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CA Public Utilities Comm'n-Retained Expert Says Three Mile LNG Hazard Distance From PoLB Site Is Minimum Credible In Terrorist Attack; CPUC Says Expert's Info Justifies Rejecting PoLB Site; LB LNG Applicant Questions Modeling, Blasts CPUC For Not Awaiting EIR (Oct. 6, 2005) -- A California state agency has for the first time presented evidence that it says justifies federal rejection of a proposed 80+ million gallon Liquefied Natural Gas (LNG) facility in the Port of LB. In an October 4 motion filed with the Federal Energy Regulatory Commission (FERC) and posted on FERC's website, the CA Public Utilities Commission (CPUC) writes in pertinent part: Although the CPUC is filing this motion to supplement the record with evidence that justifies the rejection of the proposed liquefied natural gas ("LNG") facilities at the Port of Long Beach, the CPUC recognizes the need for new LNG terminals along the West Coast in order to ensure sufficient supplies of natural gas...The CPUC is committed to facilitating the construction of new LNG terminals on the West Coast and has already ordered the intrastate pipelines in California to provide firm access to LNG-supplied natural gas.Nevertheless, the evidence accompanying this motion establishes that approximately 130,000 people living or working within three miles of the proposed site at the Port Long Beach would be in harm’s way, and many of them could be killed or incur second-degree burns if there were a terrorist attack, earthquake or human error, which caused the release of LNG. In addition, there is vital infrastructure that could be destroyed at the Port of Long Beach if LNG were released at or near the proposed site. This potential disaster can be and must be prevented. Fortunately, this is not a Hobson's choice between either insufficient natural gas supplies or siting a hazardous LNG facility in a densely populated area. The evidence accompanying this motion also establishes that there are much safer alternatives to the proposed site for an LNG terminal at the Port of Long Beach. Therefore, the CPUC respectfully submits that the FERC should consider the evidence accompanying this motion as supplemental record evidence, and the FERC should reject SES’s application as being contrary to the public interest, or, alternatively, the FERC should set an evidentiary hearing in this matter. LBReport.com posts initial reaction below from an attorney from a law firm representing LB LNG project applicant Sound Energy Solutions (SES) on environmental and permitting issues. At the conclusion of this article we post a link to the motion as filed by CPUC. CPUC's motion cites testimony and a written report by Dr. Jerry Havens, an expert retained by CPUC to evaluate the LB LNG proposal. In prepared direct testimony declared true and correct to the best of his knowledge under penalty of perjury, Dr. Havens stated in pertinent part: I specified a minimum distance of three (3) miles for the extent to which the public could be in harm's way from the initial release of approximately 3,000,000 gallons of LNG onto water at the POLB, an event which is widely considered by the scientific community to be credible. the 3 mile hazard distance as the minimum which should be considered credible to occur as a result of a terrorist attack in the Port, but I remain concerned that the fire which formed the basis for the 3 mile consequence distance would be of such severity as to make it highly likely, if not almost certain, that further failures of flammable fuel containments would occur...Dr. Havens testified that he does not regard the 3 mile hazard distance as a worst case scenario but rather recommends "the 3 mile hazard distance as the minimum which should be considered credible to occur as a result of a terrorist attack in the Port": I am very concerned that such events as provide the basis for the 3 mile distance I am recommending would be of such severity as to make it highly likely, if not almost certain, that further failures of LNG containment vessels would occur. I repeat here my concern that the exposure to the ship from such a pool fire would have the potential to cause cascading, or even simultaneous failures of the remaining tanks on the vessel, resulting in total loss of the vessel and burning of its contents. Furthermore, I believe that insufficient attention has been given to the vulnerability of land storage tanks to terrorist attack, or even to the vulnerability of land storage tanks to natural events such as earthquakes and tsunamis, consideration of which is in order, as recent events remind us...... Q. Is it your position that there should not be any new LNG import terminals constructed in or around the United States? A. No, that is not my intention, nor do I believe it is a necessary result. I do have serious concerns about the adequacy of current regulations, particularly with the failure to consider the consequences of marine releases of LNG. I have serious concerns as well about the suitability of selected sites and of the associated marine transport, and I believe that the process underway to approve LNG import terminal sites is moving far too hastily and without sufficiently careful deliberation. However, I am also convinced of the necessity to consider most carefully some expansion of LNG importation because of the value it can bring. And I am no less convinced that we have in our grasp sufficient scientific tools to enable us to provide the public with reasonable assurance of its safety in today’s environment. I believe that proper use of those tools and methods can and will permit the location, even onshore, of LNG regasification facilities that present acceptable risks to the public when all of the relevant trade-offs of risk and benefit are considered. However, I do not believe that to be the case for the proposed LNG terminal in the Port of Long Beach, because of the very large populations in the affected zone, and the near certainty that it would be practically impossible to evacuate those people in sufficient time following an incident to get them out of harm’s way. And while the public safety should be considered of paramount importance, I also believe that, assuming the availability of alternative sites that will meet the nations’ needs, it just does not make good sense to place an LNG terminal in the POLB because of the potential (and the associated attraction) for a terrorist attack to cause extreme damage and disruption that could well have major national consequences. Q. Dr. Havens, on the FERC’s website and the California Energy Commission’s (CEC) website, there are two proposed LNG import terminals listed in federal waters offshore Southern California: BHP Billiton at Cabrillo Port and Crystal Energy on the Platform Grace. According to the CEC’s LNG project descriptions, BHP Billiton’s proposed LNG terminal would be approximately 14 miles offshore and Crystal Energy’s proposed LNG terminal would be approximately 10.5 miles offshore. (See [click here]). Do these proposed LNG import terminals pose the safety risks to the people onshore, which you have testified that SES’s proposed LNG import terminal would pose at the Port of Long Beach? A. No. The distances from shore of either of these projects would obviously protect the public from events which I have testified could put them in harm’s way approximately three miles from a rapid initial spill of 3,000,000 gallons of LNG onto water, an event that is widely considered by the scientific community to be credible. Although I have stated that a 3,000,000 gallon rapid spill should not be assumed to be the worst case that could be realized, because of the possibility that the ensuing fire could result in further failures of the LNG containment systems, it is my opinion that the separation distances from shore provided by either the Cabrillo Port or Platform Grace locations would keep the public onshore out of harm’s way...  "The radius of the circle extending from the terminal location is three miles." Source: CPUC Consumer Products Safety Division, An Assessment of the Potential Hazards to the Public Associated with Siting an LNG Import Terminal in the Port of Long Beach,, p. 53, Exhibit PUC 3 to CPUC Oct. 4, 2005 FERC motion. To view a PDF of this image, click image or click here. To view the complete CPUC motion, click here. Dr. Havens also testified that Mitsubishi Corporation, the parent of LB LNG applicant Sound Energy Solutions (SES), contacted him in Spring 2005 to request his help in analyzing the consequences of a terrorist attack on an LNG terminal or LNG ship. "[T]hey requested my technical support for a safety analysis of an LNG spill on the sea from an LNG ship that could result from a terrorist attack, including such factors as LNG spread and evaporation, and possibly FEM3A simulation of LNG vapor dispersion following such a spill. As I was already under contract with CPSD [CPUC's Consumer Product & Safety Division] for the preparation of the report on which this testimony is based, I declined their offer since such an activity (consulting for Mitsubishi) would create for me a conflict of interest in the present matter," Dr. Havens testified. Reached for comment on the CPUC motion, Ken Ehrlich, a partner in the L.A. law firm of Jeffer, Mangels, Butler and Marmaro, LLP which represents SES (a joint venture company between Mitsubishi and ConocoPhillips) on environmental and permitting issues, acknowledged that Dr. Havens is a respected scientist but indicated SES is concerned about, and is investigating, the validity of the model Dr. Havens used. "SES is in the process of evaluating and trying to validate his modeling because we're concerned that there might be flaws in the modeling. SES is thoroughly investigating this and we intend to make public whatever findings we get," Mr. Ehrlich said. With respect to the bigger picture of the CPUC filing itself, Mr. Ehrlich said "there are concerns that an agency like the [C]PUC has taken such a strong stance against the project without even reviewing the EIR [Environmental Impact Report]/EIS [fed'l Environmental Impact Statement]." Mr. Ehrlich continued, "By their actions, the [C]PUC has shown their real intentions in that they're not an impartial agency here, especially without the benefit of reviewing the EIR/EIS, and I think that is a disservice to the community, the public and the process." Dr. Havens has urged application of a more protective standard (lower thermal level assumed to induce burns) than currently used by FERC to evaluate risks of burns to humans from an LNG fire. The more protective standard was also urged by the CA Energy Commission in a September 2005 safety advisory report filed with FERC regarding the proposed PoLB LNG site. Dr. Havens' materials assume release of three million gallons of LNG postulated by earlier Sandia and ABS studies...less than the full amount carried by LNG tankers or stored on site. Dr. Havens' materials don't indicate the hazard distance if larger amounts of LNG were released. CPUC says Dr. Havens' testimony "points to much safer alternatives in more remote siting in federal offshore waters, where LNG terminals can provide the needed supplies of natural gas without putting the public in harm’s way." Those locations include two applications currently pending for sites 14 and 10.5 miles off the Ventura County coast. CPUC's motion includes sworn direct testimony by Dr. Havens, including the following: Q. What were you originally asked to do for the CPUC?A. The Consumer Protection and Safety Division (CPSD) of the CPUC requested that I prepare a science-based assessment of public safety issues that should be considered regarding the proposed siting of an LNG import terminal in the Port of Long Beach, California (POLB). Subsequently, the CPUC requested that I prepare this testimony and testify as an expert witness on behalf of the CPUC... Q. What are your conclusions concerning whether or not Sound Energy Solutions’ (SES) proposed LNG import terminal should be sited at the Port of Long Beach? A. I conclude that it is not in the public’s interest to site the proposed terminal in the Port of Long Beach because of the potential severe threat to public safety and to the Port and surrounding infrastructure that could result. The details of my consequence assessment are contained in my report to the CPSD [included in CPUC's motion], which I briefly summarize here. I specified a minimum distance of three (3) miles for the extent to which the public could be in harm’s way from the initial release of approximately 3,000,000 gallons of LNG onto water at the POLB, an event which is widely considered by the scientific community to be credible. I recommend the 3 mile hazard distance as the minimum which should be considered credible to occur as a result of a terrorist attack in the Port, but I remain concerned that the fire which formed the basis for the 3 mile consequence distance would be of such severity as to make it highly likely, if not almost certain, that further failures of flammable fuel containments would occur... ... Q. Did SES’s parent, Mitsubishi Corporation, contact you in the Spring of 2005 to request your help in analyzing the consequences of a terrorist attack Exhibit PUC-1 on an LNG terminal or LNG ship? A. Yes, they requested my technical support for a safety analysis of an LNG spill on the sea from an LNG ship that could result from a terrorist attack, including such factors as LNG spread and evaporation, and possibly FEM3A simulation of LNG vapor dispersion following such a spill. As I was already under contract with CPSD for the preparation of the report on which this testimony is based, I declined their offer since such an activity (consulting for Mitsubishi) would create for me a conflict of interest in the present matter... ... Q. Please explain what would be the consequence of a pool fire. A. It is now widely accepted that spillage from a ship container of approximately 3,000,000 gallons of LNG is credible. It is highly likely that ignition sources (such as broken electrical wires, sparks resulting from friction, or open flames) would cause the LNG vapor evolving from such a spill, which would mix with air, to catch fire. Such a fire would be so large as to be completely beyond the capability of any organization to extinguish or even contain it, and it could seriously burn people to considerable distances from the fire’s edge. There is a scientific consensus that such a fire could result in heat fluxes of 5 KW/m 2 , which could cause second-degree burns to unprotected persons exposed for approximately 30 seconds, at a distance of approximately one mile from the center of the fire. Even more serious burns could occur at the one mile distance if exposure times were longer, and serious burns could occur at greater distances, even with lower thermal fluxes, with sufficient exposure times. In order to provide distances of separation which would ensure that unprotected persons would not be affected, I believe the criteria for safe separation should be based on a lower thermal flux value of approximately 1.5 KW/m 2 . If such a criterion is used, the safe separation distance would increase, for such a spill, to approximately 1 ½ to 2 miles. Furthermore, there is good reason to believe that such a large fire could result in further failures of the containment system on the ship. As the Sandia report concludes that as many as three containers might fail, increasing the safe separation distance by approximately one third, I believe that the minimum separation distance should be considered to be approximately 2 ½ to 3 miles. Q. What would happen if there were a vapor cloud fire at the Port of Long Beach? A. A vapor cloud fire could result if the LNG spill vapors were not immediately ignited, and a vapor cloud formed. The cloud thus formed would drift downwind until it reached an ignition source or became diluted below the flammable concentration level -- after which time it would not constitute a hazard. If the vapor cloud were ignited as it drifted downwind, the portions of the cloud which were above the lower flammability limit (~ 5%) would burn, and those persons in that area or immediately adjacent (thermal exposure could occur at some distance beyond the edge of the fire) who could not gain protection could be killed or seriously injured. In my opinion the maximum distance downwind to which portions of a cloud (sufficiently large to constitute a severe fire hazard) formed from the rapid spillage onto water of 3,000,000 gallons of LNG could be ignited is approximately three miles... ... Q. Is your 3-mile recommendation based upon a worst case scenario for the Port of Long Beach? A. No, I am very concerned that such events as provide the basis for the 3 mile distance I am recommending would be of such severity as to make it highly likely, if not almost certain, that further failures of LNG containment vessels would occur. I repeat here my concern that the exposure to the ship from such a pool fire would have the potential to cause cascading, or even simultaneous failures of the remaining tanks on the vessel, resulting in total loss of the vessel and burning of its contents. Furthermore, I believe that insufficient attention has been given to the vulnerability of land storage tanks to terrorist attack, or even to the vulnerability of land storage tanks to natural events such as earthquakes and tsunamis, consideration of which is in order, as recent events remind us... To view CPUC's motion filed Oct. 4 with FERC click here. Contact us: mail@LBReport.com |
     
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