City Hall To FERC/Port of LB: LNG Enviro Impact Documents Don't Meet Fed'l & CA Enviro Reqts.
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(December 7, 2005) -- The City of LB has prepared written comments for filing with the Federal Energy Regulatory Commission (FERC) and the Port of Long Beach (PoLB) that say the FERC/PoLB Environmental Impact documents for a proposed Port-sited Liquefied Natural Gas (LNG) facility don't meet CA Environmental Quality Act (CEQA) or National Environmental Protection Act (NEPA) requirements.
Stressing that City Hall's comments address only the adequacy of the environmental analysis and don't support or oppose the project proposal by the Port of LB, city management released a summary of its staff comments which will be filed on December 8, at which time the full text of the comments will be posted on City Hall's website (www.longbeach.gov).
The City says a tanker release at the LNG terminal and hostile takeover of an LNG tanker are possible and the risk of their occurrence should be assessed.
It also says FERC/PoLB's use of 5 Kw/m2 (the radiant heat level from an LNG fire at which second degree burns would result in 30 seconds) is inadequate because it implicitly accepts the potential for adverse effects on the exposed public. The City says 1.5 Kw/m2 [also recommended by the CA Energy Commission] should be used which would allow emergency responders to identify the distance at which no injuries would result from extended exposure to an LNG fire.
The City says the draft EIR/EIS "provides no information on the need for the terminal to be located onshore at the Port of Long Beach. The Port of Long Beach is just one of many possible locations for an LNG import facility, and alternative locations that appear to satisfy the purpose of the project are prematurely eliminated."
The City also faults the draft EIR/EIS for deferring submission of important plans and therefore precluding public review and comment on them. "Security and emergency response requirements that will be 'imposed' on the City of Long Beach are not identified. If the City of Long Beach Fire or Police Departments determine resources, training, or equipment are necessary, a plan for funding the needs should be established and should be made available for public review and comment." The City adds that that no air quality conformity analysis is provided and emission offsets (hard to obtain in the South Coast Air Basin) are not identified, leaving it unclear how air quality impacts would be mitigated.
The City adds that the draft EIR/EIS doesn't adequately identify members of the public, leaving Port employees and visitors with less protection (since they're not considered "the public.")
The City also says the draft EIR/EIS doesn't address disproportionate effects on low-income/minority populations (environmental justice issues)..
We post below some of city staff's salient points [text as provided in its summary]:
Alternatives are not evaluated appropriately
- ...Project purpose and need provides no information on the need for the terminal to be located onshore at the Port of Long Beach. The Port of Long Beach is just one of many possible locations for an LNG import facility, and alternative locations that appear to satisfy the purpose of the project are prematurely eliminated.
- NEPA requires alternatives to be evaluated in equal detail as the proposed project. This does not happen in the Draft EIS/EIR.
Deferred submittal of important plans precludes public review and comment
- Security and emergency response requirements that will be "imposed" on the City of Long Beach are not identified. If the City of Long Beach Fire or Police Departments determine resources, training, or equipment are necessary, a plan for funding the needs should be established and should be made available for public review and comment.
- No Air Quality Conformity Analysis is provided. Emission offsets, which are very hard to obtain in the South Coast Air Basin, are not identified. As a result, it is not clear how air quality impacts would be mitigated.
- No Waterway Suitability Assessment is provided. Thus, there is no information on how LNG tankers will affect other Port vessel traffic, and no information on how safety and security will be ensured.
- Omission of these plans eliminates the opportunity for the public to comment on their content.
- CEQA does not allow deferral of disclosing impacts or mitigation measures
Failure to fully and appropriately characterize worst-case LNG release scenarios underestimates the severity of risks
- A tanker release at the LNG terminal is not deemed credible, and hostile takeover of an LNG tanker is not evaluated. These events are possible and the risk of their occurrence should be assessed.
- Pipelines would pose a greater level of risk than as stated.
- An inappropriate thermal radiation distance is used. An exposure level of 5 Kw/m2 (which would cause 2nd degree burns in 30 seconds) is inadequate. This implicitly accepts the potential for adverse effects on the exposed public. A 1.5 Kw/m2 (450 Btu/hr-ft2) threshold should be used because it would allow emergency responders to identify the distance at which no injuries would result from extended exposure to an LNG fire.
- Members of the public are not adequately identified. Port employees and visitors are not considered as "the public" and are therefore afforded less protection.
- Disproportionate effects on low-income/minority populations (environmental justice) are not addressed
Important information is missing
- The Draft EIS/EIR does not include information on quality of the imported gas. Therefore, it cannot be determined if natural gas liquids (NGL) can be adequately removed by the NGL recovery unit or if natural gas will meet utility or state requirements. Descriptions of the following are also missing: procedures that would be followed if unexploded ordinance is encountered in soils or dredged material; the steps that would be taken to protect pipelines and foundations against corrosive soils; the onsite C2+ storage needs; and the air emissions by LNG consumers caused by LNG of uncertain quality.
- An accidental release from the C2 pipeline is not considered. Additionally, the likelihood of a pipeline incident that would cause serious injury or death is characterized qualitatively using criteria inconsistent with those used on other California pipeline projects subject to CEQA. The likelihood of a fatality from a pipeline accident being about 1:15,000 per year appears to be a substantial increase in the potential for incidents.
- The use of ~25 million gallons of water for testing of the LNG storage tanks needs to be concurred with by the City of Long Beach.
- The Port Master Plan Amendment does not define LNG as a "hazardous cargo", which it is. In addition, the document does not incorporate info from Master Plan Amendments No. 9 and 13. Amendments No. 9 and 13 modified the list of permitted uses in District 4 to include a three-acre site for a non-residential homeless service center and a 15 acre site in a different area for the City of Long Beach Police Department headquarters and training academy, respectively.
- In many cases, the Draft EIS/EIR does not address specific CEQA criteria. Current criteria recommended by the South Coast Air Quality Management District are not followed. The document does not clearly identify the significance level of each impact.
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