will be in breach of the Seveso II international directive due to the serious risk of explosion of gas vapour, with "catastrophic" consequences for locals.
Mr Coyle, who is from the north Mayo area, has called on Mayo Council Council to reject the revised application.
He says the Minister for the Marine, Mr Ahern, should review the foreshore licence already granted for onshore pipeline section of the €800 million project, which runs under Dooncarton hill.
In a submission to the council, Mr Coyle highlights the unstable nature of the proposed terminal site at Bellanaboy, and the fact that An Bord Pleanála's own inspector described it as the "wrong" location.
Last April, An Bord Pleanála rejected two of its inspector's recommended grounds for refusing the original application, but ruled unanimously against the plan because of the high risk posed by the transfer of some 650,000 cubic metres of peat to adjoining blanket bog - equivalent to an unstable "blanket" covering 94 acres, with part of it running down onto a regional road.
Mr Coyle says he is not objecting to the terminal or gas project, but to the current site, and believes that an offshore terminal is the best and safer option for developing the Corrib field.
He says if an onshore site is required, it should be on stable ground, and outside the catchment of a major drinking water supply.
He says the current inland terminal site is surrounded by blanket bog that can become unstable - by Shell's own estimation - at an angle of two degrees or more. Shell cannot control natural events, such as last September's landslide.
Specialists recently employed by Mayo County Council had said that such a slide could recur. If the pipeline had already been in place when the first of the landslides occurred last autumn, it would have fractured or sheared it and caused a potentially "catastrophic" disaster.
Mr Coyle notes that Shell had proposed building the terminal at the foot of Dooncarton Hill, which points to more "shortcomings" in its investigations.
He says the company's new proposal to remove 450,000 cubic metres of peat and 50,000 cubic metres of mineral soil to an alternative location 11 kilometres away at Srahmore will discharge at least 400 million litres of acidic base water into the north and south of Carrowmore Lake, the only drinking water supply for the entire region.
He says the transfer of peat will also result in over 100,000 traffic turning movements on the shortest route available between north Erris and Mayo General Hospital in Castlebar. This could create safety issues even during the construction stage.
Mr Coyle says there is no known example where a successful large deposition of saturated blanket bog has taken place. He notes that Shell, formerly Enterprise Energy Ireland, had previously ruled against removing peat, and had cited "construction and safety difficulties" attached to such a plan in its initial submission.
He says in his submission that the terminal or refinery itself will be the only inland one of its type, and with the longest pipeline link. If built, it will constitute a "Seveso II high risk event" given that local residents will be living within the construction sound buffer zone.
An Bord Pleanála's inspector, Mr Kevin Moore, raised concerns about the very limited spatial corridor for the pipeline, and said that the criteria used to determine the pipeline route had been seriously breached.
He also pointed out in his report that the landfall location was in a proposed candidate Special Area of Conservation, and that Sruwadaccon Bay, through which the pipe would run, is a Special Protection Area.
Mr Coyle says Shell has failed to provide in-depth, site-specific information for alternative terminal sites, and he also rejects the company's arguments against an offshore terminal. The Corrib gas water depth is about 200 metres, and gas has been extracted in waters deeper than 1,000 metres.
A spokesman for Shell said yesterday that it would examine all submissions through the planning process rather than commenting publicly, but it was happy that the terminal was in the correct location and that all aspects of the project were environmentally and technically safe.