Liquefied Natural Gas : Security and Hazards [1 ed.] 9781614701897, 9781606922743

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Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved. Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved. Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved.

LIQUEFIED NATURAL GAS: SECURITY AND HAZARDS No part of this digital document may be reproduced, stored in a retrieval system or transmitted in any form or by any means. The publisher has taken reasonable care in the preparation of this digital document, but makes no expressed or implied warranty of any kind and assumes no responsibility for any errors or omissions. No liability is assumed for incidental or consequential damages in connection with or arising out of information contained herein. This digital document is sold with the clear understanding that the publisher is not engaged in rendering legal, medical or any other professional services.

Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved. Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved.

LIQUEFIED NATURAL GAS: SECURITY AND HAZARDS

LOHN T. LAYTON AND BARRY W. KELLER EDITORS

Nova Science Publishers, Inc. New York

Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

Copyright © 2009 by Nova Science Publishers, Inc. All rights reserved. No part of this book may be reproduced, stored in a retrieval system or transmitted in any form or by any means: electronic, electrostatic, magnetic, tape, mechanical photocopying, recording or otherwise without the written permission of the Publisher. For permission to use material from this book please contact us: Telephone 631-231-7269; Fax 631-231-8175 Web Site: http://www.novapublishers.com

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NOTICE TO THE READER The Publisher has taken reasonable care in the preparation of this book, but makes no expressed or implied warranty of any kind and assumes no responsibility for any errors or omissions. No liability is assumed for incidental or consequential damages in connection with or arising out of information contained in this book. The Publisher shall not be liable for any special, consequential, or exemplary damages resulting, in whole or in part, from the readers’ use of, or reliance upon, this material. Independent verification should be sought for any data, advice or recommendations contained in this book. In addition, no responsibility is assumed by the publisher for any injury and/or damage to persons or property arising from any methods, products, instructions, ideas or otherwise contained in this publication. This publication is designed to provide accurate and authoritative information with regard to the subject matter covered herein. It is sold with the clear understanding that the Publisher is not engaged in rendering legal or any other professional services. If legal or any other expert assistance is required, the services of a competent person should be sought. FROM A DECLARATION OF PARTICIPANTS JOINTLY ADOPTED BY A COMMITTEE OF THE AMERICAN BAR ASSOCIATION AND A COMMITTEE OF PUBLISHERS. LIBRARY OF CONGRESS CATALOGING-IN-PUBLICATION DATA ISBN: 978-1-61470-189-7 (eBook)

Published by Nova Science Publishers, Inc. New York

Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

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Evolution and Schizophrenia

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CONTENTS Preface Chapter 1

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Chapter 2

Chapter 3

Chapter 4

ix Maritime Security:Public Safety Consequences of a Terrorist Attack on a Tanker Carrying Liquefied Natural Gas Need Clarification GAO

1

Maritime Security: Public SafetyConsequences of a Liquefied Natural Gas Spill Need Clarification Jim Wells

43

Liquefied Natural Gas (LNG)Infrastructure Security: Issues for Congress Paul W. Parfomak

49

Maritime Security: Opportunities Exist to Further Clarify the Consequences of a Liquefied Natural Gas Tanker Spill Mark Gaffigan

Index

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PREFACE Liquefied natural gas (LNG) is a hazardous fuel shipped in large tankers from overseas to U.S. ports. Because LNG infrastructure is highly visible and easily identified, it can be vulnerable to terrorist attack. This book discusses the new measures taken into effect in response to September 11th 2001. Public concerns are addressed about LNG risks, which continue to raise questions about LNG security. This book also examines the concerns that Congress faces with regards to the adequacy of security provisions in federal LNG regulation. Although potentially catastrophic events could arise from a serious accident or attack on tankers, import terminals or inland storage plants, LNG has a record of relative safety for the last 40 years, and no LNG tanker or land-based facility has ever been attacked by terrorists. However, the likelihood and possible impacts from LNG attacks is widely debated among experts. Thus, a discussion on this controversial topic is included in this book. Chapter 1 - The six unclassified studies we reviewed all examined the heat impact of an LNG pool fire but produced varying results; some studies also examined other potential hazards of a large LNG spill and reached consistent conclusions on explosions. Specifically, the studies’ conclusions about the distance at which 30 seconds of exposure to the heat could burn people ranged from about 500 meters (less than 1/3 of a mile) to more than 2,000 meters (about 1-1/4 miles). The Sandia National Laboratories’ study concluded that the most likely distance for a burn is about 1,600 meters (1 mile). These variations occurred because researchers had to make numerous modeling assumptions to scale-up the existing experimental data for large LNG spills since there are no large spill data from actual events. These assumptions involved the size of the hole in the tanker, the number of tanks that fail, the volume of LNG spilled, key LNG fire properties, and environmental conditions, such as wind and waves.

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Three of the studies also examined other potential hazards of an LNG spill, including LNG vapor explosions, asphyxiation, and cascading failure. All three studies considered LNG vapor explosions unlikely unless the LNG vapors were in a confined space. Only the Sandia National Laboratories’ study examined asphyxiation, and it concluded that asphyxiation did not pose a hazard to the general public. Finally, only the Sandia National Laboratories’ study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks would be involved in such an event and that this number of tanks would increase the duration of the LNG fire. Chapter 2 - The six unclassified studies we reviewed all examined the heat impact of an LNG fire but produced varying results; some studies also examined other potential hazards of a large LNG spill and reached consistent conclusions on explosions. Specifically, the studies’ conclusions about the distance at which 30 seconds of exposure to the heat could burn people— also termed the heat impact distance—ranged from less than 1/3 of a mile to about 1-1/4 miles. These variations occurred because, with no data on large spills from actual events, researchers had to make numerous modeling assumptions to scale up the existing experimental data for large LNG spills. These assumptions involved the size of the hole in the tanker, the number of tanks that fail, the volume of LNG spilled, key LNG fire properties, and environmental conditions, such as wind and waves. Three of the studies also examined other potential hazards of an LNG spill, including LNG vapor explosions, asphyxiation, and the sequential failure of multiple tanks on the LNG vessel (cascading failure). All three studies considered LNG vapor explosions unlikely unless the vapors were in a confined space. Only the Sandia study examined asphyxiation and concluded that asphyxiation did not pose a hazard to the general public. Finally, only the Sandia study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks on a typical LNG vessel would be involved in such an event and that this number of tanks would increase the duration of the LNG fire. Our panel of 19 experts generally agreed on the public safety impact of an LNG spill, disagreed on specific conclusions of the Sandia study, and suggested future research priorities. Experts agreed on three main points: (1) the most likely public safety impact of an LNG spill is the heat impact of a fire; (2) explosions are not likely to occur in the wake of an LNG spill unless the LNG vapors are in confined spaces; and (3) some hazards, such as freeze burns and asphyxiation, do not pose a hazard to the public. However, the experts disagreed with a few conclusions reached by the Sandia study that the Coast Guard uses to assess the suitability of waterways for LNG tankers going to proposed LNG terminals. Specifically, all experts did not agree with the study’s 1-mile estimate of heat

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impact distance resulting from an LNG fire: 7 of 15 thought Sandia’s distance was “about right,” 8 were evenly split on whether the distance was “too conservative” or “not conservative enough,” and 4 did not answer this question. Experts also did not agree with the Sandia National Laboratories’ conclusion that only three of the five LNG tanks on a tanker would be involved in a cascading failure. Finally, experts suggested priorities to guide future research aimed at clarifying uncertainties about heat impact distances and cascading failure, including largescale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques. DOE’s recently funded study involving large-scale LNG fire experiments addresses some, but not all, of the research priorities the expert panel identified. Chapter 3 - iquefied natural gas (LNG) is a hazardous fuel shipped in large tankers from overseas to U.S. ports. Because LNG infrastructure is highly visible and easily identified, it can be vulnerable to terrorist attack. Since September 11, 2001, the U.S. LNG industry and federal agencies have put new measures in place to respond to the possibility of terrorism. Nonetheless, public concerns about LNG risks continue to raise questions about LNG security. Faced with a perceived national need for greater LNG imports, and persistent public concerns about LNG risks, some in Congress are examining the adequacy of security provisions in federal LNG regulation. LNG infrastructure consists primarily of tankers, import terminals, and inland storage plants. There are nine active U.S. terminals and proposals for many others. Although potentially catastrophic events could arise from a serious accident or attack on such facilities, LNG has a record of relative safety for the last 40 years, and no LNG tanker or land-based facility has been attacked by terrorists. The likelihood and possible impacts from LNG attacks continue to be debated among experts. Several federal agencies oversee LNG infrastructure security. The Coast Guard has lead responsibility for LNG shipping and marine terminal security under the Maritime Transportation Security Act of 2002 (P.L. 107-295) and the Security and Accountability for Every Port Act of 2006 (P.L. 109-347). The Office of Pipeline Safety (OPS) and the Transportation Security Administration (TSA) both have security authority for LNG storage plants within gas utilities, as well as some security authority for LNG marine terminals. The Federal Energy Regulatory Commission (FERC) approves the siting, with some security oversight, of on-shore LNG marine terminals and certain utility LNG plants. The Coast Guard, OPS and FERC cooperate in the siting approval of new LNG facilities, inspection and operational review of existing facilities, informal communication, and dispute resolution.

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Federal initiatives to secure LNG are still evolving, but a variety of industry and agency representatives suggest they are reducing the vulnerability of LNG to terrorism. S. 1594 would strengthen federal protection of vessels and infrastructure handling LNG and other especially hazardous cargoes through new international standards, new training requirements, vessel security cost-sharing, incident response and recovery plans, and other provisions. H.R. 2830, which passed in the House of Representatives on April 24, 2008, but which President Bush has threatened to veto, would require the Coast Guard to secure LNG tankers, and would limit the agency’s reliance on state and local resources in doing so, among other provisions. As Congress continues its oversight of LNG, it may consider whether future LNG security requirements will be appropriately funded, whether these requirements will be balanced against evolving risks, and whether the LNG industry is carrying its fair share of the security burden. Congress may also act to improve its understanding of LNG security risks. Finally, Congress may initiate action to better understand the security and trade implications of efforts to promote U.S.-flagged LNG tankers and U.S. crews. Chapter 4 - The six studies we reviewed all examined the heat impact of an LNG fire but produced varying results; some studies also examined other potential hazards of a large LNG spill and reached consistent conclusions on explosions. Specifically, the studies’ conclusions about the distance at which 30 seconds of exposure to the heat could burn people—also termed the heat impact distance—ranged from less than 1/3 of a mile to about 1- 1/4 miles. These variations occurred because, with no data on large spills from actual events, researchers had to make numerous modeling assumptions to scale up the existing experimental data for large LNG spills. These assumptions involved the size of the hole in the tanker, the number of tanks that fail, the volume of LNG spilled, key LNG fire properties, and environmental conditions, such as wind and waves. Three of the studies also examined other potential hazards of an LNG spill, including LNG vapor explosions, asphyxiation, and the sequential failure of multiple tanks on the LNG vessel (cascading failure). All three studies considered LNG vapor explosions unlikely unless the vapors were in a confined space. Only the Sandia study examined asphyxiation and concluded that asphyxiation did not pose a hazard to the general public. Finally, only the Sandia study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks on a typical LNG vessel would be involved in such an event and that this number of tanks would increase the duration of the LNG fire. Our panel of 19 experts generally agreed on the public safety impact of an LNG spill, disagreed on specific conclusions of the Sandia study, and suggested future research priorities. Experts agreed on three main points: (1) the most likely

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public safety impact of an LNG spill is the heat impact of a fire; (2) explosions are not likely to occur in the wake of an LNG spill unless the LNG vapors are in confined spaces; and (3) some hazards, such as freeze burns and asphyxiation, do not pose a hazard to the public. However, the experts disagreed with a few conclusions reached by the Sandia study that the Coast Guard uses to assess the suitability of waterways for LNG tankers going to proposed LNG terminals. Specifically, all experts did not agree with the study’s 1-mile estimate of heat impact distance resulting from an LNG fire: 7 of 15 thought Sandia’s distance was “about right,” 8 were evenly split on whether the distance was “too conservative” or “not conservative enough,” and 4 did not answer this question. Experts also did not agree with the Sandia National Laboratories’ conclusion that only three of the five LNG tanks on a tanker would be involved in a cascading failure. Finally, experts suggested priorities to guide future research aimed at clarifying uncertainties about heat impact distances and cascading failure, including largescale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques. DOE’s recently funded study involving large-scale LNG fire experiments addresses some, but not all, of the research priorities the expert panel identified.

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In: Liquefied Natural Gas: Security and Hazards ISBN 978-1-60692-274-3 Editors: J.T. Layton, B.W. Keller, pp. 1-42 © 2009 Nova Science Publishers, Inc.

Chapter 1

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MARITIME SECURITY: PUBLIC SAFETY CONSEQUENCES OF A TERRORIST ATTACK ON A TANKER CARRYING LIQUEFIED NATURAL GAS NEED CLARIFICATION* GAO WHAT GAO FOUND The six unclassified completed studies GAO reviewed examined the effect of a fire resulting from an LNG spill but produced varying results; some studies also examined other potential hazards of a large LNG spill. The studies’ conclusions about the distance at which 30 seconds of exposure to the heat (heat hazard) could burn people ranged from less than 1/3 of a mile to about 1-1/4 miles. Sandia National Laboratories (Sandia) conducted one of the studies and concluded, based on its analysis of multiple attack scenarios, that a good estimate of the heat hazard distance would be about 1 mile. Federal agencies use this conclusion to assess proposals for new LNG import terminals. The variations among the studies occurred because researchers had to make modeling assumptions since there are no data for large LNG spills, either from accidental spills or spill experiments. *

Excerpted from GAO report GAO-07-316, dated February 2007.

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These assumptions involved the size of the hole in the tanker; the volume of the LNG spilled; and environmental conditions, such as wind and waves. The three studies that considered LNG explosions concluded explosions were unlikely unless the LNG vapors were in a confined space. Only the Sandia study examined the potential for sequential failure of LNG cargo tanks (cascading failure) and concluded that up to three of the ship’s five tanks could be involved in such an event and that this number of tanks would increase the duration of the LNG fire. GAO’s expert panel generally agreed on the public safety impact of an LNG spill, but believed further study was needed to clarify the extent of these effects, and suggested priorities for this additional research. Experts agreed that the most likely public safety impact of an LNG spill is the heat hazard of a fire and that explosions are not likely to occur in the wake of an LNG spill. However, experts disagreed on the specific heat hazard and cascading failure conclusions reached by the Sandia study. DOE’s recently funded study involving large-scale LNG fire experiments addresses some, but not all, of the research priorities identified by the expert panel. The leading unaddressed priority the panel cited was the potential for cascading failure of LNG tanks.

Source: GAO. LNG Tanker Passing Downtown Boston on its Way to Port.

WHY GAO DID THIS STUDY The United States imports natural gas by pipeline from Canada and by tanker as liquefied natural gas (LNG) from overseas. LNG—a supercooled form of natural gas— currently accounts for about 3 percent of total U.S. natural gas

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supply, with an expected increase to about 17 percent by 2030, according to the Department of Energy (DOE). With this projected increase, many more LNG import terminals have been proposed. However, concerns have been raised about whether LNG tankers could become terrorist targets, causing the LNG cargo to spill and catch on fire, and potentially explode. DOE has recently funded a study to consider these effects; completion is expected in 2008. GAO was asked to (1) describe the results of recent studies on the consequences of an LNG spill and (2) identify the areas of agreement and disagreement among experts concerning the consequences of a terrorist attack on an LNG tanker. To address these objectives, GAO, among other things, convened an expert panel to discuss the consequences of an attack on an LNG tanker.

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WHAT GAO RECOMMENDS GAO recommends that the Secretary of Energy ensure that DOE incorporates into its LNG study the key issues identified by the expert panel. In reviewing our draft report, DOE agreed with our recommendation. www.gao.gov/cgi-bin/getrpt?GAO-07-316. To view the full product, including the scope and methodology, click on the link above. For more information, contact Jim Wells at (202) 512-3841 or [email protected].

ABBREVIATIONS BLEVE DOE DOT FERC kW/m2 LNG LPG 2 m 3 m

m/s RPT WSA

boiling liquid expanding vapor explosion Department of Energy Department of Transportation Federal Energy Regulatory Commission kilowatts per square meter liquefied natural gas liquefied petroleum gas square meters cubic meters meters per second rapid phase transition Waterway Suitability Assessment

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February 22, 2007 The Honorable John D. Dingell Chairman The Honorable Joe Barton Ranking Member Committee on Energy and Commerce House of Representatives The Honorable Bennie G. Thompson Chairman The Honorable Peter King Ranking Member Committee on Homeland Security House of Representatives

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The Honorable Edward J. Markey House of Representatives Worldwide, over 40,000 tanker cargos of liquefied natural gas (LNG) have been shipped since 1959, and imports of LNG are projected to increase over the next 10 years. LNG is a supercooled liquid form of natural gas—a crucial source of energy for the United States. Natural gas is used in homes for cooking and heating and as fuel for generating electricity, and it accounts for about one-fourth of all energy consumed in the United States each year. Prices for natural gas in the United States have risen over the past 5 years as demand for natural gas has increased faster than domestic production. To make up for the domestic shortfall, the United States imports some natural gas in pipelines from Canada. However, most reserves of natural gas are overseas and cannot be transported through pipelines. Natural gas from these reserves has to be transported to the United States as LNG in tankers. Because of the projected increase in LNG tankers arriving at U.S. ports, concerns have been raised about whether the tankers could become terrorist targets. LNG—primarily composed of methane—is odorless and nontoxic. It is produced by supercooling natural gas to minus 260 degrees Fahrenheit at atmospheric pressure, thus reducing its volume by more than 600 times. This process makes transport by tankers feasible. The tankers are double- hulled, with each tanker containing between four and six adjacent tanks heavily insulated to maintain the LNG’s supercool temperature. Generally, these ships can carry enough LNG to supply the daily energy needs of over 10 million homes.

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Importing LNG requires specialized facilities—called regasification terminals—at ports of entry. At these terminals, the liquid is reconverted into natural gas and then injected into the pipeline system for consumers. Currently, the United States has a total of five LNG import terminals—four are considered onshore terminals, that is, they are located within 3 miles of the shore; one is an offshore terminal located 116 miles off the Louisiana coast in the Gulf of Mexico.1 The United States imports about 3 percent of its total natural gas supply as LNG in recent years, but by 2030, LNG imports are projected to account for about 17 percent of the U.S. natural gas supply, according to the Department of Energy’s (DOE) Energy Information Administration. To meet this increased demand, energy companies have submitted 32 applications to build new terminals for importing LNG in 10 states and five offshore areas. Figure 1 shows the locations of LNG terminals that are operational, approved, and proposed.

Sources: FERC and GAO. Figure 1. Existing, Approved, and Proposed LNG Terminals in the United States, as of October 2006.

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As of October 2006, the Federal Energy Regulatory Commission (FERC)2— responsible for approving onshore LNG terminal siting applications—and the U.S. Coast Guard3—responsible for approving offshore LNG terminal siting applications—had together approved 13 of these applications. In addition, the Coast Guard contributes to FERC’s review of onshore LNG facilities by reviewing and validating an applicant’s Waterway Suitability Assessment (WSA) and reaching a preliminary conclusion as to whether the waterway is suitable for LNG operations with regard to navigational safety and security considerations. The WSA includes a security risk assessment to evaluate the public safety risk of an LNG spill from a tanker following an attack. The security risk assessment analyzes potential types of attacks, their probability, and the potential consequences. The WSA also identifies appropriate strategies that can be used to reduce the risk posed by a terrorist attack on an LNG tanker, either by reducing the probability of an attack, or by reducing its consequences. If the WSA deems the waterway suitable for LNG tanker traffic, the Coast Guard provides FERC with a “Letter of Recommendation,” which describes the overall risk reduction strategies that will be used on LNG tankers traveling to the proposed terminal. The Coast Guard is the lead federal agency for ensuring the security of active LNG import terminals and tankers traveling within U.S. ports. As figure 1 shows, six new facilities have been proposed for the northeastern United States, a region that faces gas supply challenges. The Northeast has limited indigenous supplies of natural gas, and receives most of its natural gas either through pipelines from the U.S. Gulf Coast or Canada, or from overseas via tanker as LNG. The pipelines into the Northeast currently run at or near capacity for much of the winter, and demand is projected to significantly increase over the next 5 years, exceeding available supply by 2010. To meet the increasing demand, new supplies of natural gas must reach the Northeast by expanding existing pipeline capacity, constructing new pipelines, or constructing new LNG terminals—all of which have risk associated with them. Difficulties siting LNG facilities in the Northeast could lead to higher natural gas prices unless additional supply can be brought into the region via new, or expansion of old, pipelines. Scientists and the public have raised concerns about the potential hazards that an LNG spill could pose. When LNG is spilled from a tanker, it forms a pool of liquid on the water. Individuals who come into contact with LNG could experience freeze burns. As the liquid warms and changes into natural gas, it forms a visible, foglike vapor cloud close to the water. The cloud mixes with ambient air as it continues to warm up and eventually the natural gas disperses into the atmosphere. Under certain atmospheric conditions, however, this cloud

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could drift into populated areas before completely dispersing. Because an LNG vapor cloud displaces the oxygen in the air, it could potentially asphyxiate people who come into contact with it. Furthermore, like all natural gas, LNG vapors can be flammable, depending on conditions.4 If the LNG vapor cloud ignites, the resulting fire will burn back through the vapor cloud toward the initial spill. It will continue to burn above the LNG that has pooled on the surface—this is known as a pool fire. Experiments to date have shown that LNG fires burn hotter than oil fires of the same size. Both the cold temperatures of spilled LNG and the high temperatures of an LNG fire have the potential to significantly damage the tanker, causing multiple tanks on the ship to fail in sequence—called a cascading failure. Such a failure could increase the severity of the incident. Finally, concerns have been raised about whether an explosion could result from an LNG spill. Although LNG tankers have carried over 40,000 shipments worldwide since 1959, there have been no LNG spills resulting from a cargo tank rupture. Some safety incidents, such as groundings or collisions, have resulted in small LNG spills that did not affect public safety. In the 1970s and 1980s, experiments to determine the consequences of a spill examined small LNG spills of up to 35 meters in diameter. Following the terrorist attacks of September 11, 2001, however, many experts recognized that an attack on an LNG tanker could result in a large spill—a volume of LNG up to 100 times greater than studied in past experiments. Since then, a number of studies have reevaluated safety hazards of LNG tankers in light of a potential terrorist threat. Because a major LNG spill has never occurred, studies examining LNG hazards rely on computer models to predict the effects of hypothetical accidents, often focusing on the properties of LNG vapor fires. The Coast Guard uses one of these studies, conducted in 2004 by Sandia National Laboratories,5 as a basis for conducting the security risk assessment required in the WSA for proposed onshore LNG facilities.6 Access to accurate information about the consequences of LNG spills is crucial for developing accurate risk assessments for LNG siting decisions. While an underestimation of the consequences could expose the public to additional risk in the event of an LNG spill, an overestimation of consequences could result in the use of inappropriate and costly risk mitigation strategies. DOE recently funded a new study—to be completed by Sandia National Laboratories in 2008— that will conduct small- and large-scale LNG fire experiments to refine and validate existing models (such as the one used by Sandia National Laboratories in their 2004 study) that calculate the heat hazards of large LNG fires. In this context, you asked us to (1) describe the results of recent unclassified studies on the consequences of an LNG spill and (2) identify the areas of

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agreement and disagreement among experts concerning the consequences of a terrorist attack on an LNG tanker. To address the first objective, we identified eight unclassified, completed studies of LNG hazards and reviewed the six studies that included new, original research (either experimental or modeling) and clearly described the methodology used. While we have not verified the scientific modeling or results of these studies, the methods used seem appropriate for the work conducted. We also interviewed agencies responsible for LNG regulations and visited all four onshore LNG import facilities and one export facility. To address the second objective, we identified 19 recognized experts in LNG hazard analysis and convened a Webbased expert panel to obtain their views on LNG hazards and to get agreement on as many issues as possible. In selecting experts for the panel, we sought individuals who are widely recognized as having experience with one or more key aspects of LNG hazard analysis. We sought to achieve balance in representation from government, academia, consulting, research organizations, and industry. Additionally, we ensured that our expert panel included at least one author from each of the six unclassified studies of LNG hazards. Because some of the studies conducted are classified, this public version of our findings supplements a more comprehensive classified report produced under separate cover. A more detailed description of our scope and methodology is presented in appendix I. We conducted our work from January 2006 through January 2007 in accordance with generally accepted government auditing standards.

RESULTS IN BRIEF The six unclassified studies we reviewed all examined the heat impact of an LNG pool fire but produced varying results; some studies also examined other potential hazards of a large LNG spill and reached consistent conclusions on explosions. Specifically, the studies’ conclusions about the distance at which 30 seconds of exposure to the heat could burn people ranged from about 500 meters (less than 1/3 of a mile) to more than 2,000 meters (about 1-1/4 miles). The Sandia National Laboratories’ study concluded that the most likely distance for a burn is about 1,600 meters (1 mile). These variations occurred because researchers had to make numerous modeling assumptions to scale-up the existing experimental data for large LNG spills since there are no large spill data from actual events. These assumptions involved the size of the hole in the tanker, the number of tanks that fail, the volume of LNG spilled, key LNG fire properties,

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and environmental conditions, such as wind and waves. Three of the studies also examined other potential hazards of an LNG spill, including LNG vapor explosions, asphyxiation, and cascading failure. All three studies considered LNG vapor explosions unlikely unless the LNG vapors were in a confined space. Only the Sandia National Laboratories’ study examined asphyxiation, and it concluded that asphyxiation did not pose a hazard to the general public. Finally, only the Sandia National Laboratories’ study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks would be involved in such an event and that this number of tanks would increase the duration of the LNG fire. Our panel of 19 experts generally agreed on the public safety impact of an LNG spill, disagreed with a few conclusions reached by the Sandia National Laboratories’ study, and suggested priorities for research to clarify the impact of heat and cascading tank failures. Experts agreed that (1) the most likely public safety impact of an LNG spill is the heat impact of a fire; (2) explosions are not likely to occur in the wake of an LNG spill, unless the LNG vapors are in confined spaces; and (3) some hazards, such as freeze burns and asphyxiation, do not pose a hazard to the public. Experts disagreed with the heat impact and cascading tank failure conclusions reached by the Sandia National Laboratories’ study, which the Coast Guard uses to prepare WSAs. Specifically, all experts did not agree with the heat impact distance of 1,600 meters. Seven of 15 experts thought Sandia’s distance was “about right,” and the remaining eight experts were evenly split as to whether the distance was “too conservative” or “not conservative enough” (the other 4 experts did not answer this question). Experts also did not agree with the Sandia National Laboratories’ conclusion that only three of the five LNG tanks on a tanker would be involved in a cascading failure. Finally, experts suggested priorities to guide future research aimed at clarifying uncertainties about heat impact distances and cascading failure, including largescale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques. DOE’s recently funded study involving large-scale LNG fire experiments addresses some, but not all, of the research priorities identified by the expert panel. We are recommending that DOE incorporate into its current LNG study the key issues identified by the expert panel. We particularly recommend that DOE examine the potential for cascading failure of LNG tanks.

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BACKGROUND Natural gas is primarily composed of methane, with small percentages of other hydrocarbons, including propane and butane. When natural gas is cooled to minus 260 degrees Fahrenheit at atmospheric pressure, the gas becomes a liquid, known as LNG, and it occupies only about 1/600th of the volume of its gaseous state. Since LNG is maintained in an extremely cooled state—reducing its volume—there is no need to store it under pressure. This liquefaction process allows natural gas to be transported by trucks or tanker vessels. LNG is not explosive or flammable in its liquid state. When LNG is warmed, either at a regasification terminal or from exposure to air as a result of a spill, it becomes a gas. As this gas mixes with the surrounding air, a visible, low-lying vapor cloud results. This vapor cloud can be ignited and burned only within a minimum and maximum concentration of air and vapor (percentage by volume). For methane, the dominant component of this vapor cloud, this flammability range is between 5 percent and 15 percent by volume. When fuel concentrations exceed the cloud’s upper flammability limit, the cloud cannot burn because too little oxygen is present. When fuel concentrations are below the lower flammability limit, the cloud cannot burn because too little methane is present. As the cloud vapors continue to warm, above minus 160 degrees Fahrenheit, they become lighter than air and will rise and disperse rather than collect near the ground. If the cloud vapors ignite, the resulting fire will burn back through the vapor cloud toward the initial spill and will continue to burn above the LNG that has pooled on the surface. This fire burns at an extremely high temperature—hotter than oil fires of the same size. LNG fires burn hotter because the flame burns very cleanly and with little smoke. In oil fires, the smoke emitted by the fire absorbs some of the heat from the fire and reduces the amount of heat emitted. Scientists measure the amount of heat given off by a fire by looking at the amount of heat energy emitted per unit area as a function of time. This is called the surface emissive power of a fire and is measured in kilowatts per square meter (kW/m2). Generally, the heat given off by an LNG fire is reported to be more than 200 kW/m2. By comparison, the surface emissive power of a very smoky oil fire can be as little as 20 kW/m2. The heat from fire can be felt far away from the fire itself. Scientists use heat flux—also measured in kW/m2—to quantify the amount of heat felt at a distance from a fire. For instance, a heat flux of 5 kW/m2 can cause second degree burns after about 30 seconds of exposure to bare skin. This heat flux can be compared with the heat from a candle— if a hand is held about 8 to 9 inches above the candle, second degree burns could result in about 30

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seconds. A heat flux of about 12.5 kW/m2, over an exposure time of 10 minutes, will ignite wood, and a heat flux of about 37.5 kW/m2 can damage steel structures. Four types of explosions could potentially occur after an LNG spill: rapid phase transitions (RPT), deflagrations, detonations, and boiling-liquidexpandingvapor-explosions (BLEVE).7 More specifically: •

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•

•

An RPT occurs when LNG is warmed and changes into natural gas nearly instantaneously. An RPT generates a pressure wave that can range from very small to large enough to damage lightweight structures. RPTs strong enough to damage test equipment have occurred in past LNG spill experiments on water, although their effects have been localized at the site of the RPT. Deflagrations and detonations are explosions that involve combustion (fire). They differ on the basis of the speed and strength of the pressure wave generated: deflagrations move at subsonic velocities and can result in pressures (overpressures) up to 8 times higher than the original pressure; detonations travel faster—at supersonic velocities—and can result in larger overpressures—up to 20 times the original pressure. Methane does not detonate as readily as other hydrocarbons; it requires a larger explosion to initiate a detonation in a methane cloud. A BLEVE occurs when a liquefied gas is heated to above its boiling point while contained within a tank. For instance, if a hot fire outside an LNG tanker sufficiently heated the liquid inside, a percentage of the LNG within the tank could “flash” into a vapor state virtually instantaneously, causing the pressure within the tank to increase. LNG tanks do have pressure relief valves, but if these were inadequate or failed, the pressure inside the tank could rupture the tank. The escaping gas would be ignited by the fire burning outside the tank, and a fireball would ensue. The rupture of the tank could create an explosion and flying debris (portions of the tank).

World natural gas reserves are abundant, estimated at about 6,300 trillion cubic feet, or 65 times the volume of natural gas used in 2005. Much of this gas is considered “stranded” because it is located in regions far from consuming markets. Russia, Iran, and Qatar combined hold natural gas reserves that represent more than half of the world total. Many countries have imported LNG for years. In 2005, 13 countries shipped natural gas to 14 LNG-importing countries. LNG

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imports, as a percentage of a country’s total gas supply, for each of the importing countries ranged from 3 percent in the United States to nearly 95 percent in Japan. In 2005, LNG imports to the United States originated primarily in Trinidad and Tobago (70 percent), Algeria (15 percent), and Egypt (11 percent). The remaining 4 percent of U.S. LNG imports came from Oman, Malaysia, Nigeria, and Qatar. LNG tankers primarily have two basic designs, called membrane or Moss (see fig. 2). Both designs consist of an outer hull, inner hull, and cargo containment system. In membrane tank designs, the cargo is contained by an Invar, or stainless steel double-walled liner, that is structurally supported by the vessel’s inner hull. The Moss tank design uses structurally independent spherical or prismatic shaped tanks. These tanks, usually five located one behind the other, are constructed of either stainless steel or an aluminum alloy. LNG tankers ships are required to meet international maritime construction and operating standards, as well as U.S. Coast Guard safety and security regulations.

Source: GAO. Figure 2. LNG Membrane Tanker.

STUDIES IDENTIFIED DIFFERENT DISTANCES FOR THE HEAT EFFECTS OF AN LNG FIRE The six studies we examined identified various distances at which the heat effects of an LNG fire could be hazardous to people. The studies’ variations in heat effects result from the assumptions made in the studies’ models. Some

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studies also examined other potential hazards such as LNG vapor explosions, other types of explosions, and asphyxiation, and identified their potential impacts on public safety.

Studies Identified Various Distances that the Heat Effects of an LNG Fire Could Be Hazardous to People because of Assumptions Made The studies’ conclusions about the distance at which 30 seconds of exposure to the heat could burn people ranged from about 500 meters (less than 1/3 mile) to more than 2,000 meters (about 1-1/4 miles). The results—size of the LNG pool, the duration of the fire, and the heat hazard distance for skin burn—varied in part because the studies made different assumptions about key parameters of LNG spills and also because they were designed and conducted for different purposes. Key assumptions made included the following:

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•

•

•

Hole size and cascading failure. Hole size is an important parameter for modeling LNG spills because of its relationship to the duration of the event—larger holes allow LNG to spill from the tanker more quickly, resulting in larger LNG pools and shorter duration fires. Conversely, small holes could create longer-duration fires. Cascading failure is important because it increases the overall spill volume and the duration of the spill. Waves and wind. These conditions can affect the size of both the LNG pool and the heat hazard zone. One study indicated that waves can inhibit the spread of an LNG pool, keeping the pool size much smaller than it would be on a smooth surface, and thereby reducing the size of the LNG pool fire. Wind will tend to tilt the fire downwind (like a candle flame blowing in the wind), increasing the heat hazard zone in that direction (and decreasing it upwind). Volume of LNG spilled. The amount of LNG spilled is one of the factors that can affect the size of the pool.

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Table 1. Key Assumptions and Results of the LNG Spill Consequence Studies

Hole size (m2)

Quest 19.6 Consultants Inc. 19.6 (Quest)a 19.6 Sandia 2 National 5 Laboratories (Sandia) 5 5d 12 Pitblado, et al. 1.77 (Pitblado)e ABS 0.79 Consulting 19.6 (ABSC)f Fay (Fay)h 20

Key assumptions Number of Environmental tanks that conditions modeled: rupture Wind Wind (cascading speed and speed failure its effect on and its waves effect on (m/s) fire (m/s 1 1.5 1.5 1 5.0 5.0

12,500 12,500

b

1 3 3

9.0 c c

12,500 37,500 37,500

b

1 1 1 1

c c c

c

350 220 220

c

3.0

12,500 12,500 12,500 17,250

1 1

c

8.9 8.9

12,500 12,500

1

c

c

14,300

c

9.0 c c

c c

Key results Spill volume Fire surface (m3) emissive Pool Distance to power diameter the 5kw/m2 (kW/m2) (meters) heat level (meters)

Duration (minutes )

156 146

497 531

14.3 16.6

110 209 572

493 784 2,118

28.6 20 8.1

330 330-405 512 171

1,652 1,305-1,579 1,920 750

8.1 5.4-8.1 3.4 32

265 265

200g 620g

650 1,500

51 4.2

b

b

1,900

3.3

b

220 220

b

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Lehr and Simecek-Beatty (Lehr) i

b

b

c

c

500

200

b

500

2-3

Source: GAO analysis of spill consequence studies. a “Modeling LNG Spills in Boston Harbor.” Copyright© 2003 Quest Consultants, Inc., Norman, OK 73609; Letter from Quest Consultants to DOE (October 2, 2001); Letter from Quest Consultants to DOE (October 3, 2001). b Information not available. cNot included in the model. d The study examined multiple scenarios of 5m2. The ranges listed summarize the highest and lowest values for those scenarios. e R. M. Pitblado, J. Baik, G. J. Hughes, C. Ferro, and S. J. Shaw. “Consequences of Liquefied Natural Gas Marine Incidents.” Process Safety Progress 24 no. 2 (June 2005). f ABS Consulting Inc. Consequence Assessment Methods for Incidents Involving Releases from Liquefied Natural Gas Carriers. May 13, 2004. FERC “Staff’s Responses to Comments on the Consequence Assessment Methods for Incidents Involving Releases from Liquefied Natural Gas Carriers,” June 18, 2004. g ABS Consulting modeled pool size as a semicircle and reported the radius of that semicircle in the study. The reported radii were used to calculate the diameter of the semicircle so the study results could be compared with the other studies. h J.A. Fay. “Model of Spills and Fires from LNG and Oil tankers.” Journal of Hazardous Materials B96 (2003): 171-1 88. I William Lehr and Debra Simecek-Beatty. “Comparison of Hypothetical LNG and Fuel Oil Fires on Water.” Journal of Hazardous Materials 107 (2004): 3-9.

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Surface emissive power of the fire. While the amount of heat given off by a large LNG fire is unknown, assumptions about it directly affect the results for the heat hazard zone. It is expected that the surface emissive power of LNG fires will be lower for large fires because oxygen will not circulate efficiently within a very large fire. Lack of oxygen in the middle of a large fire would lead to more smoke production, which would block some of the heat from the fire.

The LNG spill consequence studies’ key assumptions and results are shown in table 1. In terms of the studies’ results, we identified the following three key results: • •

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•

Pool size describes the extent of the burning pool—and can help people understand how large the LNG fire itself will be. Heat hazard distance describes the distance at which 30 seconds of exposure could cause second degree burns. Fire duration of the incident describes how long people and infrastructure will be exposed to the heat from the fire. The longer the fire, the greater potential for damage to the tanker and for cascading failure.

Although all the studies considered the consequences of an LNG spill, they were conducted for different purposes. Three of the six studies—Quest, Sandia, and Pitblado—specifically addressed the consequences of LNG spills caused by terrorist attacks. Two of these three studies—Quest and Sandia—were commissioned by DOE. The Quest study, begun in response to the September 11, 2001, attacks, was designed to quantify the heat hazard zones for LNG tanker spills in Boston Harbor. Only the Quest study examined how wind and waves would affect the spreading of the LNG on the water and the size of the resulting LNG pool. The Quest study based its wind and wave assumptions on weather data from buoys near Boston Harbor. The Quest study found that, while the waves would help reduce the size of the LNG pool, the winds that created the waves would tend to increase the heat hazard distance downwind. To simplify the modeling of the waves, the Quest study considered “standing” waves (rather than moving waves) of various heights and, therefore, did not consider the impact of wave movement on LNG pool spreading. The ABSC study expressed concern that Quest’s standing wave assumption resulted in pool sizes that were too small because wave movement might help spread the LNG.

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The 2004 Sandia study was intended to develop guidance on a risk-based analysis approach to assess potential threats to an LNG tanker, determine the potential consequences of a large spill, and review techniques that could be used to mitigate the consequences of an LNG spill. The assumptions and results in table 1 for the Sandia study refer to the scenarios Sandia examined that had terrorist causes. According to Sandia, the study used available intelligence and historical data to develop credible and possible scenarios for the kinds of attacks that could breach an LNG tanker. Sandia then modeled how large a hole each of the weapon scenarios could create in an LNG tanker.8 Two of these intentional breach scenarios included cascading failure of three tanks on an LNG tanker. In these cases, the LNG spill from one tank, as well as the subsequent fire, causes the neighboring two tanks to fail on the LNG tanker, resulting in LNG spills from three of the five tanks on the tanker. After considering all of its scenarios, Sandia concluded that, as a rule-of-thumb, 1,600 meters is a good approximation of the heat hazard distance for terrorist-induced spills. However, as the table shows, one of Sandia’s scenarios—for a large spill with cascading failure of three LNG tanks—found that the distance could exceed more than 2,000 meters and that the cascading failure would increase the duration of the incident. Finally, the stated purpose of industry’s Pitblado study was to develop credible threat scenarios for attacks on LNG tankers and predict hazard zones for LNG spills from those types of attacks. The study identified a hole size smaller than the other studies that specifically considered terrorist attacks. The other studies we reviewed examined LNG spills regardless of cause. FERC commissioned the ABS Consulting study to develop appropriate methods for estimating heat hazard zones from LNG spills. FERC uses these methods, in conjunction with the Sandia study, to examine the public safety consequences of tankers traveling to proposed onshore LNG facilities before granting siting approval. The two scenarios in the ABSC study illustrate how small holes could result in longer fires, which have a higher potential to damage the tanker itself. One scenario used a hole size of 0.79 square meters and the other a hole size of about 20 square meters. The difference in duration is striking—it takes 51 minutes and 4.2 minutes, respectively, for the fire to consume all the spilled LNG. Finally, the Lehr and Fay studies compared the fire consequences of LNG spills with known information about oil spills and fires. Although most studies made similar assumptions about the volume of LNG spilled from any single LNG tank, Lehr examined a much smaller spill volume—just 500 cubic meters of LNG, compared with a range of 12,500 to 17,250 cubic meters.

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Some Studies Examined other Potential Hazards and Identified Their Impact on Public Safety Three of the studies also examined other potential hazards of an LNG spill, including LNG vapor explosions, other types of explosions, and asphyxiation.

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LNG Vapor Explosions Three studies—Sandia, ABSC, and Pitblado— examined LNG vapor explosions, and all agreed that it is unlikely that LNG vapors could explode and create a pressure wave if the vapors are in an unconfined space. Although the three studies agreed that LNG vapors could explode only in confined areas, they did not conduct modeling or describe the likelihood of such confinement after an LNG spill from a tanker. The Sandia study stated that fire will generally progress through the vapor cloud slowly and without producing an explosion with damaging pressure waves. The study did suggest, however, that if the LNG vapor cloud is confined (e.g., between the inner and outer hull of an LNG carrier), it could explode but would only affect the immediate surrounding area. The ABSC study and the Pitblado study agreed that a confined LNG vapor cloud could result in an explosion. Other Types of Explosions Three studies—Sandia, ABSC, and Pitblado— examined the potential for RPTs. The Sandia study concluded that, while RPTs have generated energy releases equivalent to several pounds of explosives, RPT impacts will be localized near the spill. Sandia also noted that RPTs are not likely to cause structural damage to the vessel. The ABSC study noted that their literature search suggested that damage from RPT overpressures would be limited to the immediate vicinity, though it noted that the literature did not include large spills like those that could be caused by a terrorist attack. Only one study, Pitblado, discussed the possibility of a BLEVE. According to our discussions with Dr. Pitblado, an LNG ship with membrane tanks could not result in a BLEVE, but he said that Moss spherical tanks could potentially result in a BLEVE. A BLEVE could result because it is possible for pressure to build up in a Moss tanker. A 2002 LNG tanker truck incident in Spain resulted in an explosion that some scientists have characterized as a BLEVE of an LNG truck. Portions of the tanker truck were found 250 meters from the accident itself, propelled by the strength of the blast.

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Asphyxiation Only the Sandia study examined the potential for asphyxiation following an LNG spill if the vapors displace the oxygen in the air. It concluded that fire hazards would be the greatest problem in most locations, but that asphyxiation could threaten the ship’s crew, pilot boat crews, and emergency response personnel.

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EXPERTS GENERALLY AGREED THAT THE MOST LIKELY PUBLIC SAFETY IMPACT OF AN LNG SPILL IS FIRE’S HEAT EFFECT, BUT THAT FURTHER STUDY IS NEEDED TO CLARIFY THE EXTENT OF THIS EFFECT Our panel of 19 experts generally agreed on the public safety impact of an LNG spill and disagreed with a few of the conclusions of the Sandia study.9 The experts also suggested priorities for future research—some of which are not fully addressed in DOE’s ongoing LNG research—to clarify uncertainties about heat impact distances and cascading failure. These priorities include large-scale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques.

Experts Agreed that the Heat from an LNG Fire Was most Likely to Affect Public Safety, but that Explosions from an LNG Spill Are Unlikely Experts discussed two types of fires: vapor cloud fires and pool fires. Eighteen of 19 experts agreed that the ignition of a vapor cloud over a populated area could burn people and property in the immediate vicinity of the fire. While the initial vapor cloud fire would be of short duration as the flames burned back toward the LNG carrier, any flammable object enveloped by the vapor cloud fire could ignite nearby objects, creating secondary fires that present hazards to the public. Three experts emphasized in their comments that the vapor cloud is unlikely to penetrate very far into a populated area before igniting. Expanding on this point, one expert noted that any injuries from a vapor cloud fire would occur only at the edges of a populated area, for example, along beaches. One expert

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disagreed, arguing that a vapor cloud fire is unlikely to cause significant secondary fires because it would not last long enough to ignite other materials. Experts agreed that the main hazard to the public from a pool fire is the heat from the fire but emphasized that the exact hazard distance depends on sitespecific and scenario-specific factors. Furthermore, a large, unconfined pool fire is very difficult to extinguish; generally almost all the LNG must be consumed before the fire goes out. Experts agreed that three of the main factors that affect the amount of heat from an LNG fire are the following: •

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•

•

Site-specific weather conditions. Weather conditions, such as wind and humidity, can influence the heat hazard distances. For example, more humid conditions allow heat to be absorbed by the moisture in the air, reducing heat hazard distances. Composition of the LNG. The composition of the LNG can also affect the distance at which heat from the fire is felt by the public. In small fires, methane, which comprises between 84 percent and 97 percent of LNG, burns cleanly, with little smoke. Other LNG components—propane and butane—produce more smoke when burned, absorbing some of the fire’s heat and reducing the hazard distance. As the fire grows larger, the influence of the composition of LNG is hypothesized to be less pronounced because large fires do not burn efficiently. Size of the fire. The size of the fire has a major impact on its surface emissive power; the heat hazard distance increases with pool size up to a point but is expected to decrease for very large pools, like those caused by a terrorist attack.

Experts also discussed the following hazards related to an LNG spill: •

•

RPTs. Experts agreed that RPTs could occur after an LNG spill but that the overpressures generated would be unlikely to directly affect the public. Detonations and deflagrations. Experts made a key distinction between these types of explosions in confined spaces as opposed to unconfined spaces. For confined spaces, they agreed that it is possible, under controlled experimental conditions, to induce both types of explosions of LNG vapors; however, a detonation of confined LNG vapors is unlikely following an LNG spill caused by a terrorist attack. Experts were split on the likelihood of a confined deflagration occurring after a terrorist attack:

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•

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eight thought it was unlikely, four thought it likely, and five thought neither likely nor unlikely.10 For unconfined spaces, experts were split on whether it is possible to induce such explosions; however, even experts who thought such explosions were possible agreed that deflagrations and detonations in unconfined spaces are unlikely to occur following an LNG spill caused by a terrorist attack. BLEVE. Experts were split on whether a BLEVE is theoretically possible in an LNG tanker. Of the ten experts who agreed it was theoretically possible, six thought that a BLEVE is unlikely to occur following an LNG spill caused by a terrorist attack on a tanker.11 Freeze burns and asphyxiation. Experts agreed that freeze burns do not present a hazard to the public because only people in close proximity to LNG spill, such as personnel on the tanker or nearby vessels, might come into contact with LNG or very cold LNG vapor. For asphyxiation, experts agreed that it is unlikely that an LNG vapor cloud could reach a populated area while still sufficiently concentrated to pose an asphyxiation threat.

Experts Disagreed with a Few Key Conclusions of the Sandia National Laboratories Study Experts disagreed with heat hazard and cascading failure conclusions of the Sandia study. Specifically, 7 of 15 experts thought Sandia’s heat hazard distance was “about right,” and the remaining 8 experts were evenly split as to whether the distance was “too conservative” (i.e., larger than needed to protect the public) or “not conservative enough” (i.e., too small to protect the public). Experts who thought the distance was too conservative generally listed one of two reasons. First, the assumptions about the surface emissive power of large fires were incorrect because the surface emissive power of large fires would be lower than Sandia assumed. Second, Sandia’s hazard distances are based on the maximum size of a pool fire. However, these experts pointed out that once a pool fire ignites, its diameter will begin to shrink, which will also reduce the heat hazard distance. Experts who thought Sandia’s heat hazard distance was not conservative enough listed a number of concerns. For example, Sandia’s distances do not take into consideration the effects of cascading failure. One expert suggested that a 1-meter hole in the center tank of an LNG tanker that resulted in a pool fire could cause

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the near simultaneous failure of the other four tanks, leading to a larger heat hazard zone. Officials at Sandia National Laboratories and our panel of experts cautioned that the hazard distances presented cannot be applied to all sites. According to the Sandia study authors, their goal was to provide guidance to federal agencies on the order of magnitude of the hazards of an LNG spill on water. As they pointed out in interviews and in their original study, further analysis for specific sites is needed to understand hazards in a particular location. Six experts on our panel also emphasized the importance of site-specific and scenario-specific factors. For instance, one expert explained that the 5kW/m2 hazard distance depends on the size of the tanker and the spill scenario, including factors such as wind speed, timing of ignition, and the location of the hole. Other experts suggested that key factors are spill volume and the impact of waves. Additionally, two experts explained that there is no “bright line” for hazards—that is, 1,599 meters is not necessarily “dangerous,” and 1,601 meters is not necessarily “safe.” Only 9 of 15 experts agreed with Sandia’s conclusion that only three of the five LNG tanks on a tanker would be involved in cascading failure. Five experts noted that the Sandia study did not explain how it concluded that only three tanks would be involved in cascading failure. Three experts said that an LNG spill and subsequent fire could potentially result in the loss of all tanks on board the tanker. Twelve of 16 experts agreed, however, with Sandia’s conclusion that cascading failure events are not likely to greatly increase (by more than 20 to 30 percent) the overall fire size or heat hazard ranges. The four experts who disagreed with Sandia’s conclusion about the public safety impact of cascading failure cited two main reasons: (1) Sandia did not clearly explain how it reached that conclusion and (2) the impact of cascading failure will partly depend on how the incident unfolds. For instance, one expert suggested that cascading failure could include a tank rupture, fireball, or BLEVE, any of which could have direct impacts on the public (from the explosive force) and which would change the heat hazard zones that Sandia identified. Finally, experts agreed with Sandia’s conclusion that consequence studies should be used to support comprehensive, risk-based management and planning approaches for identifying, preventing, and mitigating hazards from potential LNG spills.

Experts Suggest Future Research Priorities to Determine the Public Safety Impact of an LNG Spill

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In the second iteration of the Web-based panel, we asked the experts to identify the five areas related to the consequences of LNG spills that need further research. Then, in the final iteration of the Web-based panel, we provided the experts with a list of 19 areas—generated by their suggestions and comments from the second iteration—and asked them to rank these in order of importance. Table 2 presents the results of that ranking for the top 10 areas identified and indicates those areas that are funded in the DOE study discussed earlier. As the table shows, two of the top five research areas identified are related to large LNG fires—large fire phenomena and large-scale fire testing. Experts believe this research is needed to establish the relationship between large pool fires and the surface emissive power of the fire. Experts recommended new LNG tests for fires between 15 meters and 1,000 meters. The median suggested test size was 100 meters. Some experts also raised the issue of whether large LNG fires will stop behaving like one single flame but instead break up into several smaller, shorter flames. Sandia noted in its study that this behavior could reduce heat hazard distances by a factor of two to three. Experts also ranked research into cascading failure of LNG tanks second in the list of priorities. Concerning cascading failure, one expert noted that, although the consequences could be serious, there are virtually no data looking at the hull damage caused by exposure to extreme cold or heat. Table 2. Expert Panel’s Ranking of Need for Research on LNG Rank

Research area

Funded in DOE’s study √

1 2 3 4 5 6 7 8 9 10

Large fire phenomena Cascading failure Large-scale spill testing on water √ Large-scale fire testing √ Comprehensive modeling: interaction of physical processes Risk tolerability assessments Vulnerability of containment systems (hole size) Mitigation techniques Effect of sea water coming in as LNG flows out Impact of wind, weather, and waves

Source: GAO. Note: A rank of 1 is the highest rank, and a rank of 10 is the lowest. Panel members ranked 19 areas of research from 1 to 19; a score was calculated for each area based on this ranking. Only the 10 areas with the highest scores are presented in this table.

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As table 2 shows, DOE’s recently funded study involving large-scale LNG fire experiments addresses some, but not all, of the research priorities identified by the expert panel. For DOE, Sandia National Laboratories plans to conduct large-scale LNG pool fire tests beginning with a pool size of 35 meters—the same size as the largest test conducted to date. Sandia will validate the existing 35meter data and then conduct similar tests for pool sizes up to 100 meters. The goal of this fire testing is to document the impact of smoke on large LNG pool fires. Sandia suggests that these tests will create a higher degree of knowledge of largescale pool fire behavior and significantly lower the current uncertainty in predicting heat hazard distances. According to researchers at Sandia National Laboratories, some of the research our panel of experts suggested may not be appropriate. Sandia indicated that comprehensive modeling, which allows various complex processes to interact, would be very difficult to do because of the uncertainty surrounding each individual process of the model. One expert on our panel agreed, noting that while comprehensive modeling of all LNG phenomena is important, combining those phenomena into one model should wait for experiments that lead to better understanding of each individual phenomenon.

CONCLUSIONS It is likely that the United States will increasingly depend on the importation of LNG to meet the nation’s demand for natural gas. Understanding and resolving the uncertainties surrounding LNG spills is critical, especially in deciding on where to locate LNG facilities. Because there have been no large-scale LNG spills or spill experiments, past studies have developed modeling assumptions based on small-scale spill data. While there is general agreement on the types of effects from an LNG spill, the results of these models have created what appears to be conflicting assessments of the specific consequences of an LNG spill, creating uncertainty for regulators and the public. Additional research to resolve some key areas of uncertainty could benefit federal agencies responsible for making informed decisions when approving LNG terminals and protecting existing terminals and tankers, as well as providing reliable information to citizens concerned about public safety. Although DOE has recently funded a study that will address large-scale LNG fires, this study will address only 3 of the top 10

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issues—and not the second-highest ranked issue—that our panel of experts identified as potentially affecting public safety.

RECOMMENDATION FOR EXECUTIVE ACTION To provide the most comprehensive and accurate information for assessing the public safety risks posed by tankers transiting to proposed LNG facilities, we recommend that the Secretary of Energy ensure that DOE incorporates the key issues identified by the expert panel into its current LNG study. We particularly recommend that DOE examine the potential for cascading failure of LNG tanks in order to understand the damage to the hull that could be caused by exposure to extreme cold or heat.

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AGENCY COMMENTS AND OUR EVALUATION We requested comments on a draft of this report from the Secretary of Energy (DOE). DOE agreed with our findings and recommendation. In addition, DOE included technical and clarifying comments, which we included in our report as appropriate. As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to interested congressional committees, the Secretary of Energy, and other interested parties. We also will make copies available to others upon request. In addition, the report will be available at no charge on the GAO Web site at http://www.gao.gov. If you or your staff have any questions regarding this report, please contact me at (202) 512-3841 or [email protected]. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix IY. Jim Wells Director, Natural Resources and Environment

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APPENDIX I: SCOPE AND METHODOLOGY To address the first objective, we identified eight unclassified, completed studies of liquefied natural gas (LNG) hazards and reviewed the six studies that included new, original research (either experimental or modeling) and clearly described the methodology used. While we have not verified the scientific modeling or results of these studies, the methods used seem appropriate for the work conducted based on conversations with experts in the field and our assessment. We also discussed these studies with their authors and visited all four onshore LNG import facilities and one export facility. We attended a presentation on LNG safety and received specific training on LNG properties and safety. We also conducted interviews with officials from Sandia National Laboratories, Federal Energy Regulatory Commission, Department of Transportation, Department of Energy, and the U. S. Coast Guard. During our interviews, we asked officials to provide information on past LNG studies and plans for future LNG spill consequences work. To obtain information on experts’ opinions of the public safety consequences of an LNG spill from a tanker, we conducted a three-phase, Web-based survey of 19 experts on LNG spill consequences. We identified these experts from a list of 51 individuals who had expertise in one or more key aspects of LNG spill consequence analysis. In compiling this initial list, we sought to achieve balance in terms of area of expertise (i.e., LNG experiments, modeling LNG dispersion, LNG vaporization, fire modeling, and explosion modeling). In addition, we included at least one author of each of the six major LNG studies we reviewed, that is, studies by Sandia National Laboratories; ABS Consulting; Quest Consultants Inc.; Pitblado, et al.; James Fay (MIT); and William Lehr (National Oceanic and Atmospheric Administration). We gathered resumes, publication lists, and major LNG-related publications from the experts identified on the initial list. We selected 19 individuals for the panel. One or more of the following selection criteria were used: (1) has broad experience in all facets of LNG spill consequence modeling (LNG spill from hole, LNG dispersion, vaporization and pool formation, vapor cloud modeling, fire modeling, and explosion modeling); (2) has conducted physical LNG experiments; or (3) has specific experience with areas of particular importance, such as LNG explosion research. In addition, we

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included: (1) at least one author from each of the major LNG studies and (2) representatives from private industry, consulting, academia, and government. All 19 experts selected for the panel agreed to participate. The names and affiliations of panel members are included in appendix II. To obtain consensus concerning public safety issues, we used an iterative Web-based process. We used this method, in part, to eliminate the potential bias associated with group discussions. These biasing effects include the potential dominance of individuals and group pressure for conformity. Moreover, by creating a virtual panel, we were able to include more experts than possible with a live panel. For each phase in the process, we posted a questionnaire on GAO’s survey Web site. Panel members were notified of the availability of the questionnaire with an e-mail message. The e-mail message contained a unique user name and password that allowed each respondent to log on and fill out a questionnaire but did not allow respondents access to the questionnaires of others. In the questionnaires, we asked the experts to agree or disagree with a set of statements about LNG hazards derived from GAO’s synthesis of major LNG spill consequence studies. Prior to the first iteration, we had an LNG spill consequence expert who was not a part of the panel review each statement and provide comments about technical accuracy and tone. Experts were asked to indicate agreement on a 3-point scale (completely agree, generally agree, do not agree) and to provide comments about how the statements could be changed to better reflect their understanding of the consequences of LNG spills. If most experts agreed with a statement during the first iteration, we did not include it in the second iteration. If there was not agreement, we used the experts’ comments to revise the statements for the second iteration. The second iteration was posted on the Web site, using the same protocol as used for the first. Again, panel members were asked to agree or disagree and provide narrative comments. We revised the statements where there was disagreement and posted them on the Web site again for the third iteration. At the end of the third iteration, at least 75 percent of the experts agreed or generally agreed with most of the ideas presented. Because some of the studies conducted are classified, this public version of our findings supplements a more comprehensive classified report produced under separate cover. We conducted our work from January 2006 through January 2007 in accordance with generally accepted government auditing standards.

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APPENDIX II: NAMES AND AFFILIATIONS OF MEMBERS OF GAO’S EXPERT PANEL ON LNG HAZARDS Myron Casada T.Y. Chu Philip Cleaver Bob Corbin John Cornwell James Fay Louis Gritzo Jerry Havens Benedict Ho Greg Jackson Ron Koopman Bill Lehr Georges Melhem Gordon Milne Robin Pitblado Phani Raj Velisa Vesovic Harry West John Woodward

ABS Consulting Sandia National Laboratories Advantica U.S. Department of Energy Quest Consultants, Inc. Massachusetts Institute of Technology FM Global University of Arkansas BP University of Maryland Hazard Analysis Consulting National Oceanic and Atmospheric Administration ioMosaic Corporation Lloyd’s Register Det Norske Veritas Technology and Management Systems, Inc. Imperial College Texas A&M University Baker Engineering and Risk Consultants, Inc.

APPENDIX III: SUMMARY OF EXPERT PANEL RESULTS For each question below, we show only those responses that were selected by at least one expert. The number of responses adds up to 19— the total number of experts on the panel. Percentages may not add to 100% due to rounding.

Introduction

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LNG is a cryogenic liquid composed primarily of methane with low concentrations of heavier hydrocarbons, such as ethane, propane, and butane. LNG is colorless, odorless, and nontoxic. When LNG is spilled, it boils and forms LNG vapor (natural gas). The LNG vapor is initially denser than ambient air and visible; LNG vapor will stay close to the surface as it mixes with air and disperses. LNG and LNG vapor pose four possible hazards: freeze burns, asphyxiation, fire hazard, and explosions. What is your level of agreement with this paragraph? (Finalized in the second iteration.) Count 8 11

Percentage 42.11% 57.89%

Label Completelyagree Generally agree

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LNG Hazards Overall Hazards LNG is a cryogenic liquid composed primarily of methane with low concentrations of heavier hydrocarbons, such as ethane, propane, and butane. LNG is colorless, odorless, and nontoxic. When LNG is spilled, it boils and forms LNG vapor (natural gas). The LNG vapor is initially denser than ambient air and visible; LNG vapor will stay close to the surface as it mixes with air and disperses. LNG and LNG vapor pose four possible hazards: freeze burns, asphyxiation, fire hazard, and explosions. What is your level of agreement with this paragraph? (Finalized in the second iteration.) Count 5 12 2

Percentage 26.32% 63.16% 10.53%

Label Completely agree Generally agree Do not agree

LNG Hazards-Freeze Burns LNG poses a threat of freeze burns to people who come into contact with the liquid or with very cold LNG vapor. Since LNG boils immediately and vaporizes after it leaves an LNG tank and LNG vapor warms as it mixes with air, only people in close proximity to the release, such as personnel on the tanker or nearby escort vessels, might come into contact with LNG or LNG vapor while it is still cold enough to result in freeze burns. Freeze burns do not present a direct hazard

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to the public. What is your level of agreement with this paragraph? (Finalized in the second iteration.)

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Count 14 5

Percentage 73.68% 26.32%

Label Completely agree Generally agree

LNG Hazards-Asphyxiation After an LNG spill, LNG vapor forms a dense, visible vapor cloud that is initially heavier than air and remains close to the surface. The cloud warms as it mixes with air and as portions of the cloud reach ambient air temperatures, they begin to rise and disperse. Asphyxiation occurs when LNG vapor displaces oxygen in the air. Asphyxiation is a threat primarily to personnel on the LNG tanker or to people aboard vessels escorting the tanker at close range. An LNG vapor cloud could move away from the tanker as it mixes with air and begins to disperse. However, it is unlikely that the vapor cloud could reach a populated area while still sufficiently concentrated to pose an asphyxiation threat to the public. What is your level of agreement with this paragraph? (Finalized in the second iteration.) Count 8 10 1

Percentage 42.11% 52.63% 5.26%

Label Completely agree Generally agree Do not agree

LNG Hazards-Vapor Cloud: Wind Effect The effect of wind on an LNG vapor cloud varies with wind speed. The most hazardous wind conditions, however, are low winds, which can push a vapor cloud downwind without accelerating the LNG vapor dispersion into the atmosphere. Low wind conditions have the highest potential of allowing an LNG vapor cloud to move a significant distance downwind. What is your level of agreement with this paragraph? (Finalized in the third iteration.) Count 8

Percentage 42.11%

Label Completely agree

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52.63% 5.26%

31

Generally agree Do not agree

LNG Hazards-Fire Hazard Because LNG vapor in an approximately 5 to 15 percent mixture with air is flammable, LNG vapor within this flammability range is likely to ignite if it encounters a sufficiently strong ignition source such as a cigarette lighter or strong static charge. What is your level of agreement with this paragraph? (Finalized in the third iteration.)

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Count 13 6

Percentage 68.42% 31.58%

Label Completely agree Generally agree

LNG Hazards-Fire Hazard: Thermal Hazard End Point The main hazard to the public from a pool fire is the thermal radiation, or heat, that is generated by the fire rather than the flames themselves. Often this heat is felt at considerable distance from the fire. Scientific papers have used two different thresholds as end points to describe the impact of thermal radiation on the public: 5 kilowatts per square meter and 1.6 kilowatts per square meter. Which level do you think is the appropriate end point to use to define thermal hazard zones in order to protect the public? (Please indicate your response, then provide an explanation in the textbox below your answer.) Count 8 2 6 3

Percentage 42.11% 10.53% 31 .58% 15.79%

Label 5 kilowatts per square meter 1.6 kilowatts per square meter Other I do not have the expertise necessary to respond to this question.

Of the six experts who answered “other,” two experts indicated that 5kW/m2 is a useful or appropriate level for measuring the impact on people. One expert suggested that dosage (a measure that combines thermal radiation and duration of exposure) is most appropriate. Another expert suggested that both thresholds are appropriate, depending on the circumstances of the analysis. (Finalized in the first iteration.)

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LNG Hazards-Fire Hazard: Pool Fire A pool fire could form in the wake of a vapor cloud fire burning back to the source or just after an LNG spill, if there is immediate ignition of the LNG vapor. A pool fire burns the vapor above a liquid LNG pool as the liquid boils from the pool. A large, unconfined pool fire is very difficult to extinguish; generally almost all the LNG must be consumed before the fire goes out. What is your level of agreement with this paragraph? (Finalized in the second iteration.)

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Count 13 5 1

Percentage 68 .42% 26.32% 5.26%

Label Completely agree Generally agree Do not agree

The main hazard to the public from a pool fire is the thermal radiation, or heat, from the fire. This heat can be felt at a considerable distance from the flames themselves. Numerous factors can impact the amount of thermal radiation that could affect the public: site-specific weather conditions, including humidity and wind speed and direction, the composition of the LNG, and the size of the fire. What is your level of agreement with this paragraph? (Finalized in the second iteration.) Count 13 6

Percentage 68 .42% 31.58%

Label Completely agree Generally agree

The wind speed and direction also affect the distance at which thermal radiation from the fire is felt by the public. In high winds, the flames will tilt downwind, increasing the amount of heat felt downwind of the fire and decreasing the amount of heat felt upwind. More humid conditions allow heat to be absorbed by the moisture in the air reducing the heat felt by the public. What is your level of agreement with the above paragraph? (Finalized in the second iteration.) Count 6 11 2

Percentage 31.58% 57.89% 10.53%

Label Completely agree Generally agree but suggest the following clarification. I do not have the expertise necessary to respond to this

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section. The composition of the LNG can also affect the distance at which thermal radiation from the fire is felt by the public. In small fires, methane, which comprises between 84 percent and 97 percent of LNG, burns cleanly, with little smoke. Cleaner-burning LNG fires, particularly those burning LNG with higher methane content, result in higher levels of thermal radiation than oil or gasoline fires of the same size because the smoke generated by oil and gasoline fires acts as a shield, reducing the amount of thermal radiation emitted by the fire. While LNG composition can have a large impact on the thermal radiation from small LNG fires, as LNG fires get larger, these effects are hypothesized to be less pronounced. What is your level of agreement with this paragraph? (Finalized in the third iteration.)

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Count 5 10 3 1

Percentage 26.32% 52.63% 15.79% 5.26%

Label Completely agree Generally agree Do not agree I do not have the expertise necessary to respond to thissection.

The size of the fire has a major impact on the thermal radiation from an LNG pool fire. Thermal radiation increases with pool size up to a point but is expected to decrease for very large pools, like those caused by a terrorist attack. What is your level of agreement with this paragraph? (Finalized in the second iteration.) Count 4 10 4 1

Percentage 21.05% 52.63% 21.05% 5.26%

Label Completely agree Generally agree Do not agree I do not have the expertise necessary to respond to thissection.

LNG Hazards–Vapor Cloud Fire If an LNG vapor cloud formed in the wake of an LNG spill and drifted away from the tanker as it warmed and dispersed, the vapor cloud could enter a populated area while areas of the cloud had LNG vapor/air mixtures within the flammability range. Since populated areas have numerous ignition sources, those portions of the cloud would likely ignite. The fire would then burn back through

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the cloud toward the tanker and continue to burn as a pool fire near the ship, assuming that liquid LNG still remains in the spill area. Ignition of a vapor cloud over a populated area could burn people and property in the immediate vicinity of the fire. While the initial fire would be of short duration as the flames burned back toward the LNG carrier, secondary fires could continue to present a hazard to the public. What is your level of agreement with the above paragraph? (Finalized in the second iteration.) Count 7 11

Percentage 36.84% 57.89%

1

5.26%

Label Completely agree Generally agree but suggest the following clarification Do not agr

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LNG Hazards–Vapor Cloud Fire: Burn Back Speed After ignition of a vapor cloud that drifted away from an LNG tanker spill, how fast could the flame front travel back toward the spill site if it was unconfined or confined? (Finalized in the second iteration.) Count 15 2

Percentage 78.95% 10.53%

2

10.53%

Label Not checked I do not have the expertise necessary to respond to this section. No answer

Experts did not agree on the speed of a flame front traveling through an LNG vapor cloud in either a confined or unconfined state. Responses varied from less than 5 meters per second up to 50 meters per second in unconfined settings and from 0 meters per second to 2,000 meters per second in confined settings.

Explosions-RPT A rapid phase transition (RPT) can occur when LNG spilled onto water changes from liquid to gas virtually instantaneously due to the rapid absorption of ambient environmental heat. While the rapid expansion from a liquid to vapor state can cause locally large overpressures, an RPT does not involve combustion. RPTs have been observed during LNG test spills onto water. In some cases, the overpressures generated were strong enough to damage test equipment in the immediate vicinity. Overpressures generated from RPTs would be very unlikely

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to have a direct affect on the public. What is your level of agreement with this paragraph? (Finalized in the second iteration.) Count Percentage Label 15 78.95% Completely agree 4 21.05% Generally agree

Explosions-Deflagrations and Detonations Deflagrations and detonations are rapid combustion processes that move through an unburned fuel-air mixture. Deflagrations move at subsonic velocities and can result in overpressures up to eight times the original pressure, particularly in congested/confined areas. Detonations move at supersonic velocities and can result in overpressures up to 20 times the original pressure. What is your level of agreement with this paragraph? (Finalized in the third iteration.) Percentage 5.26% 36.84% 52.63% 5.26%

Label Not checked Completely agree Generally agree Do not agree

Detonation in a confined setting

Boiling-liquidexpanding-vaporexplosion(BLEVE)

Under controlled experimental conditions, it is possible to induce this type of explosion in this type of setting. This type of setting

Detonation in an unconfined setting

Answer

Deflagration with overpressure in a confined setting

Explosions—Deflagrations, Detonations, and BLEVEs Please choose the response that best describes your opinion about each type of explosion of LNG vapors in each setting described. (Finalized in the third iteration.) Deflagration with overpressure in an unconfined setting

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Count 1 7 10 1

7

18

4

15

11

8

0

11

2

7

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cannot support this type of explosion.

Detonation in an unconfined setting

Detonation in a confined setting

Boiling-liquidexpanding-vaporexplosion(BLEVE)

3

0

0

0

0

1

0

1

1

2

1

1

Detonation in a confined setting

Boiling-liquidexpandingvapor-explosion (BLEVE)

Highly unlikely 3 Unlikely 2 Neither likely nor 1 unlikely

Detonation in an unconfined setting

Answer

Deflagration with overpressure in a confined setting

If experts answered that “under controlled experimental conditions, it is possible to induce this type of explosion in this type of setting,” they were asked to answer the following question: What is the likelihood of a each type of explosion of LNG vapors in each setting described occurring following an LNG spill caused by a terrorist attack on a tanker? (Finalized in the third iteration.) Deflagration with overpressure in an unconfined setting

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More research is necessary to answer this question. I don’t have the expertise necessary to answer this question. No answer/not checked

Deflagration with overpressure in a confined setting

Answer

Deflagration with overpressure in an unconfined setting

Table. Continued

6 2 5

1 3 0

7 3 3

4 2 3

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1 0 0

4 0 1

0 0 0

2 0 0

37

1 0 1

LNG Hazards – Is BLEVE the Worst? A BLEVE is the worst potential hazard of an LNG spill. It would result in the rupture of one or more LNG tanks, perhaps simultaneously, on the ship, with potential rocketing debris and damaging pressure waves. What is your level of agreement with the above paragraph? (Finalized in the first iteration.) Count 2 16

Percentage 10.53% 84.21%

1

5.26%

Label Completely agree Do not agree (Please explain in the textbox below.) No answer

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Questions about the 2004 Sandia National Laboratories Study1 The Sandia report concluded that the most significant impacts to public safety exist within 500 meters of a spill, with much lower impacts at distances beyond 1,600 meters even for very large spills. Please choose the response that best describes your opinion about these hazard distances. (Finalized in the third iteration.) C ount 4

Percentage 23.54%

7 4

41.18% 23.53%

2

11.76%

Label They are too conservative (i.e., should be smaller) They are about right They are not conservative enough (i.e., should be larger) No answer

The Sandia report concluded that large, unignited LNG vapor clouds could spread over distances greater than 1,600 meters from a spill. For a nominal intentional spill, the hazard range could extend to 2,500 meters. The actual hazard

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distances will depend on breach and spill size, site-specific conditions, and environmental conditions. Please choose the response that best describes your opinion about these hazard distances. (Finalized in the third iteration.) Count 4

Percentage 23.53%

6 4

35.29% 23.53%

1 2

5.88% 11.76%

Label They are too conservative (i.e., should be smaller) They are about right They are not conservative enough (i.e., should be larger) Do not have the expertise to answer No answer

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The Sandia report concluded that cascading damage (multiple cargo tank failure) due to brittle fracture from exposure to cryogenic liquid or fire- induced damage to foam insulation is possible under certain conditions but is not likely to involve more than two or three cargo tanks for any single incident. What is your level of agreement with this paragraph? (Finalized in the third iteration.) Count 3 6 6 2

Percentage 17.65% 35.29% 35.29% 11.76%

Label Completely agree Generally agree Do not agree I do not have the expertise necessary to respond to this section.

The Sandia report concluded that cascading events are not expected to greatly increase (not more than 20-30 percent) the overall fire size or hazard ranges (500 meters for severe impacts, much lower impacts beyond 1,600 meters) but will increase the expected fire duration. What is your level of agreement with this paragraph? (Finalized in the third iteration.) Count 7 5 4 1

Percentage 41.18% 29.41% 23.53%

Label Completely agree Generally agree Do not agree

Since two of the experts were authors of the Sandia study, their responses to all the questions related to the study below have been excluded. For the questions related to the Sandia study, there are 17 experts responding.

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No answer

The Sandia report suggested that consequence studies should be used to support comprehensive, risk-based management and planning approaches for identifying, preventing, and mitigating hazards to public safety and property from potential LNG spills. What is your level of agreement with this paragraph? (Finalized in the third iteration.) Count Percentage Label 8 47.06% Completely agree 8 47.06% Generally agree 1 5.88% Do not agree

Commodity Comparison In your opinion, what is the risk to public safety posed by an attack on tankers carrying each of the following energy commodities? (Finalized in the first iteration.)

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Answer

Liquefied natural gas Little to None 1 Little 3 Medium 6 Large 3 Very Large 2 No expertise to 1 answer No answer 3

Crude Diesel oil

Gasoline

Heatin Jet g oil fuel

2 10 3 0 0 1

1 11 3 0 0 1

0 5 8 2 0 1

1 11 3 0 0 1

1 6 6 2 0 1

Liquefied petroleum gas 0 1 4 5 5 1

3

3

3

3

3

3

Future Research In the first and second survey iterations, you noted areas related to LNG spill consequences that need further research. We are interested in your thoughts on the relative level of need for research in these areas, and also the five areas you think should be of highest priority in future research.

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Please indicate the degree to which further research is needed in each of the areas listed below. (Finalized in the third iteration.) Responses to each part of this question are in the table below, which is sorted by mean score so that the highest-ranked research priorities appear first.

Great need (2)

Moderate need(3)

Some need (4)

Little to no need (5)

Do not have the expertise to

No answer (7)

Mean score

Large fire phenomena (impact of smoke shielding, large flame versus smaller flamelets) Cascading failure Large-scale LNG spill testing on watera Large-scale fire testingb Comprehensive modeling allowing different physical processes to interact Risk tolerability assessments Vulnerability of LNG containment systems, including validating hole size predictions for the double hull ship structure Mitigation techniques Effect of sea water pouring into a hole as LNG flows out Impact of wind, weather, and waves (on pool spread size, evaporation rate, pool formation, etc.) Improvements to 3-D computational fluid dynamics dispersion modeling Effects of different LNG compositions (on vaporization rates, thermal radiation, explosive behavior, etc.) Whether an explosive attack will result in immediate vapor

Very great need (1) Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved.

Type of research

9

5

3

0

1

1

0

4.17

5 7

9 7

4 2

1 1

0 2

0 0

0 0

3.95 3.84

7 2

6 10

3 3

2 4

1 0

0 0

0 0

3.84 3.53

5 5

4 4

3 3

1 5

3 2

1 0

2 0

3.44 3.26

3 2

5 6

6 5

3 3

2 2

0 0

0 1

3.21 3.17

3

4

6

3

3

0

0

3.05

0

4

6

6

2

1

0

2.67

2

2

4

8

3

0

0

2.58

0

5

4

5

4

1

0

2.56

Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

Maritime Security: Public Safety Consequences of a Terrorist Attack … cloud ignition Rapid phase transitions: likelihood in various scenarios and impact Effects of igniting LNG vapors in containment or ballast tanks BLEVE properties of tanks on LNG ships Deflagration/detonation of LNG Effects of a large, unignited vapor cloud drifting from the incident site Effect of clothing and obstructions on the radiant heat level received by the public Otherc

1

2

6

6

4

0

0

2.47

0

5

3

5

6

0

0

2.37

1

4

3

4

7

0

0

2.37

1 0

0 0

5 7

8 5

5 7

0 0

0 0

2.16 2.00

1

1

2

6

9

0

0

1.89

12

2

0

0

0

0

5

d

41

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a

Experts suggested pool sizes of 15 meters up to 1,000 meters, though the median response was 100 meters. b Experts suggested pool sizes of 15 meters up to 1,000 meters, though the median response was 100 meters. c Experts suggested frequency modeling, determination of acceptable risk to society, analysis of foam on LNG tankers, risk analysis for larger LNG tankers, CFD modeling for pool spreading and evaporation, and improvement to existing techniques used for fighting LNG fires. d Not applicable.

ENDNOTES 1

2

3

The onshore facilities are near Boston, Massachusetts; Cove Point, Maryland; Savannah, Georgia; and Lake Charles, Louisiana. The United States also has one LNG export facility in Kenai, Alaska, that ships LNG to Japan. Under the Natural Gas Act, as amended, FERC has exclusive authority to approve or deny an application for the siting, construction, or operation of onshore LNG terminals, including pipelines, and offshore facilities in state waters—that is, generally within 3 miles of shore. The Coast Guard, along with the Department of Transportation’s Maritime Administration, has jurisdiction under the Deep Water Port Act of 1974, as amended, to approve the siting and operation of offshore LNG facilities in federal waters.

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GAO

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4

LNG vapors only ignite when they are in a 5 percent to 15 percent concentration in the air. If the LNG concentration is higher, there is not enough oxygen available for fire. If the concentration is lower, there is likewise not enough fuel for fire. 5 Sandia National Laboratories. Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water. Albuquerque: 2004. 6 DOE is also sponsoring additional research that applies the 2004 Sandia National Laboratories’ methodology to LNG tankers larger than those previously studied, which is expected to be completed in July 2007. 7 Generally, an explosion is an energy release associated with a pressure wave. Some explosions are large enough that the pressure wave can break windows or damage structures, while others are much smaller. 8 Please note that the information used to develop Sandia’s terrorist scenarios is classified and will be discussed in GAO’s classified report. 9 We considered experts “in agreement” if more than 75 percent of experts indicated that they completely agreed or generally agreed with a given statement. Not all experts commented on every issue discussed. 10 Two experts did not comment. 11 Three experts said that BLEVEs were “neither likely nor unlikely,” and one expert thought that BLEVEs were likely.

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In: Liquefied Natural Gas: Security and Hazards ISBN 978-1-60692-274-3 Editors: J.T. Layton, B.W. Keller, pp. 43-48 © 2009 Nova Science Publishers, Inc.

Chapter 2

MARITIME SECURITY: PUBLIC SAFETY CONSEQUENCES OF A LIQUEFIED NATURAL GAS SPILL NEED CLARIFICATION *

Jim Wells Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved.

Natural Resources and Environment

ABSTRACT The six unclassified studies we reviewed all examined the heat impact of an LNG fire but produced varying results; some studies also examined other potential hazards of a large LNG spill and reached consistent conclusions on explosions. Specifically, the studies’ conclusions about the distance at which 30 seconds of exposure to the heat could burn people— also termed the heat impact distance—ranged from less than 1/3 of a mile to about 1-1/4 miles. These variations occurred because, with no data on large spills from actual events, researchers had to make numerous modeling assumptions to scale up the existing experimental data for large LNG spills. These assumptions involved the size of the hole in the tanker, the number of tanks that fail, the volume of LNG spilled, key LNG fire properties, and environmental conditions, such as wind and waves. Three of the studies also examined other potential hazards of an LNG spill, including LNG vapor explosions, asphyxiation, and the sequential failure of multiple tanks on the LNG vessel *

Excerpted from GAO report GAO-07-633T, dated March 21, 2007.

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Jim Wells (cascading failure). All three studies considered LNG vapor explosions unlikely unless the vapors were in a confined space. Only the Sandia study examined asphyxiation and concluded that asphyxiation did not pose a hazard to the general public. Finally, only the Sandia study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks on a typical LNG vessel would be involved in such an event and that this number of tanks would increase the duration of the LNG fire. Our panel of 19 experts generally agreed on the public safety impact of an LNG spill, disagreed on specific conclusions of the Sandia study, and suggested future research priorities. Experts agreed on three main points: (1) the most likely public safety impact of an LNG spill is the heat impact of a fire; (2) explosions are not likely to occur in the wake of an LNG spill unless the LNG vapors are in confined spaces; and (3) some hazards, such as freeze burns and asphyxiation, do not pose a hazard to the public. However, the experts disagreed with a few conclusions reached by the Sandia study that the Coast Guard uses to assess the suitability of waterways for LNG tankers going to proposed LNG terminals. Specifically, all experts did not agree with the study’s 1-mile estimate of heat impact distance resulting from an LNG fire: 7 of 15 thought Sandia’s distance was “about right,” 8 were evenly split on whether the distance was “too conservative” or “not conservative enough,” and 4 did not answer this question. Experts also did not agree with the Sandia National Laboratories’ conclusion that only three of the five LNG tanks on a tanker would be involved in a cascading failure. Finally, experts suggested priorities to guide future research aimed at clarifying uncertainties about heat impact distances and cascading failure, including large-scale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques. DOE’s recently funded study involving large-scale LNG fire experiments addresses some, but not all, of the research priorities the expert panel identified.

BACKGROUND As scientists and the public have noted, an LNG spill could pose potential hazards. When LNG is spilled from a tanker, it forms a pool of liquid on the water. As the liquid warms and changes into natural gas, it forms a visible, foglike vapor cloud close to the water. The cloud mixes with ambient air as it continues to warm up, and eventually the natural gas disperses into the atmosphere. Under certain atmospheric conditions, however, this cloud could drift into populated

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areas before completely dispersing. Because an LNG vapor cloud displaces the oxygen in the air, it could potentially asphyxiate people who come into contact with it. Furthermore, like all natural gas, LNG vapors can be flammable, depending on conditions. If the LNG vapor cloud ignites, the resulting fire will burn back through the vapor cloud toward the initial spill. It will continue to burn above the LNG that has pooled on the surface—this is known as a pool fire. Small-scale experiments to date have shown that LNG fires burn hotter than oil fires of the same size. Both the cold temperatures of spilled LNG and the high temperatures of an LNG fire have the potential to significantly damage the tanker, causing a cascading failure. Such a failure could increase the severity of the incident. Finally, concerns have been raised about whether an explosion could result from an LNG spill. The Federal Energy Regulatory Commission is responsible for approving applications for onshore LNG terminal sitings, and the U.S. Coast Guard is responsible for approving applications for offshore sitings. In addition, the Coast Guard reviews an applicant’s Waterway Suitability Assessment, reaches a preliminary conclusion on whether the waterway is suitable for LNG imports, and identifies appropriate strategies that reduce the risk posed by the movement of an LNG tanker.

Studies Identified Different Distances for the Heat Effects of an LNG Fire, but Agreed on other LNG Hazards The six studies we examined identified various distances at which the heat effects of an LNG fire could be hazardous to people. The studies’ results about the distance at which 30 seconds of exposure to the heat could burn people ranged from less than 1/3 of a mile (about 500 meters) to about 1-1/4 miles (more than 2,000 meters). The studies’ variations in heat effects occurred because (1) different assumptions were made in the studies’ models about key parameters of LNG spills and (2) the studies were designed and conducted for different purposes. Since no large-scale data are available for LNG spills, researchers made numerous modeling assumptions to scale up the existing experimental data for large spills. Key assumptions made included hole size and cascading failure, waves and wind, the volume of LNG spilled, and the amount of heat radiated from the fire. For example, studies made assumptions for the size of the hole in the LNG tanker that varied from less than 1 square meter up to 20 square meters. Additionally, the studies were conducted for different purposes. Two studies were academic analyses of the differences between LNG and oil spills; three

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specifically addressed spills caused by terrorist attacks, which was a concern in the wake of the September 11 attacks; and the final study developed appropriate methods for regulators to use to estimate heat hazards from LNG fires. Results of these studies can be found in our report being released today. Some studies also examined other potential hazards, such as explosions, asphyxiation, and cascading failure, and identified their potential impacts on public safety. Three studies examined the potential for LNG vapor explosions, and all agreed that it is unlikely that LNG vapors could explode if the vapors are in an unconfined space. Only one study examined the potential for asphyxiation following an LNG spill if the vapors displace the oxygen in the air. It concluded that fire hazards would be the greatest problem in most locations, but that asphyxiation could threaten the ship’s crew, pilot boat crews, and emergency response personnel. Finally, only the Sandia study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks would be involved in such an event and that this number of tanks would increase the duration of the LNG fire.

Experts Generally Agreed that the most Likely Public Safety Impact of an LNG Spill Is the Heat Effect of a Fire, but that Further Study is Needed to Clarify the Extent of this Effect The 19 experts on our panel generally agreed on the public safety impact of an LNG spill, disagreed with specific conclusions of the Sandia study, and suggested future research priorities.1 Specifically: •

•

1

Experts agreed that the main hazard to the public from a pool fire is the heat from the fire, but emphasized that the exact hazard distance depends on site-specific weather conditions; composition of the LNG (relative percentages of methane, propane, and butane); and the size of the fire. Eighteen of 19 experts agreed that the ignition of a vapor cloud over a populated area could burn people and property in the immediate vicinity of the fire. Three experts emphasized in their comments that the vapor cloud is unlikely to penetrate very far into a populated area before igniting.

We considered experts to be “in agreement” if more than 75 percent of them indicated that they completely agreed or generally agreed with a given statement. Not all experts commented on every issue discussed.

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With regard to explosions, experts distinguished between explosions in confined spaces and in unconfined spaces. For confined spaces, such as under a dock or between the hulls of a ship, they agreed that it is possible, under controlled experimental conditions, to induce explosions of LNG vapors; however, a detonation—the more serious type of vapor cloud explosion—of confined LNG vapors is unlikely following an LNG spill caused by a terrorist attack. For unconfined spaces, experts were split on whether it is possible to induce such explosions under controlled experimental conditions; however, even experts who thought such explosions were possible agreed that vapor cloud explosions in unconfined spaces are unlikely to occur following an LNG spill caused by a terrorist attack.

Our panel of 19 experts disagreed with a few of the Sandia study’s conclusions and agreed with the study authors’ perspective on risk-based approaches to dealing with the hazards of potential LNG spills. For example:

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•

•

•

Seven of 15 experts thought Sandia’s heat hazard distance was “about right,” and the remaining 8 experts were evenly split as to whether the distance was “too conservative” (i.e., larger than needed to protect the public) or “not conservative enough” (i.e., too small to protect the public). Officials at Sandia National Laboratories and our panel of experts cautioned that the hazard distances presented cannot be applied to all sites because of the importance of site-specific factors. Additionally, two experts explained that there is no “bright line” for hazards—that is, 1,599 meters is not necessarily “dangerous,” and 1,601 meters is not necessarily “safe.” Nine of 15 experts agreed with Sandia’s conclusion that only three of the five LNG tanks on a tanker would be involved in cascading failure. Five experts noted that the Sandia study did not explain how it concluded that only three tanks would be involved in cascading failure. Finally, experts agreed with Sandia’s conclusion that consequence studies should be used to support comprehensive, risk-based management and planning approaches for identifying, preventing, and mitigating hazards from potential LNG spills.

The experts also suggested priorities for future research—some of which are not fully addressed in DOE’s ongoing LNG research—to clarify uncertainties

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about heat impact distances and cascading failure. These priorities include largescale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques. As part of DOE’s ongoing research, Sandia plans to conduct large-scale LNG pool fire tests, beginning with a pool size of 35 meters—the same size as the largest test conducted to date. Sandia will validate the existing 35-meter data and then conduct similar tests for pool sizes up to 100 meters. Of the top 10 LNG research priorities the experts identified, only 3 have been funded in the DOE study, and the second highest ranked priority, cascading failure, was not funded. One expert noted that although the consequences of cascading failure could be serious, because the extreme cold of spilled LNG and the high heat of an LNG fire could damage the tanker, there are virtually no data looking at how a tanker would be affected by these temperatures.

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CONCLUSIONS It is likely that the United States will increasingly depend on LNG to meet its demand for natural gas. Consequently, understanding and resolving the uncertainties surrounding LNG spills is critical, especially in deciding where to locate LNG facilities. While there is general agreement on the types of effects of an LNG spill, the study results have created what appears to be conflicting assessments of the specific heat consequences of such a spill. These assessments create uncertainty for regulators and the public. Additional research to resolve some key areas of uncertainty could benefit federal agencies responsible for making informed decisions when approving LNG terminals and protecting existing terminals and tankers, as well as providing reliable information to citizens concerned about public safety. To provide the most comprehensive and accurate information for assessing the public safety risks posed by tankers transiting to proposed LNG facilities, we recommended that the Secretary of Energy ensure that DOE incorporates the key issues the expert panel identified, particularly the potential for cascading failure, into its current LNG study. DOE concurred with our recommendation. Mr. Chairman, this concludes my prepared statement. I would be happy to respond to any questions that you or Members of the Committee may have.

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Chapter 3

LIQUEFIED NATURAL GAS (LNG) INFRASTRUCTURE SECURITY: ISSUES FOR CONGRESS *

Paul W. Parfomak Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved.

Energy and Infrastructure Resources, Science, and Industry Division

ABSTRACT Liquefied natural gas (LNG) is a hazardous fuel shipped in large tankers from overseas to U.S. ports. Because LNG infrastructure is highly visible and easily identified, it can be vulnerable to terrorist attack. Since September 11, 2001, the U.S. LNG industry and federal agencies have put new measures in place to respond to the possibility of terrorism. Nonetheless, public concerns about LNG risks continue to raise questions about LNG security. Faced with a perceived national need for greater LNG imports, and persistent public concerns about LNG risks, some in Congress are examining the adequacy of security provisions in federal LNG regulation. LNG infrastructure consists primarily of tankers, import terminals, and inland storage plants. There are nine active U.S. terminals and proposals for many others. Although potentially catastrophic events could arise from a serious accident or attack on such facilities, LNG has a record of relative safety for the last 40 years, and no LNG tanker or land-based facility has *

Excerpted from CRS Report for Congress, Order Code RL32073, dated May 13, 2008.

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Paul W. Parfomak been attacked by terrorists. The likelihood and possible impacts from LNG attacks continue to be debated among experts. Several federal agencies oversee LNG infrastructure security. The Coast Guard has lead responsibility for LNG shipping and marine terminal security under the Maritime Transportation Security Act of 2002 (P.L. 107-295) and the Security and Accountability for Every Port Act of 2006 (P.L. 109-347). The Office of Pipeline Safety (OPS) and the Transportation Security Administration (TSA) both have security authority for LNG storage plants within gas utilities, as well as some security authority for LNG marine terminals. The Federal Energy Regulatory Commission (FERC) approves the siting, with some security oversight, of on-shore LNG marine terminals and certain utility LNG plants. The Coast Guard, OPS and FERC cooperate in the siting approval of new LNG facilities, inspection and operational review of existing facilities, informal communication, and dispute resolution. Federal initiatives to secure LNG are still evolving, but a variety of industry and agency representatives suggest they are reducing the vulnerability of LNG to terrorism. S. 1594 would strengthen federal protection of vessels and infrastructure handling LNG and other especially hazardous cargoes through new international standards, new training requirements, vessel security cost-sharing, incident response and recovery plans, and other provisions. H.R. 2830, which passed in the House of Representatives on April 24, 2008, but which President Bush has threatened to veto, would require the Coast Guard to secure LNG tankers, and would limit the agency’s reliance on state and local resources in doing so, among other provisions. As Congress continues its oversight of LNG, it may consider whether future LNG security requirements will be appropriately funded, whether these requirements will be balanced against evolving risks, and whether the LNG industry is carrying its fair share of the security burden. Congress may also act to improve its understanding of LNG security risks. Finally, Congress may initiate action to better understand the security and trade implications of efforts to promote U.S.-flagged LNG tankers and U.S. crews.

INTRODUCTION Liquefied natural gas (LNG) facilities are receiving a great deal of public attention due to their increasingly important role in the nation’s energy infrastructure and their potential vulnerability to terrorist attack. LNG has long been important to U.S. natural gas markets, although energy economics and public

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perceptions about LNG risks have limited the industry’s growth. Concerns about rising natural gas prices and the possibility of domestic gas shortages have been driving up demand for LNG imports. But LNG is a hazardous1 liquid transported and stored in large quantities. Consequently, LNG infrastructure may directly impact the security of communities where this infrastructure is located. Faced with the widely perceived national need for greater LNG imports, and persistent public concerns about LNG risks, some in Congress are examining the adequacy of security provisions in federal LNG regulation.2 S. 1594, which was introduced by Senator Frank Lautenberg and three cosponsors and referred to the Senate Committee on Commerce, Science, and Transportation on June 12, 2007, would strengthen federal protection of vessels and infrastructure handling LNG and other especially hazardous cargoes. H.R. 2830, which passed in the House of Representatives on April 24, 2008, would require the Coast Guard to enforce security zones around LNG tankers, would limit reliance on state and local government resources to provide LNG security, and would require the Coast Guard to certify it has adequate resources for LNG security before approving an LNG facility’s security plan. H.R. 2830 would further require a comparative risk assessment of vessel-based and facility-based LNG regasification processes and a report on state and local augmentation of Coast Guard security resources, among other provisions. This report provides an overview of industry and federal activities related to LNG security. The report describes U.S. LNG infrastructure, the industry’s safety record and security risks, and the industry’s security initiatives since September 11, 2001. It summarizes recent changes in federal LNG and maritime security law and related changes in the security roles of federal agencies. The report discusses several policy concerns related to federal LNG security efforts: 1) public costs of marine security, 2) uncertainty regarding LNG terrorism risks, and 3) security implications of promoting U.S.-flagged LNG tankers and U.S. crews.

SCOPE AND LIMITATIONS This report focuses on industry and federal activities in LNG infrastructure security. The report includes some discussion of state and local agency activities as they relate to federal efforts, but does not address the full range of state and local issues of potential interest to policy makers. The report also focuses on shipping, marine terminals and land-based storage facilities within gas utilities; it does not address LNG trucking, special purpose LNG facilities, or LNG-fueled

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vehicles. The report discusses activities in LNG safety only as they relate to security. For further discussion of LNG terminal safety, including LNG safetyrelated legislative proposals, see CRS Report RL32205, Liquefied Natural Gas (LNG) Terminals: Siting, Safety and Regulation, by Paul Parfomak and Adam Vann.

BACKGROUND

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What Is LNG? When natural gas is cooled to temperatures below minus 260EF it condenses into liquefied natural gas, or “LNG.”3 As a liquid, natural gas occupies only 1/600th the volume of its gaseous state, so it is stored more effectively in a limited space and is more readily transported by ship or truck. A single tanker ship, for example, can carry huge quantities of LNG — enough to supply the daily energy needs of over 10 million homes. When LNG is warmed it “regasifies” and can be used for the same purposes as conventional natural gas such as heating, cooking and power generation. In 2007, LNG imports to the United States originated in Trinidad and Tobago (57.3%), Egypt (15.3%), Nigeria (12.7%), Algeria (9.9%), Qatar (2.4%), and Equatorial Guinea (2.4%).4 In recent years, some LNG shipments have also come from Malaysia, Oman, Australia, and other countries.5 Brunei, Indonesia, Libya, and the United Arab Emirates also export LNG, and may be significant U.S. suppliers in the future. In addition to importing LNG to the lower 48 states, the United States exports Alaskan LNG to Japan.

Expectations for U.S. LNG Growth The United States has used LNG commercially since the1940s. Initially, LNG facilities stored domestically produced natural gas to supplement pipeline supplies during times of high gas demand. In the 1970s LNG imports began to supplement domestic production. Due primarily to low domestic gas prices, LNG imports stayed relatively small — accounting for only 1% of total U.S. gas consumption in 2002.6 In countries with limited domestic gas supplies, however, LNG imports grew dramatically over the same period. Japan, for example, imported 97% of its natural gas supply as LNG in 2002, over 11 times as much LNG as the United

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States.7 South Korea, France, Spain, and Taiwan also became heavy LNG importers. Natural gas demand has accelerated in the United States over the last several years due to environmental concerns about other energy sources, growth in natural gas-fired electricity generation, and historically low gas prices. Supply has not been able to keep up with demand, however, so gas prices have recently become high and volatile. As Figure 1 shows, average annual gas prices at the wellhead have risen from between $1.50 and $2.50/Mcf (“thousand cubic feet”) through most of the 1990s to above $6.00/Mcf since 2005. At the same time, international prices for LNG have fallen because of increased supplies and lower production and transportation costs, making LNG more competitive with domestic natural gas. While cost estimation is speculative, some industry analysts believe that LNG can be economically delivered to U.S. pipelines for between $2.25 to $4.15/Mcf, depending upon the source.8 In 2003 testimony before the House Energy and Commerce Committee, the Federal Reserve Chairman, Alan Greenspan, called for a sharp increase in LNG imports to help avert a potential barrier to U.S. economic growth. According to Mr. Greenspan’ s testimony

Source: Energy Information Administration. “U.S. Natural Gas Wellhead Price.” Internet database. Updated Feb. 29, 2008. [http://tonto.eia.doe.gov/dnav/ng/hist/ n9190us3m.htm] Figure 1. Average U.S. Natural Gas Wellhead Price ($/Mcf).

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Paul W. Parfomak ... notable cost reductions for both liquefaction and transportation of LNG ... and high gas prices projected in the American distant futures market have made us a potential very large importer.... Access to world natural gas supplies will require a major expansion of LNG terminal import capacity.9

If current natural gas trends continue, the Energy Information Administration (EIA) projects U.S. LNG imports to account for 13% of total U.S. gas supply in 2030.10

OVERVIEW OF U.S. LNG INFRASTRUCTURE The physical infrastructure of LNG consists of interconnected transportation and storage facilities, each with distinct physical characteristics affecting operational risks and security needs. This overview focuses on the three major elements of this infrastructure: tanker ships, marine terminals, and storage facilities.

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LNG Tanker Ships LNG is transported to the United States in very large, specialized tanker ships. LNG tankers are double hulled, containing several massive tanks, each sealed and insulated to maintain safe LNG temperature and prevent leakage during transit. There are currently 200 tankers in service around the world, with a combined cargo capacity of over 24 million cubic meters of LNG, equivalent to over eight times the average daily U.S. natural gas consumption. More than 200 additional tankers are expected to enter service by 2013.11 There are no U.S.flagged LNG tankers.

LNG Marine Terminals LNG tankers unload their cargo at dedicated marine terminals which store and regasify the LNG for distribution to domestic markets. Onshore terminals typically consist of docks, LNG handling equipment, storage tanks, and interconnections to regional gas pipelines. As discussed later in the report, the siting of onshore LNG import terminals is regulated by the Federal Energy

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Regulatory Commission (FERC). There are eight active onshore LNG terminals in the United States: •

•

•

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•

•

•

•

•

Everett, Massachusetts. The Everett terminal is located across the Mystic River from Boston; tankers must pass through Boston harbor to reach it. The terminal serves gas utilities and electric power producers in New England, receiving approximately 65 LNG shipments annually.12 Cove Point, Maryland. Cove Point is located on the Chesapeake Bay 60 miles southeast of Washington, DC. Under federally approved expansion plans, the terminal could be capable of receiving up to 200 shipments per year in 2008.13 Elba Island, Georgia. The Elba Island terminal is located on an island five miles down the Savannah River from Savannah, Georgia and ten miles from the Atlantic coast. The terminal completed a major expansion in 2006, allowing it to receive approximately 118 shipments per year.14 Kenai, Alaska. Built in 1969, this is the oldest LNG marine terminal in the United States and the only one built for export (to Japan). The Kenai terminal is located in Nikiski near the Cook Inlet gas fields. Since 1969 the terminal has exported an average of approximately 34 LNG shipments each year.15 Lake Charles, Louisiana. The Lake Charles terminal is located approximately nine miles southwest of the city of Lake Charles near the Gulf of Mexico. The terminal completed a major expansion in 2006, allowing it to receive up to 175 shipments per year.16 Peñuelas, Puerto Rico. The Peñuelas terminal, located on the southern coast of Puerto Rico, is dedicated to fueling an electric generation plant which supplies 20% of Puerto Rico’s power.17 The terminal receives 10 to 15 LNG shipments annually.18 Quintana Island, Texas. This terminal is located southeast of the city of Freeport, in Brazoria County. The terminal has the capability of receiving approximately 200 ships per year.19 It received it first commercial cargo in April 2008.20 Sabine Pass, Louisiana. This terminal is located near the Sabine Pass Channel in Cameron Parish. The terminal has the capability of receiving approximately 300 ships per year.21 It also received it first commercial cargo in April 2008.22

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Offshore LNG terminals connect to land only by underwater pipelines. These offshore terminal designs seek to avoid community opposition, permitting, and operating obstacles which have hindered the construction of new on-shore LNG terminal facilities. Because offshore terminals would be located far from land, they also would present fewer security risks than on-shore LNG terminals. Offshore terminals may present environmental concerns, however, if they use seawater for regasification. Such a process cools the waters in a terminal’s vicinity with potential impacts on the local ecosystem due to the lower water temperatures.23 As discussed later in the report, offshore LNG terminals are regulated jointly by the Maritime Administration (MARAD) and the U.S. Coast Guard. There is currently one operating offshore LNG terminal in U.S. waters:

Source: Federal Energy Regulatory Commission (FERC), “Approved North American LNG Import Terminals,” Updated April 21, 2008. [http://www.ferc.gov/ industries/lng.asp] Figure 2. Approved LNG Terminals in North America.

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Gulf of Mexico, Louisiana. The Gulf Gateways (Energy Bridge) terminal was completed in 2004 and received its first LNG shipment in March, 2005. The terminal consists of an offshore gas pipeline buoy system and is served by specialized tankers which regasify their LNG cargoes on board. The terminal expects up to be able to serve up to 60 LNG shipments per year.24

A second offshore terminal near Boston, Massachusetts, is scheduled to begin operations in 2008.25 In addition to these active terminals, some 28 LNG terminal proposals have been approved by regulators across North America to serve the U.S. market (Figure 2). A number of these proposals have been withdrawn, however, due to siting problems, financing problems, or other reasons. Developers have proposed another 13 U.S. terminals prior to filing formal siting applications.26

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LNG Peak Shaving Plants Many gas distribution utilities rely on “peak shaving” LNG plants to supplement pipeline gas supplies during periods of peak demand during winter cold snaps. The LNG is stored in large refrigerated tanks integrated with the local gas pipeline network. The largest facilities usually liquefy natural gas drawn directly from the interstate pipeline grid, although many smaller facilities without such liquefaction capabilities receive LNG by truck. LNG tanks are generally surrounded by containment impoundments which limit the spread of an LNG spill and the potential size of a resulting vapor cloud. LNG peak shaving plants are often located near the populations they serve, although many are in remote areas away from people. According to the Pipeline and Hazardous Materials Safety Administration (PHMSA) there are 103 active LNG storage facilities in the United States distributed across 31 states.27 These facilities are mostly in the Northeast where pipeline capacity and underground gas storage have historically been constrained.

LNG RISKS AND VULNERABILITIES The safety hazards associated with LNG terminals have been debated for decades. A 1944 accident at one of the nation’s first LNG facilities killed 128

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people and initiated public fears about LNG hazards which persist today.28 Technology improvements and standards since the 1940s have made LNG facilities much safer, but serious hazards remain since LNG is inherently volatile and is shipped and stored in large quantities. A January 2004 accident at Algeria’s Skikda LNG terminal which killed or injured over 100 workers added to the ongoing controversy over LNG facility safety.29 LNG infrastructure is also potentially vulnerable to terrorist attack.

Physical Hazards of LNG Natural gas is combustible, so an uncontrolled release of LNG poses a serious hazard of explosion or fire. LNG also poses hazards because it is extremely cold. Experts have identified several potentially catastrophic events that could arise from an LNG release. The likelihood and severity of these events have been the subject of considerable research and analysis. While open questions remain about the impacts of specific hazards in an actual accident, there appears to be consensus as to what the greatest LNG hazards are.

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•

Pool fires. If LNG spills near an ignition source, the evaporating gas in a combustible gas-air concentration will burn above the LNG pool.30 The resulting “pool fire” would spread as the LNG pool expanded away from its source and continued evaporating. Such pool fires are intense, burning far more hotly and rapidly than oil or gasoline fires.31 They cannot be extinguished — all the LNG must be consumed before they go out. Because LNG pool fires are so hot, their thermal radiation may injure people and damage property a considerable distance from the fire itself. Many experts agree that a pool fire, especially on water, is the most serious LNG hazard.32 Flammable vapor clouds. If LNG spills but does not immediately ignite, the evaporating natural gas will form a vapor cloud that may drift some distance from the spill site. If the cloud subsequently encounters an ignition source, those portions of the cloud with a combustible gas-air concentration will burn. Because only a fraction of such a cloud would have a combustible gas-air concentration, the cloud would not likely explode all at once, but the fire could still cause considerable damage. An LNG vapor cloud fire would gradually burn its way back to the LNG spill where the vapors originated and would continue to burn as a pool fire.33 If an LNG tank failed due to a collision or terror attack, experts believe

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the failure event itself would likely ignite the LNG pool before a large vapor cloud could form.34 Consequently, they conclude that large vapor cloud fires are less likely than instantaneous pool fires. Flameless explosion. If LNG spills on water, it could theoretically heat up and regasify almost instantly in a “flameless explosion” (also called a “rapid phase transition”). While the effects of tanker-scale spills have not been studied extensively, Shell Corporation experiments with smaller LNG spills in 1980 did not cause flameless explosions. Even if there were a flameless explosion of LNG, experts believe the hazard zones around such an event “would not be as large as either vapor cloud or pool fire hazard zones.”35

In addition to these catastrophic hazards, an LNG spill poses hazards on a smaller scale. An LNG vapor cloud is not toxic, but could cause asphyxiation by displacing breathable air. Such clouds rise in air as they warm, however, diminishing the threat to people on the ground. Alternatively, extremely cold LNG could injure people or damage equipment through direct contact. The extent of such contact would likely be limited, however, as a major spill would likely result in a more serious fire. The environmental damage associated with an LNG spill would be confined to fire and freezing impacts near the spill since LNG dissipates completely and leaves no residue (as crude oil does).36

Safety Record of LNG The LNG tanker industry claims a record of relative safety over the last 45 years; since international LNG shipping began in 1959, tankers reportedly have carried over 47,000 LNG cargoes without a serious accident at sea or in port.37 LNG tankers have experienced groundings and collisions during this period, but none has resulted in a major spill.38 The LNG marine safety record is partly due to the double- hulled design of LNG tankers. This design makes them more robust and less prone to accidental spills than single-hulled oil and fuel tankers like the Exxon Valdez, which caused a major Alaskan oil spill after grounding in 1989.39 LNG tankers also carry radar, global positioning systems, automatic distress systems and beacons to signal if they are in trouble. Cargo safety systems include instruments that can shut operations if they deviate from normal as well as gas and fire detection systems. The safety record of onshore LNG terminals is more mixed. There are more than 40 LNG terminals (and more than 150 other LNG storage facilities)

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worldwide. Since 1944, there have been approximately 13 serious accidents at these facilities directly related to LNG. Two of these accidents caused single fatalities of facility workers — one in Algeria in 1977, and another at Cove Point, Maryland, in 1979. On January 19, 2004, a fire at the LNG processing facility in Skikda, Algeria killed an estimated 27 workers and injured 74 others. The Skikda fire completely destroyed a processing plant and damaged a marine berth, although it did not damage a second processing plant or three large LNG storage tanks also located at the terminal.40 The Skikda accident did not injure the rest of the 12,000 workers at the complex, but it was considered the worst petrochemical plant fire in Algeria in over 40 years.41 According to press reports, the accident resulted from poor maintenance rather than a facility design flaw.42 Another three accidents at worldwide LNG plants since 1944 have also caused fatalities, but these were construction or maintenance accidents in which LNG was not present.43

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LNG Security Risks LNG tankers and land-based facilities may be vulnerable to terrorism. Tankers could be physically attacked to destroy their cargo — or commandeered for use as weapons against coastal targets. Land-based LNG facilities could also be physically attacked with explosives or through other means. Alternatively, computer control systems could be “cyber-attacked,” or both physical and cyber attack could happen at the same time. Some LNG facilities could also be indirectly disrupted by other types of terror strikes, such as attacks on regional electricity grids or communications networks, which could in turn affect dependent LNG control and safety systems. Since LNG is fuel for power plants, heating, military bases, and other uses, disruption of LNG shipping or storage poses additional “downstream” risks, especially in more LNG-dependent regions like New England.

LNG Tanker Vulnerability LNG tankers cause the most concern among security analysts because they are potentially more accessible than fixed terminal facilities, because they may transit nearer to populated areas, and because LNG spills from tankers could be more difficult to control. According to a 2004 report by Sandia National Laboratories, an intentional LNG spill and resulting fire could cause “major” injuries to people and “significant” damage to structures within approximately 500 meters (0.3 mile) of the spill site, more moderate injuries and structural

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damage up to 1,600 meters (1.0 mile) from the spill site, and lower impacts out to 2,500 meters (1.5 miles).44 These results are used by federal agencies in reviewing LNG terminal siting applications. Other LNG hazard studies have reached somewhat different conclusions about LNG tanker vulnerability. A report by the Government Accountability Office (GAO) released in 2007 reviewed six unclassified studies of LNG tanker hazards, including the Sandia study. The GAO report concluded that45

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The Gaz Fountain Attack Although there have been no terrorist attacks on LNG tankers, there is at least one documented case of a gas tanker of similar construction being attacked in wartime. During the Iran-Iraq War in the 1990s, the double-hulled LPG tanker Gaz Fountain was fired upon by an Iranian aircraft using three air-to-ground, armor- piercing Maverick missiles. Two of the missiles exploded on or above the ship’s deck, causing relatively minor damage. The third missile penetrated the deck and exploded above a butane storage tank, opening a 6 square-meter (65 square-foot) hole in the roof of the tank. The escaping gas ignited, establishing a large fire on deck above the missile entry hole. The fire aboard the Gaz Fountain was successfully extinguished by a salvage ship, her remaining cargo was successfully unloaded to another tanker, and she was eventually repaired.48 The Gaz Fountain attack and salvage provides some evidence as to the robustness of double-hulled gas tankers like those that carry LNG. But the relatively benign outcome in the Gaz Fountain attack does not necessarily demonstrate that attacks on LNG tankers would have similarly limited impacts. The Gaz Fountain was fortunate that its storage tank was breached only at the top. If missiles had been targeted at the hull of the ship rather than its deck, one might have penetrated the side of a storage tank, causing a major spill on water and an inextinguishable pool fire. Furthermore, if the gas involved had been LNG rather than butane, the Gaz Fountain might have been subject to cryogenic damage since LNG is transported at a much lower temperature than butane (-260 F vs. +25 F). According to the Sandia report, such a combination could lead to cascading failure of adjacent storage tanks and, presumably, an even larger fire.49 E

E

Because there have been no large-scale LNG spills or spill experiments, past studies have developed modeling assumptions based on small-scale spill data. While there is general agreement on the types of effects from an LNG spill, the

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Following the GAO report, Members of Congress have expressed continuing concern about the uncertainty associated with LNG tanker vulnerability and hazard analysis.46 In 2008, Congress appropriated $8 million to fund large-scale LNG fire experiments by the Department of Energy addressing some of the hazard modeling uncertainties identified in the GAO report.47 It remains to be seen to what degree this research will increase policy makers’ confidence in LNG tanker vulnerability analyses.

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FEDERAL LNG SECURITY INITIATIVES Operators of LNG infrastructure had security programs in place prior to September 11, 2001, but these programs mostly focused on personnel safety and preventing vandalism. The terror attacks of September 11 focused attention on the vulnerability of LNG infrastructure to different threats, such as systematic attacks on LNG facilities by foreign terrorists. Consequently, both government and industry have taken new initiatives to secure LNG infrastructure in response to new threats. Several federal agencies oversee the security of LNG infrastructure. The Coast Guard has lead responsibility for LNG shipping and marine terminal security. The Department of Transportation’s Office of Pipeline Safety and the Department of Homeland Security’s Transportation Security Administration have security authority for peak-shaving plants within gas utilities, as well as some security authority for LNG marine terminals. FERC has siting approval responsibility, with some security oversight, for land-based LNG marine terminals and certain peak-shaving plants. In addition to federal agencies, state and local authorities, like police and fire departments, also help to secure LNG.

Security Activities of Federal Maritime Agencies The two federal agencies with the most significant roles in maritime security as it relates to LNG are the U.S. Coast Guard and the Maritime Administration.

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U.S. Coast Guard The Coast Guard is the lead federal agency for U.S. maritime security, including port security. Among other duties, the Coast Guard tracks, boards, and inspects commercial ships approaching U.S. waters. A senior Coast Guard officer in each port oversees the security and safety of vessels, waterways, and many shore facilities in his geographic area. The Coast Guard derives its security responsibilities under the Ports and Waterways Safety Act of 1972 (P.L. 92-340) and the Maritime Transportation Security Act of 2002 (P.L. 107-295). Maritime security regulations mandated by P.L. 107-295 are discussed below. Under P.L. 107-295 the Coast Guard and the Maritime Administration share siting approval authority for offshore LNG terminals. Shortly after September 11, 2001, the Coast Guard began to systematically prioritize protection of ships and facilities, including those handling LNG, based on vulnerability assessments and the potential consequences of security incidents. The Coast Guard evaluated the overall susceptibility of marine targets, their use to transport terrorists or terror materials, and their use as potential weapons. In particular, the Coast Guard evaluated the vulnerability of tankers to “a boat loaded with explosives” or “being commandeered and intentionally damaged.”50 While the assessments focused on Coast Guard jurisdictional vessels and facilities, some scenarios involved other vital port infrastructure like bridges, channels, and tunnels.51 The Coast Guard used these assessments in augmenting security of key maritime assets and in developing the agency’s new maritime security standards. The Coast Guard began increasing LNG tanker and port security immediately after September 11, 2001. For example, the Coast Guard suspended LNG shipments to Everett for several weeks after the terror attacks to conduct a security review and revise security plans.52 The Coast Guard also worked with state, environmental and police marine units to establish 24-hour patrols in Boston harbor.53 In July 2002, the Coast Guard imposed a 1,000-yard security zone around the Kenai LNG terminal — and subsequently imposed similar zones around other U.S. LNG terminals.54 The Coast Guard also reassessed security at the Cove Point terminal before allowing LNG shipments to resume there for the first time since 1980.55 As new LNG terminals have been proposed and approved by federal agencies, the Coast Guard has continued its involvement in LNG security. The most heavily secured LNG shipments are those bound for the Everett terminal because they pass through Boston harbor. Depending upon the level of alert, the Coast Guard and local law enforcement agencies may put in place numerous security provisions for these shipments, including:

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Inspection of security and tanker loading at the port of origin. On-board escort to Boston by Coast Guard “sea marshals.” 96-hour advanced notice of arrival of an LNG tanker. Advance notification of local police, fire, and emergency agencies, as well as the Federal Aviation Administration and the U.S. Navy. Boarding LNG tankers for inspection prior to Boston harbor entry. Harbor escort by armed patrol boats, cutters, or auxiliary vessels. Enforcement of a security zone closed to other vessels two miles ahead and one mile to each side of the LNG tanker. Suspension of overflights by commercial aircraft at Logan airport. Inspection of adjacent piers for bombs by police divers. Posting of sharpshooters on nearby rooftops. Additional security measures which cannot be disclosed publicly.56

According to the Coast Guard, such security provisions have been in place for the other U.S. LNG terminals as well, depending upon local assessments of security risk and the unique characteristics of each marine area.57 On October 22, 2003, the Coast Guard issued final rules to implement the new security requirements mandated by P.L. 107-295. The rules are codified in Title 33 of the Code of Federal Regulations, Chapter 1, Subchapter H. Among other provisions, the rules establish Coast Guard port officers as maritime security coordinators and set requirements for maritime area security plans and committees. The rules require certain owners or operators of marine assets to designate security officers, perform security assessments, develop and implement security plans, and comply with maritime security alert levels. The vessel rules apply to all LNG tankers entering U.S. ports. Facility rules apply to all land-based U.S. LNG terminals or proposed offshore LNG terminals. Finally, the rules require certain vessels, including LNG tankers, to carry an automatic identification system. The Coast Guard also has authority to review, approve, and verify security plans for marine traffic around proposed LNG marine terminals as part of the overall siting approval process led by FERC. The Coast Guard is responsible for issuing a Letter of Recommendation regarding the suitability of waterways for LNG vessels serving proposed terminals. The Coast Guard acts as a cooperating agency in the evaluation of LNG terminal siting applications.58 The Coast Guard also led the International Maritime Organization (IMO) in developing maritime security standards outside U.S. jurisdiction.59 These standards, the International Ship and Port Facility Security Code (ISPS Code)

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contain detailed mandatory security requirements for governments, port authorities and shipping companies, as well as recommended guidelines for meeting those requirements. The ISPS Code is intended to provide a standardized, consistent framework for governments to evaluate risk and to “offset changes in threat with changes in vulnerability.”60 On October 13, 2006, President Bush signed the Security and Accountability for Every Port Act of 2006 (P.L. 109-347). While not addressing LNG security specifically, the act includes general maritime security provisions which could apply to LNG vessels and facilities. These provisions include, among others, requirements relating to maritime facility security plans (Sec. 102); unannounced inspections of maritime facilities (Sec. 103); long-range vessel tracking (Sec. 107); operational centers for port security (Sec. 108); port security grants (Sec. 112); and training and exercise programs (Sec. 112-113). The Coast Guard is the federal agency primarily responsible for implementing these provisions.

Maritime Administration The Maritime Administration (MARAD) within the Department of Transportation has as its stated mission “to strengthen the U.S. maritime transportation system - including infrastructure, industry and labor - to meet the economic and security needs of the Nation.”61 As noted above, under P.L.107295, MARAD shares siting approval authority for offshore LNG terminals with the Coast Guard. Among other activities, the agency also administers its Maritime Security Program “to maintain an active, privately owned, U.S.-flag, and U.S.crewed liner fleet in international trade.”62 Consistent with this mission, Congress passed the Coast Guard and Maritime Transportation Act of 2006 (P. L. 109 — 241) directing MARAD to implement a program to promote the transportation of LNG to domestic terminals in U.S. flag vessels (Sec. 304(a)). The act also directs the agency to give top priority to the processing of offshore LNG siting applications that will be supplied by U.S. flag vessels (Sec. 304(b). The act also requires the agency to consider the nation of registry for, and the nationality or citizenship of, officers and crew serving on board LNG tankers when reviewing an LNG terminal siting application (Sec. 304(c)).

Federal Pipeline and Chemical Security Agencies Office of Pipeline Safety The Office of Pipeline Safety (OPS) within the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation

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has statutory authority to regulate the safety and security of LNG peak-shaving plants. The agency derives this authority under the Natural Gas Pipeline Safety Act of 1968 (P.L. 90-48 1). The OPS security regulations for LNG peak-shaving facilities are found in 49 C.F.R. 193, Liquefied Natural Gas Facilities: Federal Safety Standards (Subpart J-Security). These regulations govern security procedures, protective enclosures, communications, monitoring, lighting, power sources, and warning signs. Federal LNG safety regulations (33 C.F.R. 127) and National Fire Protection Association standards for LNG also include provisions addressing security, such as requirements for monitoring facilities and preparing emergency response plans.63 On December, 28, 2006, the OPS published in the Federal Register a security advisory for LNG facility operators after an August, 2006 security breach at an LNG peak-shaving plant in Lynn, MA.64 Although not a terrorist incident, the security breach involved the penetration of intruders through several security barriers and alert systems, permitting them to access the main LNG storage tank at the facility. The OPS advisory recommends that LNG facility operators ensure alarms and monitoring devices are functioning; ensure security personnel are properly trained; determine whether security personnel can respond to security breaches in a timely manner; update security procedures to incorporate the most relevant threat information; confirm that personnel properly coordinate their security activities; and independently audit facility security or conduct.65

Transportation Security Administration The Transportation Security Administration (TSA) is the lead federal authority for the security of the interstate gas pipeline network under the Natural Gas Pipeline Safety Act of 1968 (P.L. 90- 481). This security authority was transferred to TSA from the Transportation Department’s Office of Pipeline Safety (OPS) under the Aviation and Transportation Security Act of 2001(P.L. 107-7 1). The TSA has asserted its security authority over land-based LNG facilities that are considered an integral part of the interstate pipeline network.66 The TSA exercises its pipeline and LNG security oversight through the Pipeline Security Division (PSD) within the agency’s Office of Transportation Sector Network Management.67 The mission of TSA’s Pipeline Security Division currently includes developing security standards; implementing measures to mitigate security risk; building and maintaining stakeholder relations, coordination, education and outreach; and monitoring compliance with security standards, requirements, and regulations. Since 2003, TSA has put in place a number of initiatives related to pipeline security. These initiatives include the coordination, development, implementation,

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and monitoring of pipeline security plans; on-site reviews of pipeline operator security; United States and Canadian security assessment and planning for critical cross-border pipelines; regional supply studies for key natural gas markets; and pipelines security training, among other initiatives.68 As of February 2008, TSA had completed 73 CSR reviews.69 According to TSA, virtually all of the companies reviewed have developed security plans, identified critical assets, and conducted background checks on new employees. Most have also implemented employee security training programs and raised local community and law enforcement awareness of pipeline security as part of their emergency response obligations.70 In 2005, TSA issued an overview of recommended security practices for pipeline operators “for informational purposes only ... not intended to replace security measures already implemented by individual companies.”71 The agency released revised guidance on security best practices at the end of 2006 and plans to release a second revision in 2008.72

Federal Energy Regulatory Commission (FERC) The FERC is responsible for permitting new land-based LNG facilities, and for ensuring the safe operation of these facilities through subsequent inspections.73 The initial permitting process requires approval of safety and security provisions in facility design, such as hazard detectors, security cameras, and vapor cloud exclusion zones. Every two years, FERC staff inspect LNG facilities to monitor the condition of the physical plant and inspect changes from the originally approved facility design or operations.74 The FERC derives its LNG siting authority under the Natural Gas Act of 1938 (15 U.S.C. 717). The agency has jurisdiction over all on-shore LNG marine terminals and 12 peak-shaving plants involved in interstate gas trade.75 In response to public concern about LNG plant security since September 11, 2001, FERC has emphasized the importance of security at LNG facilities. According to the commission, FERC staff played key roles at inter-agency technical conferences regarding security at the Everett and Cove Point LNG terminals. According FERC staff, the commission has added a security chapter to its LNG site inspection manuals which consolidates previous requirements and adds new ones.76 As part of its biennial inspection program, FERC also inspected 11 jurisdictional LNG sites in 2005 “placing increased emphasis on plant security measures and improvements.”77 FERC’s FY2006 annual report states that “the Commission continues to give the highest priority to deciding any requests made for the recovery of extraordinary expenditures to safeguard the reliability and security of the Nation’s energy transportation systems and energy supply infrastructure.”78

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Department of Homeland Security The Department of Homeland Security (DHS) Appropriations Act of 2007 (P.L. 109-295) grants DHS the authority to regulate chemical facilities that “present high levels of security risk” (Sec. 550). In November, 2007, DHS finalized its chemical facility security regulations under the act, requiring that facilities with certain hazardous chemicals, including LNG, at or above screening threshold quantities submit information to DHS through an on-line screening tool. Based on these evaluations, DHS will identify high risk facilities required to conduct a security vulnerability assessments and prepare site security plans to address identified vulnerabilities and meet risk-based performance standards.79 These regulations may apply to inland LNG peak-shaving plants, although they exempt LNG facilities in ports which are subject to security regulations under the Maritime Transportation Security Act of 2002 (P.L. 107-295), as amended.

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Federal Interagency Cooperation in LNG Security The Coast Guard, TSA, and FERC all have potentially overlapping security jurisdiction over certain facilities at onshore LNG terminals. For example, FERC’s biennial LNG site visits explicitly include security inspections, and TSA oversees onsite pipeline security — but the Coast Guard asserts lead security authority over the entire terminal in its maritime security regulations. Under current authority, both the Coast Guard and TSA could both require their own facility security assessments for pipelines and LNG storage at LNG marine terminals. To avoid jurisdictional confusion, the Coast Guard, OPS and FERC have entered into an interagency agreement to ensure that they work in a coordinated manner to address issues regarding safety and security at waterfront LNG facilities, including the terminal facilities and tanker operations, to avoid duplication of effort, and to maximize the exchange of relevant information related to the safety and security aspects of LNG facilities and the related marine concerns.80

The agreement requires the agencies to cooperate in the siting approval of new LNG facilities, inspection and operational review of existing facilities, informal communication, and dispute resolution.81 According to FERC, in FY2006, the commission the “performed detailed reviews of [LNG] safety and

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security issues, in coordination with the U.S. Coast Guard and the U.S. Department of Transportation.”82 The FERC’s security review for new LNG terminal applications is conducted in consultation with the US Coast Guard. Security assessments of individual terminal proposals are conducted by Coast Guard field units through security workshops involving federal, state and local law enforcement officials as well as port stakeholders. FERC engineers provide technical assistance on marine spill issues. FERC and the Coast Guard require LNG terminal applicants to also submit a navigational suitability review under 33 C.F.R. 127, and begin a security assessment of their proposal in accordance with 33 C.F.R. 105. According to FERC, where site- specific security concerns have been raised, the agencies have conducted non-public technical workshops with “all relevant stakeholders and federal, state and local expert agencies” to resolve those security concerns.83

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Industry Initiatives for Land-Based LNG Security After the September 11 attacks, gas infrastructure operators, many with LNG facilities, immediately increased security against the newly perceived terrorist threat. The operators strengthened emergency plans; increased liaison with law enforcement; increased monitoring of visitors and vehicles on utility property; increased employee security awareness; and deployed more security guards.84 In cooperation with the OPS, the Interstate Natural Gas Association of America (INGAA) formed a task force to develop and oversee industry-wide security standards “for critical onshore and offshore pipelines and related facilities, as well as liquefied natural gas (LNG) facilities.”85 The task force also included representatives from the Department of Energy (DOE), the American Gas Association (AGA), and non-member pipeline operators. With the endorsement of the OPS, the INGAA task force issued security guidelines for natural gas infrastructure, including LNG facilities, in September 2002.86 The task force also worked with federal agencies, including the Department of Homeland Security, on a common government threat notification system.87

KEY POLICY ISSUES IN LNG SECURITY Government and industry have taken significant steps to secure the nation’s LNG infrastructure. But continued progress in implementing and sustaining LNG

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infrastructure protection activities may face several challenges. As discussed in detail in the following sections, members of Congress and federal officials are concerned about the growing public costs of LNG security, the uncertainty of terrorist threats against LNG, and security differences between foreign and U.S. LNG vessels and crews.

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Public Costs of LNG Marine Security Some policymakers are concerned about the public cost and sustainability of securing LNG shipments. Overall cost data for LNG security are unavailable, but estimates have been made for Everett shipments. In 2003, the Coast Guard Program Office estimated that it cost the Coast Guard approximately $40,000 to $50,000 to “shepherd” an LNG tanker through a delivery to the Everett terminal, depending on the duration of the delivery, the nature of the security escort, and other factors.88 A 2007 update from the Coast Guard Boston Sector estimates an average direct cost to the Coast Guard of an LNG delivery to Everett of approximately $62,000.89 State and local authorities also incur costs for overtime police, fire and security personnel overseeing LNG tanker deliveries. The state of Massachusetts and the cities of Boston and Chelsea estimated they spent a combined $37,500 to safeguard the first LNG shipment to Everett after September 11, 2001.90 Based on these figures, the public cost of security for an LNG tanker shipment to Everett is on the order of $100,000, excluding costs incurred by the terminal owner. Marine security costs at other active LNG terminals could be lower than for Everett to the extent they are farther from dense populations and face fewer vulnerabilities. But these terminals expect more shipments. Altogether, the nine active onshore U.S. LNG terminals, including Everett, expect to have enough capacity for over 1,100 shipments per year in 2009. Increasing LNG imports to meet 13% of total U.S. gas supply by 2030 as projected by the EIA could require some 2,300 LNG shipments to LNG terminals serving the United States. Assuming an average security cost only half that for Everett, or $50,000 per shipment, annual costs to the public for marine LNG security could exceed $55 million by 2009 if active terminals were operating at full capacity. Security costs could exceed $115 million by 2030 based on the EIA projections.91 At least over the next several years, however, analysts predict that U.S. LNG terminals will operate well below capacity, so actual marine security costs will likely be lower.92 The potential increase in security costs from growing U.S. LNG imports, and the potential diversion of Coast Guard and safety agency resources from other

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activities have been a persistent concern to policy makers.93 According to Coast Guard officials, the service’s LNG security expenditures are not all incremental, since they are part of the Coast Guard’s general mission to protect the nation’s waters and coasts. Nonetheless, Coast Guard staff have acknowledged that resources dedicated to securing maritime LNG might be otherwise deployed for boating safety, search and rescue, drug interdiction, or other security missions. LNG security is funded from the Coast Guard’s general maritime security budget, so it is not a line item in the FY2009 Department of Homeland Security budget request. However, the Coast Guard’s FY2006 budget did include an additional $11 million in funding over FY2005 levels for “Increased Port Presence and LNG Transport Security,” specifically including “additional boat crews and screening personnel at key LNG hubs.”94 In a December 2007 report, the GAO recommended that the Coast Guard develop a national resource allocation plan to address growing LNG security requirements.95 In subsequent testimony before Congress, Coast Guard Commandant Admiral Thad Allen expressed concern about the costs to the Coast Guard of securing dangerous cargoes such as LNG and called for a “national dialogue” on the issue.96 During questioning, Admiral Allen acknowledged that the Coast Guard did not currently possess sufficient resources to secure future LNG deliveries to a proposed LNG terminal in Long Island Sound which has subsequently been authorized by FERC.97 State and local agencies are also seeking more funding to offset the costs of LNG security. Otherwise, they believe that LNG security needs may force them to divert limited local resources from other important public services. Addressing these concerns, the Energy Policy Act of 2005 requires private and public sector cost- sharing for LNG tanker security (Section 31 1d). In compliance with the act and prior FERC policy, FERC officials require new LNG terminal operators to pay the costs of any additional security or safety needed for their facilities.98 The FERC has also recommended that LNG terminal operators provide private security staff to supplement Coast Guard and local government security forces.99 The public costs of LNG security may decline as federally mandated security systems and plans are implemented. New security technology, more specific threat intelligence, and changing threat assessments may all help to lower LNG security costs in the future. Nonetheless, the potential increase in security costs from growing U.S. LNG shipments may warrant a review of these costs and associated recovery mechanisms. S. 1594 would allow the DHS to establish a security costsharing plan to assist the USCG in securing LNG tankers and other vessels carrying especially hazardous cargo (Sec. 6). H.R. 2830 would prohibit LNG

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facility security plans based upon the provision of security by a state or local government unless that government has an LNG security arrangement with the facility operator (Sec. 720 (b)). H.R. 2830 would also require the Coast Guard to enforce LNG tanker security zones (Sec. 720(a)), and would require the Coast Guard to certify that it has adequate security resources in the sector where a terminal would be located before facility security plans for a new LNG terminal are approved (Sec. 720(c)). The Commandant of the Coast Guard reportedly opposes the requirement in H.R 2830 for the Coast Guard to provide LNG tanker security on the grounds that it undermines “the necessary discretion and flexibility to meet ... mission demands in an often-changing, dangerous operating environment.”100 In prior testimony before Congress, the Commandant stated that such a requirement would not appropriately balance LNG risks against the risks of other dangerous cargoes in marine transportation, and would amount to a subsidy for private LNG companies.101 The Commandant also reportedly opposes H.R. 2830 because he believes it does not adequately distribute the LNG security burden among the Coast and state and local agencies involved in LNG projects.102 Echoing the Commandant’s objections, President Bush reportedly has threatened to veto H.R. 2830 because of these LNG security provisions.103 H.R. 2830 passed the House by a margin (395-7) large enough to override a veto, however, and has yet to pass in the Senate, so it remains to be seen whether these provisions will ultimately change in response to the Commandant’s or President’s objections.

Uncertainty about LNG Threats The likelihood of a terrorist attack on U.S. LNG infrastructure has been the subject of debate since September 11, 2001. To date, no LNG tanker or landbased LNG facility in the world has been attacked by terrorists. However, similar natural gas and oil facilities have been favored terror targets internationally. For example, since 2001, gas and oil pipelines have been attacked in at least half a dozen countries.104 In October 2002, the French oil tanker Limburg was attacked off the Yemeni coast by a bomb-laden fishing boat.105 In June 2003, U.S. intelligence agencies warned about possible Al Qaeda attacks on energy facilities in Texas.106 The Homeland Security Council included terrorist attacks on “cargo ships” carrying “flammable liquids” among the fifteen hazards scenarios it developed in 2004 as the basis for U.S. homeland security “national preparedness standards.”107

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In addition to warnings of a terrorist threat to energy facilities in general, federal agencies have identified LNG infrastructure in particular as a potential terrorist target. The Department of Homeland Security (DHS) specifically included LNG assets among a list of potential terrorist targets in a security alert late in 2003.108 The DHS also reported that “in early 2001 there was some suspicion of possible associations between stowaways on Algerian flagged LNG tankers arriving in Boston and persons connected with the so-called ‘Millennium Plot’” to bomb targets in the United States. While these suspicions could not be proved, DHS stated that “the risks associated with LNG shipments are real, and they can never be entirely eliminated.”109 The 2004 report by Sandia National Laboratories concluded that potential terrorist attacks on LNG tankers, could be considered “credible and possible.”110 The Sandia report identified LNG tankers as vulnerable to ramming, pre-placed explosives, insider takeover, hijacking, or external terrorist actions (such as a Limburg-type, missile or airplane attack).111 Others further assert that terrorists have demonstrated both the desire and capability to attack such shipping with the intention of harming the general population.112 Although they acknowledge the security information put forth by federal agencies, many experts believe that concern about threats to LNG tankers is overstated.113 In 2003, the head of one university research consortium remarked, for example, “from all the information we have ... we don’t see LNG as likely or credible terrorist targets.”114 Industry representatives argue that deliberately causing an LNG catastrophe to injure people might be possible in theory, but would be extremely difficult to accomplish. Likewise, the Federal Energy Regulatory Commission (FERC) and other experts believe that LNG facilities are relatively secure compared to other hazardous chemical infrastructures which receives less public attention. In a 2004 report, the FERC stated that for a new LNG terminal proposal ... the perceived threat of a terrorist attack may be considered as highly probable to the local population. However, at the national level, potential terrorist targets are plentiful.... Many of these pose a similar or greater hazard to that of LNG.115

The FERC also has remarked, however, that “unlike accidental causes, historical experience provides little guidance in estimating the probability of a terrorist attack on an LNG vessel or onshore storage facility.”116 Former Director of Central Intelligence, James Woolsey, has stated his belief that a terrorist attack on an LNG tanker in U.S. waters would be unlikely because its potential impacts would not be great enough compared to other potential

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targets.117 LNG terminal operators which have conducted proprietary assessments of potential terrorist attacks against LNG tankers, have expressed similar views.118 In a September 2006 evaluation of a proposed LNG terminal in Long Island Sound, the Coast Guard stated that there were “currently no specific, credible threats against” the proposed LNG facility or tankers serving the facility.119 The evaluation also noted, however, that the threat environment is dynamic and that some threats may be unknown.120 Because the probability of a terrorist attack on LNG cannot be known with certainty, policy makers and community leaders must, to some extent, rely on their own judgment to decide whether LNG security measures for a specific facility will adequately protect the public. S. 1594 would increase federal protection of vessels and infrastructure handling LNG through new international standards (Sec. 2); safety and security assistance for foreign ports (Sec. 4-5), incident response and recovery plans (Sec. 7); and other provisions.

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Foreign vs. U.S. LNG Tankers and Crews There are currently no U.S.-flagged LNG tankers and few, if any, U.S. citizens among LNG tanker crews. Some policy makers are concerned that, compared to U.S. vessels and crews, foreign-flagged LNG tankers may not face the same security requirements or may not face the same level of security oversight and verification.121 This rationale underlies the provisions in P.L. 10924 1 that promote LNG shipping to the United States on U.S.-flagged vessels with U.S. crews. Prompted by these provisions, at least four LNG developers have committed to using U.S. crews in their LNG terminal siting proposals.122 Some stakeholders have called for similar measures to promote U.S. flags and crews for tankers serving onshore LNG terminals regulated by FERC. Notwithstanding the LNG tanker provisions in P.L. 109-241, Coast Guard officials have stated that existing security provisions for foreign-flagged LNG tankers and foreign place them on an equal security footing with potential U.S. counterparts.123 Our domestic maritime security regime is closely aligned with the International Ship and Port Facility Security (ISPS) Code.... Under the ISPS Code, vessels in international service, including LNG vessels, must have an International Ship Security Certificate (ISSC). To be issued an ISSC by its flag state, the vessel must develop and implement a threat-scalable security plan that, among other things, establishes access control measures, security measures for cargo handling

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and delivery of ships stores, surveillance and monitoring, security communications, security incident procedures, and training and drill requirements. The plan must also identify a Ship Security Officer who is responsible for ensuring compliance with the ship’s security plan. The Coast Guard rigorously enforces this international requirement by evaluating security compliance as part of our ongoing port state control program.

Others have questioned preferential treatment of U.S. LNG tankers and crews on the grounds that it may impinge on free trade principles by discriminating against foreign LNG tanker operators fully adhering to international standards.124 Given the potential maritime treaty and trade implications, federal efforts to promote U.S. flags and crews on LNG tankers may require careful consideration of potential benefits and costs.

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CONCLUSIONS The U.S. LNG industry is growing quickly. While rising LNG imports may offer economic benefits, they also pose risks. LNG infrastructure is inherently hazardous and it is potentially attractive to terrorists. Both lawmakers and the general public are concerned about these risks, although the LNG industry has a long history of relatively safe operations and has taken steps to secure its assets against terrorist attack. No LNG tanker or land-based facility has been attacked by terrorists, and federal, state and local governments have put in place security measures intended to safeguard LNG against newly perceived terrorist threats. These measures are evolving, but a variety of industry and agency representatives suggest that these federal initiatives are reducing the vulnerability of U.S. LNG to terrorism. The ongoing debate about LNG infrastructure security in the United States has often been contentious. Local officials and community groups have challenged numerous LNG infrastructure proposals on the grounds that they may represent an unacceptable risk to the public. Heightened public scrutiny of LNG facilities has made it difficult to site new LNG terminals near major gas markets and has increased the cost and complexity of LNG terminal siting approval. Nonetheless, both industry and government officials acknowledge that enough new LNG infrastructure will likely be approved to meet long-term U.S. import requirements. Indeed, federal agencies have approved the construction of a number of new U.S. import terminals, several of them onshore. Numerous additional terminal proposals await federal approval. Together with the expansion

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of the existing U.S. import terminals and the construction of new LNG terminals in Canada and Mexico, the approved U.S. facilities would provide enough added capacity to meet the bulk of U.S. LNG demand for the next 20 years. New U.S. LNG terminals may not be ideally located so as to minimize the cost of natural gas, but building them in these locations may be better than not building them at all. Furthermore, because their security has been subject to intense public scrutiny, new LNG terminal and tanker operations may be safer than they might have been without such scrutiny and their siting may be less likely to be challenged at a later time when construction is already underway. The construction and subsequent closure of the Shoreham nuclear power plant in the 1980’s due to new public opposition offers an example of the need to resolve safety and security concerns before capital is invested. From a purely economic perspective, therefore, the added costs of building more heavily protected LNG terminals potentially farther from their primary markets may represent the U.S. public’s willingness to pay for LNG security. Whether this implicit price of LNG security is reasonable is an open question, but the continued interest of private companies to invest billions of dollars in U.S. LNG terminals suggests that it will not prevent needed LNG development. As Congress continues its oversight of LNG infrastructure development, it may decide to examine the public costs and resource requirements of LNG security, especially in light of dramatically increasing LNG imports. In particular, Congress may consider whether future LNG security requirements will be appropriately funded, whether these requirements will be balanced against evolving risks, and whether the LNG industry is carrying its fair share of the security burden. Congress may also act to improve its understanding of LNG security risks. Costly “blanket” investments in LNG security might be avoided if more refined terror threat information were available to focus security spending on a narrower set of infrastructure vulnerabilities. Finally, Congress may initiate action to better understand the security and trade implications of efforts to promote U.S.-flagged LNG tankers. In addition to these specific issues, Congress might consider how the various elements of U.S. LNG security activity fit together in the nation’s overall strategy to protect critical infrastructure. Maintaining high levels of security around LNG tankers, for example, may be of limited benefit if other hazardous marine cargoes are less well-protected. U.S. LNG security also requires coordination among many groups: international treaty organizations, federal agencies, state and local agencies, trade associations and LNG infrastructure operators. Reviewing how these groups work together to achieve common security goals could be an oversight challenge for Congress.

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ENDNOTES

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1

49 C.F.R. 172.101. List of Hazardous Materials. Office of Hazardous Materials Safety, Department of Transportation. 2 See, for example: U.S. Representative Tim Bishop, “Bishop Calls for Congressional Hearing on Coast Guard’s Inability to Protect LNG Tankers,” Press release, March 12, 2008. 3 Natural gas typically consists of at least 80% methane, although LNG is usually over 90% methane. It may also contain other hydrocarbon gases (e.g., propane) and nitrogen. 4 U.S. Dept. of Energy, Office of Fossil Energy. “Natural Gas Import/Export Reports.” Internal database. January 7, 2008. Excludes December 2007 imports. 5 Energy Information Administration (EIA). Natural Gas Year-In-Review 2006. Washington, DC, March 2007. p. 5. 6 Energy Information Administration (EIA). Natural Gas Annual 2005. Tables 1 and 9. November 16, 2006. 7 Energy Information Administration (EIA). “World LNG Imports by Origin, 2002.” Washington, DC. October 2003. 8 Donnelly, M. “LNG as Price Taker.” Public Utilities Fortnightly. November 1, 2006. 9 Greenspan, Alan, Chairman, U.S. Federal Reserve Board. “Natural Gas Supply and Demand Issues.” Testimony before the House Energy and Commerce Comm. June 10, 2003. 10 Energy Information Administration (EIA). Annual Energy Outlook 2008 (Revised Early Release). DOE/EIA-0383(2008). Table A13. March 2008. p. 25. 11 Lloyd’s List. “US Demand for LNG Puts Pressure on Maritime Manpower.” September 11, 2007. p. 10. 12 Department of Energy, Office of Fossil Energy (OFE). “Imports of Liquefied Natural Gas (LNG).” Unpublished data. Washington, D.C. January 11, 2007. 13 Federal Energy Regulatory Commission (FERC). “Order Issuing Certificates and Granting Section 3 Authority.” Issued June 16, 2006. Docket No. CP05130-000, et al. p. 71. 14 “El Paso Corporation Announces Start of Service From Elba II Expansion.” PR Newswire. February 1, 2006; Federal Register, vol. 67, no. 181, September 18, 2002, p. 58784. 15 Marathon Oil Corporation. 2003 Annual Report. Houston. March 8, 2004. p. 11.

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16

“Second Trunkline LNG Terminal Expansion Up and Running.” Inside F.E.R. C. July 31, 2006. p. 12; Federal Register, vol. 67, no. 34, February 20, 2002, p. 7684. 17 “Gas Natural Acquires Enron’ s 50% Stake in 540-MW Gas Plant in Puerto Rico.” Platt’s Global Power Report. McGraw-Hill. July 10, 2003. p. 11. 18 OFE. January 11, 2007. 19 Federal Energy Regulatory Commission. “Order Granting Authorization Under Section 3 of the Natural Gas Act.” Docket No. CP03-75-000. June 18, 2004. p.2. 20 Fowler, T. “Freeport Gets 1st LNG Cargo.” Houston Chronicle. April 16, 2008. 21 Federal Energy Regulatory Commission. “Order Granting Authority under Section 3 of the Natural Gas Act and Issuing Certificates.” Docket No. CP0447-000. Dec. 21, 2004. p.2. 22 Gunter, F. “Cheniere Opens Sabine Pass LNG Terminal.” Houston Business Journal. April 21, 2008. 23 O’Driscoll, M. “LNG: Shell’s Gulf Landing Offshore Project Gets Green Light.” Greenwire. E&E Publishing, LLC. Washington, D.C. Feb 18, 2005. 24 Natural Gas Intelligence. “Energy Bridge Terminal Prepares for First 3 Bcf LNG Delivery This Month.” Intelligence Press, Inc. March 7, 2005. 25 “Boston Offshore LNG Port Nears Clearance to Open.” Reuter’ s. January 9, 2008. 26 Federal Energy Regulatory Commission (FERC), “Proposed North American LNG Import Terminals,” Updated April 21, 2008. [http://www.ferc.gov/industries/lng.asp] 27 Pipeline and Hazardous Materials Safety Administration. “Liquefied Natural Gas (LNG) in the U.S.” Web page. March 2008. [http://primis.phmsa. dot.gov/comm/LNG.htm] 28 Bureau of Mines (BOM). Report on the Investigation of the Fire at the Liquefaction, Storage, and Regasification Plant of the East Ohio Gas Co., Cleveland, Ohio, October 20, 1944. February 1946. 29 Junnola, J., et al. “Fatal Explosion Rocks Algeria’s Skikda LNG Complex.” Oil Daily. January 21, 2004. p. 6. 30 Methane, the main component of LNG, burns in gas-to-air ratios between 5% and 15%. 31 Havens, J. “Ready to Blow?” Bulletin of the Atomic Scientists. July/August 2003. p. 17. 32 Havens. 2003. p. 17.

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Quillen, D. ChevronTexaco Corp. “LNG Safety Myths and Legends.” Presentation to the Natural Gas Technology Conference. Houston, TX. May 14-15, 2002. p. 18. 34 Havens. 2003. p. 17. 35 Havens. 2003. p. 17. 36 Quillen. 2002. p. 28. 37 Society of International Gas Tanker and Terminal Operators Ltd. (SIGTTO).”Worth Repeating.” SIGTTO News. Vol. 17. March 2007. p. 10. 38 SIGGTO 2007; CH-IV International. Safety History of International LNG Operations. TD-02109. Millersville, MD. July, 2004. pp. 13-18. 39 Society of International Gas Tanker & Terminal Operators Ltd. (SIGTTO). “Safe Havens for Disabled Gas Carriers.” Third Edition. London. February 2003. pp. 1-2. 40 Junnola, J., et al. January 21, 2004. p. 6. 41 Hunter, C. “Algerian LNG Plant Explosion Sets Back Industry Development.” World Markets Analysis. January 21, 2004. p. 1. 42 Antosh, N. “Vast Site Devastated.” Houston Chronicle. January 21, 2004. p. B 1. 43 CH-IV International. pp. 6-12. 44 Sandia National Laboratories (SNL). Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water. SAND2004-6258. Albuquerque, NM. December 2004. p. 54. 45 Government Accountability Office (GAO). Maritime Security: Public Safety Consequences of a Terrorist Attack on a Tanker Carrying Liquefied Natural Gas Need Clarification. GAO-07-316. February 2007. p. 22. 46 See, for example Senator Barbara A. Mikulski, testimony before the House Transportation and Infrastructure Committee, Coast Guard and Maritime Transportation Subcommittee field hearing on the Safety and Security of Liquefied Natural Gas and the Impact on Port Operations. Baltimore, MD. April 23, 2007. 47 Consolidated Appropriations Act, 2008 (P.L. 110-161), Division C — Energy and Water Development and Related Agencies Appropriations Act, 2008, Title III, Explanatory Statement, p. 570. 48 Carter, J.A. “Salvage of Cargo from the War-Damaged Gaz Fountain.” Proceedings of the Gastech 85 LNG/LPG Conference. Nice, France. November 12-15, 1985. 49 SNL. December 2004. p. 151. 50 68FR126. July 1, 2003. p. 39244. 51 Ibid., p. 39246.

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McElhenny, J. “Coast Guard Lifts Ban of Natural Gas Tankers in Boston Harbor.” Associated Press. October 16, 2001. 53 Crittenden, J. “Vigilance: Holiday Puts Spotlight on Harbor Security.” Boston Herald. Boston, MA. June 30, 2002. p. 1. 54 “LNG Security in Boston to Be Permanent.” Platt’s Oilgram News. New York, NY. August 1, 2002. 55 “Coast Guard, Mikulski Clear Plan to Reactivate Cove Point LNG Plant.” Platt’s Inside FERC. Washington, DC. January 6, 2003. p. 5. 56 Greenway, H.D.S. “Is it Safe?” The Boston Globe Magazine. July, 27, 2003; Lin, J. and Fifield, A. “Risky Business?” The Philadelphia Enquirer. February 20, 2005. p. 1. 57 O’Malley, Mark, Chief, Ports and Facilities Activities, U.S. Coast Guard. Testimony before the House Committee on Transportation and Infrastructure, Subcommittee on Coast Guard and Maritime Transportation hearing on the Safety and Security of Liquid Natural Gas. May 7, 2007; U.S. Coast Guard, Boston, MA, Captain of the Port. Personal communication. March 22, 2007. 58 U.S. Coast Guard. U.S. Coast Guard Captain of the Port Long Island Sound Waterways Suitability Report for the Proposed Broadwater Liquefied Natural Gas Facility. September 21, 2006. p.2. [http://www.uscg.mil/d1/units/seclis/ broadwater/wsrrpt/WSR%20Master %20Final.pdf] 59 68FR126. July 1, 2003. p. 39241. 60 International Maritime Organization (IMO). “IMO Adopts Comprehensive Maritime Security Measures.” Press release. London. December 17, 2002. 61 Maritime Administration (MARAD). “MARAD Mission, Goals and Vision.” Web page. March 16, 2008. [http://www.marad.dot.gov/welcome/ mission.html] 62 Maritime Administration (MARAD). “MARAD Fact Sheet.” March 16, 2008. p. 2. [http://www.marad.dot.gov/Headlines/factsheets/PDF%20Versions/ Mission%20Fact%2 0Sheet.pdf] 63 National Fire Protection Association (NFPA). Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG). NFPA 59A. Quincy, MA. 2006. 64 Pipeline and Hazardous Materials Safety Administration (PHMSA). “Pipeline Safety: Lessons Learned From a Security Breach at a Liquefied Natural Gas Facility.” Docket No. PHMSA-04-19856. Federal Register. Vol. 71. No. 249. December 28, 2006. p. 78269. 65 Ibid. 66 TSA, Intermodal Security Program Office. Personal communication. August 18, 2003.

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These offices were formerly known as the Pipeline Security Program Office and the Intermodal Security Program Office, respectively. 68 Transportation Security Administration, Pipeline Modal Annex, June 2007, pp. 10-11. [http://www.dhs.gov/xlibrary/assets/Transportation_Pipeline_Modal_ Annex_5_2 1_07.pdf] 69 TSA, Intermodal Security Program Office, personal communication, February 27, 2008. 70 Mike Gillenwater, TSA, “Pipeline Security Overview,” Presentation to the Alabama Public Service Commission Gas Pipeline Safety Seminar, Montgomery, AL, December 11, 2007; TSA, Pipeline Security Division, personal communication, July 6, 2007. 71 TSA, Intermodal Security Program Office, Pipeline Security Best Practices, October 19, 2005, p. 1. 72 TSA, February 27, 2008. 73 U.S. Code of Federal Regulations. 18 C.F.R. 157. 74 Foley, R. Federal Energy Regulatory Commission (FERC), Office of Energy Projects. “Liquefied Natural Gas Imports.” Slide presentation. January 2003. p. 17. 75 Robinson, J.M, Federal Energy Regulatory Commission (FERC). Testimony before the Senate Energy and Natural Resources Committee, Subcommittee on Energy. February 15, 2005. 76 FERC. Personal communication. August 13, 2003. 77 Federal Energy Regulatory Commission (FERC). 2005 Annual Report. Washington, DC. 2006. p. 18. 78 Federal Energy Regulatory Commission (FERC). Federal Energy Regulatory Commission Annual Report FY2006. 2007. p. 23. 79 72 Fed. Reg. 17688. “Chemical Facility Anti-Terrorism Standards.”April 9, 2007; 72 Fed. Reg. 65396. “Appendix to Chemical Facility Anti-Terrorism Standards.” November 20, 2007. 80 Federal Energy Regulatory Commission (FERC). “Interagency Agreement Among the Federal Energy Regulatory Commission United States Coast Guard and Research and Special Programs Administration for the Safety and Security Review of Waterfront Import/Export Liquefied Natural Gas Facilities.” February 11, 2004. p. 1. 81 FERC. February 11, 2004. pp. 2-4. 82 Federal Energy Regulatory Commission (FERC). 2006 Annual Report. Washington, DC. 2007. p. 25.

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Robinson, J.M., Federal Energy Regulatory Commission (FERC). Testimony before the Senate Energy and Natural Resources Committee, Subcommittee on Energy. February 15, 2005. 84 American Gas Association (AGA) Natural Gas Distribution Industry Critical Infrastructure Security, 2002, and AGA, Natural Gas Infrastructure Security — Frequently Asked Questions. April 30, 2003. 85 Haener, W.J., CMS Energy Corp. Testimony on behalf of the Interstate Natural Gas Association of America (INGAA) before the House Transportation and Infrastructure Subcommittee on Highways and Transit. February 13, 2002. p. 4. 86 Interstate Natural Gas Association of America (INGAA) et al., Security Guidelines Natural Gas Industry Transmission and Distribution. Washington, DC. September 6, 2002. 87 Haener. February 13, 2002. p. 4. 88 U.S. Coast Guard, Program Office. Personal communication. August 12, 2003. This estimate is based on boat, staff and administrative costs for an assumed 20-hour mission. 89 Cdr. Mark Meservey, House Liaison, U.S. Coast Guard. “Sector Boston LNG Security Approximate Costs.” Unpublished memorandum. May 4, 2007. 90 McElhenny, J. “State Says LNG Tanker Security Cost $20,500.” Associated Press. November 2, 2001. p. 1. 91 Note that security costs associated with any LNG terminals in Canada, Mexico and the Bahamas (built primarily to serve U.S. markets) would not be a direct U.S. responsibility, although such costs might still be priced into LNG supplied from those terminals. 92 “Liquified Natural Gas Markets in U.S. Emerge in Uncertain Times, Panelists Agree.” Foster Natural Gas Report. April 11, 2008. p. 5. 93 See, for example, Representative Peter Defazio, remarks before the House Homeland Security Committee hearing on Securing Liquid Natural Gas Tankers to Protect the Homeland. March 21, 2007. 94 Department of Homeland Security (DHS). Budget-in-Brief, Fiscal Year 2006. 95 Government Accountability Office. Maritime Security: Federal Efforts Needed to Address Challenges in Responding to Terrorist Attacks on Energy Commodity Tankers. GAO-08-141. December 10, 2007. p. 79. 96 Admiral Thad Allen, Commandant, U.S. Coast Guard. Testimony before the House Committee on Appropriations, Subcommittee on Homeland Security hearing, “Coast Guard Budget: Impact on Maritime Safety, Security, and Environmental Protection.” March 5, 2008.

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Admiral Thad Allen, March 5, 2008; Federal Energy Regulatory Commission. “Order Granting Authority Under Section 3 of the Natural Gas Act and Issuing Certificates.” Docket No. CP06-54-0000. March 20, 2008. 98 Baldor, L.C. “Federal Agency, R.I. Officials Meet over LNG Terminal.” Associated Press. March 17, 2005. 99 Federal Energy Regulatory Commission (FERC). “Response to Senator Jack Reed’s 2/1/05 letter regarding the proposed Weaver’s Cove LNG Project in Fall River, MA & the proposed KeySpan LNG Facility Upgrade Project in Providence, RI under CP04-293 et al.” March 3, 2005. p. 2. 100 Joshi, R. “Allen Slams USCG Funding Bill.” Lloyd’s List. May 1, 2008. 101 Thad Allen, Commandant, U.S. Coast Guard. Testimony before the House Appropriations Committee, Homeland Security Subcommittee hearing on the Coast Guard Budget: Impact on Maritime Safety, Security, and Environmental Protection. March 5, 2008. 102 Joshi, R. 2008. 103 “Bush Warns on LNG Safety Bill.” International Oil Daily, April 29, 2008. 104 For specific examples, see CRS Report RL3 1990, Pipeline Security: An Overview of Federal Activities and Current Policy Issues, by Paul Parfomak. 105 “Ships as Terrorist Targets.” American Shipper. November, 2002. p. 59. 106 Hedges, M. “Terrorists Possibly Targeting Texas.” Houston Chronicle. June 24, 2003. 107 Homeland Security Council. Planning Scenarios: Executive Summaries. July 2004. p. 6-1. 108 Office of Congressman Edward J. Markey. Personal communication with staff. January 5, 2004. 109 Turner, P.J., Assistant Secretary for Legislative Affairs, Department of Homeland Security (DHS). Letter to U.S. Representative Edward Markey. April 15, 2004. p. 1. 110 Sandia National Laboratories (SNL). Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water. SAND2004-6258. Albuquerque, NM. December 2004. pp. 49-50. 111 SNL. December 2004. pp. 6 1-62. 112 Clarke, R.A., et al. LNG Facilities in Urban Areas. Good Harbor Consulting, LLC. Prepared for the Rhode Island Office of Attorney General. GHC-RI0505A. May 2005. 113 McLaughlin, J. “LNG is Nowhere Near as Dangerous as People Are Making it Out to Be.” Lloyd’s List. February 8, 2005. p5. 114 Behr, Peter. “Higher Gas Price Sets Stage for LNG.” Washington Post. July 5, 2003. p. D10.

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Federal Energy Regulatory Commission (FERC). Vista del Sol LNG Terminal Project, Draft Environmental Impact Statement. FERC/EIS-0176D. December 2004. p. 4-162; For example, based on data from the U.S. Office of Hazardous Materials Safety, 600 LNG tanker shipments would account for less than 1% of total annual U.S. shipments of hazardous marine cargo such as ammonia, crude oil, liquefied petroleum gases, and other volatile chemicals. 116 FERC. FERC/EIS-0176D. December 2004. p4-162. Notwithstanding this assertion, in its subsequent draft review of the Long Beach LNG terminal proposal, the FERC states that “the historical probability of a successful terrorist event would be less than seven chances in a million per year...” See FERC. October 7, 2005. p. ES-14. 117 Woolsey, James. Remarks before the National Commission on Energy, LNG Forum, Washington, D.C., June 21, 2006. 118 Grant, Richard, President, Distrigas. Testimony before the Senate Committee on Energy and Natural Resources, Subcommittee on Energy hearing on “The Future of Liquefied Natural Gas: Siting and Safety.” February 15, 2005. 119 U.S. Coast Guard. U.S. Coast Guard Captain of the Port Long Island Sound Waterways Suitability Report for the Proposed Broadwater Liquefied Natural Gas Facility. September 21, 2006. p. 146. 120 Ibid. 121 See, for example: Senator Barbara A. Mikulski. Testimony before the House of Transportation and Infrastructure Committee, Coast Guard and Maritime Transportation Subcommittee field hearing on Safety and Security of Liquefied Natural Gas and the Impact on Port Operations. Baltimore, MD. April 23, 2007. 122 States News Service. “Agreement Means New Jobs for U.S. Mariners on LNG Tankers.” February 8, 2008. 123 O’Malley. May 7, 2007. 124 “LNG Must Uphold US Free Trade, Warns ICS.” Lloyd’s List. February 21, 2007. p. 3.

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Chapter 4

MARITIME SECURITY: OPPORTUNITIES EXIST TO FURTHER CLARIFY THE CONSEQUENCES OF A LIQUEFIED NATURAL GAS TANKER SPILL* Mark Gaffigan Copyright © 2009. Nova Science Publishers, Incorporated. All rights reserved.

Natural Resources and Environment

ABSTRACT The six studies we reviewed all examined the heat impact of an LNG fire but produced varying results; some studies also examined other potential hazards of a large LNG spill and reached consistent conclusions on explosions. Specifically, the studies’ conclusions about the distance at which 30 seconds of exposure to the heat could burn people—also termed the heat impact distance—ranged from less than 1/3 of a mile to about 1- 1/4 miles. These variations occurred because, with no data on large spills from actual events, researchers had to make numerous modeling assumptions to scale up the existing experimental data for large LNG spills. These assumptions involved the size of the hole in the tanker, the number of tanks that fail, the volume of LNG spilled, key LNG fire properties, and environmental conditions, such as wind and waves. Three of the studies also examined other *

Excerpted from GAO report No. GAO-07-840T, dated May 7, 2007

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Mark Gaffigan potential hazards of an LNG spill, including LNG vapor explosions, asphyxiation, and the sequential failure of multiple tanks on the LNG vessel (cascading failure). All three studies considered LNG vapor explosions unlikely unless the vapors were in a confined space. Only the Sandia study examined asphyxiation and concluded that asphyxiation did not pose a hazard to the general public. Finally, only the Sandia study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks on a typical LNG vessel would be involved in such an event and that this number of tanks would increase the duration of the LNG fire. Our panel of 19 experts generally agreed on the public safety impact of an LNG spill, disagreed on specific conclusions of the Sandia study, and suggested future research priorities. Experts agreed on three main points: (1) the most likely public safety impact of an LNG spill is the heat impact of a fire; (2) explosions are not likely to occur in the wake of an LNG spill unless the LNG vapors are in confined spaces; and (3) some hazards, such as freeze burns and asphyxiation, do not pose a hazard to the public. However, the experts disagreed with a few conclusions reached by the Sandia study that the Coast Guard uses to assess the suitability of waterways for LNG tankers going to proposed LNG terminals. Specifically, all experts did not agree with the study’s 1-mile estimate of heat impact distance resulting from an LNG fire: 7 of 15 thought Sandia’s distance was “about right,” 8 were evenly split on whether the distance was “too conservative” or “not conservative enough,” and 4 did not answer this question. Experts also did not agree with the Sandia National Laboratories’ conclusion that only three of the five LNG tanks on a tanker would be involved in a cascading failure. Finally, experts suggested priorities to guide future research aimed at clarifying uncertainties about heat impact distances and cascading failure, including large-scale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques. DOE’s recently funded study involving large-scale LNG fire experiments addresses some, but not all, of the research priorities the expert panel identified.

BACKGROUND As scientists and the public have noted, an LNG spill could pose potential hazards. When LNG is spilled from a tanker, it forms a pool of liquid on the water. As the liquid warms and changes into natural gas, it forms a visible, foglike vapor cloud close to the water. The cloud mixes with ambient air as it continues to

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warm up, and eventually the natural gas disperses into the atmosphere. Under certain atmospheric conditions, however, this cloud could drift into populated areas before completely dispersing. Because an LNG vapor cloud displaces the oxygen in the air, it could potentially asphyxiate people who come into contact with it. Furthermore, like all natural gas, LNG vapors can be flammable, depending on conditions. If the LNG vapor cloud ignites, the resulting fire will burn back through the vapor cloud toward the initial spill. It will continue to burn above the LNG that has pooled on the surface—this is known as a pool fire. Small-scale experiments to date have shown that LNG fires burn hotter than oil fires of the same size. Both the cold temperatures of spilled LNG and the high temperatures of an LNG fire have the potential to significantly damage the tanker, causing a cascading failure. Such a failure could increase the severity of the incident. Finally, concerns have been raised about whether an explosion could result from an LNG spill. The Federal Energy Regulatory Commission is responsible for approving applications for onshore LNG terminal sitings, and the U.S. Coast Guard is responsible for approving applications for offshore sitings. In addition, the Coast Guard reviews an applicant’s Waterway Suitability Assessment, reaches a preliminary conclusion on whether the waterway is suitable for LNG imports, and identifies appropriate strategies that reduce the risk posed by the movement of an LNG tanker.

Studies Identified Different Distances for the Heat Effects of an LNG Fire, but Agreed on other LNG Hazards The six studies we examined identified various distances at which the heat effects of an LNG fire could be hazardous to people. The studies’ results about the distance at which 30 seconds of exposure to the heat could burn people ranged from less than 1/3 of a mile (about 500 meters) to about 1-1/4 miles (more than 2,000 meters). The studies’ variations in heat effects occurred because (1) different assumptions were made in the studies’ models about key parameters of LNG spills and (2) the studies were designed and conducted for different purposes. Since no large-scale data are available for LNG spills, researchers made numerous modeling assumptions to scale up the existing experimental data for large spills. Key assumptions made included hole size and cascading failure, waves and wind, the volume of LNG spilled, and the amount of heat radiated from the fire. For example, studies made assumptions for the size of the hole in the LNG tanker that

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Mark Gaffigan

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varied from less than 1 square meter up to 20 square meters. Additionally, the studies were conducted for different purposes. Two studies were academic analyses of the differences between LNG and oil spills; three specifically addressed spills caused by terrorist attacks, which was a concern in the wake of the September 11 attacks; and the final study developed appropriate methods for regulators to use to estimate heat hazards from LNG fires. Results of these studies can be found in our report. Some studies also examined other potential hazards, such as explosions, asphyxiation, and cascading failure, and identified their potential impacts on public safety. Three studies examined the potential for LNG vapor explosions, and all agreed that it is unlikely that LNG vapors could explode if the vapors are in an unconfined space. Only one study examined the potential for asphyxiation following an LNG spill if the vapors displace the oxygen in the air. It concluded that fire hazards would be the greatest problem in most locations, but that asphyxiation could threaten the ship’s crew, pilot boat crews, and emergency response personnel. Finally, only the Sandia study examined the potential for cascading failure of LNG tanks and concluded that only three of the five tanks would be involved in such an event and that this number of tanks would increase the duration of the LNG fire.

Experts Generally Agreed that the most Likely Public Safety Impact of an LNG Spill Is the Heat Effect of a Fire, but that Further Study Is Needed to Clarify the Extent of this Effect The 19 experts on our panel generally agreed on the public safety impact of an LNG spill, disagreed with specific conclusions of the Sandia study, and suggested future research priorities.1 Specifically: •

•

1

Experts agreed that the main hazard to the public from a pool fire is the heat from the fire, but emphasized that the exact hazard distance depends on site-specific weather conditions; composition of the LNG (relative percentages of methane, propane, and butane); and the size of the fire. Eighteen of 19 experts agreed that the ignition of a vapor cloud over a populated area could burn people and property in the immediate vicinity

We considered experts to be “in agreement” if more than 75 percent of them indicated that they completely agreed or generally agreed with a given statement. Not all experts commented on every issue discussed.

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of the fire. Three experts emphasized in their comments that the vapor cloud is unlikely to penetrate very far into a populated area before igniting. With regard to explosions, experts distinguished between explosions in confined spaces and in unconfined spaces. For confined spaces, such as under a dock or between the hulls of a ship, they agreed that it is possible, under controlled experimental conditions, to induce explosions of LNG vapors; however, a detonation—the more serious type of vapor cloud explosion—of confined LNG vapors is unlikely following an LNG spill caused by a terrorist attack. For unconfined spaces, experts were split on whether it is possible to induce such explosions under controlled experimental conditions; however, even experts who thought such explosions were possible agreed that vapor cloud explosions in unconfined spaces are unlikely to occur following an LNG spill caused by a terrorist attack.

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Our panel of 19 experts disagreed with a few of the Sandia study’s conclusions and agreed with the study authors’ perspective on risk-based approaches to dealing with the hazards of potential LNG spills. For example: •

•

•

Seven of 15 experts thought Sandia’s heat hazard distance was “about right,” and the remaining 8 experts were evenly split as to whether the distance was “too conservative” (i.e., larger than needed to protect the public) or “not conservative enough” (i.e., too small to protect the public). Officials at Sandia National Laboratories and our panel of experts cautioned that the hazard distances presented cannot be applied to all sites because of the importance of site-specific factors. Additionally, two experts explained that there is no “bright line” for hazards—that is, 1,599 meters is not necessarily “dangerous,” and 1,601 meters is not necessarily “safe.” Nine of 15 experts agreed with Sandia’s conclusion that only three of the five LNG tanks on a tanker would be involved in cascading failure. Five experts noted that the Sandia study did not explain how it concluded that only three tanks would be involved in cascading failure. Finally, experts agreed with Sandia’s conclusion that consequence studies should be used to support comprehensive, risk-based management and planning approaches for identifying, preventing, and mitigating hazards from potential LNG spills.

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The experts also suggested priorities for future research—some of which are not fully addressed in DOE’s ongoing LNG research—to clarify uncertainties about heat impact distances and cascading failure. These priorities include largescale fire experiments, large-scale LNG spill experiments on water, the potential for cascading failure of multiple LNG tanks, and improved modeling techniques. As part of DOE’s ongoing research, Sandia plans to conduct large-scale LNG pool fire tests, beginning with a pool size of 35 meters—the same size as the largest test conducted to date. Sandia will validate the existing 35-meter data and then conduct similar tests for pool sizes up to 100 meters. Of the top 10 LNG research priorities the experts identified, only 3 have been funded in the DOE study, and the second highest ranked priority, cascading failure, was not funded. One expert noted that although the consequences of cascading failure could be serious, because the extreme cold of spilled LNG and the high heat of an LNG fire could damage the tanker, there are virtually no data looking at how a tanker would be affected by these temperatures.

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CONCLUSIONS It is likely that the United States will increasingly depend on LNG to meet its demand for natural gas. Consequently, understanding and resolving the uncertainties surrounding LNG spills is critical, especially in deciding where to locate LNG facilities. While there is general agreement on the types of effects of an LNG spill, the study results have created what appears to be conflicting assessments of the specific heat consequences of such a spill. These assessments create uncertainty for regulators and the public. Additional research to resolve some key areas of uncertainty could benefit federal agencies responsible for making informed decisions when approving LNG terminals and protecting existing terminals and tankers, as well as providing reliable information to citizens concerned about public safety. To provide the most comprehensive and accurate information for assessing the public safety risks posed by tankers transiting to proposed LNG facilities, we recommended that the Secretary of Energy ensure that DOE incorporates the key issues the expert panel identified, particularly the potential for cascading failure, into its current LNG study. DOE concurred with our recommendation.

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Mr. Chairman, this concludes my prepared statement. I would be happy to respond to any questions that you or Members of the Committee may have.

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INDEX

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A absorption, 34 academic, 45, 88 access, 27, 66, 74 accidental, 1, 59, 73 accidents, 7, 60 accounting, 52 accuracy, 27 administrative, 82 air, 6, 10, 19, 20, 29, 30, 31, 32, 33, 35, 41, 44, 46, 58, 59, 61, 78, 86, 88 AL, 81 Al Qaeda, 72 Alabama, 81 Alaska, 41, 55 Algeria, 12, 52, 60 aluminum, 12 ambient air, 6, 29, 30, 44, 86 ambient air temperature, 30 ammonia, 84 analysts, 53, 60, 70 appendix, 8, 25, 26 application, 41, 65 Arkansas, 28 assessment, 6, 26, 67, 69 assets, 63, 64, 67, 73, 75, 81 assumptions, vii, viii, x, 1, 8, 12, 13, 14, 16, 17, 21, 24, 43, 45, 61, 85, 87

Atlantic, 55 atmosphere, 6, 30, 44, 87 atmospheric pressure, 4, 10 attacks, vii, ix, 6, 7, 16, 17, 46, 50, 60, 61, 62, 63, 69, 72, 73, 74, 88 Attorney General, 83 auditing, 8, 27 Australia, 52 authority, ix, 41, 50, 62, 63, 64, 65, 66, 67, 68 availability, 27 awareness, 67, 69

B ballast, 40 barrier, 53 barriers, 66 beaches, 19 behavior, 23, 24, 40 benefits, 75 benign, 61 Best Practice, 81 bias, 27 boats, 64 boiling, 3, 11 boils, 28, 29, 32 bomb, 72, 73 Boston, 2, 15, 16, 41, 55, 57, 63, 64, 70, 73, 78, 80, 82

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Index

breaches, 66 burn, vii, viii, x, 1, 7, 8, 10, 13, 19, 20, 33, 43, 45, 46, 58, 85, 87, 88 burning, 11, 16, 32, 33, 58 burns, viii, xi, 6, 9, 10, 16, 20, 21, 29, 32, 33, 44, 78, 86 butane, 10, 20, 28, 29, 46, 61, 88

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C Canada, 2, 4, 6, 76, 82 capacity, 6, 54, 57, 70, 76 cargo, 2, 3, 7, 12, 38, 54, 55, 60, 61, 71, 72, 74, 84 carrier, 18, 19, 34 CFD, 41 channels, 63 chemicals, 68, 84 citizens, 24, 48, 74, 90 citizenship, 65 closure, 76 clouds, 37, 58, 59 Co, 68, 78 Coast Guard, viii, ix, x, xi, 6, 7, 9, 12, 26, 41, 44, 45, 50, 51, 56, 62, 63, 64, 65, 68, 69, 70, 71, 72, 74, 75, 77, 79, 80, 81, 82, 83, 84, 86, 87 collisions, 7, 59 combustion, 11, 34, 35 combustion processes, 35 Committee on Appropriations, 82 Committee on Homeland Security, 4 communication, ix, 50, 68, 80, 81, 82, 83 communities, 51 community, 56, 67, 74, 75 complexity, 75 compliance, 66, 71, 75 components, 20 composition, 20, 32, 33, 46, 88 computational fluid dynamics, 40 concentration, 10, 41, 58 confidence, 62 confinement, 18 conformity, 27 confusion, 68

Congress, iv, v, vii, ix, x, 49, 50, 51, 62, 65, 70, 71, 72, 76 consensus, 27, 58 Consolidated Appropriations Act, 79 construction, 12, 41, 56, 60, 61, 75, 76 consulting, 8, 26 consumers, 5 consumption, 52, 54 control, 60, 74 cooking, 4, 52 costs, 51, 53, 70, 71, 75, 76, 82 cost-sharing, x, 50, 71 critical assets, 67 critical infrastructure, 76 cross-border, 67 CRS, 49, 52, 83 crude oil, 59, 84 cryogenic, 28, 29, 38, 61 CSR, 67 cutters, 64

D database, 53, 77 decisions, 7, 24, 48, 90 delivery, 70, 75 demand, 4, 5, 6, 24, 48, 51, 52, 53, 57, 76, 90 Department of Energy, 3, 5, 26, 28, 62, 69, 77 Department of Energy (DOE), 3, 69 Department of Homeland Security, 62, 68, 69, 71, 73, 82, 83 Department of Transportation, 3, 26, 41, 62, 65, 69, 77 desire, 73 detection, 59 detonation, 11, 20, 41, 47, 89 direct cost, 70 dispersion, 26, 30, 40 distress, 59 distribution, 25, 54, 57 domestic markets, 54 dominance, 27 dosage, 31

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Index DOT, 3 draft, 3, 25, 84 drug interdiction, 71 duplication, 68 duration, viii, x, 2, 9, 13, 16, 17, 19, 31, 34, 38, 44, 46, 70, 86, 88 duties, 63

exports, 52 exposure, vii, viii, x, 1, 8, 10, 13, 16, 23, 25, 31, 38, 43, 45, 85, 87 extreme cold, 23, 25, 48, 90 Exxon, 59 Exxon Valdez, 59

F

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E economic growth, 53 economics, 50 ecosystem, 56 Egypt, 12, 52 electric power, 55 electricity, 4, 53, 60 emergency response, 19, 46, 66, 67, 88 employees, 67 energy, 4, 5, 10, 18, 39, 42, 50, 52, 53, 67, 72, 73 Energy and Commerce Committee, 53 Energy and Water Development, 79 Energy Information Administration (EIA), 5, 53, 54, 77 Energy Policy Act, 71 Energy Policy Act of 2005, 71 energy supply, 67 environment, 72, 74 environmental conditions, vii, viii, x, 2, 8, 37, 43, 85 Equatorial Guinea, 52 estimating, 17, 73 ethane, 28, 29 evaporation, 40, 41 exclusion, 67 exercise, 65 expenditures, 67, 71 experimental condition, 20, 35, 36, 47, 89 expert, iv, ix, xi, 2, 3, 8, 9, 19, 21, 22, 23, 24, 25, 27, 28, 31, 42, 44, 48, 69, 86, 90 expertise, 26, 31, 32, 33, 34, 36, 38, 39, 40 explosions, vii, viii, x, xi, 2, 8, 9, 11, 12, 18, 20, 29, 42, 43, 44, 46, 47, 59, 85, 86, 88, 89 explosives, 18, 60, 63, 73

failure, viii, ix, x, xi, 2, 7, 9, 13, 14, 16, 17, 19, 21, 22, 23, 25, 38, 40, 43, 44, 45, 46, 47, 48, 59, 61, 86, 87, 88, 89, 90 fatalities, 60 fears, 58 February, 1, 4, 67, 77, 78, 79, 80, 81, 82, 83, 84 Federal Aviation Administration, 64 Federal Energy Regulatory Commission, ix, 3, 6, 26, 45, 50, 55, 56, 67, 73, 77, 78, 81, 82, 83, 84, 87 Federal Register, 66, 77, 78, 80 Federal Reserve, 53, 77 Federal Reserve Board, 77 feet, 11, 53 FERC, ix, 3, 5, 6, 15, 17, 41, 50, 55, 56, 62, 64, 67, 68, 69, 71, 73, 74, 77, 78, 80, 81, 82, 83, 84 financing, 57 fire, vii, viii, x, xi, 1, 2, 3, 7, 8, 9, 10, 11, 12, 13, 14, 16, 17, 18, 19, 20, 21, 22, 23, 24, 26, 29, 31, 32, 33, 38, 40, 41, 43, 44, 45, 46, 48, 58, 59, 60, 61, 62, 64, 70, 85, 86, 87, 88, 89, 90 fire hazard, 19, 29, 46, 59, 88 fires, 7, 10, 13, 16, 17, 19, 20, 21, 23, 24, 33, 34, 41, 45, 46, 58, 59, 87, 88 fishing, 72 flame, 10, 13, 23, 34, 40 flammability, 10, 31, 33 flammability limit, 10 flexibility, 72 fluid, 40 focusing, 7 fracture, 38 France, 53, 79

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Index

free trade, 75 freezing, 59 fuel, vii, ix, 4, 10, 35, 39, 41, 49, 59, 60 full capacity, 70 funding, 71 futures, 54

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G gas, vii, ix, 2, 3, 4, 5, 6, 10, 11, 24, 29, 34, 39, 44, 48, 49, 50, 51, 52, 53, 54, 55, 57, 58, 59, 61, 62, 66, 67, 69, 70, 72, 75, 76, 77, 78, 86, 90 gases, 77, 84 gasoline, 33, 58 generation, 52, 53, 55 Georgia, 41, 55 goals, 76 government, 8, 26, 27, 51, 62, 65, 69, 71, 72, 75 Government Accountability Office, 61, 79, 82 Government Accountability Office (GAO), 61, 79 grants, 65, 68 grids, 60 grounding, 59 groups, 75, 76 growth, 51, 53 guidance, 17, 22, 67, 73 guidelines, 65, 69 Gulf Coast, 6 Gulf of Mexico, 5, 55, 57

H handling, x, 50, 51, 54, 63, 74 hazards, vii, viii, x, xi, 1, 6, 7, 8, 9, 12, 18, 19, 20, 22, 26, 27, 29, 38, 43, 44, 46, 47, 57, 58, 59, 61, 72, 85, 86, 88, 89 hearing, 79, 80, 82, 83, 84 heat, vii, viii, x, xi, 1, 2, 7, 8, 9, 10, 12, 13, 14, 16, 17, 19, 20, 21, 22, 23, 24, 25,

31, 32, 34, 41, 43, 44, 45, 46, 47, 59, 85, 86, 87, 88, 89, 90 heating, 4, 52, 60 high risk, 68 high temperature, 7, 10, 45, 87 homeland security, 72 Homeland Security, 62, 68, 69, 71, 72, 73, 82, 83 House, x, 4, 50, 51, 53, 72, 77, 79, 80, 82, 83, 84 House Appropriations Committee, 83 humidity, 20, 32 hydro, 10, 11, 28, 29 hydrocarbon, 77 hydrocarbons, 10, 11, 28, 29

I identification, 64 implementation, 66 importer, 54 imports, ix, 2, 4, 5, 11, 45, 49, 51, 52, 53, 54, 70, 75, 76, 77, 87 Incidents, 15 indigenous, 6 Indonesia, 52 industry, ix, x, 8, 26, 49, 50, 51, 53, 59, 62, 65, 69, 75, 76 infrastructure, vii, ix, x, 16, 49, 50, 51, 54, 58, 62, 63, 65, 67, 69, 72, 73, 74, 75, 76 injuries, 19, 60 injury, iv inspection, ix, 50, 64, 67, 68 Inspection, 64 inspections, 65, 67, 68 instruments, 59 insulation, 38 intelligence, 17, 71, 72 interaction, 23 international standards, x, 50, 74, 75 international trade, 65 Internet, 53 interstate, 57, 66, 67 interviews, 22, 26 Iran, 11, 61

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Index Iraq, 61 Iraq War, 61 island, 55 iteration, 22, 27, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39

J January, 8, 27, 58, 60, 77, 78, 79, 80, 81, 83 Japan, 11, 41, 52, 55 judgment, 74 jurisdiction, 41, 64, 67, 68

60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 82, 83, 84, 85, 86, 87, 88, 89, 90 local authorities, 62, 70 local community, 67 local government, 51, 71, 72, 75 location, 22 London, 79, 80 long-term, 75 Louisiana, 5, 41, 55, 57 LPG, 3, 61, 79 lying, 10

M K King, 4

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L labor, 65 land, vii, ix, 49, 51, 56, 60, 62, 64, 66, 67, 72, 75 large-scale, ix, xi, 2, 7, 9, 19, 23, 24, 44, 45, 48, 61, 62, 86, 87, 90 law, 51, 63, 67, 69 law enforcement, 63, 67, 69 lead, ix, 6, 16, 24, 50, 61, 62, 63, 66, 68 leakage, 54 legislative, 52 legislative proposals, 52 Libya, 52 likelihood, vii, ix, 18, 20, 36, 40, 50, 58, 72 liquefaction, 10, 54, 57 liquefied natural gas, 2, 3, 4, 26, 52, 69 liquids, 72 LNG, v, vii, viii, ix, x, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59,

magnetic, iv maintenance, 60 Malaysia, 12, 52 management, 22, 38, 47, 89 MARAD, 56, 65, 80 maritime, 12, 51, 62, 63, 64, 65, 68, 71, 74, 75 Maritime Administration, 41, 56, 62, 63, 65, 80 Maritime Transportation Security Act, ix, 50, 63, 68 market, 54, 57 markets, 11, 50, 67, 75, 76, 82 Maryland, 28, 41, 55, 60 Massachusetts, 28, 41, 55, 57, 70 Massachusetts Institute of Technology, 28 measures, vii, ix, 49, 64, 66, 67, 74, 75 median, 23, 41 methane, 4, 10, 11, 20, 28, 29, 33, 46, 77, 88 Mexico, 76, 82 military, 60 Millennium, 73 missiles, 61 missions, 71 MIT, 26 modeling, vii, viii, ix, x, xi, 1, 8, 9, 13, 16, 18, 19, 23, 24, 26, 40, 41, 43, 44, 45, 48, 61, 62, 85, 86, 87, 90 models, 7, 12, 24, 45, 62, 87

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Index

moisture, 20, 32 movement, 16, 45, 87

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N nation, 65 national, ix, 49, 51, 71, 72, 73 National Oceanic and Atmospheric Administration, 26, 28 nationality, 65 natural, vii, ix, 2, 3, 4, 5, 6, 10, 11, 24, 26, 29, 39, 44, 48, 49, 50, 52, 53, 54, 57, 58, 67, 69, 72, 76, 86, 90 natural gas, vii, ix, 2, 3, 4, 5, 6, 10, 11, 24, 26, 29, 39, 44, 48, 49, 50, 52, 53, 54, 57, 58, 67, 69, 72, 76, 86, 90 Navy, 64 network, 57, 66 New England, 55, 60 New York, iii, iv, 80 Nigeria, 12, 52 nitrogen, 77 nontoxic, 4, 28, 29 normal, 59 North America, 56, 57, 78 Northeast, 6, 57 nuclear, 76 nuclear power, 76 nuclear power plant, 76

O oat, 72 obligations, 67 Offices of Congressional Relations and Public Affairs, 25 offshore, 5, 6, 41, 45, 56, 57, 63, 64, 65, 69, 87 Ohio, 78 oil, 7, 10, 17, 33, 39, 45, 58, 59, 72, 84, 87, 88 oil spill, 17, 45, 59, 88 Oman, 12, 52 on-line, 68

operator, 67, 72 Operators, 62, 79 opposition, 56, 76 organizations, 8, 76 oversight, ix, x, 50, 62, 66, 74, 76 overtime, 70 oxygen, 7, 10, 16, 19, 30, 41, 45, 46, 87, 88

P parameter, 13 password, 27 peak demand, 57 perceptions, 51 performance, 68 personal, 81 personal communication, 81 petrochemical, 60 petroleum, 3, 39, 84 phase transitions, 11, 40 Philadelphia, 80 Pipeline and Hazardous Materials Safety Administration, 57, 65, 78, 80 pipelines, 4, 6, 41, 53, 54, 56, 67, 68, 69, 72 planning, 22, 38, 47, 67, 89 plants, vii, ix, 49, 50, 57, 60, 62, 66, 67, 68 police, 62, 63, 64, 70 policy makers, 51, 62, 71, 74 policymakers, 70 pools, 13, 20, 33 poor, 60 population, 73 ports, vii, ix, 4, 5, 6, 49, 64, 68, 74 power, 10, 14, 16, 20, 21, 23, 52, 55, 60, 66, 76 power plant, 60 preferential treatment, 75 preparedness, 72 President Bush, x, 50, 65, 72 pressure, 4, 10, 11, 18, 27, 35, 37, 42 prices, 6, 51, 52, 53, 54 priorities, viii, x, 2, 9, 19, 23, 24, 39, 44, 46, 47, 86, 88, 90

Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,

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Index

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private, 26, 71, 72, 76 probability, 6, 73, 74, 84 producers, 55 production, 4, 16, 52, 53 program, 65, 67, 75 promote, x, 50, 65, 74, 75, 76 propane, 10, 20, 28, 29, 46, 77, 88 property, iv, 19, 34, 38, 46, 58, 69, 88 protection, x, 50, 51, 63, 70, 74 protocol, 27 PSD, 66 PT, 11, 18, 34 public, viii, ix, x, 2, 6, 7, 8, 9, 13, 17, 19, 20, 21, 22, 24, 25, 26, 27, 29, 30, 31, 32, 33, 34, 37, 38, 39, 41, 44, 46, 47, 48, 49, 50, 51, 58, 62, 67, 69, 70, 71, 73, 74, 75, 76, 86, 88, 89, 90 public safety, viii, x, 2, 6, 7, 9, 13, 17, 19, 22, 24, 25, 26, 27, 37, 38, 39, 44, 46, 48, 86, 88, 90 public sector, 71 public service, 71 Puerto Rico, 55, 78

Q Qatar, 11, 52 questioning, 71 questionnaire, 27

R radar, 59 radiation, 31, 32, 33, 40, 58 radius, 15 range, 10, 11, 17, 30, 31, 33, 37, 51, 65 recovery, x, 50, 67, 71, 74 reduction, 6 regional, 54, 60, 67 regulation, vii, ix, 49, 51 regulations, 8, 12, 63, 66, 68 regulators, 24, 46, 48, 57, 62, 88, 90 Regulatory Commission, 55, 81 relationship, 13, 23

reliability, 67 research, viii, x, 2, 8, 9, 19, 23, 24, 26, 36, 39, 40, 42, 44, 46, 47, 48, 58, 62, 73, 86, 88, 90 researchers, vii, viii, x, 1, 8, 24, 43, 45, 85, 87 reserves, 4, 11 resolution, ix, 50, 68 resource allocation, 71 resources, x, 50, 51, 70, 71, 72 responsibilities, 63 Rhode Island, 83 risk, 6, 7, 17, 22, 38, 39, 41, 45, 47, 51, 64, 65, 66, 68, 75, 87, 89 risk assessment, 6, 7, 51 risks, vii, ix, x, 25, 48, 49, 50, 51, 54, 56, 60, 72, 73, 75, 76, 90 robustness, 61 Russia, 11

S safeguard, 67, 70, 75 safety, vii, viii, ix, xi, 2, 6, 7, 9, 12, 24, 26, 44, 49, 51, 57, 59, 60, 62, 63, 66, 67, 68, 70, 71, 74, 76, 86 scalable, 74 scientists, 18, 44, 86 scores, 23 search, 18, 71 seawater, 56 security, vii, ix, x, 6, 7, 12, 49, 50, 51, 54, 56, 60, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 82 selecting, 8 semicircle, 15 Senate, 51, 72, 81, 82, 84 September 11, vii, ix, 7, 16, 46, 49, 51, 62, 63, 67, 69, 70, 72, 77, 88 services, iv, 71 severity, 7, 45, 58, 87 shares, 65 sharing, x, 50, 71 Shell, 59 shipping, ix, 50, 51, 59, 60, 62, 65, 73, 74

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Index

SI, 79 signs, 66 sites, 22, 47, 67, 89 skin, 10, 13 smoke, 10, 16, 20, 24, 33, 40 snaps, 57 South Korea, 53 Spain, 18, 53 specific heat, 2, 48, 90 speed, 11, 14, 22, 30, 32, 34 spills, vii, viii, x, 1, 7, 8, 13, 16, 17, 18, 22, 24, 27, 34, 37, 38, 43, 45, 47, 48, 58, 59, 60, 61, 85, 87, 89, 90 stainless steel, 12 stakeholder, 66 stakeholders, 69, 74 standards, x, 8, 12, 27, 50, 58, 63, 64, 66, 68, 69, 72, 74, 75 Standards, 66, 81 state control, 75 statutory, 66 steel, 11, 12 storage, vii, ix, 49, 50, 51, 54, 57, 59, 60, 61, 66, 68, 73 strategies, 6, 7, 45, 87 strength, 11, 18 strikes, 60 subsidy, 72 subsonic, 11, 35 supercooling, 4 supplements, 8, 27 suppliers, 52 supply, 3, 4, 5, 6, 11, 52, 54, 67, 70 surveillance, 75 susceptibility, 63 sustainability, 70 synthesis, 27 systems, 23, 40, 59, 60, 66, 67, 71

T Taiwan, 53 takeover, 73 tankers, vii, viii, ix, x, xi, 3, 4, 6, 7, 12, 15, 17, 24, 25, 39, 41, 42, 44, 48, 49, 50,

51, 54, 55, 57, 59, 60, 61, 63, 64, 65, 71, 73, 74, 75, 76, 86, 90 tanks, vii, viii, ix, x, xi, 2, 4, 7, 8, 9, 11, 12, 14, 17, 18, 19, 21, 22, 23, 25, 37, 38, 40, 41, 43, 44, 46, 47, 48, 54, 57, 60, 61, 85, 86, 88, 89, 90 targets, 3, 4, 60, 63, 72, 73, 74 task force, 69 technical assistance, 69 technology, 71 temperature, 4, 10, 54, 61 terminals, vii, viii, ix, xi, 1, 3, 5, 6, 24, 41, 44, 48, 49, 50, 51, 54, 56, 57, 59, 62, 63, 64, 65, 67, 68, 70, 74, 75, 76, 82, 86, 90 terrorism, ix, x, 49, 50, 51, 60, 75 terrorist, vii, ix, 3, 4, 6, 7, 8, 16, 17, 18, 20, 21, 33, 36, 42, 46, 47, 49, 50, 58, 61, 66, 69, 70, 72, 73, 75, 84, 88, 89 terrorist attack, vii, ix, 3, 6, 7, 8, 16, 17, 18, 20, 21, 33, 36, 46, 47, 49, 50, 58, 61, 72, 73, 75, 88, 89 terrorists, vii, ix, 50, 62, 63, 72, 73, 75, 83 testimony, 53, 71, 72, 79 Texas, 28, 55, 72, 83 theory, 73 threat, 7, 17, 21, 29, 30, 59, 65, 66, 69, 71, 73, 74, 76 threatened, x, 50, 72 threats, 17, 62, 70, 73, 74, 75 threshold, 68 thresholds, 31 time, 10, 25, 53, 60, 63, 76 timing, 22 Title III, 79 toxic, 59 tracking, 65 trade, x, 50, 65, 67, 75, 76 traffic, 6, 64 training, x, 26, 50, 65, 67, 75 training programs, 67 transition, 3, 34, 59 transport, 4, 63 transportation, 53, 54, 65, 67, 72

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Index Transportation Security Administration (TSA), ix, 50, 62, 66, 81 travel, 11, 34 Trinidad and Tobago, 12, 52 trucking, 51 trucks, 10 TSA, ix, 50, 66, 68, 80, 81

U uncertainty, 24, 48, 51, 62, 70, 90 unclassified, vii, viii, 1, 7, 8, 26, 43, 61 United Arab Emirates, 52 United States, 2, 4, 5, 6, 11, 24, 41, 48, 52, 53, 54, 55, 57, 67, 70, 73, 74, 75, 81, 90

V

W Washington Post, 83 water, ix, xi, 6, 9, 11, 16, 19, 22, 23, 34, 40, 44, 48, 56, 58, 59, 61, 86, 90 waterways, viii, xi, 44, 63, 64, 86 weapons, 60, 63 wind, vii, viii, x, 2, 8, 13, 16, 20, 22, 23, 30, 32, 40, 43, 45, 85, 87 windows, 42 winter, 6, 57 wood, 11 workers, 58, 60

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values, 15 vandalism, 62 vapor, viii, x, 3, 6, 7, 9, 10, 11, 12, 18, 19, 21, 26, 29, 30, 31, 32, 33, 34, 35, 36,

37, 40, 41, 43, 44, 46, 47, 57, 58, 59, 67, 86, 88, 89 vehicles, 51, 69 vessels, x, 10, 21, 29, 30, 50, 51, 63, 64, 65, 70, 71, 74 visible, vii, ix, 6, 10, 29, 30, 44, 49, 86 vulnerability, x, 50, 61, 62, 63, 65, 68, 75

Layton, John T., and Barry W. Keller. Liquefied Natural Gas : Security and Hazards, Nova Science Publishers, Incorporated,