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Transportation of Liquefied Natural Gas

September 1977

NTIS order #PB-273486


Honorable Warren G. Magnuson
Chairman, National Ocean Policy Study
U.S Senate

Washington, D. C. 20510
.
Honorable Ernest F. Hollings
Vice-Chairman, National Ocean Policy
Study
U. S. Senate
Washington, D. C. 20510

Gentlemen:

On behalf of the Board of the Office of Technology Assessment,


we are pleased to forward the results of this assessment of The
Transport at ion of Liquefied Natural Gas which was requested by your
Commit tee.

This report provides a concise analysis of current LNG tech-


nology and possible trends in the use of LNG. I t a l s o i d e n t i f i e s
a n d d i s c u s s e s t h e m a j o r p o l i c y i s s u e s . We hope this report will
be a useful resource to your Committee and to the Congress when
it debates energy questions in which LNG is a factor.

Sincerely,

Sincerely,

...
111

Foreword

This report is an assessment of the ing process in the certification of LNG import
transportation of liquefied natural gas (LNG). projects, and the status of current research on
The assessment was requested by the Senate LNG and the need for further inquiry.
National Ocean Policy Study for use in con-
The areas of longer range interest are:
sideration of major new projects for the im-
regulations and criteria for the siting of LNG
portation of natural gas, and of the competing
facilities, liability for LNG accidents,
alternatives for transporting natural gas from reliability of foreign suppliers of LNG, and
Alaska through Canada (pipeline all the
policies for pricing LNG.
way), or through Alaska only and thence via
LNG tankers to the lower 48 States. One LNG import terminal is currently
operating in the United States. By early 1978,
This report is divided into three parts: two others will be operational. As a result of
Chapter I presents a factual description of the these operations and other projects now pro-
LNG systems and facilities and the Federal posed, LNG could make up 5 to 15 percent of
regulatory process governing the development
the total U.S. natural gas consumption by
and operation of such systems. Chapter II 1985. Several pieces of legislation to regulate
presents a critical review of key portions of the this growing industry are now before the Con-
LNG system where technological or political gress. Hence the timeliness and importance of
problems may occur. Chapter III outlines the this assessment for the Congress.
kinds of actions desired by interested parties.
Two related studies for Congress are cur-
The report identifies nine areas which may rently in progress: a safety study by the
be of concern to the Congress as it considers
General Accounting Office, and an energy
possible new legislation, oversees Federal facility siting study by the Office of Tech-
agencies, and appropriates funds for agency
nology Assessment.
operations and research. The areas of near-
term concern are: the design and construction This assessment was performed by Peter
of LNG tankers, the regulation and inspection Johnson, project director, and the Oceans
of LNG tankers and their operation, the Program staff, under the overall direction of
regulation and inspection of LNG terminals Robert W. Niblock, the Program Manager.
and their operation, the Federal decisionmak-

DANIEL De SIMONE
Acting Director

v
OTA Oceans Program Staff

Robert W. Niblock, Program Manager


Peter A. Johnson, Project Director

Prudence S. Adler Anne Fenn


Kathleen A. Beil Emilia L. Govan
Thomas A. Cotton Judith M. Roales
Renee’ M. Crawford Bennett L. Silverstein
Karl Vischer

Consultants
Gary Baham
Richard C. Raymond
Ralph Smalley

Ad Hoc Panel on Transportation of LNG

Irvin Bupp
Harvard University
Gene Cosgriff
Bring Legal Action to Stop the Tanks
Robert Devore
American Gas Association
Martin Engler
El Paso LNG Company
Mike Eaton
Sierra Club
Max Levy
Columbia LNG Corporation
Ruth Mathes
Maryland Conservation Council
O.W. Moody
AFL-CIO Maritime Trades Department
Gene Schorsch
Sun Shipbuilding and Drydock Company
Bruce Terris
Attorney
Robert Westreich
New Jersey Department of Public Advocate

vi
Summary

It is possible that during the next two Regulation of LNG systems is hampered by
decades 5 to 15 percent of the U.S. natural jurisdictional overlaps (particularly between
gas consumption could be filled with LNG the Federal Power Commission and the Office
from Alaska or foreign countries. This would of Pipeline Safety Operations), some gaps in
be a major increase over present LNG import enforcement (particular the lack of inspec-
levels. This gas will reach the United States tion to assure compliance with stipulations in
by means of a complex and expensive system FPC permits), and the lengthy Government
consisting of liquefaction facilities, specialized procedures which do not result in timely deci-
cargo tankers, and regasification and storage sions for the applicant and do not give the
facilities. public adequate participation in decisions
(particularly in the FPC licensing of LNG
To date, there have been few serious
projects).
problems in the operation of small-scale LNG
facilities existing in the United States. In addition, the lack of firm Government
However, new ships and plants will be con- policy on such matters as LNG import levels,
siderably larger than existing ones, and pricing mechanisms to be used, and the
problems of scale and limited experience Federal role in siting of facilities makes plan-
make it difficult to predict with any degree of ning difficult for both the gas industry and the
certainty the safety of the LNG system. public.
It appears that the most serious incidents Past research has produced conflicting
could occur as a result of an LNG tanker acci- results and predictions about the safety of
dent. Therefore, while the tankers appear to LNG and it is unlikely that future research
be well designed and constructed, better con- will resolve the differences and come to firm
trol of vessel traffic in U.S. ports and water- decisions. For that reason, public policy deci-
ways, improved inspection procedures after sions about LNG systems will probably be
the ship has been commissioned, and man- made principally on the basis of nonquantita-
datory crew and inspector training are tive approaches. These decisions should result
needed. in prudent siting of facilities and strict design,
construction and operation standards.
At the onshore facilities where LNG is
received, stored, processed and sent into a gas This report identifies nine areas which may
distribution pipeline, improved inspection be of concern to the U.S. Congress in its con-
procedures are also needed to enhance the sideration of possible new legislation, over-
public safety. However, the major issue sur- sight of Federal agencies with responsibilities
rounding the onshore facilities is the question for LNG systems, or appropriation of funds for
of where they should be located. There are agency operations and research.
currently no Federal guidelines for choosing
sites of LNG or any other energy facility. The first five areas are concerns about ex-
isting equipment and procedures for facilities
There is considerable public pressure for such
which are already operating or will be operat-
guidelines, particularly criteria which would
limit facilities to unpopulated areas. ing in the near future. Regulatory changes in

vii
these areas must be such that they can be ap- The second four areas addressed have more
plied to ongoing projects. These areas are: long-range implications and will affect
● tanker design and construction (pages policies and facilities for future projects.
42-45); These areas are:

● tanker regulations and operations (pages . LNG facility siting (pages 63-67).
46-49); . liability for LNG accidents pages (68-70).
● regulation of terminal operations (pages . reliability of supply (pages 71-75).
50-52);
● pricing policy (pages 76-78).
● decisionmaking process in certification of
import projects (pages 53-57);
● safety research on LNG (pages 58-62).

...
Vm

Acknowledgments

The staff wishes to acknowledge the help and cooperation of the follow-
ing groups and individuals during the preparation of this study:
Algonquin G a s T r a n s m i s s i o n Company Department of Transportation: U.S. Coast
(Massachusetts) Guard (Washington, D. C.)
Roy Alper, California Citizen Action Group Distrigas Inc. (Massachusetts)
American Gas Association (Washington, D. C.) Frank Dorrigan, Providence City Council
Robert Apple, The Stanwick Company (Rhode Island)
(Virginia) Energy Research and Development Ad-
Larry Ask, Southern California Gas Company ministration (Washington, D. C.)
Howard Bertolucci, Massachusetts Depart- James Fay, Massachusetts Institute of Tech-
ment of Public Utilities nology
Barbara J. Bockert, New Jersey Coastal Zone Federal Power Commission (Washington,
Management Office D. C.)
Joe Bodovitz, California Coastal Zone Con- Larry Forelich, Central Power and Light
servation Commission Company (Texas)
Tim Brick, Campaign Against Utility Service Harry Fritz, New Jersey Public Utilities Com-
Exploitation (California) mission
Pat Brown, California Council for Environ- General Dynamics Corporation (Massa-
mental and Economic Balance chusetts)
John Callahan, Rhode Island Public Utilities John C. Gerard, Los Angeles Fire Department
Commission Robert Gresimer, United Gas Pipeline Com-
James Carroll, California Council for En- pany (Texas)
vironmental and Economic Balance Edwin Hood, Ship Builders Council of
Gordon Carruth, Georgia Coastal Zone Com- America (Washington, D. C.)
mission John Howard, First State Bank and Trust
John Chadwick, (California) Company (Texas)
Columbia LNG Corporation (Delaware) Frederic John, California Public Utilities
Rev. Thomas D. Corrigan, Massachusetts Commission
Fair Share Tsujio Kate, Mayor of Oxnard, Calif.
Jim Cromley, N a t i o n a l P a r k R e s i d e n t s Mrs. Terry King (New York)
Organization (New Jersey) Elizabeth Kleban, Sewaren Civic Association
Department of Commerce: Maritime Ad- (New Jersey)
ministration (Washington, D. C.) Helen Linker, Natural Resources Defense
Department of the Interior: Bureau of Mines Council (California)
(Washington, D. C.) Hank Marcus, Massachusetts Institute of
Department of State (Washington, D. C.) Technology
Department of Transportation: Office of Philip W. Marking, Point Conception Preser-
Pipeline Safety Operations (Washington, vation Committee (California)
D. C.) Keshavan Nair, Woodward-Clyde Inc.
(California)
ix
Joe D. Porricelli, ECO Inc. (Maryland) David Lee von Ludwig, Bring Legal Action to
Louise Potter, Concerned Citizens of Cumber- Stop the Tanks (New York)
land (Rhode Island) Andrew Wall, Al Larson Boat Shop (Califor-
Eldred Rich, New York Department of En- nia)
vironmental Conservation Harold R. Wesson, Wesson and Associates
Herman Rhodes, Gulf Coast Conservation Inc. (Oklahoma)
Association (Texas) Mrs. Raymond West, Washington Park
Charles Romick, Gloucester County Planning Citizens Association (Rhode Island)
Department (New Jersey) Sidney Wolf, Environmental Policy Center
Adm. N. Sonenshein, Global Marine Develop- (Washington, D. C.)
ment Inc. (California)
Contents

Chapter Page
I. Description of LNG Technology and Import System . . . . . . . . . . . . . . . 1

Volumetric Conversion Table . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2


Supply and Demand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Description of LAG...... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Safety Record of Early Use of LNG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Regulation of Import Projects. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
LNG Tanker Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
LNG Tanker Certification and Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . 18
LNG Terminal Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
LNG Terminal Siting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
LNG Terminal Regulation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Trends in LNG Use and Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Existing and Proposed LNG Projects, In Brief . . . . . . . . . . . . . . . . . . . . . . . 29
.
II. Critical Review of Components of LNG Import System . . . . . . . . . . . . 39

Paper 1—LNG Tanker Design and Construction.. . . . . . . . . . . . . . . . . . . . 42


Paper 2—LNG Tanker Regulations and Operations. . . . . . . . . . . . . . . . . . 46
Paper 3—Regulation of Terminal Operations . . . . . . . . . . . . . . . . . . . . . . . . 50
Paper 4—Decisionmaking Process in Certification of LNG Projects . . . . 53
Paper 5-Safety Research on LNG Facilities . . . . . . . . . . . . . . . . . . . . . . . . 58
Paper 6-LNG Facility Siting . . . . . . . . . . . . . . . . . . . . . . .’. . . . . . . . . . . . . . . 63
Paper 7—Liability for LNG Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
Paper 8-Reliability of LNG Supply . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Paper 9—LNG Pricing Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76

III. Public Awareness and Concerns About LNG. . . . . . . . . . . . . . . . . . . . . . . 79

Actions Desired By Gas Utility Companies . . . . . . . . . . . . . . . . . . . . . . . . . . 82


Actions Desired By Organized Labor Groups . . . . . . . . . . . . . . . . . . . . . . . . 83
Actions Desired By State and Local Officials . . . . . . . . . . . . . . . . . . . . . . . . 83
Actions Desired By Related Industries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84
Actions Desired By Public Interest Groups . . . . . . . . . . . . . . . . . . . . . . . . . . 85

IV. Appendixes .***... .**.**.*.


● ● ******** ● ***.**.* ● ***.**.* .***..... . . 87

A. Cove Point, Md., Permits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89


B. Federal Agencies Involved in LNG Import Projects . . . . . . . . . . . . . . . 96
c. Laws and Cases Relevant to LNG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
D. Congressional Hearings Conducted on LAG...... . . . . . . . . . . . . . . . . 99
E. Pending Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101

xi

LIST O F F I G U R E S

Figure No. Page


..

1. U. S.-Natural Gas Consumption 1971 -1976 . . . . . . . . . . . . . . . . . . . . . . . . . . . 3


2. World Proportional Natural Gas Reserves By Major
Supplier Country . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
3. Existing International LNG Trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
4. U.S. LNG Import Projection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
5. Status of U.S. LNG Import Projects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
6. Sources and Destinations of Major Planned LNG Import
Projects/1978-1985 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
7. International LNG Trade Routes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
8. Total Capacity of World LNG and LPG Tanker Fleet . . . . . . . . . . . . . . . . 12
9. LNG Tankers On Order or Under Construction in U.S.
Shipyards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
10. Profiles of Typical LNG Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
11. Comparison of LNG Tanker and Crude Oil Tankers . . . . . . . . . . . . . . . . . 14
12. Inboard Profile of LNG Tanker . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
13. Free-Standing Spherical LNG Tank . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
14. Free-Standing Prismatic LNG Tank . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
15. LNG Membrane Tank. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
16. Comparative Characteristics of Some LNG Tank Systems . . . . . . . . . . . . 18
17. Specially Constructed Tankers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
18. Aboveground LNG Storage Tank . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
19. Layout of Cove Point, Md., LNG Receiving Terminal . . . . . . . . . . . . . . . . 23
200 Cove Point, Md., Facility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
21. Storage and Diking at Onshore LNG Plant . . . . . . . . . . . . . . . . . . . . . . . . . . 25
22. Projected Future LNG Imports (Based on Proposed
1 Projects and Reasonable Approval Time) . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
23. Artist’s Rendering of Offshore LNG Terminal . . . . . . . . . . . . . . . . . . . . . . . 28
24. Project Data Sheet: Distrigas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
25. Project Data Sheet: Phillips/Marathon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
26. Project Data Sheet: El Paso I. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
27. Project Data Sheet: Trunkline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
28. Project Data Sheet: Pacific-Indonesia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
29. Project Data Sheet: El Paso II. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
30. Project Data Sheet: Pacific Alaska . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
31. Project Data Sheet: El Paso-Alaska . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
32. Average Vessel Capacity of World LNG Tanker Fleet. . . . . . . . . . . . . . . . 44
33. Procedure for FPC Certificate of Public Convenience
and Necessity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
34. Typical Fault Tree for Leak Which Is Not Listed . . . . . . . . . . . . . . . . . . . . 61
35. Distances a Vapor Cloud May Travel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
36. States Dependent on Companies Using LNG as Part of
Gas Supplies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73
37. Percent of LNG in State Consumption and Company
Supplies (Imports from Foreign Countries Only). . . . . . . . . . . . . . . . . . . . . 74
38. Percent of LNG in State Consumption and Company
Supplies (Including Alaskan Gas) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74

xii

Description of
LNG Technology
and Import System
Volumetric Conversion Table

VOLUME RELATIONSHIPS
LNG Gas/Liquid Ratio 619.8 to 1
1086 Btu/Cu. Ft. Spec. Grav. 0.465

Gas Liquid
LNG
Conversion Cubic Imp. Cubic Cubic Metric
Factors Feet MCF Pounds Gallons Gal. Feet Barrels Meters Tons

1 MCF 1000.0 - 46758 12070 10.051 1,6134 0.28735 0.045692 .02123 10.860

1 Gallon 82850 0.082850 3.87390 - 0.8327 0.13367 0,02380 0,003785 0001759 0.89975
1 Imp, Gal 99503 0.099503 4.6526 1,201 - 016054 0.02858 0,004546 000211 1,08059

1 Cubic Foot 619.80 061980 28.981 7.4811 6.229 - 0.17810 0.02832 0.01316 6.7311

1 Barrel 348008 3.48008 162,72 42,005 34,97 5,6148 - 0,15901 0.07388 37,794

1 Cubic Meter 21,886 21,886 1023,3 264.16 220,0 35314 6.2888 - 0.46463 32768

1 Metric Ton 47,103 4 7 1 0 3 2202,4 568,53 473,4 75.996 13.535 2.1522 - 511 54

1 Therm 92081 0,09208 4,3055 1.1114 0,92546 0,14856 0.02646 0,00421 0.00195
Chapter I

Description of LNG Technology


and Import System

SUPPLY AND DEMAND Figure 2. World Proportional Natural Gas Reserves


By Major Supplier Country
Natural gas is a major source of energy for
the United States, supplying 20 trillion cubic Country Percentage
feet, more than one-quarter of the total energy
USSR. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
consumed in this country, during 1976.1
Iran’ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Although U.S. production of natural gas United States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
has been declining since 1971 (figure 1), there Algeria*. . . . . . . . . . . . . . . . . . . . . . . . . . . 10
are significant supplies of natural gas in Abu Dhabi* . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
several regions of the world where there is lit- Total 75
● Countries with little or no gas demand.
Figure 1. U.S. Natural Gas Consumption 1971-1976 Source Department of the lnterior World Natural Gas Annual – 1975

Yearly
Total 25 tle or no gas demand (figure 2). To date, much
Consumption of this natural gas has been wasted—in 1975,
Trillion
Cubic
6.5 trillion cubic feet were vented or flared
Feet 20 worldwide. z
To use the natural gas which would other-
wise be untapped or wasted, importation of
15
natural gas is one of several supplemental
supply schemes used by those areas of the
world with large energy demand, primarily
10
the United States, Europe, and Japan.
Natural gas has been carried overland by con-
ventional pipelines, and about 1 trillion cubic
5
feet of natural gas is imported in that manner
from Canada to the United States each year.
However, in order to import natural gas in a
form practical for water transportation from
1971 1972 1973 1974 1975 1976 Eastern Hemisphere nations, a system has
U S Production been developed to convert the gas to liquid
form at about l/600th the volume. The lique-

Source Federal Energy Administration Monthly Energy Review, March 1977

U.S. Department of the Interior, Bureau of Mines,


1
Federa] Ener~ Administration, Monthly Energy World Natural Gas Annual (Washington, D. C.: U.S.
Reuzew, March 1977. Department of the Interior, Bureau of Mines, 1975).

3

4 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

fied natural gas (LNG) is then shipped in at the source of the gas, the LNG tanker, and
specially constructed tankers, introducing a the receiving terminal and regasification
marine link in the supply and demand of facility at a location near a gas distribution
natural gas. This marine link is a large com- network. It is a very capital-intensive system,
ponent, consisting of the liquefaction facility which can cost more than $1 billion to con-
struct. A large 500 million cubic feet per day
Figure 3. Existing International LNG Trade project with four ships could require a $2
billion capital expenditure for liquefac-
Amount per Day tion/export facilities ($1 billion), ships ($150
Date Started Supplier to Importer (million cubic feet) million each), and import/regasification
737
facilities ($300 million to $400 million). Im-
1972 Brunei to Japan
1977 Indonesia to Japan 550 plementation of all announced LNG projects
1964 Algeria to France 400 could require capital expenditures in excess of
1969 Libya to Italy 235 $35 billion worldwide. In the United States
1969 Libya and Algeria to Spain 160 alone, construction of facilities and ships for
1969 Alaska to Japan 135 the import of LNG could require $20 billion. a
1964 Algeria to United Kingdom 100
1971 Algeria to Boston, Mass. 44
:1’’LNG Rep&rt,” Pipeline and Gas Journal 204 (June
Source Pipeline and Gas Journal, June 1977 1977).

Figure 4. U.S. LNG Import Projection


— —

Such huge capital expenditures are The United States is presently a net ex-
generally financed by a multinational mix of porter of LNG. More than 32 billion cubic feet
governments and private firms. The U.S. of natural gas in the form of LNG has been
Government has already provided about $716 sent to Japan from southern Alaska each year
million in subsidies, loans, and loan guaran- for the past 5 years, while only about 15
tees in connection with LNG projects. More billion cubic feet per year is imported from
than two-thirds of that support has been given Algeria to Everett, Mass. The LNG imported
to the foreign portions of the projects. A to Everett is a very small amount, less than
one-twentieth of 1 percent of the U.S. con-
Europe became the first steady market for sumption of natural gas in 1976. 6 According to
LNG in 1964 (figure 3). Japan took over as the industry representatives, however, LNG could
key market about 1972, receiving about 49 be 5 to 15 percent of the total U.S. gas con-
percent of the LNG moving in international sumption by 1985 (figure 4).7 Projects are now
trade. However, the United States—which has proposed which could bring as much as 3.5
used very limited imports of LNG only since trillion cubic feet of LNG per year to the
1971–is projected to become a major LNG United States from foreign sources within the
customer if ventures now planned go for- next 10 to 15 years (figure 5).
ward. b
41nterview with Officials of Export-Import Bank of 6Federa1 power commission, “Table of LNG Imports
the United States, Washington, D. C., June 16, 1977. and Exports for 1976,” News Release, June 3, 1977, and
JDavid Hawdon, World Transport of Energy 1975 to Federal Energy Administration, Monthly Energy
1985 (London: Stanil and Hall Associates Limited, Review, March 1977.
April 1977), p. 39. TOffice of Technology Assessment LNG panel meet-
ing, Washington, D. C., June 23, 1977.

Figure 5. Status of U.S. LNG Import Projects

Project Start-up Date Supply Source Status (AGA/FPC) Quantity


(billion cubic feet/y r.)
Existing & Firm Foreign Imports
Distrigas I 1972 Algeria Existing/Operational 1,6
Distrigas IV 1978 Algeria Firm/Pending 42*
El Paso I 1978 Algeria Firm/Approved 365
Note -- Eascogas project IS deleted here because of 407
recent questions regarding approvals and project viability

Probable Foreign Imports


Panhandle Eastern 1980 Algeria Probable/Approved 179
Pacific Lighting Int 1980 Indonesia Probable/Approved 197
El Paso II 1980-82 Algeria Probable/Pending 365
741
Possible Foreign Imports
Tenneco-N B. Canada 1985 Algeria Possible/Filed 397
Occidental-El Paso 1985 +/- USSR Possible/Not Filed 365
Brown/Root-Tenneco 1985 +/- USSR Possible/Not Filed 547
Kalingas 1985 +/- Iran Possible/Not Filed 285
El Paso-Iran 1985 +/- Iran Possible/Not Filed 547
Shell-BP 1985 +/- Nigeria Possible/Not Filed 237
2,378

Grand Total 3,526

● Replaces Distrigas 1. Sources American Gas Association and the Institute of Gas Technology,

96-597 0-77 -2
—— .

Note Other possible future sources of LNG include Iran, Russia, and NIgerIa
Bcf/y = billion cubic feet per year

Source OTA.

Ultimately, the supply of natural gas is If presently planned and approved projects
limited, But since it is currently an under- move forward, Algeria would be the major
utilized resource in many foreign countries, source of the increased imports (figure 6). A
importing it as LNG could satisfy a significant smaller amount of LNG would come from In-
portion of the U.S. energy demand for at least donesia, and there is a possibility of supplies
the next 20 years. from the U.S.S.R, Iran, and Nigeria after
1 9 8 5 .9 The stability of these foreign supplies
Imports of LNG could be particularly and likely results of possible curtailment of
useful in alleviating near-term fuel shortages LNG shipments to the United States has been
in certain sectors of the economy or parts of identified by this study as one of the potential
the country. In California, which accounts for problems of the LNG system. Foreign supply
11 percent of U.S. natural gas consumption, s is discussed further in the critical review sec-
LNG could help to alleviate projected energy tion which follows this chapter.
shortfalls and air quality problems.

~Douglas M . Considive, cd., Energy Technology gAmerican Gas Association, Gas Supply Review, 5
Handbook (New York: McGraw-Hill, 1977). (February 1977).
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 7

In addition to foreign natural gas, new gas million tons. 11 In 1977, there were 441 LPG
discoveries in Alaska could be transported to tankers operating worldwide with a capacity
the west coast as LNG. This possible supply of of 3.5 million cubic meters. In comparison, 30
gas from the North Slope and southern LNG tankers were operating worldwide at the
Alaska could be more than 1 trillion cubic feet same time with a capacity of 2.2 million cubic
a year as early as 1984.10 meters.
The North Slope is by far the largest of the Some unique properties of LNG which
two Alaskan supplies of natural gas. The affect the design of tankers or terminals are:
method of transportation to be used to bring ●
it has an extremely low temperature of
the North Slope gas to the west coast was to be
–259° F;
determined by the President in September? A
proposal to transport this gas by pipeline ●
it weighs about 28 pounds/cubic foot,
through Canada was being weighed against a slightly less than half the weight of
proposal to use an LNG system. water, and would therefore float;

at normal ambient temperatures, it
DESCRIPTION OF LNG evaporates very rapidly and expands to
about 600 times its liquid volume;
Liquefied natural gas is not the only haz- ●
in the vapor state, and when still very
ardous cargo transported in the United States cold, the gas is heavier than air and, in
today, or is it necessarily the most dangerous. the event of a spill, would hug to the
Other cargoes which pose unique hazards earth’s surface for a period of time until
when transported in large volumes include substantially dissipated;
liquefied petroleum gas (LPG), chlorine,
acids, and gasoline. ●
when the vapor warms up, reaching tem-
peratures of about –100° F, it is lighter
Liquefied natural gas and LPG are similar than air and would rise and dissipate in
in many ways and are treated together as “liq- the air;
uefied gases’ by most regulators. Liquefied
petroleum gas, however, appears to be better ●
in the vapor state, it is not poisonous, but
known and accepted by the public. In 1976, 10 could cause asphyxiation due to the ab-
million tons of LPG were moving in world sence of oxygen;
trade, most of it going to Japan from the Mid- ●
in the vapor state, concentrations of 5 to
dle East countries. It is estimated that by 15 percent natural gas are flammable.
1980, LPG trade will more than double, and
that U.S. demand will be as much as 12 Liquefied natural gas is odorless and color-
less. It looks much like water. Except for its
extremely cold temperature, which requires
*NOTE: On September 8, 1977, the President special handling techniques and materials,
announced that an agreement had been the liquid is relatively safe. In bulk form it
reached with Canada for a pipeline to carry will not burn or explode. Momentary contact
natural gas across that country from Alaska on the skin is harmless although extended
to the west coast of the United States. The contact will cause severe freeze burns, On con-
Congress has 60 days after formally receiving tact with certain metals such as carbon steel
the President’s plan in which to disapprove
the choice if it so desires. ship decks, LNG can cause immediate crack-
ing.
IOFedera] power ~o~missio~, Recomme~da~~on to

the President Alaskan Natural Gas Transportation


Systems (Washington, D. C.: Federal Power Commis-
1 IH. Magelssen, “LPG-Transportation Cost, Market
sion, May 1, 1977) p. I-44.
Potential and Future Charterers,” Gastech 76 Proceed-
ings LNG and LPG Conference, New York, Oct. 5-8,
1976, (Herts, England: Gastech Exhibitions, 1977).
8 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

The behavioral patterns of LNG vapor in tanks continually heated by a surrounding


the atmosphere, however, are not so well un- flame causes a rise in pressure which leads to
derstood and may create hazards. If spilled on detonation. Open-air detonations of LPG 13
the ground, LNG would “boil,” (vaporize) have been demonstrated by experiment
very rapidly for 2 or 3 minutes until the whereas the same is not true of LNG. 14
ground was frozen and no longer emitting
Research into the behavior of spilled LNG
heat to the LNG on top of it. This would slow
and an LNG cloud is another critical area dis-
the rate of vaporization and minimize cloud
cussed in the next chapter.
formation dangers.
If spilled on water in a large-scale accident,
it is unlikely the water would freeze. Instead SAFETY RECORD OF EARLY
the water would continue to warm the floating USE OF LNG
LNG, vaporizing it and forming a spreading
cloud. Researchers currently disagree on the Liquefaction of natural gas is achieved by
shape, size, movement, and composition of the cooling the gas to –259° F. The process was
vapor cloud and the factors which will affect developed on a large scale during the first
it. It is believed that the concentration of LNG quarter of the 20th century to simplify the
vapor within the cloud is not homogeneous. At transportation and storage of natural gas,
the edge of the cloud, where the greatest mix- since the liquid state is l/600th the volume of
ing with ambient air occurs, the concentration the gaseous state.
of gas is lowest. At the core of the cloud, the Until recently, LNG was utilized primarily
concentration is highest. Where the concentra- in operations which produced the liquid and
tion falls within the flammable limits of 5 to stored it for use only during peak demand, for
15 percent, the cloud may be ignited and burn example, in cold winter weather. There are 89
back toward the source of the spill. It is of these facilities operating in the United
generally agreed that, if the vapor from a States today to produce and/or store domestic
large LNG spill ignites, it would be beyond the LNG. Known as “peak shaving plants,” they
capability of existing firefighting methods to have a combined storage capacity of 2 million
extinguish it. 12 Therefore, the key to reducing c u b i c m e t e r s .15 In addition, one plant in
the hazard of an LNG fire is a strong preven- Boston imports and stores foreign LNG. Its
tion program. capacity is 146,000 cubic meters. The peak
The hazards of transporting LNG are some- shaving plants have existed safely for years,
what similar to those of LPG, if the two are without much public attention to either their
considered in equal volumes. However, LPG is location in heavily populated areas or their
somewhat more dense than LNG vapor at operations. Only one major incident has mar-
comparable temperatures. In the event of a red the safety record of these plants.
spill of either liquid on water, the liquid That accident occurred at the first LNG in-
would rapidly spread by gravity until a large stallation in 1944. At that time, a storage tank
vapor cloud would form. LNG would vaporize owned by East Ohio Gas Company in Cleve-
considerably faster than LPG because LNG is land ruptured, spilling 6,200 cubic meters of
more volatile. Thus, the LPG vapor cloud LNG into adjacent streets and sewers. The liq-
would evolve over a longer period of time, and uid evaporated, the gas ignited and, where
would be more cohesive than the LNG cloud. confined, exploded, The disaster remains the
LPG has the greatest potential for detonation
both in open air and confined. LPG stored in
l~elephone interview with staff of the Bureau of
Mines, Pittsburgh, Pa., Sept. 7, 1977.
1 ~Society of Naval Architects and Marine Engineers, ld’l_’elephone interview with staff of Naval Weapons
Proceedings of Second Ship Technology and Research Laboratory, China Lake, Calif,, Aug. 25, 1977,
(STAR) Symposium (San Francisco, Calif.: May 25-27, 15A~erican Gas Association, LNG Information Book
1977), p. 396. 1973 (Arlington, Va.: American Gas Association, 1973).
. —

CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 9

most serious LNG accident anywhere in the took four lives in Oregon. This accident,
world. It resulted in 128 deaths, 300 injuries, however, took place during construction of the
and approximately $7 million in property storage tank before LNG had ever been in-
d a m a g e . l6 troduced into the facility. l9
Based on investigations made by the U.S. Over the past 10 to 20 years, the peak shav-
Bureau of Mines after the accident, it was ing facilities have been engaged in all phases
generally agreed that the tank failed because of LNG handlings: liquefaction, regasifica-
it was constructed of 3.5 percent nickel steel, tion, loading and unloading, storage, and
which becomes brittle on contact with the ex- shipment by pipeline, truck, rail, and barge.
treme cold of LNG. Since the Cleveland dis- However, new LNG projects involve much
aster, it has become standard practice in the larger scale facilities entirely dependent on
LNG industry to use 9 percent nickel steel, marine shipment, and these are the focus of
aluminum, or concrete and to surround this study.
storage facilities with dikes capable of con-
taining the contents of the tank if a rupture
occurs. REGULATION OF IMPORT
PROJECTS
The only other significant accident related
to LNG to date occurred at a Staten Island Before any LNG import or export project
import facility in 1973; where 40 workmen can begin operation, more than 130 permits
repairing an empty LNG tank were killed must be obtained from Federal, State, and
when the roof of the tank collapsed as a result local agencies (see appendix A), and 12
of a fire. different Federal agencies are involved in ap-
While the Staten Island tank disaster pre- provals and controls. The Federal Power
cipitated active local opposition to LNG, the Commission (FPC), the Coast Guard, and the
gas industry has repeatedly argued that the Office of Pipeline Safety Operations (OPSO),
accident was not due to any characteristic or are the agencies most involved in LNG and
handling of LNG 17 , but was an industrial ac- are discussed in appropriate sections of this
cident involving an insulation fire. However, a chapter. The others are explained in appendix
Bureau of Mines study of the accident indi- B.
cated that there was enough LNG in the in- The most crucial agency in this milieu is the
sulation that it could have been released very Federal Power Commission, which under the
quickly into the tank once ignition had Natural Gas Act of 1938, has power to ap-
started. 18 prove or reject any proposed project in three
The only other accident in the United ways: 20
States mentioned in connection with LNG ●
it must determine whether of not the
public interest will be served by LNG im-
IGU.S. Department of the Interior, Bureau of Mines, portation;
Report on the Investigation of the Fire at the Liquefac-
tion, Storage and Regasification Plant of the East Ohio

it must authorize construction or exten-
Gas Company, Cleveland, Ohio, Oct. 20, 1944. sion of any facilities to be used in the
(Washington, D. C.: U.S. Department of the Interior, transportation or sale of interstate
Bureau of Mines, February 1946). natural gas;
l@ocio.Economic Systems, Inc., Environmental Im-
pact Report for the Proposed Oxnard LNG Facilities, ●
it has the authority to establish the price
Safety, Appendix B (Los Angeles, Ca.: Socio-Economic at which the gas is sold.
Systems, 1976), p. 10.
18U.S, ConWess, House, Staten Island Explosion:
Safety Issues Concerning LNG Storage Facilities. Hear-
ings before the Special Subcommittee on Investigations lg’’LNG Scorecard,” I%”peline and Gas Journal 204
of the Committee on Interstate and Foreign Commerce. (June 1977): 22.
93rd Cong., first sess., July 10, 11, 12, 1973, pp. 143, 145. 2015 U.S.CO ~ 717 f (c) (1970).
10 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

The Federal Power Commission has broad which may uphold the initial decision or
discretionary powers in determining what is change it completely. The final decision is sub-
and what is not in the public interest and in ject to an appeal in one of the U.S. Courts of
stipulating conditions which must be met in Appeal.
order to meet the public interest.
Since the historic role of FPC has been to
To date, the FPC has been asked to rule on regulate the entry of suppliers into the inter-
one LNG export project and 10 LNG import state natural gas market and to ensure that
projects (see figure 5). The export project, with interstate sales of gas take place at prices that
liquefaction facilities in Kenai, Alaska, has are “just and reasonable,” 21 the agency has
been approved and is operating. Of the import limited its activities to licensing and ratemak-
projects, three have received final approval; ing. There is little onsite inspection to assure
one has received initial approval, subject to compliance with stipulations contained in the
review. One import project with its terminal licenses. The exception to this general rule oc-
and regasification plant in Everett, Mass., is curs when a company wishes to expand exist-
in operation. Another, with import facilities ‘in ing facilities and submits a new application.
Cove Point, Md., and Savannah, Ga., is In that context, FPC engineers inspect the
scheduled to begin operation later this year. facility to judge its operating performance. 22 A
Facilities for the approved project at Lake critical analysis of the decisionmaking process
Charles, La., have not yet been constructed, which leads to certification of LNG projects
nor have facilities for the Oxnard, Calif., ter- and the difficulties of pricing policies are dis-
minal which has received only initial ap- cussed in the next chapter.
proval.
The FPC approves the import projects by LNG TANKER TECHNOLOGY
means of an express order authorizing impor-
tation and certificates of public convenience Liquefied natural gas import projects in-
and necessity (authorization and stipulations volve a complex consortia of energy and
for construction and operation of facilities). transportation companies. The gas supplier is
The approvals are obtained by means of a usually represented by a foreign government
complicated quasi-judicial procedure which or State-owned subsidiary company. The
routinely takes several years from the time an recipient of the gas at the import terminal is
application is filed until it is approved. First, generally a consortia of gas utilities and/or
an evidentiary hearing is held before an ad- pipeline companies, which use the gas in their
ministrative law judge, in which the appli- own systems and sell to other distribution or
cant, staff, and interveners each present their utility companies. The supplier and receiver
views of the nature of the project, cost esti- are connected by a transportation company,
mates, the need for additional supply of gas, the subsidiary of an oil, gas, or pipeline com-
and environmental consequences of the proj- pany, which owns and operates the LNG
ect. The evidence presented also includes an tankers.
environmental impact statement prepared by
Liquefied natural gas tanker technology
the FPC, an engineering and safety review by
has been developed over the past 20 years to
the cryogenics division of the National Bureau
the point where, currently, about a dozen
of Standards, and a risk analysis by the FPC
worldwide trade routes are either in opera-
staff. On the basis of this evidence, the FPC
tion, planned, or proposed for LNG shipping
administrative law judge makes an initial
(figure 7). Growth in the world LNG fleet has
decision.

“ Second, there is a period of review during


which any of the parties may file exceptions to 2115 UOS.C, $ 717 ~ (a) (1970).
the decision. At the end of the review period, 221n~rvi~w~with Federal Power commission staff,
the commissioners make a final decision Washington, D. C., May 31 and June 24, 1977.
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 11

& i Q

a
12 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

Figure 8. Total Capacity of World LNG and LPG Tanker Fleet

26 51 39 28 32 44 34 22 30 67 66 60
145 172 209 242 274 307 339 352 379 404 418 441
vessels 4 6 9 13 23 24 28 45 49 42 43
5 5 5 5 8 11 14 17 20 27 35 39
Total 176 232 259 284 327 385 411 419 475 547 561 583

8,000

Source Liquid Gas Carrier Register 1977

been rapid (figure 8). Seventy-two ships will Currently, only one LNG tanker is engaged
be operational by 1980, with a possibility that in regular import trade with the United
33 more would be required if all planned LNG States, that is the French ship, the Descartes,
projects go through. 23 which has brought 25 shipments from Algeria

23
Edward Faridany, LNG: 1974-1990 Marine Opera-
tions and Market Prospects for Liquefied Natural Gas,
(London: Economist Intelligence Unit Limited, June
1974), p. 69,
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 13

Figure 9. LNG Tankers On Order or Under Construction Liquefied natural gas tankers are bulk
In U.S. Shipyards cargo ships which require unique design and
materials to handle the very low-temperature
No. of Containment gas.
Shipyard Vessels System Design
Avondale 3 Conch Self-supporting Most LNG tankers range in size from about
aluminum alloy 40,000 cubic meters to planned ships of
prismatlc tanks,
British design 165,000 cubic meters (figure 10). The industry
General Dynamics 10 Kvaerner- Spherical aluminum standard has become the 125,000- to 130,000 -
Moss alloy tank, cubic meter ship. Each ship this size carries
Norwegian design enough LNG to heat a city of 100,000 popula-
Newport News 3 Technigaz Stainless steel tion for 1 month. 26
alloy membrane
French design
Figure 10. Profiles of Typical LNG Ships
Sun Shipbuilding 2 MacDonald Invar ( nickel-steel),
Douglas/ American/French
Gas design
Transport

METHANE PRINCESS
27,400 cubic meters
to the Distrigas peak shaving plant in Boston
since July 1975.24 Nine more LNG tankers will
join the U.S. trade early next year when im-
port terminals under construction at Cove
Point, Md., and Savannah, Ga., begin opera- DESCARTES
tion, and five more when an import terminal 50,000 cubic meters
at Lake Charles, La., is online about 1980
(figure 9). If other projects now proposed are
approved, it is possible that 12 additional
LNG tankers will be required for imports to
the United States and 14 for shipments from
Alaska to the continental United States. By
1985, a total of 41 tankers could be calling at
continental U.S. ports. (In addition, two
tankers are involved in export of LNG from
Alaska to Japan through 1985). 25

ziInterviews with Officials of Distrigas Inc., Boston,


Mass., .June 15, 1977.
2 5 a , “LNG Scorecard,’ Pipeline and Gas Journal 203

(June 1976): 20.


b. American Gas Association, “Update of Status of
LNG Projects,” Gas Supply Review 5 (February
1977): 8.
c. U.S. Department of Commerce, Maritime Ad-
m i n i t r a t i o n , S t a t u s o f LNG V e s s e l s
(Washington, D. C.: U.S. Department of Com-
merce, Maritime Administration, March 15, Source National Maritime Research Center
1977).
d, U.S. Department of Commerce, Maritime Ad-
m i n i s t r a t i o n , S t a t u s o f LNG P r o j e c t s
(Washington, D. C.: U.S. Department of Com-
merce, Maritime Administration, September zGInterview with official of General Dynamics Com-
1976). pany, Boston, Mass., June 15, 1977.
14 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

By comparison to the better known crude a small percentage of the LNG cargo is re-
oil tankers, the largest LNG ships are one-half tained in the tanks for cooling purposes and
to one-fourth the total size of the very large this supplies part of the fuel requirements for
crude carriers (VLCC or “supertanker’ ) the return trip.
(figure 11), some of which are more than The tankers are equipped with specialized
400,000 deadweight tons. A 130,000 cubic
systems for handling LNG and for combating
meter LNG tanker with a 143-foot beam and a
potential hazards associated with liquid
900- to 1,000-foot length is roughly equivalent spillage and fire. These include high-expan-
to a 100,000-deadweight ton oil tanker. sion foam and dry powder fire protection
The LNG tanker is a shallow draft vessel, systems, water-spray systems for flooding
about 36 feet, on which the cargo-carrying deck piping, and pressure-, temperature-, and
capacity is increased by adding to the length leak-monitoring systems. Cargo handling
instead of the depth. It has an unusually large systems are provided for loading and dis-
amount of freeboard, rising about 50 feet out charging LNG, for cooling down and warming
of the water. Because of its visible length and up tanks, for transmittal of boiloff gas to the
height, the LNG tanker appears larger than ship boilers and, most importantly, to provide
some VLCCs. inert atmospheres in the spaces surrounding
the cargo tanks and in the tanks themselves
The LNG tanker is a high-powered, high-
prior to and after aeration at the time of dry-
speed ship, with an optimum service speed in
docking.
the 20-knot range, about 5 knots faster than
most oil tankers. Each LNG tanker is a complicated vessel,
representing approximately a $100- to $150-
New LNG tankers are fueled by their own million investment.27 Most U.S. flag LNG
cargoes. Immediately upon being loaded in tankers are financed with a variety of aids
the tanker, LNG begins to evaporate and con- from the Maritime Administration, including
tinues to do so throughout the entire voyage. construction differential subsidies, operating
In a typical design, the vapor produced during differential subsidies, and ship mortgage
the voyage is used as the ship’s fuel and may guarantees.
be sufficient to meet 100 percent of the fuel re-
quirements. However, safety regulations re-
quire that the ship carry, and be equipped to zT’’General Dynamics Gets Tanker Job for $310
use, fuel oil as well. After the ship is unloaded, million, ’ Wall Street Journal, July 28, 1977.

Figure 11, Comparison of LNG Tanker and Crude Oil Tankers

A comparison of the Principal Dimensionsa, Cargo Deadweightb, and Full-Load Dlsplacement c of a 125,000 Cubic Meter LNG Ship and a Variety of Crude
Oil Tankers

80,000 dwt 100,000 dwt 137,000 dwt 125,000 cu/m 476,000 dwt 554,000 dwt
Oil Tanker Oil Tanker Oil Tanker LNG Ship Oil Tanker Oil Tanker

Length 811 848 974 936 1,243 1,359


Breadth 125 128 134 144 203 207
Depth 57 65 85 82 118 118
Draft 44 50 54 36 93 94
Dwt 80,459 100,300 137,010 63,100 476,025 553,700
Full-Load Displacement 105,000 128,500 172,500 94,500 509.000 631,000

‘IN FEET
b
lN LONG TONS
C
IN LONG TONS Source Engineering Computer Opteconomics Inc

CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 15

To date, the Maritime Administration has construction of liquefaction plants and re-
authorized approximately $270.3 million for lated facilities.) 29
subsidy of all LNG tankers. 28 (Federal finan- The construction cost of an LNG tanker is
cial aids are also provided by the Export-Im- roughly twice that of an oil tanker of similar
port Bank, although that aid is made availa- size. Most of the increased cost for LNG
ble to foreign governments in order to promote tankers is due to special design features of the
the use of U.S. goods and services in their proj- containment system which holds the low-tem-
ects. To date, the Export-Import Bank has perature, low-density cargo.
provided approximately $483 million in loans The standard 125,000 cubic meter LNG
and loan guarantees to Algeria to support tanker usually has five cargo tanks, each with
a capacity of about 25,000 cubic meters (figure
28’’$ubsidized Shipbuilding Contract Awards’ 12). An eight-story building could fit inside
Statistical Quarterly (First quarter 1977),
zgInterview with officials of Export-Import Bank of
the United States, Washington, D. C., June 16, 1977.

Figure 12. Inboard Profile of LNG Tanker

Liquefied natural gas tankers con-


structed by General Dynamics use five
spherical tanks of about 25,000 cubic meters
each Tanks for the ships are constructed in
South Carolina and towed by barge to the
shipyard at Ouincy, Mass , where they are
mounted into the ship hull

16 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

each of these large cargo tanks, which func- ters which are welded to the ship structure.
tion in the same way as the common Thermos
bottle. A cold product—LNG—is introduced With the membrane design (figure 15), the
into the container and the insulation sur- ship’s hull, in effect, becomes the outer tank.
rounding the tank (comparable to the vacuum Insulation is installed thereon, and a
jacket in the Thermos bottle) is the sole means membrane placed on the inside to retain the
by which the cargo is kept cold. No refrigera- liquid. The inner surface of this “double hull’
tion is employed on the LNG carrier. is either high nickel steel or stainless steel.
From the 15 or more cargo tank system The unique design problems associated
designs, two basic types have become most with LNG tankers stem primarily from the
common: the freestanding tank and the need to contain and insulate the extremely
membrane tank. cold LNG cargo and from the fact that many
materials such as mild steel will become brit-
The freestandin g tanks are self-contained, tle and fail at very low temperatures. Special
usually spherical or prismatic in shape, made materials used for the interior of cargo tanks
of aluminum alloy or 9 percent nickel steel must be able to withstand both the very low
with layers of insulation on the outside temperatures when filled with LNG and the
(figures 13 and 14). The tanks are welded to normal temperatures when empty. When
cylindrical skirts or otherwise tied to suppor- metals are subject to these temperature
Figure 13. Free-Standing Spherical LNG Tank

Source U S Maritime Administration


18 CI-I. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

changes of as much as 300 degrees, they ex- more cargo tanks and spill a large amount of
pand and contract and, in the case of free- LNG onto the water. A water spill would
standing tanks, the whole structure of the spread much farther and evaporate much
tank interior must be able to move within the more quickly than a land spill. While it is
ship. In addition, up to 2 feet of very efficient most likely that a collision would produce
insulation is necessary around each tank in some source of ignition which could fire the
order to minimize heat leak into the tank dur- LNG vapor around the ship, a huge vapor
ing the voyage from liquefaction plant to cloud could be generated if no ignition oc-
receiving terminal and back. curred.
So far, none of the containment systems in A critique of LNG tanker design and con-
use has been established as clearly superior to struction is included in the next chapter.
the others (figure 16), and it is too early in the
history of LNG carriers to have determined
meaningful life-cycle cost comparisons. LNG TANKER CERTIFICATION AND
However, each of the present systems is based REGULATION
on many years of design and testing, and
research is continuing into new containment The Coast Guard has primary responsiblity
systems using materials such as concrete and for the safe construction and operation of the
glass-reinforced plastic. LNG tankers and activities in ports where the
tankers call.
Safety analyses conducted for LNG projects
have constantly identified a ship accident as Under the Ports and Waterways Safety Act
the most likely event that could trigger the of 1972 and the Dangerous Cargo Act of 1970,
most serious type of LNG accident. A ship col- the Coast Guard is required to establish and
lision could result in the rupture of one or enforce design and construction standards for
Figure 16. Comparative Characteristics of Some LNG Tank Systems

Safety in event of vessel Safest system in event of grounding


grounding/collision or or collision — tank structure
other emergency. independent of hull and most void
space between vessel hull and cargo
tanks. Spherical tanks can be
pressurized for emergency discharge
in case of cargo pump failure.

Reliability of Containment Most ship years operating Tank system easiest to analyze
System. - experience and most experience structurally: therefore can be made
without primary barrier failure. most reliable,
Structure can be analyzed and
risk of fatigue failures minimized.
Tanks can be constructed and
100% inspected prior to instal-
lation in vessel.

Source National Maritime Research Center


CH. I – DESCRIPTION OF LNGT ECHNOLOGY AND IMPORT SYSTEM 19

U.S. flag LNG tankers and foreign flag LNG fighting capability, and personnel perform-
tankers entering the 3-mile territorial waters ance. Serious problems, such as any involving
of this country. It does so by letters of com- inoperative safety equipment, leaking cargo
pliance for foreign vessels and certificates of piping, or nonexplosion-proof electrical in-
inspection for U.S. vessels. stallations, may require immediate correction.
Minor problems may require correction prior
The criteria used for both are essentially to a return trip to the United States.
the same, however, Federal regulations which
are specifically applied to U.S. flag ships are If the vessel meets all applicable require-
simply used as guidelines for foreign ships. ments, a Letter of Compliance will be issued
and the vessel must continue to meet the
The Letter of Compliance program which is standards of the first visit on all subsequent
now in operation requires that the Coast
calls at U.S. ports. To assure continued com-
Guard review the vessel with respect to cargo pliance, the Coast Guard makes a less exten-
containment, cargo safety, and the safety of sive examination of the vessel each time it en-
life and property in U.S. ports. Features ters U.S. ports.
covered by the review include: 30
The Coast Guard requirements for the

design and arrangement of cargo tanks design, construction, and testing of U.S. flag
and cargo piping and vent systems; vessels are contained in 46 CFR 38. New

arrangement and adequacy of installed regulations are being drawn up but are not yet
fire extinguishing system and equipment; complete. The Coast Guard has also proposed
regulations which would set minimum stand-

safety devices and related systems which ards for persons employed on U.S. flag LNG
check the cargo and surrounding spaces ships and is working with international
to give warning of leaks or other disor- groups to develop standards for foreign crews.
ders which could result in a casualty; The regulations now in effect cover ship

isolation of toxic cargoes; stability and survivability, ship hull
materials, gas dangerous areas, electrical ar-

compatibility of one cargo with another rangements, firefighting arrangements, ven-
and with the materials of the contain- tilation, cargo containment systems, tem-
ment system; and perature and pressure control, and instrumen-

suitability of electrical equipment in- tation of the ship. They also cover systems
stalled in hazardous areas. relating to the transfer of LNG, such as the
means of loading and offloading the cargo,
The review is accomplished by inspection of piping materials, piping insulation, valving,’
detailed plans and specifications submitted in instrumentation, construction, and testing of
writing by the vessel owner, inspection of the systems.
documentation that the vessel is accepted by a
recognized foreign classification society whose Inspections for compliance with these
standards provide the same degree of safety as standards are carried out during construction
comparable U.S. standards, and inspection of of the vessels. In general, requirements result
the ship itself on its first visit to a U.S. port. in the design of ships which the Coast Guard
Coast Guard boarding parties examine the believes to meet a consistent and reasonable
vessel’s arrangement and cargo systems, level of safety and provide for means of deal-
tanks, piping, machinery, and alarms. They ing with casualties such as tank overfilling,
also observe the condition of the vessel, vessel overpressuring, and emergency shutdowns. In
operation, cargo handling operations, fire- general, the vessels are designed t O S u r v i v e
two-compartment flooding from collision or
tollepartxnent of Transportation, U.S. Coast Guard, stranding with reserve stability. They are not
Liquefied Natural Gas, Views and Practices Policy and designed to withstand a major collision or
Safety (Washington, D. C.: Department of Transporta- stranding without cargo release, but the
tion, U.S. Coast Guard, Feb. 1, 1976), p. III-B (2).

20 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

design does limit the release to the tanks The Coast Guard claims jurisdiction over
directly involved in an incident. the entire portion of the LNG system that con-
nects the tanker to the distribution system.
In addition to minimizing the possibility of
Existing regulations give the Captain of the
collisions, strandings, or other incidents, the
Port authority to control and monitor LNG
Coast Guard has specified operational con-
waterfront operations. However, there cur-
trols on the vessels while entering, moored, or
rently are no Coast Guard regulations which
leaving a U.S. port. By regulations promul-
specifically apply to the terminal facilities.
gated under 50 USC 191, Executive Order
Development of these regulations is under-
10173, and the Ports and Waterways Safety
ways 34 and publication is expected in the fall of
Act of 1972, the Coast Guard Captain of the
1977.
Port has control over any vessel within the
territorial sea and may prescribe conditions
and restrictions for the operation of LNG TERMINAL TECHNOLOGY
waterfront facilities. 31 Under the regulations,
The proposed LNG import projects and
the Captain of the Port in Boston has drawn
projects to receive LNG which may come from
up an Operations/Emergency Plan 32 for LNG
Alaska require the construction of large ter-
shipments coming into the Everett, Mass.,
minals to receive and store the product and
LNG facility. Similar plans will be drawn up
for all LNG import terminals. The plan takes gasification plants to return the liquid to its
vapor form. A large terminal capable of sup-
into account the individual geographic
plying 500 million cubic feet of gas per day can
features and environmental characteristics of
represent an investment of more than $350
each import terminal and surrounding water-
million by the sponsoring companies.
way as well as the unique nature of the LNG
cargo. The result is a set of operational con- The technology for these terminals is an ex-
straints on LNG vessels in order to enhance trapolation of many small LNG peak shaving
port safety. These constraints may include plants which have been operating for years.
such things as the requirement for a Coast This technology has been proved opera-
Guard escort; enforcement of a “sliding safety tionally satisfactory for the small plants.
zone,’ which is an area around the LNG ship Even so, baseload LNG import terminals,
from which all other vessels are excluded as which are intended to provide a continuous
the LNG tanker proceeds to its berth; restric- flow of gas into commercial pipelines, are
tion of operations to certain times of day; designed to meet much more stringent re-
prohibitions against certain other types of quirements than smaller peak shaving units. 35
work, such as welding, or the transfer of other
types of cargo, such as LPG, during discharge Offloading of the LNG tankers is ac-
of LNG; and others.33 complished at a specially constructed pier
where the tanker is connected to pipelines by
The regulation of LNG tanker construction articulated unloading arms and the cargo is
and operations is discussed in the following pumped ashore (figure 17).
chapter.
The LNG is stored in large insulated tanks
on shore and later pumped to regasification
3133 C-FOR. $$6.04.8, 6.14.1 (1976), facilities before it enters the distribution
qz~partment of Transportation, U.S. Coast Guard,
The Port of Boston, LNG-LPG Operation/Emergency
Plan (Boston, Mass.: Department of Transportation,
U.S. Coast Guard, Mar. 29, 1977).
qqwpartment of Transportation, U.S. Coast Guard, Wbid., p. IV-4.
Liquefied Natural Gas, Views and Practices Policy and ssConversation with officials of Columbia LNG Cor-
Safety, p. IV-3. poration, Cove Point, Md., June 8, 1977.
CH. I – DESCRIPTION OF LNG Technology AND IMPORT SYSTEM 21
22 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

Figure 18. Aboveground LNG Storage Tank land, and Japan. The U.S. tanks were built for
peak shaving operations in New Jersey and
Massachusetts, but have since been aban-
doned in favor of other types of storage
because the units failed to perform satisfac-
torily.
In any type of tank, the one hazard most
often mentioned in connection with the
storage of LNG is a phenomena known as
“roll over.’
Peak shaving plants have a greater poten-
tial for rollover due to weathering of the LNG
and/or introduction of new LNG into a par-
tially filled tank.
Rollover refers to the convection or motion
of fluid which occurs when liquids of different
densities exist in a storage tank. If different
densities or stratification do occur within a
tank such that a denser and warmer liquid is
Source Scientific American. at the bottom of the tank and subject to heat
leak, that liquid can ultimately become
system (figure 18). The storage capacity of the
heated to the point that it is less dense than
tanks is roughly equivalent to twice the
the liquid above it, and it will be rapidly
capacity of a single LNG ship, but—unlike
moved by buoyant forces up the tank side
peak shaving storage tanks—the import ter-
walls to the surface. At this point, it ex-
minal tanks are intended to hold LNG only
periences a sudden decrease in pressure and
briefly.
being above its normal boiling point vaporizes
In either type of facility, the storage tanks very rapidly in large quantities causing a sig-
represent a significant portion of the costs, nificant pressure rise in the tank. As a result
and the gas industry has spent much time and of this rapid expansion, cracks or even tank
money in research to develop effective storage rupture can occur.
systems.
Currently, there are four storage concepts: However, industry research on rollover has
double-wall metal tanks, prestressed concrete been extensive, resulting in deliberate con-
tanks,’ frozen holes, and mined caverns. Tech- trolled mixing of the tank contents, selected
niques for storing liquids in aboveground top, side, or bottom filling, careful monitoring
tanks are well established and the LNG in- of the temperature of the LNG contents
dustry has drawn on these techniques. In ad- throughout the tank, higher design tank
dition, the tanks are surrounded by earthen pressures combined with low normal operat-
dikes. These dikes are a safety measure, in ing pressures, and improved venting. In addi-
that they could contain the entire contents of a tion, the potential of the phenomena occurring
tank in the event of a spill. However, they in- at a baseload plant is further reduced by an
crease the land requirements for aboveground operational practice of unloading tankers into
storage several times over. Much research has empty tanks, not partially filled tanks as can
focused on the idea of underground storage occur at peak-shaving plants.
tanks because little or no insulation other From the storage tanks, LNG is pumped to
than the earth appears to be needed and there the regasification plant where it is vaporized
is no need for diking to contain spills. by heating it. Frequently, the LNG is heated in
Underground storage tanks have been built systems using the naturally occurring heat in
for LNG in the United States, Algeria, Eng- nearby seawater. Other systems use process
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 23

heat from other equipment or have heat ex- LNG TERMINAL SITING
changers fueled with oil, electricity, gas, or
ambient air. None of the vaporizer systems is There are several factors related to pro-
obviously the most economical or technically posed LNG import terminals that set them
superior. The choice depends primarily on the apart from the existing peak shaving plants.
location and design of a specific terminal and The proposed terminals are large-scale opera-
environmental regulations. tions located in the coastal zone and major
shipping channels, some in major harbors-or
The regasification facility is one of the least
near large population centers (figures 19 and
costly sections of the terminal, but is con-
20). They require large amounts of land and
sidered important because if it should fail to
capital, and represent a large concentration of
operate, the entire purpose of the plant—to
energy at a single site.
provide natural gas —will have been defeated.
Figure 19. Layout of Cove Point, Md., LNG Receiving Terminal

Source Columbia LNG Corp


24 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

The location of a terminal can be a major requirement that an environmental impact


factor in its safety. The magnitude and extent statement (E IS) be prepared.
of any damage from an LNG spill can depend
As a part of the EIS, the National Bureau
on the proximity of the terminal and storage
sites to other industrial and residential areas. of Standards’ cryogenics division in Boulder,
Colo., u n d e r c o n t r a c t t o F P C , r e v i e w s
The site selection process is currently con- engineering and safety aspects of the proposed
ducted by the company or consortium propos- terminal. Also as part of the EIS, the FPC
ing the project. Gas industry officials consider staff prepare a quantitative risk analysis,
such factors as accessibility by large tankers, which is its principal method for determining
the availability of the market, which is largely whether a project can be considered safe. The
determined by the proximity of an existing risk analysis considers the major events which
pipeline network; costs of land acquisition; might cause an LNG spill, such as ship colli-
availability of skilled labor supply; and sion, grounding, or ramming; failure of the
availability of public facilities such as roads, unloading arms or other major pieces of
electricity, sewers, etc. Some companies also equipment; and damage to the facility from
consider area land-use characteristics and en- natural phenomena or unusual accidents. The
vironmental sensitivities important aspects of risk analysis determines the extent of damage
site selection. The FPC position is that, unless and the number of deaths and injuries which
otherwise stipulated, FPC approval of the may result from a disaster and the probability
facility allows Federal preemption of State that certain types of disasters would occur.
and local laws relating to siting. Therefore, The death probabilities from natural dis-
local and State land-use regulations could be asters are typically about 1 in 10 million. In
overruled. A company makes application to some recent applications, the FPC rejected a
the FPC only after it has done as much site because it posed a public risk to life with a
preliminary work as possible, which includes probability of greater than 1 in 10 million.
at least gaining control over, if not outright Therefore, that figure has become the infor-
ownership of, the proposed site. Thus, neither mal criteria which projects must meet for FPC
the general public nor the Federal Govern- approval. 36
ment become involved in the site selection
The FPC exerts its influence over the
decision until it has already been made by the
facilities by attaching stipulations to the cer-
company. There are, at present, no Federal tification of public convenience and necessity
siting criteria, and those projects which are
which it issues if the project is approved.
now proposed have a variety of sites, ranging
These stipulations are designed to minimize
from remote coastal and riverine areas with
environmental consequences and to promote
1,000-acre buffer zones to as little as a 90-acre
the safety of the facility. The applicant is re-
site on Staten Island.
quired to comply with these stipulations if he
accepts the certificate. Statements of com-
LNG TERMINAL REGULATION pliance and operating reports are required
regularly, but there is little or no post-cer-
The construction and operation of LNG ter- tification oversight by the FPC. Onsite FPC
minals are primarily regulated by three inspection generally occurs only when a com-
Federal agencies; the Federal Power Commis- pany wishes to expand its facilities and sub-
sion (FPC), and the Office of Pipeline Safety mits a new application. 37
Operations (OPSO), and the Coast Guard.
Federal Power Commission jurisdiction aG1nterV& with staff of Woodward-Clyde Consul-
over the terminals is included in the process of tants, Washington, D. C., June 28, 1977, and Federal
licensing import projects. The FPC considers Power Commission, Alaska Natural Gas Transporta-
tion System, R“nal Environmental Impact Statement,
approval of any LNG import project to be “a Vol. 111, p. 425d and 4253. (Washington, D. C.: Federal
major Federal action significantly affecting Power Commission, 1976).
the quality of the human environment” sub- 371nt,erview with staff of Federal Power Commission,
ject to the National Environmental Policy Act Washington, D, C., May 31, and June 24, 1977.
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 25

Figure 21. Storage and Diking at Onshore LNG Plant

Source El Paso LNG Terminal Co

The safety of the terminal facilities is ards. The standards are currently built
largely an OPSO responsibility. Under the around the safety code of the National Fire
Natural Gas Pipeline Safety Act of 1968, Protection Association, known as 59(A). In
OPSO is responsible for establishing addition to setting minimum standards for
minimum Federal safety standards for all materials, equipment, and systems the code
pipeline facilities in or affecting interstate or relies upon two basic concepts to protect the
foreign commerce. Pipeline facilities have public from LNG hazards: the requirement for
been given an extremely broad interpretation a diking and containment system and the re-
to include all components of an LNG import quirement that specific distances be main-
terminal, including the offloading facilities, tained between certain components and be-
storage tanks, regasification facilities and all tween components and the property line.
associated pipelines.
Dikes are the primary device used to pre-
Permits are not required by OPSO, which vent the uncontrolled spreading of an LNG
exercises its authority solely by inspecting spill on land (figure 21). The dikes make it
facilities for compliance with Federal stand-
— —-— —

26 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

possible to use either of two methods of con- pected that the proposed standards will
trol: seriously limit the choice of sites for LNG ter-
minals.
● In the event of an LNG spill, the liquid
can be contained within the dike and the The Coast Guard’s responsibility for ter-
rate of evaporation slowed by the use of minal facilities is an extension of the Captain
high expansion foam. All sources of igni- of the Port’s jurisdiction over waterfront
tion can be eliminated. In this way, the facilities. The Coast Guard maintains that its
LNG can dissipate in harmless con- jurisdiction, with regard to LNG vessel move-
centrations into the atmosphere. ments and waterfront facilities, is sufficient to
promulgate and enforce safety requirements
● Or, in the event of an LNG spill, the liq- for the LNG transfer operations at the receiv-
uid can be contained within the dike and ing terminal and, in that light, considers the
its evaporation controlled or even ignited pipelines between tanks and loading or
so that it immediately burns in the con- offloading equipment, the loading and
fined space where the fire can be con- offloading equipment, storage tanks, and the
trolled by known firefighting methods. entire portion of the LNG system which con-
The NFPA 59(A) regulations currently nects the tanker to the distribution system to
adopted by OPSO specify the size and con- be under its jurisdiction. The inland distribu-
struction of the dike and the design of related tion system is not the responsibility of the
equipment necessary for the diking system. Coast Guard.
The Coast Guard currently has no regula-
The other technique used to enhance safety
tions specific to LNG terminals but has under-
is to establish the distance which must lie be-
taken development of such regulations to im-
tween the dikes around the storage tanks and
plement appropriate sections of the Ports and
the property line. The distance required is one Waterways Safety Act of 1972. In the mean-
which would assure that heat from an LNG time, the Captain of the Port in each area
fire inside the dikes would not be severe where LNG is handled exercises authority by
enough at the property line to cause death or developing contingency plans for operations.
third degree burns.
A critique of the Government role in the
Current regulations require that this dis- regulation of LNG terminal siting and opera-
tance be 0.8 times the square root of the area tions is included in the following chapter.
inside the dikes.
Regulations also require that the facility be
TRENDS IN LNG USE AND
designed to meet the maximum earthquake
specifications of the Uniform Building Code. FACILITIES

New LNG terminal standards have been Liquefied natural gas could be an impor-
proposed by OPSO and are being circulated tant short-term energy supply for the United
for public comment. Generally, the proposed States over the next few decades and could
standards are more strict and cover more help alleviate some near-term fuel shortages
aspects of terminal design than do current in selected sectors of the economy. Ultimately,
standards, but in many cases they are less however, the supply of natural gas which may
definitive. The standards increase the dis- be sold to the United States as LNG is limited.
tance between dikes and property line, require LNG is not a major new source of energy
a vapor dispersion zone or a redundant which will allow unrestrained use of natural
automatic ignition system, and set more gas, and it is unlikely that many import proj-
stringent seismic design criteria. 38 It is ex- ects will be forthcoming beyond those already
proposed.
SNU.S. llepartrnent of Transportation, Office of
Pipeline Safety Operations, “Liquefied Natural Gas
Facilities (LNG); Federal Safety Standards,” Federal
Register 42, no. 77, April 21, 1977, 20776-20800.
— —

CH. I – DESCRIPTION OF LNGT ECHNOLOGY AND IMPORT SYSTEM 27

In the future, it can probably be expected in Chile, Nigeria, and Colombia and there is a
that U.S. consumption of natural gas will con- possibility of additional export projects if
tinue to decline slightly and it is possible as technology and reserves are proven in Russia,
much as 15 percent of the total natural gas Iran, China, and Australia. 39 It is likely that
consumed could be transported as LNG by sponsors of some U.S. import projects will
1985-95 (figure 22). This figure may be lower turn to these exporters for additional supplies
if a pipeline is used to transport Alaskan gas of LNG, thus reducing the dependency on
to the continental United States. Algeria.
Imports of LNG to the United States cur- Changes are also likely to occur in the sites
rently come from Algeria, and there is some chosen for U.S. import terminal facilities, in
concern about the wisdom of becoming de- some types of equipment which may be used,
pendent upon any one country as the major and in the onshore distribution of LNG.
source of supply. However, several other coun- Currently, public pressure exists for, and
tries also control major portions of the world’s the industry trend is toward, “remote” siting
natural gas reserves. For example, liquefac- of LNG terminals and storage facilities. Con-
tion and export facilities are being developed troversy over the meaning of remote and the
Figure 22. Projected Future LNG Imports (Based on characteristics which make a site acceptable
Proposed Projects and Reasonable Approval for an LNG facility, coupled with the difficulty
Time) firms may have in finding acceptable sites,
Trillions Percent of 1976 have led to the suggestion that LNG facilities
of cubic feet U.S. Natural Gas
per year Consumption could be located offshore, away from popu-
lated areas and congested harbors and water-
4 20% ways.
Several designs have been proposed for
15% offshore platforms to house LNG facilities, but
no detailed design has been developed for any
specific site. At the present time, these
10%O preliminary designs limit site selection to
locations with water depths of 600 feet. Most
of the design concepts are self-contained
5 %
facilities which look like large floating barges
installed to a mooring system (figure 23).
Other concepts propose that the platforms be
floated to a site, then grounded to the beach or
1977-80 1980-85 1985-90 seabed. There are also two other, more elabor-
Projects Planned Possible ate concepts: One would make use of subsea
Constructed Projects New storage structures, similar to those used in the
or Operating Approved Projects North Sea to store oil, with a semisubmersible
or Pending
Before FPC
or tension-leg concrete platform moored
above for the liquefaction or regasification
plant. The other features separate moored or
El Paso I
Distrigas
jack-up platforms for the process plant and
the storage structures.
El Paso II
Panhandle According to industry figures, offshore
Pac/lndonesia facilities will require 3 to 4 years construction
time. Crude estimates range from $175 million
Possible Future Supplies From
USSR, Iran, and Nigeria
39JJLNG Report, ’ ~“peline and Gas Journal 204

(June 1977).
Source OTA
28 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

Figure 23. Artist’s Rendering of Offshore LNG Terminal

to $220 million for a receiving terminal with a limited operating experience now available,
500 million cubic feet per day regasification no particular designs for either ship cargo
plant and storage for 200,000 cubic meters systems or onshore storage facilities have yet
and from $350 million to $425 million for a emerged as obviously superior. Therefore, it is
500 million cubic feet per day 40 liquefaction likely that a variety of equipment will come
plant. into use as more projects are approved.
There are many designs for LNG tankers It is also possible that increased use of LNG
and onshore facilities. However, with the will result in increased onshore transporta-
tion of LNG to secondary markets by means
4{)1bid. other than pipeline. Although the proposed
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 29

baseload import terminals have no specific EXISTING AND PROPOSED


provisions for truck and rail shipment of PROJECTS, IN BRIEF
LNG, such shipments appear to be possible
and permissible in the future. Shipment by There are two operating LNG marine
truck is already a reality at most peak shaving transport projects in the United States today,
operations and from the import terminal at the “Distrigas” project importing gas from
Everett, Mass. Algeria into Everett, Mass., and the
Prior to 1969, only a few LNG trucking “Phillips/Marathon’ project exporting gas
operations had been attempted in this coun- from Alaska to Japan. Construction of the
try, using equipment originally designed for first large baseload import project to be ap-
liquid nitrogen service. Based on the success proved by FPC, “El Paso I,” is nearing com-
of the operations, equipment was designed pletion, and the facility is expected to become
and fabricated especially for LNG. It is esti- operational early in 1978 importing gas from
mated that there are 75 LNG trucks currently Algeria to both Cove Point, Md., and Elba Is-
in operation in the United States. 41 Typical of land, Ga., (near Savannah). 42
the trucking which has taken place was the One additional large import project has re-
shipment of nearly 4.5 million gallons of LNG cently been given final approval by FPC, but
from Philadelphia, Pa., to Lowell, Mass., dur- no construction has begun. This is the
ing the winter of 1969. Since then large “Trunkline’ project to import LNG from
volumes have been transported all over the Algeria to Lake Charles, La. 43 The “Pacific-
United States to help supply outlying com- Indonesia’ project to import LNG from In-
munities, to provide temporary supplies when donesia to Oxnard, Calif., 44 has received only
service is interrupted, and to provide small initial FPC approval and no construction has
quantities for experimental work. begun.
Liquefied natural gas could also be moved Three additional projects have been filed
from import terminals or liquefaction plants with the FPC for some time and decisions or
by barges or railway tank cars. approvals are expected soon. These are: the
The use of barges was first proposed to “El Paso II*’ project to import LNG from
transport LNG up the Mississippi River to the Algeria to Port O’Connor, Tex., the “Pacific-
Chicago Union Stockyards, and one barge was Alaska” project to transport LNG from Cook
constructed and tested for this purpose in the Inlet in southern Alaska to California; and
1950’s. It was never used commercially. the “El Paso-Alaska” project to transport the
Another barge, the 297-foot Massachusetts, huge North Slope Alaska gas reserves from
was constructed by Distrigas for distributing Gravina Point, Alaska (after pipelining from
LNG from a Staten Island import terminal. the North Slope) to California. 45
However, that barge has been taken out of Since these eight projects have a reasonable
service because of opposition. probability of being operational in the future
Railway tank cars have been proposed as a (the early 1980’s), a brief description of each is
means of carrying LNG to isolated areas included in this section. Other planned or pro-
which do not justify construction of pipelines.
q~Dean Hale, “Cold Winter Spurs LNG Activity,”
Tank cars now in use hauling liquid oxygen, Pipeline and Gas Journal 204 (June 1977): 30.
nitrogen, and hydrogen would be suitable for q:~Federal Power Commission, TrunkZine LNG Corn-
LNG service, but the economics are such that p a n y et al., O p i n i o n N o . 7 9 6 - A , D o c k e t N o s .
it is unlikely there would be much emphasis CP74-138-140 (Washington, D. C.: Federal Power Com-
on rail movement of LNG. mission, June 30, 1977).
~~Federal Power Commission, “FPC Judge Approves
Importation of Indonesia LNG,” News Release, No.
23292, July 22, 1977.
~ I Interviews with officials of Distrigas Inc., Boston, ~~Dean Hale, “Cold Winter Spurs LNG Activity,”:
, Mass., June 15, 1977. 31.
30 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

posed projects have not been included for This report reflects the situation as of the
various reasons. For example: the “Eascogas’ summer of 1977. Many other projects are in
project which was planned for Staten Island, the early planning states. Many factors affect
N. Y., and Providence, R. I., terminals has been these plans, however, and changes are com-
delayed so many times that its viability is in mon prior to actual construction of facilities.
question. A project planned by Tenneco to im-
port gas from Algeria to St. John’s, N. B., in 1. The Distrigas Project (figure 24)
Canada, and then pipe the gas to the United
State 46 is now in the early review stages by This project has been in operation since
FPC. Another recently announced project is 1971. The 50,000 cubic meter LNG tanker
one by the Peoples Natural Gas Company of D e s c a r t e s is now on a regular delivery
Chicago to import LNG from either Iran or schedule on approximately a 20-day cycle. 4 8
Chile to a terminal near Corpus Christi, The ship, which was built in France in 1971
T e x . 47 and operates under the French flag, 49 h a s

AGIbid., p. 31. A~Interviews with officials of Distrigas Inc., Boston,


ATFederal Power Commission, “NGP-LNG Inc., Ap- Mass, June 15, 1977.
plication and Request for Phased Proceeding,” Federal AgU.S. Department of Commerce, Maritime Ad-
Register 42, No. 131, July 8, 1977. ministration, Status of LZVG Vessels (Washington, D, C.:
U.S. Department of Commerce, March 1977).

Figure 24.
Project Data Sheet: Distrigas
Import Source: Skikda, Algeria
Import Terminal: Everett, Mass.

Contract FPC Number Ships/ Estimated investment ($106) Estimated


Location Expected volume status Shipyard/ price ($)
Companies revolved of u s Project operational Bcf/yr (as of 3
Capacity m / Receiving delivered into
terminal designation date (M Mcfd) 9/1/77) Tank design Tankers
— terminal
— pipeline/MMBtu
Supplier. Sonatrach
(Algerian National
Gas Co ).
Shipper. Alocean Everett, Distrigas I Operational 16 Approved 1/Chantier- — 33 1.90
(Sonatrach subsidiary). Ma, since 1971 (43 6) 1972, Atlantique l
Reopened (France)/
1974, 50,000 m3/
Approved membrane
U S. Importer: Distrigas 1977
Corp
Distributors: Various Everett, Distrigas 1977 (1,5 16 total — 2.80
gas companies in New Ma, Ill yr. supple- (43.6) Pending
England, New York, and mental con-
New Jersey tract)
Supplier. Sonatrach. Everett, Distrigas
2
1978 42 Filed 1/Chantiers- — 9–lo 2.91
Importer Distrigas Ma, Iv (115) Feb. Ciotat (added
(Project pending), 1977 (France)/ investment)
125,000 m3/
Spherical
free-standing

CURRENT IMPORT TERMINAL CHARACTERISTICS 1 The 50,000 cubic meter ship “Descartes’ wiII be taken out of
Storage capacity Regasification Type of storage Number of Terminal
service upon arrival of the latest contract (Distrigas IV).
(MMcf) capacity (MMcfd) containers storage tanks acreage
2
The Distrigas I and Ill projects will be phased into the Distrigas IV
project when the latter commences
3250 —
135 Aboveground – -
2 37
9% nickel steel Source OTA
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 31

been delivering LNG from Skikda, Algeria, to and total import volume has been filed and is
the terminal at Everett, Mass., at the rate of pending approval by FPC. Under the terms of
about 15 trips each year. The terminal is lo- a new 20-year contract with the Algerian Na-
cated on the Mystic River, up from the main tional Gas Company, Distrigas would import
Boston harbor and less than one-half mile 42 billion cubic feet of gas per year beginning
from the Boston city limits, in a highly in- in 1978. 53 This contract would replace the ex-
dustrialized region with both LPG and isting one and a new 125,000 cubic meter ship,
gasoline terminals adjacent to the property. so the Mostefa Ben Boulaid, would be used in
place of the Descartes. Additional unloading
The Everett facility has operated without
facilities, but no new storage tanks, are
major incident for 6 years.
planned for this expansion. 54
The principal market for this LNG is the
Northeastern States with distribution made 2. The Phillips/Marathon Project
by both truck and pipeline. At present 40 per- (figure 25)
cent of the LNG is distributed by trucks and
more than 60 trucks operate out of the facility The oldest operating marine LNG project in
to other satellite storage tanks in the North- the United States is the project now exporting
east. 51 The Distrigas project has contracted gas from fields in Cook Inlet in southern
for a supply of 16 billion cubic feet of gas per Alaska, through a terminal at Kenai, to
year, and in 1976 actual imports totaled Neigishi, Japan. This project has been oper-
slightly over 10 billion cubic feet. 52 ated by the Phillips Petroleum Company and
Marathon Oil Company since 1969.
While this project has received FPC ap-
proval, a modification to expand the terminal Two 71,500 cubic meter LNG tankers, the

~t}Interviews with officials of Distrigas Inc., Boston, ~:~Dean Hale, “Cold Winter Spurs LNG Activity,”:
Mass., June 15, 1977. 30.
,5 I Ibid. ~qlnterViews with officials of Distrigas Inc., Boston,
~~Federal power Commission, United States 1772pOr~S Mass, June 1
and Exports of Natural Gas 1976 (Washington, D. C.:
Federal Power Commission, May 1977).

Figure 25.
Project Data Sheet: Phillips/Marathon
LNG Export Source: Kenai, Alaska (Plant at Nikiski)
LNG Export Terminal: Neigishi, Japan
Kenai to Neigishi – 3,280 nmi I
— —-
Contract FPC Number Ships/ Estimated Investment ($10°)
Location Expected volume status Shipyard/ — — —
Companies Involved of u s Project operational Bcf/yr (as of Capacity m3/ Receiving Exported price
facility
— designation date (MMcfd)
. 9/1/77) Tank design Tankers terminal ($)-1976 /MMBtu
Gas Supplier: Phillips
and Marathon Plant.
Operator: Phillips
Petroleum Kenai. Phillips/ Operational 49,3 Approved 2/K, M, – —
Shipper: Marathon Oil. Alaska Marathon since 1969 (135) Verkstads 1 66
Importers Tokyo Electric, 1 5-year (Sweden)/
Tokyo Gas. contract) 7 1 , 5 0 0 m3 / –
— — membrane
CURRENT EXPORT SOURCE CHARACTERISTICS
Storage capacity Liquefaction Type of storage Number of Facility
(MMcf) capacity
— (M Mcfd) containers storage tanks acreage
2300 185 Aboveground 3
aluminum
Source OTA
32 CH. 1 – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

Arctic Tokyo and the Polar Alaska, were built the Jones Act prohibiting the use of foreign
in Sweden and operate under the Liberian flag tankers in U.S. trade. A French-built
flag with Italian crews. 55 3,5,000 cubic meter tanker, the Kenai Multina,
flying the Liberian flag was used. 57 This proj-
The contract to supply Tokyo Electric and
ect contract expires in 1985. Beyond that, ap-
Tokyo Gas companies is for 135 billion cubic plication may be made to bring the gas to
feet of gas per year, and in 1976 about 50 southern California.
billion cubic feet were actually delivered. 56
This project has operated without a major
3. The El Paso I Project (figure 26)
problem since initiation.
During the extreme winter of 1977 a special The agreement between El Paso Natural
delivery of one shipload of LNG was made to Gas Company and Sonatrach (Algeria) will
Everett, Mass., from Alaska, after a waiver of lead to the initial transport of the LNG

MU.S. Ilepartrnent of Commerce, Maritime Ad- s~ean Hale, “Cold Winter Spurs LNG Activity ”,:
ministration, Status of LNG Vessels. 21.
sGFederal Power Commission, United States Imports
and Exports of Natural Gas 1976.

Figure 26.
Project Data Sheet: El Paso I
Import Source: Arzew, Algeria
Import Terminal: Cove Point, Md. and Elba Island, Ga.
Arzew to Cove Point– 3,570 n mi
Arzew to Savannah – 3,77o n mi I
Contract FPC Number Ships/ Estimated Investment ($106) Estimated
Location Expected volume status Shioyard/ .-—————–— price ($)
Companies involved of u s Project operational Bcf/yr (as of Capacity m3/ Receiving delivered iinto

terminals designation
—— dale (MMcfd) 9/1/77) Tank design Tankers terminal pipeline/MMBtu
Suppliers: Sonatrach 3/Chantiers-
(Algerian National Dunkirk
Gas Co. ) Cove Point, 3651 Approved (France)/
Shipper: El Paso Algeria Md (1000) 1972, 125,000 m3/ 350 1.66-181
Corp. 1973: membrane (Cove
Reopened Point)
Cove Point purchasers: 1974
Consolidated System
LNG Co and Columbia El Paso I 1978 Approved 3/Avondale 1100
LNG Co. (also operators) 1-1977 (U.S.A.)/ for all
3

Elba Island purchasers: 125,000 m / 9 ships


Southern Energy Co Free-standing 127 1.70
(also operators) Elba Island, Prismatic (Elba Is, )
Drstributors Columbia Gas Ga.
Transmission Corp., 3/Newport
Consolidated Gas (U.S.A.)/
Supply Co., Southern 125,000 m3/
Natural Gas Co Technigaz
membrane

CURRENT IMPORT TERMINAL CHARACTERISTICS 1


Of this amount. Cove Point shall
Storage capacity Regasification Type of storage Number of Terminal — receive about two-thirds,
Location (MMcf) capacity (MMcfd) containers storage tanks acreage I Elba Island one-third

Cove Point, Md. 5000 1000 Aboveground, 4 60 (plant, structures)


aluminum 300 acres allocated
1100 acre tract
Elba Island, Ga. 4000 325 — 3 150 acres allocated
800 acre tract
Source OTA
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 33

equivalent of 1 billion cubic feet per day (365 Nine 125,000 cubic meter LNG tankers are
billion cubic feet per year) of natural gas to to be used to serve both El Paso I terminals.
the United States. Three tankers were built in France, are now
completed and laid-up, and are planned to be
The Columbia Gas System, along with the operated by El Paso under the Liberian flag.
Consolidated Gas System, has entered into
Six others are under construction at two U.S.
contract for some two-thirds of this gas. The shipyards (Avondale and Newport News), and
LNG will be delivered to a terminal located
are planned to be operated by El Paso under
on the Chesapeake Bay at Cove Point, Md.
U.S. flag. 6l
The terminal will be jointly owned by Colum-
bia and Consolidated and will become opera- The entire project is about 2 years behind
tional early in 1978. The remainder of LNG schedule. The principal technical problem
will be delivered to Southern Natural Gas at a was completion of the large liquefaction
new terminal under construction on Elba Is- facilities in Algeria. After one U.S. contractor
land, Ga. 58 failed to perform, the Algerian National Gas
Company canceled the contract and hired a
The Cove Point terminal has two tanker
new contractor. The U.S. terminals and the
berths, four storage tanks and several process
U.S.-built tankers are now almost completed,
areas. The two tanker berths are located
after a slow-down to await completion of the
about 1 mile offshore along a 2,500-foot pier
Algerian terminal. The present schedule is for
which is connected to shore by an under-
LNG shipments to begin in January 1978. 62
ground tunnel containing both LNG pipes and
vapor return lines. The initial operating plans The FPC approved the El Paso I project in
call for about 140 ship arrivals per year. The June 1972.
Cove Point facility is located on a 1,100-acre
tract of land along the Chesapeake Bay in 4. The “Trunkline’’Project (figure 27)
Calvert County, Md. 59
The Trunkline project was approved by
The gas will be piped from Cove Point to an FPC on June 30, 1977, after an appeal of an
existing pipeline in Loudoun County, Va., and initial opinion in April. 63
then to markets in middle Atlantic States
served by Columbia and Consolidated The proposed LNG facility would be near
Natural Gas Companies. the Lake Charles Harbor in Louisiana and
within the Terminal District Industrial Park.
The Elba Island terminal is on an 800-acre It would be located on a 139-acre site and
site of undeveloped land, wholly owned by would be used to unload, store, and ship LNG
Southern Natural Gas. It is located 5 miles
imported from Algeria. The LNG terminal
downriver from Savannah, Ga., and will sup-
would consist of a berthing dock for LNG
ply gas to southeastern U.S. markets. This
unloading, an onshore facility consisting of
LNG is expected to represent about 15 percent
three 600,000-barrel LNG storage tanks sur-
of Southern Natural Gas sales when the ter- rounded by a dike, two 25,000-gallon liquid
minal is operational. It is planned that 50
nitrogen storage tanks, one 250,000 Bunker C
LNG tankers will call at the Elba Island ter-
fuel-oil tank for servicing the LNG tankers,
minal each year, substantially increasing the
and a process area which would contain
ship traffic at the Savannah port entrance. GO
equipment for all LNG transfer operations.

Wbid., p. 30. GIU.S. Department of Commerce, Maritime Ad-


~gMax Levy, “The Cove Point, Maryland LNG Ter- ministration, Status of LNG Vessels.
minal,” Conference on LNG Importation and Terminal 621bid.
Safety, Boston, Mass., June 13-14, 1972. 63Federal Power commission, Trunk/ine LN(j corn.
GoSouthern Natural Gas Company, Facts on Elba Is- pany et al., O p i n i o n N o . 7 9 6 - A , D o c k e t N O S.
land, Savannah, Georgia LNG Terminal, (n. p.: CP74-138-140 (Washington, D. C.: Federal Power Com-
Southern Natural Gas Company, n.d. ). mission, June 30, 1977).
——

34 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORTS SYSTEM

Figure 27.
Project Data Sheet: Trunkline
Import Source: Arzew, Algeria
Import Terminal: Lake Charles, La.

Contract FPC Number Ships/ Estimated investment ($106) Estimated


Location Expected
Companies Involved of u s Project operational
terminal designation date
- -
Supplier Sonatrach ‘- “ –

(Algerian National
Gas Co. )
Terminal builder & Lake “Panhandle’ 1980-81
operator Trunkline Charles, ‘‘Trunkline”
LNG Co La ‘‘Calcasleu’
Buyer & distributor 3/125,000 m3/
Trunkline Gas Co shipyard &
(Subsidiary of Panhandle design not
Eastern Pipeline Co) known
Market Illinois. Indiana,
Michigan, Ohio (primarily)

CURRENT
. . IMPORT TERMINAL CHARACTERISTICS
Storage capacity Regasification Type of storage Number of Terminal
(MMcf) capacity (MMcfd) containers storage tanks acreage
6000 540 Above-ground, 75 (plant,
aluminum 3 structures)
(139 acre site)
Source OTA

Ancillary facilities would include offices, ships are to be built at General Dynamics’,
equipment for wastewater treatment, fire con- Quincy, Mass., shipyard. The three other
trol and detection, fire protection equipment, vessels for this project are expected to be pro-
water supply, electrical power, and com- vided by the Algeria National Shipping Com-
munications. 64 p a n y .66
The project is planned for importing 179
5. The “Pacific Indonesia” Project
billion cubic feet of gas per year using five
125,000 cubic meter LNG tankers. The (figure 28)
tankers would reach the facility at the arrival
In an initial decision on July 22, 1977, an
rate of 65 per year through a 24-mile channel
FPC Administrative Law Judge approved a
from the Gulf of Mexico.65
proposal to import 200 billion cubic feet of gas
Subsidiaries of Panhandle Eastern Pipe per year from Indonesia to a terminal in Ox-
Line Company, G e n e r a l D y n a m i c s , a n d nard, Calif. The decision is subject to Commis-
Moore-McCormack Bulk Transport, Inc., sion review. 67 There is considerable contro-
have formed a partnership, Lachmar, to build, versy in California over the site, and some
own, and operate two of the ships. These two State legislation on siting is pending.

6 4 Federa] power commission, Flnaz ~nuironmental GGDean Hale, “Cold Winter Spurs LNG Activity,”:
Impact Statement Calcasieu LNG Project Trunkline 30.
LNG C o m p a n y D o c k e t N o . CP74- 138 et al., ~TFederal Power Commission, “FPC Judge Approves
(Washington, D.C.: Federal Power Commission, Sep- Importation of Indonesia LNG.”
tember 1976).
b51bid.
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 35

Figure 28. Oxnard, Ca


Project Data Sheet: Pacific-Indonesia
Indonesia Sumatra,

Sumatra 10 Oxnard – 8,300 n ml


Contract FPC Number Ships/ Estimated investment ($106 Estimated
Expected volume status Shipyard/ — price ($)
3
Project operational Bcf/yr (as of Capacity m / ‘Receiving delivered into
designatlon date (MMcfd) 9/1/77) Tank design Tankers terminal pipeline/MMBtu
61U.S.A.)/ 155 per
1 2 5 , 0 0 0 m 3 / U S Tanker
shipyard &
48 months 200 Initial tank design
Pacific-
approval not known
Indonesia after approv- (550)
Project al (Liquefac- 6-77, sub-
tion facilities ject to review
m Indonesia 2/ Chandlers- 270 306-360
under con- Atlantique
struction) (France)/
125,000 m3/
membrane
1/Chantiers-
Ciotat/
125,000 m3/
Free standing
spherical

PROPOSED IMPORT TERMINAL CHARACTERISTICS


.
Storagecapacity Regasification Type of storage Number of Terminal
(MMcfi) capacity (MMcfd) containers storage tanks acreage
7700 4600 Above-ground, 4 Plant, -
90/0 nickel steel structures
38 (ulti-
mately 55)
21 O-acre
— site
Source OTA

The proposed Oxnard facility would be transfer the LNG from the ship to the storage
owned and operated by Western LNG Ter- facilities through 42-inch cryogenic pipes. 68
minals. It would be located on a 210-acre site Liquefaction facilities in Indonesia are now
in the City of Oxnard, on the coast of Califor- under construction.
nia. This plant would import LNG at a rate of
546 million cubic feet of gas per day for Conditional agreements have been reached
markets within the State of California. The with shipping companies for nine 125)000
LNG storage and vaporization facilities would cubic meter LNG tankers. Pacific Indonesia
occupy 38 acres of the site containing two to will charter the ships, three of which will be
four 550,000-barrel, double-wall, above- French built and the remaining six U.S.
-ground tanks, 240-feet in diameter with an built. 69 No U.S. ship construction contract has
overall height of 129 feet. The plant facilities been announced.
would require 55 acres of the site, and the
marine terminal would occupy 34 acres of 68 Federa] power commission, Final Environmental
leased subtidal land extending approximately Impa et Sta tern en t Pacific Indonesia Project
6,000 feet offshore at Ormand Beach. Unload- (Washington, D. C.: Federal Power Commission, Decem-
ing arms at the marine terminal would ber 1976).
fi~u.s. Department of Commerce, Maritime Ad-
ministration, Status of LNG Vessels.
36 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

6. The El Paso II Project (figure 29) 7. The “Pacific-Alaska’’ P roject


(figure 30)
The El Paso II project is pending before the
FPC. The proposal is to transport 365 billion A project to transport LNG from Cook Inlet
cubic feet of gas per year from Algeria to a gas fields near Kenai, Alaska, to California is
new facility at Port O’Connor, Tex. TO A fleet pending before FPC. 73 A terminal is planned
of twelve 125,000 cubic meter LNG tankers at either Oxnard or Los Angeles, Calif. Ques-
would be required. It is planned that six of tions of terminal siting now being addressed
these would be U.S. flag and U.S. built, but no by the State of California are delaying some
construction contracts have been an- decisions on this project. It is planned that ini-
nounced. 71 Safety reports have been submit- tially two 130,000 cubic meter tankers would
ted and FPC hearings were held during the be used to import 73 billion cubic feet of gas
summer of 1977. Draft and final environmen- per year. Sun Shipbuilding Company has
tal impact statements have been issued. 72 signed contracts for these ships with an affili-

~[~Federa] Power Commission, Algeria 11 Proj”ect Out- ~JDean Hale, “Cold Winter Spurs LNG Activity,”:
line of Contracts, El Paso Eastern Company, et al., 31.
Docket No. CP77-330, et al. (Washington, D. C.: Federal
Power Commission, n.d. )
~IU.S. Department of Commerce, Maritime Ad-
ministrate ion, Status of LNG Vessels.
~~Federal Power Commission, Joint LNG Safety
Report of El Paso Atlantic Company et al., Respecting
the Proposed Algeria II Project, Docket No. CP73-258,
et al. (Washington, D. C.: Federal Power Commission,
Apr. 1, 19’77).

Figure 29.
Project Data Sheet: El Paso II
Import Source: Algeria
Import Terminal: Port O’Connor, Tex.
Arzew to Port O'Connor — 5024 n mi

Contract FPC Number Ships/ Estimated Investment (S106) Estimated


Location Expected volume status Shipyard/ price ($)
Companies Involved of u s Project operational Bcf/yr (as of Capacity 3
m/ -
Receiving -
delivered into
(project status) terminals designation date (MMcfd) 9/1/77) Tank design Tankers terminal pipeline/MMBtu

Supplier Sonatrach 12
(Algerian National 125,000 m3, 2,000 457 —
Gas Co. ) Port El Paso II 1982-83 365 Pending shipyard &
Shipper El Paso Atlantic O’Connor, (1 000) tank design
Tx. not known
co
Matagorda
Receiver El Paso Bay
Eastern Co
Distributors El Paso,
LNG Terminal,
United Gas Pipeline.
— ——. . ————.
CURRENT IMPORT TERMINAL CHARACTERISTICS
Storage capacity Regasification Type of storage Number of Terminal
(MMcf) capacity ( MMcfd) containers storage tanks acreage

4168 — Aboveground 3
— Source OTA
CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM 37

ate of Pacific Lighting Company, but no con-


struction has started. 74

8. The “El Paso--Alaskan’’ Project


(figure 31)

This project is one of the proposed transpor-


tation systems to deliver gas from the major
Alaskan North Slope fields to the lower 48
States. While the other systems involve gas
pipelines through Canada, this project pro-
poses a gas pipeline from the North Slope
along the present oil pipeline route to
southern Alaska, A liquefaction facility would
be built at Gravina Point, Alaska, and an ini-
tial fleet of eight 165,000 cubic meter LNG

7 4 Feder a 1 power c Ommission, ~ecom mendatzon t. 751 bid,


the President Alaskan Natural GUS Transportation
Systems (Washington, D. C.: Federal Power Commis-
sion, May 1, 1977).

96-597 0-77 -4
38 CH. I – DESCRIPTION OF LNG TECHNOLOGY AND IMPORT SYSTEM

Figure 31.
Project Data Sheet: El Paso-Alaska
LNG Source: Gravina Point, Alaska’
LNG Terminal: Oxnard, Ca. and/or Point Conception, Ca.

Location
Companies revolved of u s Project
(project status) terminals designation
Liquefaction plant budder O x n a r d ,
and shipper El Paso Ca
Alaska Co and for

1
PROPOSED LNG SOURCE AND TERMINAL CHARACTERISTICS via pipeline from the North Slope
Iiuefactlon or I
2
Not the ultimate (combined) terminal , which
Location Storaqe capacity reqasification Type of storaqe Number of Terminal I will have an estimated cost of $460 million
(MMcf) capacity (MMcfd) containers - storage tanks acreage I
Terminals Oxnard, Ca. 7700 4600 Aboveground 4 38-55
9% nickel (210 acre
site)
Point Conception, Ca. 7700 3300 Aboveground 4 1000 acres
9% nickel
Source Gravina Point, Ak. 6000 3375 Aboveground 4
9% nickel Source OTA

Under the Alaska Natural Gas Transporta- tion. The President’s recommendation was
tion Act of 1976, the President is required to announced in favor of a trans-Canada gas
recommend to Congress on the selection of the pipeline on September 8, 1977, but formal
best transportation system and Congress will recommendation had not yet been made to
then have 60 days to review this recommenda- Congress at this printing.
Critical Review of
Components
of LNG Import System
Chapter II

Critical Review of Components


of the LNG Import System

This chapter presents a series of discussions problems highlighted. Some analyses of future
and critiques of important aspects of the liq- trends and effects are also included.
uefied natural gas (LNG ) system which are es-
sentially components of the existing and pro-
posed projects described in chapter 1. The first five papers are principally subjects
for near-term attention and could be used as
The aspects addressed were identified by basis for congressional review of regulatory
OTA after consideration of public concerns agencies or general investigation of the safety
and analysis of both near-term and longer issue in the context of existing projects and
term effects of deploying this technology in facilities. These papers are:
many locations around the country. Consider-
ing the present status and trends of develop- 1. Tanker Design and Construction.
ing projects and LNG technology, the nine 2. Tanker Regulations and Operations.
subjects covered here were judged to be
deserving of attention at the Federal Govern- 3. Regulation of Terminal Operations.
ment level based on either public concerns, 4. Decisionmaking Process in Certification
the possibility of significant problems develop- of Import Projects.
ing, or both.
5. Safety Research on LNG.
Since some LNG projects are already
operating or approved and a significant
amount of technology is already in place or The remaining four papers are principally
developed, Federal attention seems to be subjects which may require longer term atten-
desirable in two separate time frames: tion following determination of policy in the
national interest. There may be need for
● attention to near-term problem areas of specific legislation to influence projects if ma-
technology, regulation, decisionmaking, jor policy changes are determined. Some of the
or research which could affect many proj- subjects require further study or investigation
ects already operating or nearly so; and and these are noted in the discussions. The
● attention to longer term policies which subjects are:
may be more important as the technology 6. LNG Facility Siting,
develops and becomes more dominant on
the national scene. 7. Liability for LNG Accidents.
8. Reliability of Supply.
Each subject in this chapter is presented as
a critical review of the present system with key 9. Pricing Policy.

41
42 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Critical Review: Paper 1

LNG TANKER DESIGN AND CONSTRUCTION

The Coast Guard specifies and enforces There is, however, concern about the risks
design standards for U.S. flag ships and for of a major collision that would penetrate an
foreign flag ships calling at U.S. ports. Stand- LNG cargo tank. These concerns are not re-
ards for foreign ships were worked out in lated to design and construction of the LNG
cooperation with the Intergovernmental tankers, but rather to the possibility that in-
Maritime Consultative Organization (IMCO), creased numbers of tankers and other ships
and a draft code is under consideration. In ad- will be operating in more and more congested
dition, the Coast Guard published proposed harbors and coastal areas. This is an opera-
standards for self-propelled vessels carrying tional and regulatory problem which is dis-
bulk liquefied gases on October 1, 1976. The cussed in the next section.
proposed standards for U.S. flag ships differ
only slightly from the IMCO code and the The two oldest LNG ships in operation ap-
effective date for both sets of standards is the pear to be typical of the quality of design and
same. The new standard is intended to replace construction. The ships, the Methane Princess
both the Letter of Compliance program for and the Methane Progress, are 27,000 cubic
foreign vessels and existing 46 CFR, Chapter I meters each, which are about the size of a
regulations for domestic vessels. single tank on 1977 LNG carriers, and have
been transporting LNG from Algeria to Eng-
As of September 1976, the existing fleet and land since 1964. No major accidents have oc-
scheduled deliveries of LNG ships totaled 79 curred on these ships with over one million
vessels. All of these vessels and any additional voyage miles each. A study done in 1973 pre-
ones contracted for prior to October 31, 1976, sented an analysis of technical problems of
or delivered or converted prior to June 30, these ships and the 71,000 cubic meter ships,
1980, will not be subject to the new design and Arctic Tokyo and Polar Alaska, which have
construction standards. 1 These vessels will been in service from Alaska to Japan since
comprise a significant portion of the fleet until 1969.
the end of the century that will not be subject
to the new regulations, although some of these The Methane ships’ cargo tanks were an
vessels may still meet the new standards. early freestanding prismatic tank design of
aluminum construction. The Alaska ships had
However, LNG ship technology has a later version of a membrane tank design
developed over the past 20 years and is cur- with stainless steel interior lining. The
rently in use in worldwide trade with only Methane ships experienced minor problems
minor technical problems. Modern LNG ships with the insulation system, as the cargo tanks
have been in use for the past 5 years in Boston caused cold spots on the inner hull and some
and 8 years in Alaska. No serious accidents cracking in the mild steel hull. The problems
have occurred and it appears that existing were either repaired while in service or
U.S. Coast Guard standards of design and postponed until the next shipyard period. The
construction are probably adequate to average number of days out-of-service for
assure equally low risks of ship failures in repairs has been 25 per year for each of the
the future. Methane ships. This is only slightly higher
than the 20 days per year usually planned for
regular repairs to large, complex ships.

IU. S. Department of Commerce, Maritime Ad-


ministration, Status of LNG Vessels (Washington, D. C.:
U.S. Department of Commerce, Mar. 15, 1977).
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 43

The Alaska ships experienced much higher have been made. The major concern about the
out-of-service rates (about 50 days per year) development of much larger ships is that an
and several more operational problems in accident will have more serious consequences.
their first 4 years of service. Some factors that Before designs are firm it would be prudent to
may have influenced this include: 1 ) the ships consider the need for limits on either tank
were much larger than previous designs; 2) sizes or total ship sizes. Some correlation be-
the voyage from Alaska to Japan is much tween siting of facilities, ship or tank size, and
longer than previous LNG routes; and 3) the research into LNG spill behavior may also be
extreme temperatures and weather in Alaska. useful.
The problems experienced by the Alaska ships
include damage to membrane and insulation An interesting example of difficulties which
due to tank-sloshing loads, damage to may occur in getting a major new technical
membrane due to a cable tray failure, over- system in operation is provided by a recent ac-
pressurizing of barrier spaces around tanks, counts of the 125,000 cubic meter LNG tanker
Hilli. Unloading of the tanker was halted in a
and various machinery failures. Some
redesign and overhaul was necessary to cor- Japanese harbor when a metal bolt was found
rect the containment problems but none in the cargo lines. The ship has been taken out
caused any serious personnel safety hazard. z of service and, along with two sister ships
scheduled to enter service soon, is undergoing
In fact, there have been no serious accidents intensive inspections until the source of the
or serious safety problems involving any of the bolt is found. It is estimated that the activity
32 ships now in the worldwide LNG fleet.3 may take 2 months and could cost millions of
dollars. 5
However, the new LNG tankers now enter-
ing the trade are larger and do employ some However, such problems with new ships,
new systems. Although they have been carefully built, operated, and monitored in
carefully designed and constructed some early stages of projects, appear to have a
concern is merited due to the increase in negligible effect on public safety. However, as
scale and new containment systems the present fleet grows older, risks of
employed. failures could increase. Future concerns for
projects now in the design and construction
Most of the LNG ships now under construc-
tion, built, or designed for the major U.S. im- stages include:
port projects are of the 125,000 to 130,000 How well each ship will be maintained
cubic meter size. Forty-seven of this size and and kept in adequate condition.
none of any other size were under construction
as of March 1977 (figure 32). Plans have been How well various new containment
made for 165,000 cubic meter ships for the systems will perform over time.
proposed North Slope Alaska to California How well inspection and monitoring of
project by El Paso but this project is not ap- ship and machinery condition and opera-
proved and no ship contract has been let. tion will be performed.
Some consideration has also been given to
How well foreign flag operation will con-
LNG ships as large as 300,000 cubic meters to
serve offshore terminals, d but no firm plans tinue to adhere to U.S. standards and
whether countries such as Liberia will
zBOOZ.Allerl Applied Research Inc., Analysis Of LNG perform adequate surveys and inspec-
Marine Transportation (Bethesda, Md.: Booz-Allen Ap- tions.
plies Research Inc., November 1973). v.], p. VI-30-38,
:IU. S. Depart m ent of Corn m erce, Maritime Ad- How well shipyard repairs and surveys
ministration, Status of LNG VesseZs (Washington, D. C.: can be performed on these complex
U.S. Department of Commerce, Mar. 15, 1977). vessels with tight operating schedules.
qHenry Marcus, offshore Liquefied Gas Terminals,
draft report (Cambridge, Mass.: MIT Center for S“LNG halt could last months,” Lloyd’s L&~, June 4,
Transportation Studies, July 1977). 1977, p.1.
— —

44 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Figure 32. Average Vessel Capacity of World LNG Tanker Fleet

Cubic Meters
(thousand)

90

80

70


●*
● ** ●“ “
60 ● **m..,

50

40

— ● *o*g
●☛ ● ● 000(
30 ●
●“


— ●




20 4

● 0006 ● 0004

10

In this study, OTA looked only at LNG


tankers. However, the study indicated that it
is logical that liquefied bulk gas carriers
should be treated together for purposes of
future controls on design, construction, and
maintenance. Liquefied petroleum gas (LPG)
carriers and other gas tankers have been in
service for longer periods and in much more
varied shipping circumstances than LNG car-
riers. Some of these other gas carriers have
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 45

had more serious accidents.6 In addition, standards for LNG and LPG tankers stems
many more U.S. ports are regularly receiving from the same legislation. T Recently, however,
or shipping LPG and other gas cargoes. public concern about LNG has forced the
Coast Guard to give disproportionate atten-
The Coast Guard and international agen- tion to LNG tankers. In all design, construc-
cies have considered all liquefied gas carriers tion, and maintenance controls, LNG and
together in the past, and the Coast Guard’s all other hazardous cargo tankers should be
mandate for setting design and construction considered together.

Whe Yuyo Maru—a hybrid gas carrier collided with TU.S. Congress, Ports and Waterways Safety Act of
a Liberian cargo vessel in Tokyo Bay in November 1974, 2972, P.L. 92-340, 92d Cong., 1972.
resulting in a fire setting the naphtha alight in wing
tanks which, in turn, eventually reached the LPG in
other tanks.
46 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Critical Review: Paper 2

LNG TANKER REGULATIONS AND OPERATIONS

Regardless of the design safeguards re- Coast Guard cutter will escort the tanker to
quired for LNG tankers, the possibility and the terminal, remain berthed nearby during
consequences of a major spill on water due the unloading operation, and finally escort
to a ship accident are the most serious con- the tanker back out to the open sea. During
cerns. The gas industry, Government officials, the transit to and from the terminal, the Coast
and those who joined in OTA’s public par- Guard broadcasts warnings to keep the har-
ticipation program during this assessment all bor clear of all other traffic. Simultaneous
agree on that fact. unloading of LPG tankers in an adjacent
berth is prohibited.
As marine traffic in such hazardous cargoes
as LNG and LPG increases in the future, Due to the unique traffic problems with
much more attention will be needed in the each LNG terminal site, local planning will
whole area of vessel traffic monitoring and always be required. However, the present
control, especially since the movements of method of operation—especially closing
other marine traffic in the vicinity of liquefied down long sections of Boston waterways
gas tankers may not be as predictable as the during an LNG tanker transit-may be
movement of the LNG ships. very costly and unworkable as increased
numbers of LNG tankers enter service.
Tanker Traffic Effective long-range planning to handle
traffic problems is required now.
The Coast Guard has authority to grant
With tanker deliveries once every 20 to 30
the Captain of the Port the power to control days into the relatively uncrowded Boston
any vessel within the territorial sea and to Harbor, the inconveniences and costs to other
prescribe conditions and restrictions for the shipping activity are modest. However, when
operation of waterfront facilities. deliveries are made more regularly or into
The only U.S. ports where LNG tankers are very busy harbors, pressures will exist for the
currently operating are Boston, Mass., and Coast Guard to be less rigorous in their con-
Kenai, Alaska. The Captain of the Port in trols.
Boston has prepared an operations/emergency For example, LNG tanker deliveries to the
plan specifically for LNG. The Captain of the
new terminal at Cove Point, Md., are expected
Port in Kenai has not. He relies instead on a
every 2 to 3 days. At the same time, more than
voluntary operations plan drawn up by the 4,000 major ships per year pass Cove Point on
four industrial users of the port. 2
their way to and from the Port of Baltimore,
The Boston plan requires that all LNG one of the 10 largest ports in the United
vessels bound for the Everett, Mass., terminal States. (By comparison, Boston Harbor han-
meet a Coast Guard cutter 4 miles out for an dles only 1,500 ships per year; the Delaware
inspection of cargo systems prior to entering River, 5,000; New York Harbor, 10,000). 3 I n
port. The officer-in-charge will then make a addition, LNG ships bound for Cove Point
determination of whether the ship should be will have to mix with other ship traffic in the
allowed to enter the harbor. From that point Chesapeake Bay at Hampton Roads.
on, if permission to enter port is given, the
:W.S. Department of the Army, Corps of Engineers,
IU.S. Congress, Ports and Waterways Safety Act of Waterborne Commerce of the United States, Calendar
1972, P. L. 92-340, 92d Congress., 1972. Years, 1973, 2974, 2975 (Vicksburg, Va.: U.S. Depart-
Conversation with officials of the U.S. Coast Guard, ment of the Army, Corps of Engineers, 1974, 1975,
Washington, D. C., Aug. 12, 1977. 1976).
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 47

Probably the greatest single safety measure ●


the percentage of ship traffic in haz-
that could be taken to develop and to main- ardous cargoes in relationship to all
tain safe LNG shipping and safer shipping in traffic in the port;
general would be the adoption of positive ●
the potential for increased traffic in
traffic control over vessels within harbors, hazardous cargoes; and
rather than simply allowing ships to follow
rules of the road. ●
the impacts of various types of ship acci-
dents which might occur in each harbor.
Historically, oil tanker casualty data have
indicated a need for improved marine traffic Admittedly, VTS are complex and costly
safety in U.S. ports and waterways. systems. However, the complexity and cost of
current practices--such as halting traffic
The Ports and Waterways Safety Act of around LNG tankers and providing in-
1972 authorizes the Coast Guard to establish, dividual Coast Guard cutter escorts for each
operate, and maintain vessel traffic services LNG tanker—will become more unmanagea-
(VTS) in congested waterways, require in- ble and less feasible as traffic increases.
stallation of electronics for implementation of Since all proposed sites for LNG import
traffic safety systems, and control vessel terminals are not now scheduled for VTS
traffic where conditions require it through systems, special handling of the ships will
routing schemes and speed limits. While this probably continue to be required in the
is not a positive control system in the same near term. However, in the future safety of
sense that air traffic controllers exercise all vessels around and including, hazard-
authroity over flight, it does give the Coast ous cargo ships depends on implementation
Guard the statutory authority to deal with of some level of VTS system by the Coast
hazardous cargo traffic in a concrete way. Guard to reduce the probability of ship col-
The Coast Guard completed a detailed lisions.
analysis of ports and waterways traffic in In testimony before a Coast Guard hearing
1973. 4 VTS systems for San Francisco, Puget considering the need for VTS in the
Sound, and the Houston Ship Channel are Chesapeake Bay, a representative of the firm
now operational, and systems for New which will operate the LNG tankers into Cove
Orleans and Valdez are expected to be opera- Point noted that working VHF radios and
tional late in 1977. A system is being radar are not now required on ships entering
developed for New York Harbor and its ap- the Bay. He indicated faith in the LNG
proaches. tankers, which are so equipped, but added,
“We are concerned, however, about the basis
Priorities for ports to be outfitted with VTS for entry and transit (of other vessels) and
have been set by the Coast Guard based on who will pass our berthed vessels at Cove
historic information reflecting the level of Point.” 5
traffic, the opportunity for accident, and the
costs and benefits of installing the system. I t Citizens who joined in OTA’s public par-
now appears that the Coast Guard should ticipation program expressed considerable
also study harbors and waterways and concern about the operation of LNG tankers
possibly consider new VTS locations based in crowded harbors and the problems of tying
on at least three additional factors related up other ship traffic. One participant sug-
to the cargoes: gested that in order to minimize the possibility

4u.s. Ilepartrnent of Transportation, U.S. Coast sHearings before the U.S. Coast Guard on- the
Guard, Vessel Traffic Systems Issue Study, Final Chesapeake Bay Vessel Traffic System at Norfolk, Va.,
Report ( W a s h i n g t o n , D.C. U . S . D e p a r t m e n t o f Jan. 27, 1977, John Boylston, marine manger of
Transportation, U.S. Coast Guard, March 1973). Methane Tanker Service Company.
48 CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

of collision and to provide a large area of s Are the Coast Guard inspectors available
empty water in which an LNG spill might dis- in sufficient numbers with adequate
sipate, LNG tankers be restricted to routes training in hazardous materials?
away from normal shipping lanes and ter- To date, Coast Guard inspectors have had
minals be restricted to isolated coastal points little specific training in LNG or other lique-
away from other shipping ventures. fied gases. However, a 3-week course in haz-
ardous materials, including LNG, is being
Tanker Inspections developed and is scheduled to begin this fall.
The course is designed to train more than 100
The Coast Guard assures the compliance of Coast Guard personnel each year in inspec-
foreign LNG tankers to established standards tion techniques for hazardous material car-
by boarding the ships for an inspection when riers. However, the course is a voluntary one,
they enter U.S. ports. and it is not clear that all personnel involved
Inspections are required at least every 2 in regulation and inspection of LNG carriers
years and may be carried out, as they are in will actually receive training. G
Boston, on each arrival in a U.S. port. A detailed course outline had not been com-
These inspections are limited to cargo-han- pleted when this report was written, but it ap-
dling systems, deck machinery and compart- peared from preliminary materials that ap-
ments, and fire and gas detectors for the cargo propriate subjects would be offered.
system. The general condition of the ship and
the capability of the crew are not included in Crew Training
these inspections. Thus the inspection does
not reduce the risk of failure of propulsion, The Coast Guard has already proposed
navigation, and steering systems, or even regulations setting out minimum standards
verify the crew’s training and experience. for persons employed on U.S. flag LNG
tankers. T But there appears to be disagree-
One very specific criticism of the Coast ment over whether the Coast Guard has a
Guard’s inspection procedures is that it relies
mandate to propose similar standards for per-
totally on shipboard instrumentation during
sonnel on foreign flag ships entering U.S. har-
the inspection. While most systems can be
bors. To date, the Coast Guard has preferred
checked by actuation of controls and by built- to work internationally to develop those
in self-test features, there is one very obvious
standards and is participating in Intergovern-
oversight. The ability of the ship’s gas detec-
mental Maritime Consultative Organization
tion system will be limited to sensor location
(IMCO) sessions on the subject. It is open to
in hazardous areas only.
question whether this approach ensures an
The major questions to be raised about the adequate level of training and competence
inspection procedures are: among foreign crews.
“ Is the Coast Guard determining and This situation could be changed signifi-
using the best means of detecting gas in cantly by S.B. 682, the Tanker Safety Act of
void spaces? 1977. If passed, the act would mandate crew
standards on all tankers entering U.S. ports,
“ Is the Coast Guard developing inspection
regardless of flag.
procedures which will allow them to ade-
quately inspect the growing fleet of
Conversation with officials of the U.S. Coast Guard,
vessels which will soon include ships of Washington, D. C., Aug. 12, 1977.
several different designs, with different W.S. Department of Transportation, U.S. Coast
foreign flags and crews of different na- Guard, “Qualifications of the Person in Charge of Oil
tionalities? Transfer Operations,” Federal Register 42, no. 79, Apr.
25, 1977, 21190-21200.
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 49

Several training programs, funded by ship- selection or command decision capability.’ 8


ping companies and unions, are in existence, In fact, fire or explosion currently accounts for
but training at these schools is not required 90 percent of the deaths and injuries in all
currently by any Federal agency. tanker collisions. The tanker casualty rate did
not show a decrease between the years 1970
One particular area of concern is training in
and 1975. The actual number of collisions in-
the use of fire protection equipment. Ex-
creased with the increase in traffic. g Analysis
perience has shown that serious accidents
of 825 fires aboard U.S. Navy ships shows a
which involve tankers with flammable cargo
similar trend. 10
almost always result in a fire. As the Ad-Hoc
Maritime Committee of the AFL-CIO states, Thus, minimum requirements for crew
“hands-on type fire prevention, detection, ex- training in the use of fire prevention and
tinguishment, and containment training pres- protection equipment should be a cor-
ently available to professional seamen, is nerstone of the Coast Guard safety efforts.
lacking in magnitude, depth and scope. . . .
sAd Hoc Committee, (AFL-CIO), Fire Protection,
Repetitive retraining, at various Maritime Detection, Containment and Extinguishment Proposal
Administration sponsored field schools, . . . (n.p.: Ad Hoc Committee, (AFL-CIO), n.d.)
is, at best, presently capable of exposing per- gu.s, Congress, Office of Technology Assessment, Oil
sonnel only to historically employed evolu- Transportation by Tankers: An Analysis of Marine
tions that require no prethinking, equipment Pollution and Safety Measures (Washington, D. C.: U.S.
Government Printing Office, July 1975), p. 36 and 57.
IOGeorge G. Sharp, Inc., Patrol Frigate Machinery
Space Fl”re Protection and Safety Hazards Study (n.p.:
George G. Sharp, Inc., December 1972).
50 CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Critical Review: Paper 3

REGULATION OF TERMINAL OPERATIONS

Standards for Terminals however, the proposed standards are less


definitive than the existing specification.
The existing industry standard for produc- These areas include specifications for concrete
tion, storage, and handling of LNG in land- materials, equipment spacing within the
based terminals is the National Fire Protec- facility, valves, piping, and electrical equip-
tion Association (NFPA) 59A. These stand- ment. Industry representatives have criticized
ards have been adopted by many State agen- the regulations as being overly stringent in
cies as well as by OPSO, making them part of defining thermal and vapor dispersion exclu-
the Federal regulations for LNG terminals. sion zones, specifying inappropriate estimat-
ing techniques for determining these exclusion
To date, many portions of baseload LNG zones.
import terminals appear to have been
designed to much more stringent requirements There is also concern that the proposed
than the minimum specifications set forth in regulations do not allow for the develop-
59A. Still, a strong case can be made for more ment and use of several alternative means
stringent requirements in many areas, par- of controlling vapor cloud generation in the
ticularly those relating to public safety. Indus- event of a spill. The proposed regulations
try is opposed to promulgation of tougher stipulate the use of a buffer zone (which could
standards unless the need is clearly demon- be as large as 3 to 7 miles depending on the
strated. This opposition is at least partly size of the diked area around storage tanks) 2
because of the fear that such standards would or provisions for automatic ignition of a vapor
be retroactively applied to existing peak shav- cloud.
ing and import facilities which would be The use of automatic ignition during an
difficult and costly to modify. On the other LNG release may have an effect opposite of
hand, some members of the public interest that desired in a fire protection system; it
groups which cooperated in OTA’s public par- could result in cascading equipment failures
ticipation program are calling for retroactive and much greater damage than would be the
application of new standards with a gradual case with other methods of control.
phasing out of any facilities which do not meet
these standards. Ideally, the regulations should provide for
developing technology which both protects the
The prospect for retroactive application of plant and enhances public safety. Some typical
new requirements does now exist with the pro- alternatives which have been proposed and
posed standards recently published by large-scale tested are the use of high-expan-
OPSO. 1 sion foam systems for direct control of im-
There are several areas in which the pro- pounded LNG spill fires, the use of high-ex-
posed standards are considerably more com- pansion foam systems for reductions in the
prehensive than the NFPA 59A standard. downwind travel of vapors from LNG on land,
These include definition of a thermal exclu- the use of fixed dry chemical systems for im-
sion zone, vapor dispersion zone, and seismic
design criteria. I n m a y o t h e r r e s p e c t s , ~Wesson & Associates, Inc., Compilation of Data on
Wesson & Associates, Inc., Key Personnel, Major Ex-
periences in LNG Technology—Safety—Fire Protection,
IU. S. Department o f T r a n s p o r t a t i o n , Office of Industrial LNG Fire Training School and Comparison
Pipeline Safety Operations, “Liquefied Natural Gas of NFPA No. 59A with the Proposed OPSO LNG
Facilities (LNG); Federal Safety Standards,” Federal Facility Federal Safety Regulations, (Norman, Olda.:
Register 42, no. 77, Apr. 21, 1977, 20776-20800. Wesson & Associates, Inc., 1977.
CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 51

pounded spill fire extinguishment, and the use Inspection of LNG Facilities
of certain types of fireproofing coatings for
cryogenic and thermal protection of structural Once standards for construction and opera-
steels. tion of LNG facilities are clarified, there will
still remain the necessity to inspect facilities
In general, LNG spill and fire research has for compliance with regulations.
resulted in the improvement of and applica-
tion for commercial fire protection and It appears that there are gaps in current in-
damage control systems in LNG facilities. spection procedures which could cause
While it is generally conceded that these type problems in the future.
facilities have excellent safety records and ac- The Office of Pipeline Safety Operations
cident-free histories, they can still be im- (OPSO) has the responsibility for inspection of
proved. It was also generally agreed during all pipelines and other facilities used in
the December 1976 ERDA LNG Workshop, transportation or sale of natural gas in inter-
that adequate fire protection equipment per- state commerce. However, the small size of
formance and design requirements have been the OPSO staff limits its ability to inspect
experimentally established for definition of facilities. In fact, OPSO has been described
the hazard-control systems for typical operat- by industry managers as “almost invisible in
ing and impounded LNG spill conditions. the field.” A The small staff also impairs
However, one expert estimates that only 30 OPSO’s ability to participate in FPC hearings
percent of the existing peak shaving facilities although compliance with OPSO regulations
have adequately designed and installed fire is one subject of the hearings.
protection systems capable of controlling a
major LNG spill condition. 3 Thus, attention to The Secretary of Transportation is
these issues and recognition of the hazard therefore authorized to enter into agreements
reduction capabilities of experimentally with State agencies to take over inspection
proven fire protection and safety systems both duties. 5 These agreements require that:
in the development of regulations and in ●
the State must adopt at least minimum
allocations for research and development Federal safety standards; and
programs would be well justified.

the State must submit an annual cer-
Concern about firefighting ability extends tification that it has adopted such stand-
beyond that of the LNG facility. There has ards and is complying with a number of
been considerable public discussion of other more technical conditions.
whether local fire departments near an LNG
facility have the expertise and financial The Office of Pipeline Safety Operations
resources to prepare themselves for dealing does not have these agreements with all States
with a possible LNG emergency. and the inspection mechanisms vary in the
States which do participate. 6 This could result
Those who contributed to the public par- in uneven enforcement of regulations concern-
ticipation program had few suggestions for ing LNG facilities. For this reason, it appears
specific changes in terminal regulations. They that guidelines for inspection and enforce-
did, however, desire that regulations be
ment should be included in OPSO regula-
clearly defined and strictly enforced. Many
tions along with standards for construction
suggested that regulations include require-
and operation of the facilities.
ments for training of personnel employed at
the terminals and the preparation of evacu- qInterView with officials of Columbia Gas Corp.,
ation plans for the areas near an LNG facility Cove Point, Md., June 8, 1977.
in the event of a major accident. ~Natural Gas Pipeline Safety Act of 1968, 49 U.S. C.
$! 1671 et seq (1970).
Conversation with staff of State Programs Division
of the Office of Pipeline Safety Operations, Department
~Wesson & Associates, Inc. of Transportation, Washington, D. C., Aug. 10, 1977.
52 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Guidelines for training of inspectors, faith agreements with the company than a
methods of inspection, and how often facilities regulatory order.
should be inspected could raise public confi- In addition, the FPC can and does require
dence, enhance safety of LNG plants, and en- occasionally higher standards than those con-
sure equitable enforcement practices. tained in existing OPSO regulations. g
There also appears to be a problem of in- However, OPSO does not verify compliance
specting facilities for compliance with stipula- with these higher requirements during its in-
tions which may be imposed by FPC when it spection of LNG facilities. 9
issues a certificate of public convenience and It appears that inspection of facilities for
necessity. In some recent FPC rulings, these compliance with all similar requirements—
stipulations have been quite complex and regardless of the source of the requirement—
technical. At the present time, however, should be fixed with a single agency. Since
there is no mechanism for enforcing these most of the duty already falls to OPSO or its
orders. The FPC staff is insufficient for per- delegated State authority, it appears logical
forming followup inspections on a routine OPSO should be charged with this expanded
basis. Inspections are performed only when, task.
and if, the applicant applies for modifications
to an existing facility.7 Thus, the conditions
of certification are considered more as good ~lnterview with staff of Federal Power Commission,
Washington, D. C., June 24, 1977.
Conversation with staff of State Programs Division
of the U.S. Department of Transportation, Office of
71nterviews with staff of Federal Power Commission, Pipeline Safety Operations, Washington, D. C,, Aug. 10,
Washington, D. C., May 31 and June 24, 1977. 1977.
CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 53

Critical Review: Paper 4

DECISIONMAKING PROCESS IN CERTIFICATION OF LNG PROJECTS

The Federal Power Commission (FPC) is made an affirmative finding that such stand-
the lead agency in determining whether or not ards were necessary to protect the public in-
each individual LNG import project is in the terest. 2 As a result of the court decision, the
public interest and, therefore, will be allowed. Distrigas terminal outside of Boston came
under FPC jurisdiction. It now appears likely
However, both the LNG industry and con- that such jurisdiction will include any other
cerned members of the public have found the terminals which may sell imported gas only to
agency unresponsive to their needs. Most an intrastate market.
criticism leveled against the agency can be col-
lected into four areas: Jurisdiction is also clouded in another area
where there is a lack of guidelines for the
● lack of clearly enunciated Federal policy
division of responsibility among the FPC,
and jurisdiction on import matters;
OPSO, and the U.S. Coast Guard in promul-
● length of time required for approval proc- gation and enforcement of safety and siting
ess: standards which an applicant must meet.
Since the Coast Guard’s role has been mostly
● financial difficulties inherent in the ap- to review applications and advise the FPC in
proval process; and
areas of Coast Guard expertise, the more
● lack of adequate information and oppor- serious present conflict is with OPSO. There
tunity for intelligent participation in the are two major questions involved in the con-
decisionmaking process. flict:
1) To what extent can the FPC require
Lack of Clear Policy and Jurisdiction higher standards than those contained
in OPSO regulations?
Historically, the FPC’s role has been to
regulate the entry of suppliers into the inter- The two agencies clashed directly on this
state natural gas market and to ensure that point in the past. In a controversy involv-
interstate sales take place at prices which are ing the Chattanooga Gas Company, the
“just and reasonable.” 1 Early on in the im- FPC temporarily closed down an LNG
port of LNG, that caused a problem of peak shaving facility which OPSO had
jurisdiction which has not yet been completely inspected and approved. 3 This led to an
resolved. For an import facility where the gas effort between the two agencies to
is to be sold interstate, there is little difficulty develop a memorandum of understand-
since FPC approval is required for both the ing delineating responsibilities; however,
importation and the construction/operation of so far this effort has not been successful.
facilities to handle the gas. However, where 2) Which agency—if either—shall establish
the imported gas is to be sold intrastate, there
siting criteria for the location of import
has been confusion as to whether the FPC
terminals?
could require that facilities meet Federal
standards.
In 1974, a U.S. Court of Appeals ruled that 2D~t@~ Corporation v. Federal Pouter Cornrrzzk -
sion, 495 F,2d 1057 (D.C. Cir. 1974).
the FPC could require certain standards of !31n the time since original FPC certification, a num-
the intrastate facilities if the Commission first ber of homes had been constructed on land which the
FPC felt was dangerously near the storage tanks. The
FPC required the company to purchase the adjoining
115 U.S,C. $ 717 c(a) (1970). land.

96-597 0 -77-5
54 CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

OPSO has proposed new safety stand- before individual project decisions are
ards for LNG terminals which bear m a d e . There are currently no national
heavily on the selection of specific sites. policies for LNG which could be used as a
The effort has surfaced two problems: basis for consistent FPC decisions on these
subjects. However, the policy void in which
a) T h e r e a p p e a r s t o b e a s t a t u t o r y
the FPC now operates may be filled by the
prohibition against OPSO standards new Department of Energy.
prescribing the location of LNG
facilities; A and Under the Department of Energy Organiza-
tion Act,6 the FPC will be absorbed by a new
b) The FPC has expressed concern that
five member Federal Energy Regulatory Com-
it has exclusive jurisdiction over site mission, which will be a semiautonomous
selection. The FPC has received a re- body in the Department of Energy.
quest by the attorneys general of
several east coast States to begin In general, the change is an effort to strike a
rulemaking on uniform siting criteria balance between maintaining independent
and has asked for comments on this re- regulation of energy and fitting such regula-
quest; however, the outcome of this tion into a policy framework which is respon-
issue is far from certain. sive to the President. In part, the Act sets out
the following:
Until these jurisdictional problems are
decisively resolved, it is difficult, if not im- ●
the Commission has jurisdiction over
possible, to plan facilities which can be ap- natural gas prices and the granting of
proved. certificates of public convenience and
necessity;
The LNG industry has been particularly
critical of the FPC in the realm of decision- ●
the Secretary of Energy has respon-
making. One representative told OTA that the sibility for regulating imports and ex-
recurrent theme of industry’s relationship ports of natural gas and for issuing cer-
with the FPC was “we can’t follow the rules tificates of public convenience and
because we don’t know what the rules are or necessity for imports and exports;
will be.’ 5 ●
the Secretary has the authority to
establish natural gas curtailment
One of the underlying problems which priorities, which are then implemented
frustrates the FPC’s decisionmaking duties and enforced by the Commission; and
and processes is the fact that it is a
regulatory agency, not a policymaking ●
the Secretary may act as an intervener in
body. The questions of import levels, pric- the Commission’s proceedings and may
ing mechanisms, and siting criteria which set reasonable time limits for the comple-
the FPC must regularly consider are all tion by the Commission of its rulemaking
pieces of basic energy and environmental proceedings.
policy issues which should be determined
Currently, the relationship between the
Secretary’s import approval and the Commis-
4Natura] Gas Pipeline Safety Act of 1968, 49 U.S.C. $
1671 (4) ( 1970). “Pipeline facilities includes . . . new and
sion’s certification function is unclear and
existing pipe right-of-way and any equipment facility, or needs to be clarified. On the positive side,
building used in the transportation of gas or the treat- however, the Secretary’s authority over im-
ment of gas during the course of transportation but ports provides at least the institutional
‘rights-of-way ‘as used in this chapter does not authorize
the Secretary (of Transportation) to prescribe the loca-
tion or routing of any pipeline facility. ” (emphasis ad-
ded). 6U. S. Congress, House, Department of Energy
sInterview with officials of Algonquin Gas Transmis- Organization Act, Conference Report 95-539 to Accom-
sion Company in Boston, Mass., June 16, 1977. pany S.826, 95th Congress, 1st session, 1977.
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 55

possibility that LNG decisions will be made made in favor of Federal preemption in
in the framework of conscious policy choices natural gas. The balance between State and
concerning the role of LNG in the Nation’s Federal powers in one LNG peak shaving
energy mix, the acceptable level of imports, plant has been described by a U.S. Court of
the preferred supplier countries, and trade- Appeals in the Hackensack Meadowlands
ofls between LNG and alternative domestic case—“Although the States are not precluded
and imported fuels. from imposing reasonable restraints and
restrictions on interstate commerce, and
This policy framework has been lacking in although the authority to enact zoning ordi-
the present structure and is sorely needed. nances under the State’s police power is
clear. . . , it is equally settled that a State may
Meanwhile, the FPC practice of making not exercise that police power where the neces-
case-by-case decisions on such matters makes sary effect would be to place a substantial
planning difficult for the LNG industry or by burden on interstate commerce.’ 10 However,
opponents of any particular project. There is the FPC’s recent action in the Trunkline case
another troublesome policy question: In re- clouds the matter considerably.
cent decisions, the FPC has issued its ap-
proval contingent upon receipt of all State Another area of uncertainty is the question
and local approvals. 7 These decisions raised whether provisions of the Coastal Zone
concern among some industry representatives Management Act apply to the various permits
that the FPC was abdicating its authority to which the Federal Government grants in con-
local politicians. 8 nection with LNG. Under the Act, applicants
for any Federal license or permit for an ac-
The issue here is one of Federal preemption. tivity in the coastal zone of any State with an
What if the FPC authorized a particular proj- approved coastal zone program are required
ect and State authorities refuse to allow it? to certify that their proposed project is consist-
The Natural Gas Act provides for condemna- ent with the State’s program. The Federal
tion of land for pipelines, but does not Government is prohibited from issuing the
specifically mention terminal facilities. Case license or permit until the State concurs or
law on the subject is limited and the question fails to act within 60 days or the Secretary of
has never been decided directly by the courts Commerce makes a finding that the proposed
(see appendix C). There is, however, a close project is consistent with the overall objectives
analogy in the FPC’s jurisdiction over hy- of the Coastal Zone Management Act. 11
droelectric facilities. There, the courts have There are two problems in this procedure as
expressly held that Federal jurisdiction it relates to LNG: First, it is not entirely clear
preempts that of State authorities. g The Com- what kinds of authorizations are covered by
mission’s jurisdiction over hydroelectric the terms “license or permit’ and, therefore,
facilities comes from a different statute than it is unclear if FPC certificates of public
the Natural Gas Act, but there is probably an convenience and necessity would be in-
equally strong or stronger argument to be cluded. Second, another provision of the
Coastal Zone Management Act states that the
Act is not to modify laws applicable to
~Federal Power Commission, Trunkline LNG ConZ - Federal agencies.
pany and Trunkline Gas Company, Opinion No. 796,
D o c k e t N o s . CP74- 1 3 8 , CP74-139, CP74-140 The FPC has announced its intention of
(Washington, D. C.: Federal Power Commission, Apr. conducting a rulemaking on the Act, but has
29, 1977.)
~Interview with officials of Algonquin Gas Transmis-
sion Company in Boston, Mass., June 16, 1977. 1 ~Transcontinental Gas ~“pe Line Corp. V . Hacken -
gw~hington Departmen/ of Game v. FPC, 207 F.2d sack Meadowlands Development Commission, 464 F. 2d
391 (9th Cir. 1953); FPC v. Oregon, 349 U.S. 435 (1955); 1358, 1362 (3d Cir. 1972), cert. denied, 409 U.S. 1118
City of Tacoma v. Taxpayers of Tacoma, 357 U.S. 320 (1973).
( 1957). 1116 U.S.C. $$ 1451 et seq. (Supp. 1974).
56 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

not yet taken a position on what procedure it from abroad, for acquisition of the land, and
will adopt. 12 for construction of the tankers which will
carry LNG to the United States. 13 It is not
Time Required for Approval difficult to understand that such early com-
mitments may not always be approved or be
To date, the first LNG import project ap-
compatible with plans which are approved.
proved, the El Paso I project at Cove Point,
Md., required 49 months to gain final FPC Much of the time used up by FPC is ex-
certification. The recent Trunkline decision hausted dealing with generic policy issues
took 43 months; the Pacific-Indonesia deci- which could, and should, be decided in ad-
sion, which is still subject to review, has taken vance so that individual applications could
44 months. However, the FPC has adopted an move through a well-defined series of decision
accelerated schedule for the El Paso II project points. As noted earlier, there is the potential
and anticipates that the procedures will re- for considerable improvement in the time
quire only 9 months. Meanwhile, the long schedule for decisionmaking under the new
process coupled with the uncertainties such Department of Energy.
as what type of pricing scheme will be im-
posed as a condition of the final certificate, Some citizens who joined in the OTA public
make it difficult for U.S. firms to compete
participation program expressed concern that
successfully with foreign countries which
the United States could lose needed supplies
are capable of making faster decisions of foreign gas if Government processes are not
(figure 33). The problem, however, lies not coordinated and expedited. However, others
only with the FPC, but in the fact that the
expressed concern that any attempt to
decisionmaking process in private industry in
streamline procedures may result in fewer op-
which long-range commitments are made
portunities for the public to be involved.
early on is not compatible with the lengthy, There was strong support in all segments—the
sometimes unpredictable, Government proc- gas industry and related businesses, State and
ess.
local governments, and public interest
For example, before an LNG company groups—for increased effort to make LNG ap-
makes application for Federal permits, com- proval procedures more open to those who are
mitments have been made for an LNG supply concerned.

1 ~Interviews with FPC staff counsel, on May 31, laln&rVieWS with officials of Distrigas Inc., 130stm,
1977. Mass., June 15, 1977.

Figure 33- Procedure for FPC Certificate of Public Convenience and Necessity

FPC determines major NBS DEIS — Comments FEIS


— — —
Federal action: cryogenics prepared and received prepared
EIS required review distributed .

Application by Application Hearing: Hearing: staff


,
company to FPC reviewed Applicant’s case . . answering case

I r 9 v r
r
Administrative law Exceptions by party — Commissioner’s - Final FPC — Applicant may Applicant may appeal
judge’s initial or staff review, decision petition FPC to a U.S. Court
if any if any 4 for rehearing of Appeals
decision
h
Source OTA.
CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNC IMPORT SYSTEM 57

Financial Diffiulties legal fees. Although representation by an at-


torney is not strictly required by Commission
The financial problems caused by the cum- rules, the complexities of the quasi-judicial
bersome approval procedure are on two proceedings make a lawyer a practical
levels: first, the lengthy process allows con- necessity. Even at the reduced rates offered by
siderable cost escalation to occur resulting in public interest law firms, legal services for an
a higher cost to the ultimate consumer; sec- average 20-day hearing would be approx-
ond, both the applicant and interveners who imately $25,000.16
may oppose the applicant must invest con-
siderable sums of money in the project prior to Information and Opportunities for
approval or rejection by the FPC. Participation
The cost escalation which most routinely
occurs is in the contract price paid to the sup- Adequate information about applications
plier of the LNG. For example, in the case of and FPC proceedings are necessary for effec-
tive participation in the decisionmaking proc-
the recently abandoned Eascogas project, con-
ess, However, the specialized nature of the
tract price of the LNG rose form 44.75 cents
subject and the quasi-judicial practices of
per thousand cubic feet to $1.32 per thousand
FPC are a major deterrent to public involve-
cubic feet as it was necessary to renegotiate
ment. Moreover, FPC, like most other Govern-
the contracts during the 5 years in which the
ment agencies, relies on the Federal Register
application was pending. 14
as its means of providing notice of applica-
In addition, industry claims a $5 million to tions and proceedings to the public. There is
$8 million investment in paperwork is neces- little, if any, effort to encourage participation
sary to get an import project moving through from a broad range of groups which maybe in-
the approvals process. 15 These early costs are, terested in the proceedings or affected by the
of course, ultimately borne by the consumer. project.
The process is equally as expensive for In practice, the public input into OPSO and
members of the public who may wish to par- Coast Guard regulations appears to be less
ticipate in the FPC process. In theory, the limited, and both agencies mail announce-
right to participate as an intervener at FPC ments to a list of interested parties in addition
proceedings is one of the most direct and effec- to publishing such announcements in the
tive public participation mechanisms in the Federal Register. These actions are taken
executive branch. It is a formal opportunity under the Administrative Procedure Act, and
for all interested parties to participate in the regulations which provide an opportunity for
decisionmaking process. In actual practice, public hearings if the agencies deem them to
however, participation is limited to groups be necessary.l7 Both OPSO and the Coast
with sufficient finances and expertise to Guard also have technical advisory commit-
closely and continuously monitor FPC pro- tees, although membership in these groups is
ceedings. This generally means that gas com- generally limited to people with backgrounds
panies and State utility commissions are able in appropriate gas-related fields. Except for a
to participate effectively, but other groups subtask force of the Natural Gas Survey, the
which are affected by FPC decisions, such as FPC has no advisory committee directly re-
environmental and consumer groups, have lated to LNG.
not been able to participate extensively.
One of the major expenses facing groups
which wish to participate as interveners is IGBased on interview with an attorney in a public in-
terest law firm. The figure includes 20 days of prepara-
141 nterview with officials o f Algonquin Gas tion and 20 days of hearings at a rate of $40 an hour
Transmission Company in Boston, Mass., June 16, 1977. plus other costs.
151 nterv ie w with of fi ci a 1s o f A 1 go n qu i n Gas 1T33 C.F.R. $ 1.05 (1976) and 49 C.F.R. $$ 102.13,
Transmission Company in Boston, Mass., June 16, 1977. 102.15 (1975).
58 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Critical Review: Paper 5

SAFETY RESEARCH ON LNG FACILITIES

Research to determine whether LNG and of public works projects, such as the
facilities are safe for the public involves: failure of the Teton Dam in Idaho.
● postulating a “worst case” scenario;
Vapor Cloud Research
“ estimating the extent of a vapor cloud,
which is a central key event of any LNG
Researchers differ in their findings about
disaster scenario; and
the behavior of a LNG vapor cloud as it dis-
c estimating the probability of other events perses into the atmosphere after a spill on
occurring and their consequences water. From a safety perspective, the key issue
(through fault tree and risk analysis). is how far and how broadly a vapor cloud
travels. Estimated distances vary from less
Making sense of the LNG facility safety
than 1 mile to more than 50 miles.1 Some have
question requires examination of each of these
argued that these differences indicate the need
subissues. for more investigation and more research.
However, combined past research is in-
Scenarios
conclusive because researchers use
different initial assumptions about a spill,
Postulating an LNG disaster scenario is
have different concepts about how the vapor
clearly an almost limitless task. There are
cloud would behave, and different in-
countless combinations of events which could
terpretations of data which is available.
lead to an accident. Of necessity, then, LNG
Further research could resolve only some of
safety researchers have simplified the task. It
these differences.
must be questioned, however, whether in the
process of simplifying, important possibilities DIFFERENT ASSUMPTIONS.-One of
for faults have been overlooked, thereby lead- the reasons research results differ is that
ing to overly optimistic or pessimistic results. different weather conditions are assumed for
Since there has been little worldwide ex- the time of the spill. To some extent the
perience with shipping LNG, compared to the meteorological research community has tried
shipping of other cargoes, the historical record to standardize assumptions about weather
is scant and statistical evidence is limited. conditions by using commonly accepted
The creation of LNG disaster scenarios is, classifications of weather states. There are,
therefore, a somewhat subjective undertaking however, several classification schemes in use.
which is vulnerable to the biases of individual
Furthermore, some researchers use “worst
analysts.
case’ (stable) weather conditions while others
The use of disaster scenarios to search for argue that such assumptions are pointless
possible faults in a system is a useful analyti- because an LNG tanker would not enter a
cal approach. But to infer, as most LNG harbor under these conditions because they
safety reports do, however inadvertently, only occur at night.
that all the important possibilities have
been “covered” may be shortsighted. A
review of the investigation of past disasters of
IU. S. Depart,rnent of Transportation, U.S. Coast
other types shows how “failure paths’ can be
Guard, Predictability of LNG Vapor Dispersion from
overlooked or summarily dismissed. This was C a t a s t r o p h i c Spills on Water: An Assessment
true of NASA catastrophes, such as the death (Washington, D. C.: U.S. Department of Transportation,
of three astronauts in the Apollo program, April 1977).
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNC IMPORT SYSTEM 59

Further research will not resolve these records. In these situations, the techniques
types of differences in initial assumptions. enable the risk analyst to determine with
some confidence the probability that specific
CONCEPTS.—Further research could
components will fail. In innovative situations,
however, minimize the differences in concep-
however, risk is less amendable to this kind of
tual approaches used in LNG models.
analysis.
For example, some researchers assume
One reliability/safety analyst with 11 years
LNG is vaporizing from a single spot; others
experience in the aerospace industry described
assume that the source is a line or an area.
in testimony before the FPC how, in the late
Some researchers visualize a vapor cloud as a 1950’s, the aerospace industry was quite op-
continuous plume; others see it as a series of
timistic about risk-assessment methodology.
puffs. All of these different visualizations lead
But he points out:
to different mathematical representations in
the models and to different equations and This optimism was soon dispelled by
results. hundreds of cases of unexpected test and
operational failures and thousands of system
INTERPRETATION OF DATA.—Further malfunctions. Many of the failures and mal-
experiments could also develop data which functions modes had either been previously
would help resolve differences in interpreta- analyzed and seemed to be noncredible events
tion of raw data that is now available. For ex- or had come as a complete surprise which pre-
ample, it has been shown that an LNG cloud vious analyses had not identified at all. By
is flammable only when the concentration of the early 1960’s, it had become apparent that
natural gas is between 5 and 15 percent. the traditional method of identifying poten-
tial failure events and assigning historical
Therefore, because there is a lack of data probabilities of occurrence to these events, as
on large spills, researchers must make an edu- was done in the Little and Homer reports
cated guess about the maximum distance (Little was consultant to an LNG applicant
downwind a vapor cloud could still contain before the FPC, Homer was a consultant to
pockets of gas sufficiently concentrated to be FPC) had consistently led to overly optimistic
conclusions. Consequently, the failure rates
flammable. This question bears directly on were consistently underestimated. 2
the issue of how far a plume must travel
before it is unignitible. More data from The risk assessment issue is also one of con-
further experiments could possibly answer tention between the Department of Transpor-
this question with greater certainty than pres- tation agencies (U.S. Coast Guard and OPSO)
ently exists. and the FPC.
Most LNG researchers would like to see In his initial decision on the application by
further experiments undertaken. But until Pac Indonesia LNG Company and Western
there can be some agreement in the LNG Terminal Associates to import LNG to
assumptions to be used in such experi- Oxnard, Calif., FPC Administrative Law
ments, and until there is some faith that the Judge Samuel Gordon supported his opinion
assumption are realistic, such investiga- on LNG safety by citing the risk-assessment
tions cannot be useful for public policy- statistics of the applicants’ consultant.
making. The analysis shows that under the worst case,
the highest fatality probability is one chance
Estimating the Risk to the Public in 6.7 million per person per year within five-
eighths of a mile of the site, decreasing to
Fault-tree analysis and risk analysis have
been applied successfully to equipment ~Federal Power Commission, Testimony of William
systems which have been in use over an ex- Bryon before the Federal Power Commission in the ap-
tended period of time and for which there ex- plication of Eascogas LNG, Inc., and Distrigas Corp.,
ists a firm data base of failure and repair Docket Nos. CP73-47, and CP73-132, 1976.
60 CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

probabilities of one chance in 10 million per is to be made between types of equipment or


person per year or less within 1 mile of the site procedures. E v e n i n t h e s e a p p l i c a t i o n s
and to one chance in 1 billion to 10 billion however, a reliable data base and historical
per person per year or less beyond 3 miles of record of performance are important. As pres-
the site. The probability of one occurrence is ently applied by the FPC, the use of fault-
113,000 with a probability of one chance in
710 septendecillion (710 followed by 54 zeros) tree analysis and risk analysis to determine
per years whether LNG facilities are safe is most
questionable; worst of all such inappropri-
In contrast, a DOT study on LNG took an op- ate use of the research techniques leads to a
posite position regarding the applicability risk false sense of knowledge about the possible
analysis: risks.
Several approaches may be taken in the
analysis of potential system failures and the Value of Further Research
consequent risk. A statistical estimate of risk
can be made if enough years of experience Research on the behavior of LNG spills and
with the system are available. Unfortunately, the possible consequences of spill accidents
the total operating experience of the LNG in- has been conducted over the past 10 years by
dustry is not sufficient to demonstrate that various Federal agencies and private industry
risk levels are acceptably low on a purely groups. Recent Federal efforts have been pri-
statistical basis. For example, to assure that marily sponsored by the Coast Guard who
the risk of any fatality from an LNG facility is have an annual budget of about $1 million
at a level of less than 10–5/year (equivalent to
the risks associated with machinery) would designated for LNG safety researches These
require a statistical data base of about efforts have included experiments and
500,000 plant-years of operation without ma- analyses on many of the same subjects that
jor accident causing a fatality beyond the are now being suggested by ERDA for much
plant boundaries. Even with major growth in expanded research programs, ie: LNG vapor
the LNG industry, experience accumulated generation and dispersion; fire prediction and
through the next decade will be about two or- control; and, explosive characteristics. G
ders of magnitude below that required to
assure a risk level of 1 -5 fatality/year by The most recent spill tests have been con-
statistical data. Therefore, a statistical ap- ducted at the Naval Weapons Center at China
proach is not sufficient to quantify LNG Lake, Calif., and have been jointly sponsored
facility risks.4 by the American Gas Association (AGA). T
Accordingly, OPSO and the Coast Guard do These have included vapor-cloud ignition
not use risk analysis in consideration of LNG tests, pool-ignition tests, and explosion tests.
operations. The vapor and pool ignition tests have
resulted in data on evaporation rates, down-
It appears that fault-tree analysis and risk wind vapor concentration, flame propagation,
analysis are useful management techniques to and radiation characteristics. The explosion
identify “trouble spots’ in a complex system tests have been exploring the applicability of
so that preventive measures can be taken such theories as dynamic self-mixing, which
(figure 34). It is also useful for comparing one has been applied to recent weapons develop-
kind of a risk against another where a choice ment and has been used to explain large
variations in the energy yield from volcanic
:~Federa] power commission, Initial Decision Of Ad-
ministrative Law Judge Samuel Gordon on Application ~Conversation with staff of U.S. Coast Guard,
of Pacific Indonesia LNG Company and Western LNG Washington, D. C., Mar. 18, 1977.
Terminal Associatesj Docket Nos. CP74-207 and Csummary of Workshop Recommendations on LNG
CP75-83, Washington, D. C., July 22, 1977, p. 118-119. Safety and Control (n.p.: Energy Research and Develop-
AArthur D. Little, Inc., Technology and Current prac- ment Administration, Dec. 15-16, 1976).
tices for Processing, Transferring and Storing Liquefied ~R.V. DeVore and L.A. Sarkes, LNG Research
Natural Gas, (Cambridge, Mass.: Arthur D. Little, Inc., Programs (n.p.: American Gas Association, Jan. 3,
December 1974). 1977).
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 61

Figure 34. Typical Fault Tree for Leak Which Is Not Isolated

Source Western LNG Terminal Co

explosions. If such theories do apply, it is con- about $50 million, making it the largest LNG
sidered possible that an unconfined LNG research program ever undertaken. The
vapor cloud could be detonated. However, in research design is still in the formative stages
all tests to date, no detonation of LNG clouds and it has not yet been determined how many
has been accomplished and efforts to detonate experiments will be conducted, how large they
using explosive triggers have resulted in igni- will be, and whether they will be on land or
tion and burning of the cloud but not explo- water.
sion. There are three critical questions about this
Some researchers believe that further tests proposed research and any large-scale, long-
are necessary to demonstrate that an uncon- range research which may be considered:
fined LNG cloud will not detonate. ●
FEASIBILITY: Is it possible to
At the present time, the Energy Research economically and safely transport large
and Development Administration is ten- quantities of LNG to a test site, to set up
tatively planning to conduct and study over a reliable monitoring equipment, and
period of more than 5 years several major generally to set off a large LNG fire
spills of LNG. The project is expected to cost which is both measurable and safe?
62 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

● VALIDITY: How valid will the results Many of these specific types of research
be from just one experiment or a small were called for by those who joined the OTA
series of experiments? Unless a large public participation program during the LNG
enough number of spills are conducted, assessment. These suggestions included:
the arguments resulting from interpreta- ●
site planning research to develop a na-
tion of a data base which is inadequate
tionwide siting plan and establish
will continue.
specific siting criteria;
● TIMELINESS: How timely will the ●
an independent detailed analysis of the
results of this research be 5 or more years
LNG system to specifically identify the
from now? How many significant LNG
safety issues involved;
policy decisions will still remain to be
resolved? ●
further investigation to determine the
Past research has produced conflicting most efficient methods of handling LNG
results and predictions, and it is unlikely that fires, to assess the possible impacts of
the United States can afford the time and such fires, and to establish procedures for
money to conduct enough research to resolve coordinating and mobilizing local fire-
the differences and come to firm decisions fighting efforts and evacuating neighbor-
about the safety and behavior of LNG. F o r ing areas;
this reason, decisions about LNG systems ●
a study of the capabilities and equipment
should be made on the basis of nonquan - of agencies responsible for inspection of
titative approaches which result in prudent LNG tankers and facilities; and
siting criteria and strict design, construc-
tion and operation standards. Existing

an analysis of the decisionmaking proc-
research techniques should be used to identify ess for LNG project applications so that
potentially dangerous elements in the overall better procedures can be established to
system so that specific research can be under- guarantee that the public will be able to
taken to find ways of improving the safety of express its concerns about the safety of
those elements. facilities.
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 63

Critical Review: Paper 6

LNG FACILITY SITING

One of the most controversial aspects re- in consideration of industry’s proposed site.
lated to LNG is the location of major import The lack of such participation has been iden-
terminals, storage facilities, and regasification tified as a serious concern of most of the public
plants. interest groups contacted during this study.
Siting is closely related to safety or to the The lack of any standards, which proposed
public’s perception of the safety of facilities. sites must meet, has led many groups to sug-
Environmental, land-use, and aesthetic con- gest that specific siting criteria be established.
siderations are also important. It seems possible either that a standard site
screening process could be established by the
There is currently no operating experience
Federal Government or that a set of uniform
with major baseload import terminals in the
siting criteria could be developed.
United States and only limited experience in
LNG shipping throughout the world. There are differing views on the ad-
Researchers, therefore, do not have sufficient visability of establishing such criteria on a
data on which to predict with any degree of Federal level: The American Gas Association
accuracy the likelihood that a major LNG has stated that each site is unique and must
spill will occur, how the spilled liquid and be treated on its own merits, while some repre-
resulting vapors will behave, and what would sentatives of public interest groups have
be the impacts of a spill. Since little is known, stated that a national LNG siting policy is
some citizens are fighting LNG facilities and needed to address safety and siting concerns.
have urged that the facilities, if needed at all,
During OTA’s public participation
be located at the sites which are remote from
program, the one concern most often voiced
dense population centers. about siting criteria w a s that the public
The principal questions of the siting con- should be involved to the maximum extent
troversy are: possible in establishing such criteria. Groups
also said they felt more public participation
“ Who should establish siting criteria?
would be necessary in permit processes or
● What criteria should be considered in ap- decisionmaking procedures set in place by
proving an LNG site? adoption of siting criteria.
● What is a “remote site?” Currently, three Federal agencies have
some bearing on site selection: FPC, OPSO,
Who should establish siting criteria? and the Coast Guard.

The FPC, which ultimately approves or
Site selection is currently undertaken solely
disapproves a site, was asked by a
by the company or consortium proposing an
group of Eastern States in May 1976, to
LNG import project for approval. The con-
establish siting criteria, but so far has
siderations which lead to a final selection are
taken no such action.
technical and economic ones. The Federal
Government’s role is strictly reactive, in that ●
The Office of Pipeline Safety Operations,
it can approve or disapprove sites proposed by which is responsible for the safety o f
industry but does not tell industry in advance facilities and pipelines involved in inter-
where it may or may not locate. state transportation of natural gas, has
proposed regulations which will impact
In addition, the Federal process is not on site selection primarily by mandating
designed to encourage local participation the size of a buffer zone to protect sur-

64 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

rounding areas from the heat of a fire at request of an applicant before FPC proceed-
the storage tanks and from the vapor ings begin or in response to the environmental
cloud which might form as a, result of a impact statement prepared by the FPC. The
tank rupture. 1 analysis considers such things as the depth
and width of the channels to be used by LNG
Since the LNG terminal operator would
ships, the necessity of dredging, the adequacy
have little control over property utilization
of surveys and charts, and the density and
outside his own property line, the result of
location of other waterborne activity.
the OPSO proposals is to require that the
However, the Coast Guard has no specific
terminal and storage tanks be located on a
criteria to use in evaluating each of these
large piece of property owned by the LNG
areas or specific standards which proposed
company. Under the proposed regulations, a
thermal exclusion zone would require that sites must meet. 3
storage tank dikes be about one-half mile Obviously, if there are to be Federal siting
away from humans in any public area. In ad- criteria, the expertise of these three Federal
dition, there is a requirement for a vapor dis- agencies should be combined and a single set
persion zone, which is the area necessary for of regulations formulated. However, it is not
vapor from an instantaneous spill of an LNG clear that these criteria should, in fact, be set
tank to dissipate to the point where gas con- at the Federal level. The selection of accepta-
centration in the cloud is less than 2 percent. ble sites for LNG facilities will involve many
Depending on the size of the LNG tanks and tradeoffs between environmental preserva-
the design of the dikes surrounding them, that tion, economics, and safety which can possibly
area could range from 1,000 to 12,000 acres best be made at the State and local level.
under the proposed regulations. z The alterna-
tive offered in the proposed regulations is a re- One possible mechanism for combining
dundant automatic ignition system, which local preferences with the national interest is
would set a spill afire and contain the heat in already in place. That is the Coastal Zone
the one-half mile thermal exclusion zone. Management Act. The Act charges coastal
States with formulating land-use and siting
. The Coast Guard has an indirect in- plans for coastal areas in exchange for
fluence on site selection by exercising its Federal funds for planning, implementation,
a) responsibility to determine if ships will and impact compensation. It requires that
be permitted access to a proposed site, facilities which require Federal licenses and
and b) its responsibility to advise all con- permits comply with the State plan unless
cerned parties of operational constraints specifically exempted by the Secretary of Com-
and safety criteria which would be ap- merce. 4
plied to the marine portions of the project
if it is approved. While the Act itself is still the center of
some controversy and has yet to prove itself as
The Coast Guard assessment of marine a management tool, the Act could provide a
transportation and safety aspects of a pro- framework in which to consider sites for LNG
posed project is made informally, either at the terminals and other energy facilities.

IU. S. Department of Transportation, office of What criteria should be considered?


Pipeline Safety Operations, “Liquefied Natural Gas
Facilities (LNG); Federal Safety Standards,” Federal
Register 42, no. 77, Apr. 21, 1977, 20776-20800.
Distance and population density should not
Zwesson & Associates, Inc., Compilation of Data on be the only criteria for siting LNG facilities.
Wesson & Associates, Inc. Key Personnel, Major Ex- Many other factors also affect the safety and
periences in LNG Technology—Safety—Fire Protection,
Industrial LNG R“re Training School and Comparison 3Conversation with staff of U,SO Coast G u a r d ,
of NFPA No. 59A with the Proposed OPSO LNG Washington, D. C., Aug. 15, 1977.
Facility Federal Safety Regulations, (Norman, Okla,: coastal Zone Management Act of 1972, 16 U.S.C. ##
Wesson & Associates, Inc., 1977. 1461 et seq (Supp, 1972).
CH. 11 – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 65

acceptability of a site, and it is possible that in The Federal Government could prepare na-
some aspects, such as availability of firefight- tional plans for future LNG import projects
ing equipment, nearness to distribution lines, based on:
and ease of access, remote siting may be a
1) the existing gas pipeline networks and
drawback,
projected demand;
One list of such factors is included in an
2) the projected domestic supply of gas to
alternative site study conducted for the FPC
these pipelines; and
during preparation of the environmental im-
pact statement for the Tenneco Atlantic 3) the possible foreign countries with ex-
Pipeline Company (TAPCO) application to cess gas to export.
build a 495-mile pipeline to New York from an
In this way an accurate number of future
LNG terminal in New Brunswick. s In this
projects could be forecasted. The American
study, a large section of the northeast coast
Gas Association has stated that less than 1 0
was screened for oceanographic, bathymetric,
additional LNG import terminals will be re-
navigational, and land-use conditions which
quired, but logical locations and relative
would identify potential LNG terminal sites. needs for these terminals have not been
The potential sites were then evaluated in
established. Following a national plan,
relation to other land uses, other shipping ac- evaluation of various possible sites or projects
tivities, safety, the consequences of accidents,
could be established utilizing guidelines
the possibility of system outages, environmen- covering such items as:
tal impact, and economic cost.
1) Location of sites relative to dense
If the Federal Government were to population centers and other land-use
establish siting criteria, an approach in three conflicts with terminal activities and
parts would probably be desirable. The first consideration of specific safety hazards.
would cover very minimum standards that ev-
ery site of a certain capacity would have to 2) Location of terminal relative to other
meet, the second would involve national ship traffic and existence of special
strategic planning, and the third would be traffic control.
specific site evaluation based on established 3) Local benefits of the specific industry
guidelines. base and possible satellite development.
Minimum standards could cover: 4) Possible degradation of natural areas
1) Property dimension and distance from or residential areas due to establishing
storage tanks or ship terminals to prop- added industrial activities,
erty lines; 5) Location of populated areas exposed to
2 ) Conditions of harbor entrances, ship- specific accident scenario at a terminal.
ping channels, turning basins, 6) Presence of specific external factors
anchorages, and tanker berths; which may lead to accidents such as
3 ) Relations to other marine and land-use severe weather, active seismic zones,
activities in the region, including im- nearby airports, etc.
pacts on natural resource values; and 7) Availability of equipment and methods
4 ) Presence of unusual hazards or related to control effects of accidents, such as
hazardous operations in the region. firefighting equipment and emergenc y
contingency planning.

~Resource Planning Associates, Inc., Alternative Site


8) Use of accident-prevention measures
Study, Northeast Coast Liquefied Natural Gas Conver- such as monitoring and inspection of
sion Facility (Cambridge, Mass.: Resource Planning facilities or operation, training of per-
Associates, July 1977). sonnel, and control of shipping traffic.
66 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

A number of citizen groups say that make it necessary that some facilities be as
offshore LNG terminals may be preferable much as 7 miles from populated areas. 6
from the standpoint of safety and land-use
One piece of legislation which appears to
issues.
define “remote” is the proposed California
Technology for offshore LNG terminals, Siting Act. It specifies that an LNG site meet
particularly mooring systems, transfer the following criteria:
systems, cryogenic pipelines, and large storage
tanks requires more detailed evaluation and s Within a radius of 1 mile of the site and
development. Standards for this technology the area within which maintenance and
are not developed and the environmental, operation of the facility will occur, no
economic, and technical tradeoffs have not person resides or works, other than per-
been evaluated. Offshore systems need sons who would be employed at the
detailed technical analysis and testing facility or at associated facilities that
before they can be considered viable alter- make substantial use of byproducts of
natives to onshore sites. LNG processing, such as facilities that
utilize waste cold.
What is remote?

Remote is not a definitive term; and even Figure 35. Distances a Vapor Cloud May Travel
those who argue for remote siting of LNG
facilities disagree on what they mean by the
Maximum Downwind Distance to 5 Percont Concentration Level Following
term. It generally implies a combination of 25,000 Cubic Meter Instantaneous Spill Of LNG onfo Water
distance and low-population density. —
Model Distance (Miles)
The unresolved question of what distance ——
from population centers would be acceptable U S Bureau of M i n e s 252-50.3*
is related to the unresolved questions of how American Petroleum Institute 52
far and how fast an LNG vapor cloud from a Cabot Corporation 11.5
major spill would disperse and what would U S Coast Guard CHRIS 16.3**
Professor James Fay 17 4**
happen if the cloud were ignited.
Federal Power Commission 075
Research models have made a variety of Science Applications, Inc 1.2***
/
predictions for the distance the cloud would ———-
travel following the largest possible spill on
water and assuming the vapors would not ig- Note Assumes 5 mph wind except as noted and meteorological condi-
tions considered applicable by investigating groups
nite initially. The predictions ranging from 1
mile to more than 50 miles (figure 35). ● A range was presented to indicate uncertainty in vapor evolution rate
● *Wind velocity not considered explicitly m model
An equally wide variety of distances have ●● ● For 37,500 cubic meter instantaneous release,
been suggested by parties interested in the wind velocity = 6.7mph
LNG siting issue, suggesting that facilities be Source U S Coast Guard
located between 1 to 25 miles away from
populated areas.
There are currently no Federal require- 6Wesson & Associates, Inc., Compilation of Data on
ments for remote siting, but proposed OPSO Wesson & Associates, Inc., Key Personnel, Major Ex-
periences in LNG Technology—Safety—lTre Protection,
regulations could, if adopted in present form, Industrial LNG Fire Training School and Comparison
of NFPA No. 59A with the Proposed OPSO LNG
Facility Federal Safety Regulations, (Norman, Olda.:
Wesson & Associates, Inc., 1977.
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 67

Within a radius of 6 miles of the site and radial distances specified in the section
the area within which maintenance and at any time.7
operation of the facility will occur, there
Although “remoteness’ (distance and
exists no residential or working, or both
population that exceeds 60 persons oc- population) is the siting criteria most often
cupying an area of 1 square mile, exclud- publicly mentioned it is not the only factor
which should be considered, as has been dis-
ing persons who would be employed at
the facility or such associated facilities. cussed in the preceding pages.
TCa]ifornia Assembly, Siting of Liquefied Naturat
The site is so located that no ship Gas Facilities, No. AB220, 1977-78 Regular Session,
transporting LNG will pass within the Jan. 17, 1977.
68 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Critical Review: Paper 7

LIABILITY FOR LNG ACCIDENTS

The liability issue is extremely complicated cessful; nevertheless, the law remains on the
and the law concerning it is far from clear. I t books.
seems possible, however, that the most
A difficult question would be posed if a fire
serious form of LNG accident, a ship acci -
originated onboard an LNG ship and spread
dent, could leave injured parties with little
to a surrounding harbor (or a vapor cloud
or no effective compensation. Preliminary in-
from the ship spread over the nearby land
vestigations indicate that the liability ques-
area and subsequently ignites). That is: would
tion is clouded by three areas of uncertainty:
the Limitation of Liability Act apply, since the
“ the extent to which maritime law would accident originated with the ship? Another
govern various possible accidents; provision of the shipping laws, the Admiralty
Extension Act of 1948, seems to indicate that
● the uncertainty within the maritime area
it would, in that admiralty jurisdiction is to
as to how far the States can go in exercis-
extend to all injuries “caused by a vessel . . .
ing jurisdiction concurrently with the
notwithstanding that such damage or injury
Federal Government; and
be done or consummated on land.” 3
● the variety of State laws that would ap-
Since this Act was passed in 1948,4 it is
ply in instances where nonmaritime law
doubtful that Congress had in mind the poten-
applies.
tial disasters which could conceivably be
This is not to say that compensation for caused by LNG vessels. Furthermore, the
damage done in an LNG accident would charterer of a vessel may be deemed to be the
definitely not be forthcoming; however, that owner in certain specific cases and thus reap
possibility does exist. Therefore, this is an ex- the same benefits of liability limitation. 5
cellent area for more indepth analysis.
The situation is further complicated by the
complex patterns of vessel ownership which
Maritime law have evolved in the past 30 years. It is custom-
ary for a vessel to be owned by a special cor-
The most commonly discussed LNG acci-
poration which has no other assets besides
dent scenario starts with a ship collision, and
that vessel (i.e., if a fleet owner has six ships,
maritime law is, therefore, called into play.
each one will be “owned’ by a separate cor-
The most important consequences of maritime
poration). Although in maritime law a claim-
law is that, under the Shipowner’s Limitation
ant can attach a vessel until all claims relat-
of Liability Act, a vessel owner’s liability for
ing to it are settled (presumably bringing forth
“any act, matter, or thing, loss, damage, or
the true owners), in the case of an accident
forfeiture, done, occasioned or incurred, with-
where the ship is lost there is obviously
out the privity or knowledge of such owner’ is
nothing to attach. Furthermore, the corpo-
limited to the value of the vessel after the acci-
rate-shell device frustrates any action against
dental An exception is made for loss of life or
the owner, since without the ship the owner-
bodily injury, in which case liability is limited
to $60 per ton of the vessel.2 The judicial con-
struction of the terms “privity or knowledge’ 346 LJ, S,C. $ 740 ( 1970).
has been expanded so as to limit the number @rant Gilmore and Charles L. Black, Jr., The Law
of petitions for limitation which are suc- of the Admiralty, 2d ed. (Minneola, N. Y.: Foundation
Press, Inc., 1975), p. 523.
~If the charterer “Mans, victuals, and navigates such
146 L1. s.c. $ 183 (a) ( 1970). vessel at his own expense’ he is deemed to be the owner
~Ibid. $183 (b). for liability purposes. 46 U.S.C. $ 186 (1970).
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 69

corporation has no assets beyond its insurance based on its powers over interstate and
coverage and any judgment against it would foreign commerce.
be correspondingly limited.
In the absence of statute, case law would
govern. At a cursory look, there would not ap-
State versus Federal jurisdiction pear to be any uniformly applied analogy to
LNG; there are cases where the storage of
To complicate matters still further, there flammable liquids in proximity to population
has been considerable confusion recently as to or property has been held to be an abnormally
the extent to which the States may exercise dangerous activity requiring strict liability,
jurisdiction concurrently with the Federal while the same activity in a wilderness or less
Government regarding maritime activities. A obviously dangerous setting has not required
1973 Supreme Court decision refused to strike such liability. 9 A more definite statement on
down as unconstitutional a Florida statute land-based liability would require a closer
which set stricter State liability limits than look at the law in each of the States con-
Federal law for oil spills from tankers, 6 and a cerned. However, even where gas companies
Washington law banning supertankers from have liability insurance such insurance comes
Puget Sound will be reviewed by the Supreme into play only after the company’s liability
Court during the fall term of 1977.7 State- has been proven.
Federal jurisdiction in the maritime area is
therefore in a state of flux. Staff Working Paper No. 1
Since New York already has an LNG bill
which could be interpreted as providing for In November 1976, Senate Commerce Com-
strict liability for LNG tanker owners for mittee staff prepared a draft bill on LNG,
any accident occurring in port, 8 a n d Staff Working Paper No.1. 10 In addition to
California is currently working on an LNG providing for an LNG damages fund to help
bill, the ambiguity of State-Federal pay compensation in the event of an LNG acci-
jurisdiction in the maritime area may come dent, the draft bill also provided for strict
to plague LNG as well as oil. liability for both terminal and vessel owners
and operators up to a specified dollar
Land-based liability amount. 11 The fund would be used to pay for
claims which exceeded the set liability limits.
It seems relatively clear that if an acci- The American Gas Association (AGA) sup-
dent which did not involve a ship occurred ported the LNG damages fund in principle,
at an LNG terminal the law of the State in although it considered the version in the draft
which the terminal was located would bill “impractical.” Strict liability was opposed
govern the terminal owner’s liability. The by AGA, viewing it as “not consistent with the
key legal problem is whether there would be risks of LNG operations. ’ 12
strict liability or whether a showing of
negligence would be required. At least one Representatives from both the gas indus-
State, New York, has adopted a statute for try and public interest groups which joined
LNG which provided for strict liability, and
this is an area where Congress could legislate,
gWilliam L. Presser, H a n d b o o k of the La U* of
l%rts,4th cd., (St. Paul, Minn.,: West Publishing Co.,
1971).
~Askew v. The American Waterujays Operators, Inc., 1 [)Staff Working Paper No. 1, Nov. 12, 1976.
411 U.S. 325 (1973). 1 IIn the case of vessels, $75 million or $1,000 per ton,
may v. Atlantic Richfield Company, No. 76-930, as whichever is less; in the case of terminals, an upper limit
reported in the New York Times, Mar, 1, 1977, p. 16. of $100 million.
Welephone interview with staff of New York State 1 ILetter from AGA president George H. Lawrence ‘ 0
Assembly Services, Aug. 15, 1977. Sen. Warren G. Magnuson, Feb. 2, 1977.

96.597 0 -77-6
70 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

in OTA public participation program in fact, the problems of liability and insurance
cited liability as a serious problem. Many dealing with LNG accidents are not greatly
said that terminal owners cannot buy liability different than the problems of liability for
insurance beyond $100 million and saw a nuclear accidents, large oil spills, or other
need for either a liability fund financed by a catastrophic accidents. However, since many
tax on LNG sales or for legislation which pro- of these areas have already been the subject of
vides for coverage of possible disasters such as public and congressional concern and debate
that now in effect for nuclear powerplants. which have not yet resulted in legislation (see
appendix E), it may be desirable to consider
Some members of the LNG industry have
all possible catastrophic accidents as a class
stressed that LNG systems should not be
and consider liability and insurance problems
treated any differently in matters of liability
for the entire class, rather than for individual
and insurance than traditional commercial
members of the class.
activities, especially shipping activities. And,
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 71

Critical Review: Paper 8

RELIABILITY OF LNG SUPPLY

In a decade in which the United States has Government would review each application to
suffered from an embargo on petroleum and a import LNG with regard to the reliability of
four-fold increase in crude oil prices, importa- the selling country, the degree of U.S. de-
tion of any fuel raises legitimate questions pendence such sales would create, the safety
about the reliability of the energy supply. conditions associated with any specific in-
Algeria, a member of OPEC, is currently the stallation, and all costs involved. 3 The new
sole supplier of LNG imports to the United procedure also seeks to ensure that imports
States. Indonesia, the next likely supplier, is are distributed throughout the country, in an
also an OPEC member. Thus, reliability of effort to limit regional dependence.
these supplies and the results of a possible
curtailment should be considered. Any discussion of U.S. economic
vulnerability to an LNG embargo should take
However, it is not likely that these two na- the following factors into account:
tions will remain the only sources of LNG.
Several other countries also control major 1) IMPORTANCE.—Imported LNG cur-
portions of the world natural gas reserves and rently accounts for only one-twentieth
may market LNG in the United States. These of 1 percent of the natural gas consumed
possible future suppliers include Chile, in this country. In the future, however,
Nigeria, Colombia, the U. S. S. R., Iran, China, that percentage may rise to as much as
a n d A u s t r a l i a .1 Any contracts with these 15 percent.
other nations would, of course, provide 2) SUPPLIERS.—The two major foreign
greater diversity of supply and would mini- suppliers of LNG, in the near term, will
mize the potential for, and the impacts of, a
be Algeria and 1ndonesia.
disruption in LNG trade.
Relations with Algeria over the past decade
Reliability of suppliers can best be characterized as strained but im-
proving. As a result of the 1967 Middle East
1n 1976, the Energy Resources Council War and U.S. support of Israel, diplomatic
(ERC) sponsored an interagency task force on relations between the United States and
LNG. One subject examined was the security Algeria were severed. Algeria participated in
of supply question. On the basis of a review the 1973 oil embargo organized by the Arab
conducted by the Department of State the members of OPEC, but did not stop deliveries
ERC recommended that total imports of LNG of LNG at that time. Since 1973, however,
be limited to 2 trillion cubic feet per year, and diplomatic relations have been restored and
imports from any one country be limited to 1 trade between the two countries has been in-
trillion cubic feet per year. 2 The Carter Ad- creasing. The question remains whether
ministration, however, changed the recom- Algeria would curtail exports of LNG to the
mendations, adopting instead a more flexible United States as a result of future conflict in
posture that set no upper limit on LNG im- the Middle East or other political crisis.
ports. Under the new procedure, the Federal
United States gas company spokesmen are
quick to point out two factors mitigating
against a cutoff. First j Algeria itself has in-
IDean Hale, “LNG Report, ’ Pipeline and Gas Jour-
nal 204 (June 1977): p. 20.
ZExecutive o f f i ce of t he P r e s i d e n t , T he Natlona/ IExecutive C)ffice of the President, The National
Energy Plan (Washington, D. C.: U.S. Government Energy Plan (Washington, D. C.: U.S. Government
Printing Office, 1977), p. 57. Printing Office, 1977), p. 57.
72 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNC IMPORT SYSTEM

vested large sums of money in gas production However, as the natural gas shortage
and liquefaction facilities and has borrowed during the winter of 1976–77 demon-
heavily to finance these investments. Any strated, conversion to these sub-
overall supply cutoff would jeopardize stitutes-even if they are availabl--
Algeria’s ability to repay these loans and its cannot be undertaken rapidly and
efforts to channel LNG revenues to internal severe dislocations can result.
economic development. Second, the gas indus-
4) FEASIBILITY OF CARTEL AC-
try claims to have had good experience in
TION.—This is not the question of
dealing with the country.
whether a given country or group of
It seems fairly certain that an embargo countries might attempt cartel action,
would be imposed only in a time of crisis. but rather the question of whether such
Therefore, since the entire point of an em- an attempt is likely to be successful.
bargo is to exert the maximum possible There are four major conditions which a
economic pressure in order to achieve political cartel must meet if it is to exercise sus-
goals, Algeria’s economic self-interest could tained influence over international
be a minor factor in the debate on whether to trade for a given material: 6
embargo LNG supplies to the United States.
This is not to say that Algeria will impose an ● the concentration of exports among a
LNG embargo in the event of any future Mid- few countries;
dle East crisis, It does mean, however, that a ● inelastic demand for the material;
politically motivated disruption of LNG
supplies is at least plausible and should not ● inelastic supply of the material (or of
be dismissed quite as lightly as some LNG close substitutes) from sources out-
proponents have argued. side the cartel; and
Relations between the United States and ● policy cohesion and export discipline
Indonesia have, on balance, been good. In- among members to keep supply
donesia is a member of OPEC and has been a limited enough to maintain high
strong supporter of higher oil prices, but it did prices or possibly to achieve other
not participate in the 1973 embargo and does goals as well. Members of the cartel
not advocate using oil as a political weapon.4 must be strong enough financially to
The State Department views U.S. relations accumulate stocks and forego current
with Indonesia as extremely good at the pres- export earnings.
ent time. 5 Liquefied natural gas is somewhat difficult
There has been considerable concern to analyze along these lines. Trade in LNG is
among the international financial community such that it meets all four of these conditions.
in the last 2 years over Indonesia’s foreign In addition, since the present and likely future
debt and financial problems within its State suppliers of LNG are OPEC members, the
oil and gas company. This might limit Export- framework for concerted action is already in
Import Bank credit to Indonesia for LNG place.
facilities. However, there is one aspect of LNG which
3) SUBSTITUTES,—In normal circum- argues strongly against the probability of an
stances, petroleum, coal, and nuclear embargo. That is, unlike oil or other products
energy are alternatives to natural gas. which can be delivered to a customer almost
anywhere, LNG requires highly specialized
~Robert F. Ichord, “Indonesi a,’ in Gerard J. and very expensive processing and handling
Mangone, cd., Energy Policies of the World, v. 2: In- equipment. The long leadtime required—3 to
donesia, The North Sea Countries, The So~~iet Union
(New York: Elseview, 1977), p. 68. 6Edward R. Fried, “International Trade in Raw
~Department of State, Background Notes.” Indonesia Materials: Myths and Realities,” Science 191 (F’eb. 20,
(Washington: Department of State, July 1974), p. 7. 1976): 641-646.
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 73

4 years to construct LNG facilities—fairly well estimating the total State supply in 1980 and
limits the number of customers to whom a 1985, the 1975 supply was reduced by 12 per-
supplier can sell. The limited number of cent or 20 percent respectively, and then in-
customers who can receive LNG shipments creased by the anticipated LNG supply.
makes the supplier almost as dependent upon
uninterrupted service as the receiver. The results are tentative because not all of
the El Paso II LNG has been precisely allo-
Impacts of an interruption in supply cated to the States. However, in most cases
this imprecision is not significant.
Based on OTA’s work, it does not appear This study indicates that in the next
that there is, at present, any serious threat to decade these eight States expect to get from
the national economy from dependence on im- 33 to 91 percent of their natural gas (figure
ported LNG, nor is there likely to be a danger 36) from a group of companies which plan
in the near future. However, regional or local to meet as much as half of their gas needs
dependence on LNG supplies could cause with imported LNG. As a result some in-
some problems. dividual States will be dependent upon im-
It appears that about eight States could be ported LNG for nearly one-fourth of their
dependent on LNG for a large part of their natural gas supplies (figure 37).
natural gas supplies by 1985 if currently Alaskan natural gas which might be moved
planned import projects go into operation. as LNG was not counted in these calculations.
These States are: Nevertheless, it is clear that reliance on LNG
Alabama New York could be considerable.
California Ohio
Georgia Pennsylvania
Figure 36 States Dependent on Companies Using LNG
Michigan South Carolina
as Part of Gas Supplies
These States stand to benefit directly from im-
ported LNG; therefore, they also are the most State Suppliers 1975 volume Percent of State
vulnerable to any interruption in the supply. to use LNG delivered consumption
(consumption (in Bcf) provided by
For purposes of this study, a State’s de- in Bcf) suppliers listed
pendence on LNG was measured in terms of ——.
Ohio Columbia 490.4
its natural gas supplies from all sources, in-
(957) Consolidated 269.2
cluding LNG. According to an earlier OTA
study, domestic supplies of gas (excluding sup-
Panhandle 66.9 86
Pennsylvania Columbia 211 2
plementary sources s u c h a s S Y N g a s o r (654) Consolidated 987 47
Alaskan gas) will decline 12 percent na- Georgia Southern 269 91
tionally by 1980 and 20 percent by 1985. 7 (326)
These are at best crude figures, which over- California El Paso 943 51
look regional differences. g Therefore, in (1848)
S. Carolina Southern 96.3 78
VJ. S. Congress, Office of Technology Assessment, (122.9)
Analysis of the Proposed National Energy Plan
(Washington, D. C.: U.S. Government Printing Office,
New York Consolidated 190.3 33
(576.8)
August 1977), extrapolated from p. 30.
Wurrent synthetic gas production from petroleum Michigan Trunkline 151 3
feedstock was included in the analysis but no additional (887) Panhandle 680 25
production was estimated on account of recent govern- Alabama Southern 1677 64
mental actions restricting it. If the contribution of (264)
SYNgas from coal in the early to mid-1980’s is small, as
seems possible in light of delays in starting proposed .
projects, then U.S. supplies of natural gas will be from
domestic reserves and LNG almost entirely. Source OTA
— ——. .

74 CH.II CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Figure 37. Percent of LNG in State Consumption and For example, the average delay in the con-
Company Supplies (Imports from Foreign struction of three LNG tankers at the Quincy
Countries Only) Shipyard has been about 2 years. Part of the
delay was planned because no terminals were
—.—.——. ————
LNG supply if all
ready for the ships, but many shipbuilding
projects approved LNG use as a problems caused other actual delays. 9
and operating on percent of total
State schedule (in Bcf) supply In addition, at all the U.S. shipyards in-
— .—.-—— volved with LNG tankers, there have been in-
1980 1985 1980 1985
Figure 38. Percent of LNG in State Consumption and
California 226 463 12 24 Company Supplies (Including Alaskan Gas)
Ohio 122 143 13 15
Pennsylvania 41 48 7 8 —. .
New York 59 74 10 14 LNG supply if all
projects approved LNG use as a
Georgia 61 94 18 30(20#) and operating on percent of total
Alabama 23 35 8 13 State schedule (in Bcf) supply
South Carolina 20 31 16 28 (22#) ——
Michigan 87 87 10 11 .—
(#) Percent of LNG use possible if domestic production IS reduced by 20 1980 1985 1980 1985
percent and consumption remains relatively unchanged — —
Company California 299 913 13# 43( 24 # )
Columbia 116 116 13 14 Ohio 122 265 13 30 (20#)
Consolidated’ 136 190 26 44 Pennsylvania 41 95 7 15
Southern” 136 210 28 56 New York 59 74 10 14
El Paso o 237 0 26’ ● Georgia 61 94 18 30( 20#)
Trunkline 902 902 52 66 Alabama 23 35 8 13
23* ●●
Panhandle 738 738 17 South Carolina 20 32 16 28(22#)
Pacific Gas & El 113 113 ( )( ) Michigan 87 101 10 12
So Calif. & (#) Percent of LNG use possible if domestic production i S reduced by 20
Pacific Lighting 113 113 ( )( )
percent and consumption remains relatively unchanged
Company
● Assumes certain deliveries of LNG from El Paso II (United Gas Pipeline) Columbia 116 362 14 44
● 24% with planned production from coal gasification Included in Consolidated’ ● * 136 190 26 44
supply Southern** 136 210 28 56
● *•18.2% with planned production from coal gasification included in El Paso o 383 0 39*
supply Trunkline 902 902 52 66
Panhandle 738 131.8 17 32*
Pacific Gas & El 113 259 ( ) 24
So Calif &
Pacific Lighting 113 429 ( ) 40
If Alaskan LNG is factored into the sup-
——-——.—
plies, on the theory that technological as well
as political problems could cause interrup- ‘Includes SYNgas from coal m total estimate
tions in supply, dependency in California ● ● Assumes 74 Bcf/yr from El Paso II (deliveries from
would rise drastically (figure 38). United Gas Pipeline)
● * ● Assumes 54 Bcf/yr from El Paso II (deliveries from

Technological interruptions are not out of United Gas Pipeline)


the question. There has already been ample
evidence that they are possible, Source OTA

9
Tom Connors, “Domestic LNG Vessel Construc-
tion, ” paper presented at the Chesapeake Section Meet-
ing of Society of Naval Architects and Marine
Engineers, Bethesda, Md., May 1977.
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 75

stances of subcontractor failures, startup possibility that LNG could provide a signifi-
difficulties after construction of new facilities, cant portion of the supply. However, many of
or other delays. State supplies could be just as the citizens and public interest groups also
seriously affected by this type of interruption indicated concern about the reliability and
or delay as by embargoes or cartel action. the cost of LNG supplies which would be
coming from foreign nations. Several
Most members of OTA’s public participa-
specifically questioned the political stability
tion program were well aware of the need for of supplier nations.
more natural gas and understood the
76 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

Critical Review: Paper 9

LNG PRICING POLICY

In the complex LNG system, the price for following prices have been set for imported
which the product can be sold is a key con- LNG: 1
straint on the development of new projects. Distrigas $1.90 per million
There is no internationally accepted price of (Boston ) Btu (1972)
natural gas at the wellhead, but in most El Paso I $1.80 per million
foreign markets gas supplies—including (Md. & Ga. ) Btu (1972)
LNG—are price linked to alternative energy Panhandle $3.37 per million
sources on a Btu-equivalency basis. (La.) Btu (1977)
Pac/Indonesia $3.59 per million
Foreign pricing mechanisms make it fairly (Calif.) Btu (1977)
likely that LNG will be price competitive with
other fuels in the near future, thus making it
The lower prices appear competitive with
likely these countries will be strong markets
other fuels imported to the east coast, but
for LNG.
there is consensus that future Algerian LNG
In the United States, however, the cost/price will be increased to account for the costs of
situation is extraordinarily complicated by other alternative fuels.
the regulation of natural gas prices, making it
In contrast, the wellhead price of domestic
more difficult to determine if LNG will be
natural gas in interstate sales is now regu-
price competitive with other fuels.
lated by the FPC at a top price of $1.44 p e r
In Western Europe, the threshold price for m i l l i o n- Btu’s for gas produced from wells
imported gas, whether it is transported by commenced on or after January 1, 1975, and
conventional pipeline or as LNG, will be set by at an average of about 76 cents per million
North Sea gas and low-sulfur content im- Btu’s for all U.S.-produced interstate gas. The
ported fuel oil. On the basis of 1977 prices, im - President’s proposed National Energy Plan
portation of Algerian LNG should be price places a ceiling on all new natural gas, pro-
competitive for the foreseeable future. De- duced from wells beginning in 1978, of $1.75
pending on prices set by producing nations, per million Btu’s at the wellhead.
LNG from Nigeria and the Persian Gulf could
Thus, it appears probable that for the
also be price competitive in the major Western
foreseeable future the price of imported
European markets.
LNG will be significantly higher than the
Japan is now importing low-sulfur fuels regulated price-of ‘domestic gas and proba-
from several world suppliers and LNG from bly of many other energy alternatives. In
Indonesia and Alaska. Liquefied natural gas addition, the confused cost/price situation, in
can command a higher price in Japan than combination with the substantial technical
can alternative fuels because its clean-burn- and commercial risks associated with LNG,
ing properties offer a way of providing pollu- may limit growth beyond those projects which
tion-free, electric-power generation. are now proposed.
In the United States, where prices and At present there is no policy for the FPC
mechanisms for passing prices on to the ulti- to follow in making decisions about pricing
mate customer are established by the FPC, the LNG. The major debate centers on the use of

IThe world market price for crude landed in U.S.


during 1976 averaged $13.48 per barrel which is
equivalent to $2.32 per million Btu’s.
CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM 77

rolled-in pricing versus the use of incremental would probably sell for at least $3,00 per
pricing. thousand cubic feet. Therefore, a customer
could bid for new gas up to the $1.75 ceiling
Incremental pricing means that each
but would then be forced to jump to the $3.00
customer using LNG is charged the full cost of level if he wanted more than the $1.75 price
the amount of LNG he actually uses. Under a would bring forth. Any natural gas that could
rolled-in pricing formula, he would pay a
be produced at intermediate prices would be
price determined by the weighted average of foreclosed, which would defeat some of the
all the flowing gas and LNG used in the
purpose for going to incremental pricing in the
system. 2 first place.
In most cases industry has claimed that
Another difficulty with rolled-in pricing is
rolled-in pricing is necessary to the financial
that it forces all customers to subsidize LNG
viability of LNG import projects.
whether they use it or not. However, industry
Industry fears that the market will become spokesmen argue that supplemental gas proj-
so uncertain if the gas is incrementally priced, ects such as LNG are of direct benefit to all
that the necessary financing will not be ob- customers because they increase the quantity
tainable at acceptable interest rates. The of gas supplies.
argument is also made that rolled-in pricing is
The main argument against incremental
the best method to ensure maximum use of the pricing is that it would raise gas prices to a
existing pipeline system.
point where the market for LNG may become
Since the gas pipeline system is a major unstable. Another argument against incre-
capital investment and therefore a large fixed mental pricing is that there is no feasible
cost, when volumes decline the utilities are mechanism for separating and selling a cer-
forced to charge customers a higher unit price tain portion of high-priced gas to specific
for the gas. It is therefore argued that even if customers. Finally, it is claimed that incre-
supplemental gas itself is very costly, rolled-in mental pricing cannot be administered while
pricing will lower the unit charges to con- also following a policy of curtailing gas for
sumers because more of the pipeline will be low-priority customers.
filled. There were few comments addressed to the
The principal objection to rolled-in pricing pricing issue during OTA’s public participa-
is that the consumer does not pay the replace- tion program. There was, however, discussion
ment cost for the gas he is using. He is given of the fact that it is a complex issue which the
an incorrect signal as to the actual value of public is still attempting to understand. There
these incremental LNG supplies and has less was also considerable discussion of the subject
incentive to look for more efficient ways to use at OTA’s LNG panel meeting.
gas or for alternatives that would be less cost- In general, it appears that gas-related
ly. Therefore, adoption of rolled-in pricing businesses and industries support rolled-in
would appear to be counter to the goals of pricing while public interest groups sup-
energy conservation and replacement cost port incremental pricing. The stand behind
pricing set forth in the President’s proposed incremental pricing appears to be motivated
National Energy Plan. by the desire to have energy priced at a true
However, if LNG is incrementally priced it cost which will encourage conservation and
the search for alternatives.
ZFor “Rolled-in’ versus “incremental’ pricing argU-
ment see—” Incremental Pricing of Supplemental Gas”
To date, the FPC has approved rolled-in
by FPC Office of Economics—Aug. 1976; Response to pricing for all major new LNG import proj-
this report by Robert Nathan Associates, Dec. 1976; and ects. And, traditionally, all new natural gas
“The Future of Natural Gas; Economic Myths, supplies have been priced on a rolled-in, or
Regulatory Realities” by FPC Bureau of Natural Gas— average, basis to the consumer. However, in
Nov. 1976.
78 CH. II – CRITICAL REVIEW OF COMPONENTS OF LNG IMPORT SYSTEM

the recent Trunkline case, the FPC made an the new Department of Energy. Some of the
initial decision for incremental pricing, which questions which should be addressed include:
was later reversed. ●
Should pricing mechanisms be used to
Although it is not certain, it appears that encourage or discourage the develop-
rolled-in pricing may be the mechanism ment of LNG projects?
chosen in the future. When considering only ●
Will the use of rolled-in pricing dis-
the two pricing mechanisms, it appears that
courage the use of alternative energy
rolled-in pricing would provide less incen-
sources which might be available at
tive for industry to seek new domestic sup-
prices lower than the incremental price
plies. It may, instead provide an incentive
or have greater long-term security of sup-
for importing LNG and using other expen-
ply possibilities, such as solar energy?
sive alternatives, the costs of which will be
passed on to the consumer. ●
Will rolled-in pricing give certain LNG
projects unfair competitive advantage
Thus, pricing decisions for future LNG proj-
because customers will not notice the
ects will have effects beyond the immediate
added cost?
cost of gas to consumers. They will also affect
the supply, demand, and prices of other ●
Will rolled-in pricing unfairly affect cer-
energy, and major energy decisions related to tain regions by encouraging use of LNG
the national interest. at the expense of developing more
domestic supplies at a possibly lower
Ultimately, pricing is not strictly an LNG
cost ?
issue. It is an issue which now surrounds all
forms of energy. No decision on LNG pricing ●
Can incremental pricing be established in
should be made in isolation. Pricing of all a way that will allow companies to pro-
forms of energy should be considered in the duce and sell LNG separately from other
context of a national’ policy. This issue gas and be compatible with curtailment
should be one which gets early attention from policies?
.

Public Awareness
and Concerns
About LNG
Chapter III

Public Awareness and Concerns


About LNG

Like many other types of energy and energy More than 100 persons from gas utilities
systems, the use of LNG as a method of and related industries and financial institu-
transporting natural gas from distant sources tions, organized labor, State and local agen-
has become a subject of public attention and cies, and public interest groups were directly
controversy in recent years. involved in the public participation program.
Through them, OTA was able to identify the
Thus, the range and diversity of views held key issues which have been or will be raised in
by the people who will be affected by the use of the public debate and which should be
LNG are important to Congress in its con- analyzed for possible Federal action. Through
sideration of possible new legislation, over- them, OTA was also able to appreciate the
sight activities, and budget appropriations to wide range of views on these issues and incor-
Federal agencies involved in the regulation of porate those views into its report to Congress.
LNG projects and facilities.
In order to provide Congress with informa- Much of the discussion of LNG during the
tion on these views, OTA conducted a public public participation program centered on
participation program in connection with this specific LNG projects and the concerns which
assessment of the transportation of liquefied various interest groups have had about those
natural gas. The program consisted of a day- projects. Public involvement with LNG proj-
long workshop in Washington, D. C., a ques- ects has been limited to date, but has included
tionnaire/interview survey in relevant coastal participation in formal hearings before the
areas, and a review of this draft report by FPC, legal action, and dissemination of infor-
members of the public. mation about the issues involved. 1
These activities were designed to obtain in- Although individual opinions on issues
formation about the opinions and beliefs of varied, it was obvious from the public par-
the public in four areas: ticipation program that there are three major
issues in the consideration of LNG systems:

the benefits and risks which various
groups associated with the development s safety of LNG ships and terminals;
of an LNG system or alternatives to that
● criteria for siting of LNG facilities; and
development;
● public participation in decisionmaking

concerns about marine transportation of
processes.
liquefied natural gas and the siting of
LNG facilities;

the adequacy of the decisionmaking and ILeonard E, Bassil, “Cove Point Liquefied Natural
regulatory processes relating to LNG; G a s T e r m i n a l , Calvert County, Md., ” National
and Academy of Sciences National Research Board,
Maritime Transportation Research (unpublished), and

the need for Government action in the Andrew J. Van Horn and Richard Wilson, Liquefied
form of legislation, policymaking, or Natural Gas Safety Issues, Public Concerns, and Deci-
sion Making. Cambridge: Harvard University, 1976.
research.
81
82 CH. III – PUBLIC AWARENESS AND CONCERNS ABOUT LNG IMPORT PROJECTS

The varied views of the public who worked human resources away from the develop-
with OTA in this effort are particularly ment of alternative types of energy?
reflected in the section, “Critical Review of
● Will the development of LNG systems
Components of the LNG System.” Their
produce unwarranted confidence in tra-
specific suggestions for action to help resolve
ditional energy supplies and prevent a
major problems are itemized in the next sec-
major commitment to energy conserva-
tion of this chapter. However, the public also
tion?
expressed strong interest in several broader
issues which are beyond the scope of this On the other end of that concern, many asked
report. These broader questions which have about the impact of not developing LNG
not been answered to the satisfaction of many systems. They argued that not proceeding
include: could result in “an unprecedented economic
disaster” by creating shortages of energy in
● Is there a need for LNG in the first place?
critical industries, decreasing possible con-
“ Will the development of LNG systems tributions to the gross national product, and
divert major amounts of capital and increasing unemployment.

Actions Desired By
GAS UTILITY COMPANIES

Gas company respondents included repre- the possibility of overdependence on a


sentatives of the American Gas Association, single source should be addressed on a
Algonquin Gas of Massachusetts, Columbia project-by-project basis.
LNG Corp., Southern California Gas, Central ●
The State and local approval processes
Power and Light Company in Texas, and should be consolidated where feasible.
United Gas Pipeline Company of Texas.

The Federal Government should
The respondents suggested the following: establish clear safety criteria on a
“ The Federal Government should generic, rather than case-by-case, basis.
streamline the regulatory process by ●
The Federal Power Commission should
declaring policies on LNG pricing, LNG approve a formula to allow companies to
facility siting, a n d o t h e r i m p o r t a n t pass on escalations in the cost of foreign
aspects of LNG development. gas or transportation without new hear-
● One Federal agency should coordinate ings.
all LNG procedures in order to accelerate ●
The Federal Power Commission should
the regulatory process and eliminate allow rolled-in pricing.
jurisdictional overlaps among the
Federal Power Commission, the Office of

The Federal Government should main-
Pipeline Safety Operations, and the U.S. tain existing financial incentives now
Coast Guard. available through the Maritime Ad-
ministration and the Export-Import
● There should be Federal preemption on Bank.
environmental and siting issues. ●
Congress should adopt legislation pro-
● Ceilings on LNG imports should be viding for adequate insurance coverage
avoided, but the security of supply and by means of a fund supported by LNG
sales.
CH. III – PUBLIC AWARENESS AND CONCERNS ABOUT LNG IMPORT PROJECTS 83

● The Federal Government should under- to be carried out by the Coast Guard and
take additional studies of LNG safety, the Energy Research and Development
especially vapor cloud studies and risk Agency.
analysis, with large-scale LNG spill tests

Actions Desired B y
ORGANIZED LABOR GROUPS

Respondents from organized labor groups Federal preemption should be used if


included representatives of the AFL-CIO and necessary to arrive at early decisions on
other groups. LNG issues, but there should also be
maximum State, regional, and local in-
The respondents suggested the following: volvement in decisions.

Congress should adopt legislation to cor- All Coast Guard procedures should be
rect deficiencies in the LNG regulatory reviewed to determine the adequacy of
process and eliminate counterproductive
ship traffic control and inspection of
time lapses and delays. LNG tankers.

Ratesetting policies should not dis- The Federal Government should require
courage the utilization of imported LNG. agencies involved in LNG approval proc-

Congress should adopt legislation to esses to act on permit applications within
mandate the use of U.S. flag ships with a given time frame.
U.S. personnel for LNG transportation in Additional studies should be undertaken
order to increase national security and to determine the capability of Coast
ensure full compliance with construction Guard units assigned to aid LNG tankers
and safety standards. and to assess the adequacy of equipment

There should be a prompt decision on the in use.
gas transportation system to be used for Studies should also be undertaken to
North Slope Alaskan gas, including pro-
determine what industries are compati-
vision for a western delivery system.
ble and could be located near LNG ter-
minals.

Actions Desired By
STATE AND LOCAL OFFICIALS

Respondents from State and local offices tal Conservation, and the Georgia Coastal
included representatives of the Public Utilities Zone Management Office,
Commission staffs in New Jersey, California, The respondents suggested the following:
Rhode Island, and Massachusetts; represent-
atives of the cities of Providence, R. I., Oxnard ● The Federal Government, with the in-
and Los Angeles, Calif.; and representatives volvement of local interest groups and
of the New York Department of Environment- governments, should establish pro-
84 CH. 111 – PUBLIC AWARENESS AND CONCERNS ABOUT LNG IMPORT PROJECTS

cedures for the selection of suitable loca- “ Congress should adopt legislation which
tions for future LNG facilities. will ensure that the costs of shipping
LNG by oceangoing vessels are just and
● The Federal Government should, where
reasonable.
practical, eliminate overlapping jurisdic-
tion with respect to siting, construction c Additional studies should be made of
and monitoring of LNG facilities. LNG spills on water, underground
storage of LNG, and greater use of im-
“ The Federal Government should ex-
ported LNG as pipeline gas.
pedite and consolidate the various permit
processes required for approval of an s The Federal Government should also
LNG facility. promote research into alternative fuels
which might be more abundant and
● The Federal Government should pro-
possibly less costly; research into conser-
mulgate and enforce safety regulations vation methods; and studies of the
and establish standards for transporta-
possibility of curtailing the sales ac-
tion and storage of LNG.
tivities of gas distributors.

Actions Desired By
RELATED INDUSTRIES

Respondents from businesses and indus- ●


The Federal Government should develop
tries related to the LNG industry included a pricing structure which will ensure ade-
representatives of shipbuilding companies and quacy of supply.
associations, gas pipeline companies, safety ●
The Federal Government should adopt a
consulting firms, marine engineering firms,
clear policy on incremental and rolled-in
the industrial construction industry and fi-
pricing.
nancial institutions.

Additional study should be made of
The respondents suggested the following:
pipeline vs. LNG systems of transporta-
c The Federal Government should resolve tion, including study of the political,
the issue of who is in charge of siting and security of supply, safety, and environ-
safety matters and should establish a mental issues.
“one stop’ permit process. ●
Studies should also be made which
“ Clearly defined policies and fair regula- would improve LNG vapor dispersion
tions should be adopted to accelerate the analysis and allow refinement of vapor
regulatory process. dispersion models to take into considera-
“ The Federal, State and municipal permit tion local topography and manmade
obstructions.
processes should be coordinated.

Studies should be undertaken to identify
● The Federal Government should assist
industry in meeting energy demands and the problems and solutions associated
with transportation and distribution of
in determining the safest, most viable
LNG to and from inland baseload and
means to transport, store, and distribute
LNG in interstate commerce. peak shaving plants.*

“ The Federal Government should ensure *Note: on e respondent said further studies were
a smooth transition to the new Depart- not desirable because they would only cause addi-
ment of Energy. tional delays in development of LNG.
CH. 111 – PUBLIC AWARENESS AND CONCERNS ABOUT LNG IMPORT PROJECTS 85

Actions Desired By
PUBLIC INTEREST GROUPS

Respondents from public interest groups in- needed and limit LNG imports so that
cluded representatives of California-based na- they do not become a major part of the
tional groups such as the Natural Resources U.S. gas supply.
Defense Council and the Sierra Club; ●
The Federal regulatory procedure should
Washington-based national groups such as be improved to allow for timely selection
the Environmental Policy Center; and local
of sites, if they are needed, with max-
citizens groups in Maryland, California, imum public participation in the process.
Rhode Island, New Jersey, New York,
Massachusetts, and Texas. ●
The Federal Power Commission should
mandate incremental pricing for LNG,
The respondents suggested the following:
and keep a close watch on price and sup-
c Congress should adopt legislation to ply.
restrict LNG storage tanks and terminals ●
Federal supervision of daily operations
to isolated areas.* of LNG facilities should be increased.
● The Federal Government should take a ●
Existing LNG tanks that do not meet new
more active planning role in LNG ter- siting criteria should be phased out.
minal siting and should establish broad
Federal policy on siting in advance of in- ●
The Federal Government should set
dividual project decisions. mandatory conservation standards and
determine uses of natural gas in order to
● Federal siting policy should be developed diminish reliance on natural gas.
through public hearings on generic safety
and siting considerations. ●
The Federal Power Commission should
develop procedures for ensuring effective
“ The Federal Government, in conjunction public participation, including adequate
with State and local groups, should iden- notice of pending proceedings and pay-
tify and review available sites which ment of attorney and witness fees for in-
could be potential LNG terminal loca- tervenors.
tions without waiting for specific applica-
tions. ●
The environmental impact statement
process should be simplified and should
●The Federal Government should act to
include consideration of safety issues.
ensure rational land-use planning by the
States through the Coastal Zone ●
The Coast Guard should strictly control
Management Act or other means. the movement of LNG tankers and other
ship traffic on the LNG tanker route.
“ The Federal Government should deter-
mine whether and how much LNG is ●
There should be intensive training of all
& Note. Respondents varied in siting criteria. personnel involved in the inspection and
regulation of LNG tankers and facilities.
Some said LNG terminals and tanker
routes should be at least 1 mile from popu- ●
Transportation of LNG by truck should
lated areas. Other suggested distances be controlled with procedures similar to
ranging up to 25 miles from populated those which regulate the movement of
areas. Several said terminals should be LNG tankers.
restricted to offshore sites. One said ter-
minals should be located in already in- ●
The Federal Government should man-
dustrialized areas with small populations. date development of evacuation plans by
96.597 0 -77-7
86 CH. III – PUBLIC AWARENESS AND CONCERNS ABOUT LNG IMPORT PROJECTS

local jurisdictions near LNG facilities dangered, methods of combating LNG


and ensure that there will be adequate fires, and methods of protecting citizens
local firefighting capability. in endangered areas.
“ Congress should adopt legislation to en- ●
Studies should also be made of LNG im-
sure that there will be adequate liability port projections under all regulatory cir-
insurance which defines coverage and cumstances (i.e., with and without import
responsibility for accidents. restrictions, with rolled-in pricing, with
incremental pricing, etc. ) and the
s There should be additional studies of economic consequences of LNG em-
large marine spills of LNG, vapor disper- bargoes by producing nations.
sion, and other safety questions, includ-
ing the consequences of large terminal ●
Studies should be made to find appropri-
accidents, the effect of such accidents on ate alternatives to the development of
homes and industries supplied by the ter- LNG systems.
minal, the time required to rebuild a ter- ●
Siting of LNG facilities in areas which
minal, alternate energy sources available have prime ecological or aesthetic values
after an accident, size of the area en- should be avoided.
—...— .... —

.
Appendix A

Cove Point, Md., Permits

Terminal

Application Permit
Regulatory Agency Description of Action Date Date

Board of County Commissioners of Rezoning 317.722 acres from — 8/11/70


Calvert County, Md. Al to Il.
Federal Power Commission. Opinion No. 622 CP71-68. 9/21/70 6/28/72
Federal Power Commission. Opinion No. 622A CP71-289. 6/ 4/71 10/ 5/72
Federal Power Commission. Amended—Tunnel plan 12/ 8/72 3/30/73
Calvert County Department of In- Site grading for office building 6/ 9/72 6/14/72
spection and Permits.
Calvert County Health Department Deep-drilled well and sewage- 6/19/72 7/13/72
disposal system.
Completion certificate. 11/15/72
Calvert County Department of In- Construction of office and 6/22/72 7(21172
spection and Permits. maintenance building.
Department of the Army, Baltimore Construction of pier. 9/ 1/72
District, Corps of Engineers. 4/ 7/71 8/31/72
State of Maryland, Department of Water quality certification. — 12/18/72
Natural Resources.
State of Maryland, Department of Wetlands license. 12/ 4/72 12/26/72
Natural Resources.
Department of the Army, Baltimore Construct unloading terminal 12/ 4/72 12/29/72
District, Corps of Engineers. and tunnel and dredge in
Chesapeake Bay.
State of Maryland, Department of Appropriate and use ground 10/21/72 11/28/72
Natural Resources water for sanitary facilities.
State of Maryland, State Highway Construction of two entrances. 11/20/72 3/12/73
Administration. Extension. 7/ 5/73
Calvert Soil Conservation District. Erosion and sediment control 4/ 5/73 5/14/73
measures
Calvert County Department of In- Site grade and preparation for 4/ 5173 5/18/73
spections and Permits construction; LNG terminal
process area,

96-597 0- ~~ -8
89
90 APPENDIX A

Application Permit
Regulatory Agency Description of Action Date Date

Calvert County Department of In- Construction of cofferdam 8/14/73 8/15/73


spections and Permits
State of Maryland Fire Marshal Approval of office and 8/31/73
warehouse
State of Maryland, Department of Burning debris 9/17/73
Forests and Parks
State of Maryland, Department of Small pond permit 10/ 1/73
Natural Resources
Calvert County Department of In- Site grading in lowland area. 10/12/73 10/12/73
spections and Permits
Calvert County Department of In- Construction of LNG storage 10/15/73 10/24/73
spections and Permits tanks.
State of Maryland Comptroller of the Sales and use tax direct pay- 1/ 2/74
Treasury ment permit.
Calvert County Health Department Construction of deep drilled 10/25/73 1/29/74
well and sewage disposal
system.
Completion certificate. 2/24/75
Calvert County Health Department Construction of deep drilled 10/25/73 1/29/74
well and sewage disposal
system.
Completion certificate 1/ 7/75
State of Maryland, Water Resources Appropriate and use water for 1/31/74
Administration sanitary facilities, cooling
water, testing and fire pro-
tection
Federal Communications Commis- Radio license. 4/15/74
sion
State of Maryland Fire Marshal Approval of fire protection 5/30/74
plan.
Department of Transportation, U.S. Private aids to navigation (five 7/ 5/74 7/18174
Coast Guard lighted survey towers)
State of Maryland Fire Marshal Approval of use of tunnel by 8/26/74
personnel
Calvert County Department of in- Construction of two firewater 9/18/74 9/20/74
spections and Permits storage tanks
Calvert County Department of In- Construction of 12 buildings 10/21/74 10/23/74
spections and Permits for use with receiving ter-
minal
State of Maryland Environmental Construction of emergency 7/11/75 9/16/75
Health Administration vent heater
APPENDIX A 91

Application Permit
Regulatory Agency Description of Action Date Date

State of Maryland Environmental Construction of LNG vaporizer 7/1 1/75 9/16/75


Health Administration
State of Maryland Environmental Construction of emergency 7/1 1/75 9/17/75
Health Administration purge nitrogen vaporizer
State of Maryland Environmental Construction of firewater tank 7/1 1/75 9/17/75
Health Administration heater
State of Maryland Environmental Construction of gas turbine 7/1 1/75 9/17/75
Health Administration fuel gas heater
State of Maryland Environmental Construction of boil-off gas 7/1 1/75 9/17/75
Health Administration reheater
State of Maryland Environmental Construction of gas turbine 7/1 1/75 9/17/75
Health Administration generator
Calvert County Department of Electrical permit for onshore 9/ 5/75
Electrical Inspections ventilation building
Calvert County Department of In- Construction of seven offshore 1/23/76 2/ 3/76
spections and Permits buildings
State of Maryland Fire Marshal Review of electrical area 6/ 4/76
classifications
Calvert County Fire and Rescue Inspection of fire apparatus 8/ 3/76
Commission
Calvert County Department of In- Site grade for warehouse 8/1 1/76
spections and Permits
Calvert County Department of In- Construction of warehouse 8/1 1/76
spections and Permits
Calvert County Department of In- Construction of sign at ter- 8/27/76 8/31/76
spections and Permits minal entrance
United States Department of the In- Seagull depredation permit. 11/ 9/76
terior
United States Coast Guard Approval of survival capsules. 6/17/76
State of Maryland, Department of License and regulation certifi- 1/ 7/77
Licensing and Regulation cate for offshore elevator.
United States Coast Guard. Certificate of Inspection for 9/30/76
Miss Methane.
United States Coast Guard. License of vessel under 20 tons 1/31/77
for Miss Methane.
State of Maryland, Water Resources Oil operations permit 3/ 3177 5/ 5/77
Administration
92 APPENDIX A

Pipeline

Application Permit
Regulatory Agency Description of Action Date Date

Maryland Board of Public Works— Wetland license. 4/ 1/74 9/19/74


Department of Natural Resources. 4/25/75
Maryland Department of Natural Construction in a waterway. 4/ 1/74 4/23/75
Resources.
Corps of Engineers. Construction of five 36-inch 4/10/74 4/15/75
pipeline submarine cross-
ings.
Amended. 3/ 7/75 12/31/75
Maryland Department of Natural Water Quality Certification 8/22/74
Resources. five pipeline crossings.
Revised. 9/10/74
Virginia Marine Resources Commis- Dredge and backfill a trench 3/ 7/75 8/27/74
sion for pipeline crossing of
Potomac River
Revised. 3/25/75
Viginia State Water Control Board Dredge and backfill a trench 7/15/74 9/26/74
for pipeline crossing
Potomac River.
Amended, 3/ 7/75 4/ 3/75
Virginia Department of Taxation Sales and use tax direct pay- 3/ 1/75
ment permit.
Federal Power Commission Amended route. 4/10/75
Change construction dates. 8/ 1/75
Commonwealth of Virginia Depart- Permit for temporary entrance August
ment of Highways and Transporta- to right-of-way #754738. 1975
tion (Fairfax County)
Commonwealth of Virginia Depart- Permit for temporary entrance August
ment of Highways and Transporta- to right-of-way #754826, 1975
tion (Fairfax County)
Commonwealth of Virginia, Depart- Permit for temporary entrance July 1976
ment of Highways and Transporta- to right-of-way #754513.
tion (Fairfax County).
Commonwealth of Virginia Depart- Permit for temporary entrance October
ment of Highways and Transporta- to right-of-way #754950. 1975
tion (Fairfax County).
Commonwealth of Virginia Depart- Permit for temporary entrance 11/ 7175 11/19/75
ment of Highways and Transporta- to right-of-way #755740.
tion (Fairfax County).
Commonwealth of Virginia Depart- Permit for temporary entrance 11/ 7/75 1 1/19/75
ment of Highways and Transporta- to right-of-way #755739
tion (Fairfax County)
APPENDIX A 93

Application Permit
Regulatory Agency Description of Action Date Date

Commonwealth of Virginia Depart- Permit for temporary entrance October


ment of Highways and Transporta- to right-of-way #75511 1975
tion (Fairfax County)
Commonwealth of Virginia Depart- Permit for temporary entrance September
ment of Highways and Transporta- to right-of-way #755008 1975
tion (Fairfax County)
Commonwealth of Virginia Depart- Permit for temporary entrance 10/31/75 December
ment of Highways and Transporta- to right-of-way #755734 1975
tion (Fairfax County)
Commonwealth of Virginia Depart- Permit for temporary entrance 12/ 9/75 12/17/75
ment of Highways and Transporta- to right-of-way #756041
tion (Loudoun County)
Commonwealth of Virginia Depart- Permit for temporary entrance 12/ 9/75 12/17/75
ment of Highways and Transporta- to right-of-way #756040
tion (Loudoun County)
Board of County Commissioners of Grading permit, pipeline right- 10/21/74 10/24/74
Charles County, Md. of-way.
Washington Suburban Sanitary Sediment Control Permit, 7/16/74
Commission-Prince Georges Coun- pipeline right-of-way. 9/16/74
ty
State of Maryland-Maryland Forest Roadside tree permit (Calvert, 7/14/75 7/22175
Service, Department of Natural Charles & Prince Georges
Resources Counties)
Department of Inspections and Per- Zoning approval, pipeline 6/17/75 6/18/75
mits, Calvert County, Md. right-of-way 6/23/75
Department of Inspections and Per- Grading permit, pipeline right- 6/ 7/74 10/11/74
mits, Calvert County, Md. of-way 6/13/75
Department of Inspections and Per- Grading permit, access road to 7/24/74 7/24/75
mits, Calvert County, Md. right-of-way Cove Point
Department of Inspections and Per- Use and occupancy permit 2/17/75 2/18/75
mits, Calvert County, Md.
Department of Public Works, Prince Construction within public 6/10/75 8/ 4/75
Georges County, Md. right-of-way (three road
crossings)
Department of Transportation, State Pipeline road crossing #5- May 1975
of Maryland (Calvert County) C10943-75
Department of Transportation, State Pipeline road crossing #5- April 1975
of Maryland (Calvert County) C-1088O-75
Department of Transportation, State Road crossing (cable ) August
of Maryland (Calvert County) #50C-11046-75 1975
Department of Transportation, State Pipeline road crossing #5- July 1975
of Maryland (Charles County) CH-10881-75
94 APPENDIX A

Application Permit
Regulatory Agency Description of Action Date Date

Department of Transportation, State Pipeline road crossing #5- May 1975


of Maryland (Charles County) CH-10942-75
Washington Suburban Sanitary Pipeline road crossing #17090, May 1975
Commission (Prince Georges 3-pg. 208-75
County, Md.)
Washington Suburban Sanitary Pipeline road crossing #17094, June 1975
Commission (Prince Georges 3-pg. 282-75
County, Md.)
Washington Suburban Sanitary Pipeline road crossing #17089 May 1975
Commission (Prince Georges
County, Md.)
United States of America, U. S. Navy Pipeline railroad crossing 7/21/75
Railroad (Maryland) #NF(R)26225
Calvert Soil Conservation District Sediment and erosion control 6/ 7/74 3/12/75
for Calvert County, Md. .
Charles Soil Conservation District Sediment and erosion control 9/25/74 10/24/74
for Charles County, Md.
County of Fairfax, Va. Sediment and erosion control 11/ 7/74 2/13/75
for Fairfax County 8/22/75
9/ 5/75
County of Fairfax, Va. Occupancy permit September September
1975 1975
County of Fairfax, Va. Site plan waiver for pipeline 3/ 3175
construction 9/10/75
Department of Environmental Pipeline road crossing # 1043O 2/17/76
Management, Fairfax County, Va.
Zoning Administrator, Loudoun Zoning permit for measuring 4/ 8/76 4/ 8/76
County, Va. station at Loudoun
Department of Engineering and In- Building permit for instrument 4/14/76 6/ 1/76
spections, Loudoun County, Va. and transducer buildings at
Loudoun
Department of Engineering and In- Electrical permit for instru- 7/ 8/76 7/ 8/76
spections, Loudoun County, Va. ment and transducer build-
ings at Loudoun
Health Department, Loudoun Coun- Permit to install sewage dis- 4/14/76 5/24/76
ty, Va. posal system and water well
Maryland Board of Public Works Wetlands license 9/19/74
Fairfax Planning Commission Construction approval for 2/13/75
modified route per settle-
ment agreement
Fairfax County Board of Supervisors Final approval given modified 3/ 3175
route
APPENDIx A 95

Application Permit
Regulatory Agency Description of Action Date Date

Fairfax Board of Zoning Zoning approval given 3/10/75


modified route
Charles County Pipeline construction report 5115175
filed
Calvert County Pipeline construction report 6/30/75
f i l e d
Fairfax County Sediment and erosion control 8/22/75
\ plan approved
State of Maryland License to cross Calvert Cliffs 9/29/75
State Park
Prince Georges County Special ordinance authorizing 11/24/75
pipeline construction
Loudoun County Sediment and erosion control 1/23/76
plan filed-permit not re-
quired
Loudoun County Planning Commis- Pipeline route approved 1/26/76
sion
Maryland Department of Natural Surface water appropriation 3/29/76
Resources for hydrostatic test
Maryland Department of Natural Permit for discharge of test 3/29/76
Resources water
Appendix B

Federal Agencies Involved


in LNG Import Projects

Council on Environmental Quality. The FPC Federal Power Commission. The FPC regulates
submits preliminary and final environmental importation and the interstate transportation
impact statements to CEQ for review. and sale of natural gas.
Department of Defense. DOD is consulted by the Office of Pipeline Safety Operations. O P S O
FPC for views on national security implications establishes and enforces minimum Federal
of each LNG import application. safety standards for all pipelines in or affecting
interstate or foreign commerce.
Department of the Interior. Permits are required
if construction or operation of a terminal affects U.S. Army Corps of Engineers. Permit is re-
wildlife in the area. quired for any dredging activity and construc-
tion of any object in the navigable waters of the
Department of State. State is consulted by the United States.
FPC for views on national security implications
of each LNG import application. U.S. Coast Guard. The Coast Guard is responsible
for the safety of the marine link of LNG import
Environmental Protection Agency. Permit is re- operations, by certification of LNG ships to en-
quired from EPA if there are any discharges into sure that minimum design and construction
the ocean adjacent to an LNG terminal. standards, and the establishment of operating
Export-Import Bank. Provides loans to foreign procedures for bringing LNG into U.S. ports.
governments to support purchases of U.S. goods U.S. Maritime Administration. MARAD pro-
and services in the construction of liquefaction vides a variety of financial aids for the construc-
and related LNG facilities. tion and operation of U.S. flag LNG tankers.
Federal Communications Commission.
Licenses are required for radio operations.

96
Appendix C

Laws and Cases


Relevant to LNG

STATUTES AND EXECUTIVE ORDERS

Administrative Procedures Act, 5 U.S.C. §§551 Commission, which will absorb many of the func-
et seq (1970) tions of the Federal Power Commission as they
relate to LNG. The major exception is that the
Establishes the minimum procedures which Secretary of Energy will have authority to approve
agencies of the executive branch must follow in or disapprove import applications.
establishing rules and regulations.
Executive Order 10173-Regulations relating to
Admiralty Extension Act of 1948, 46 U.S.C. § the safeguarding of vessels, harbors, ports, and
740 (1970) waterfront facilities of the United States.
Provides that admiralty jurisdiction is to extend Authorizes the Coast Guard to “supervise and
to all injuries caused by a vessel even if such control” the transportation, loading and unload-
damage or injury is “done or consummated” on ing of dangerous cargoes. Also allows the Coast
land. Guard to require owners and operators to obtain a
Coastal Zone Management Act of 1972, 16 Coast Guard permit for the waterfront facilities
U.S.C. $$1451 et seq (Supp. 1972) used in the handling of such cargo. (The Coast
Guard does not currently require such a permit. )
Authorizes the Secretary of Commerce to make
annual grants to any coastal State to assist in Federal Water Pollution Control Act, Amend-
developing a management program for land and ments of 1972, 33 U.S.C. §§ 1251 et seq (Supp.
water resources of its coastal zone. Such grants are 1972)
contingent on approval by the secretary of the A comprehensive act aimed at cleaning up the
State’s program, i.e. that it meets certain criteria Nation’s waters. Discharges of pollutants require
specified in the Act. After approval of a State’s permits administered by EPA and the Army Corps
program, no Federal permit or license for an ac- of Engineers. In certain cases, this permit authority
tivity affecting that State’s coastal zone unless that may be delegated to the States.
activity has been certified as consistent with the
State’s program. National Environmental Policy Act of 1969
(NEPA) 42 U.S.C. §4321 et seq (1970)
Dangerous Cargo Act, 46 U.S.C. §170 (1970)
Provides that each “major Federal action sig-
Directs the Coast Guard to identify all nificantly affecting the quality of the human en-
dangerous cargoes, prescribe regulations establish- vironment’ must be preceded by an analysis of
ing standards for containers and handling of ex- that action’s environmental impact.
plosives and other dangerous cargoes and for in-
spection to ensure compliance with these regula- Natural Gas Act of 1938, 15 U.S.C. §§ 717a et seq
tions. (1970)
Department of Energy Organization Act o f Gives the Federal Power Commission b r o a d
1977, P.L. 95-91 powers to regulate imports, exports, and the inter-
state transportation and sale of natural gas. Under
Creates a new Department of Energy consolidat- Section 3, no imports or exports may proceed with-
ing many of the energy organizations of Govern- out an order from the Commission. Under Section
ment. Of particular interest to LNG is the creation F, no facilities for interstate transportation or sale
of semiautonomous Federal Energy Regulatory
97
98 APPENDIX C

may be constructed without a certificate of public CASES AND FPC OPINIONS


convenience and necessity from the Commission,
The Commission’s authority over interstate sales Distrigas Corporation v. Federal Power Com-
of natural gas includes setting the prices at which mission, 495 F.2d 1057 (D.C. Cir. 1974).
the gas is sold.
Decided that the FPC may, under the Natural
Natural Gas Pipeline Safety Act of 1968, 49 Gas Act, impose the equivalent of Section F cer-
U.S.C. $$1671 et seq (1970) tification requirements for LNG imports even if the
gas is to be sold intrastate. This authority is discre-
Authorizes the Secretary of Transportation to tionary, and must be preceded by the Commission’s ●

set minimum Federal safety standards for finding such requirements to be necessary to pro-
pipelines, establishes a cooperative State-Federal tect the public interest.
enforcement program, and provides for Federal aid
to States to bring State standards up to the level of Federal Power Commission, Opinion No.
Federal standards. 795, Trunkline LNG Company and Trunkline
Gas Company, Docket Nos. CP74-138, 139, 140,
Outer Continental Shelf Act, 43 U.S.C. $$1331 issued April 29, 1977.
et seq (1970)
Declares U.S. jurisdiction over the subsoil and Opinion No. 796-A, Issued June 30, 1977.
seabed of the Outer Continental Shelf and
The first Trunkline opinion ordered incremental
establishes the system for Federal leasing of these
pricing and conditioned the certification upon
lands for resource development.
Trunkline compliance with all other Federal,
Ports and Waterways Safety Act of 1972, 33 State, and local laws and regulations. In the sec-
U.S.C. $$1221 et seq (Supp. 1972) ond opinion, the FPC reversed itself as to pricing
(allowing rolled-in pricing) but kept its condition of
Title I provides that the Secretary of the Depart- compliance with other laws and regulations.
ment in which the Coast Guard is operating may
prescribe standards and regulations to promote the Washington Department of Game v. Federal
safety of vessels and structures in or adjacent to the Power Commission 207 F.2d 391 (9th Cir.
navigable waters of the United States and $0 pro- 1953); Federal Power Commission v.
tect such waters and their resources from environ- Oregon, 349 U.S. 435 (1955); City of Tacoma
mental harm due to vessel damage or loss. v. Taxpayers of Tacoma, 357 U.S. 320 (1957).
Title II provides that the Secretary shall
The above cases conclusively determined that, in
prescribe minimum design, construction, and
the permitting of hydroelectric facilities, the
operation standards for vessels carrying certain
jurisdiction of the Federal Power Commission
cargoes in bulk (e.g. oil).
preempts that of any State commission or body.
Shipowners Limitation of Liability A C t 46
Transcontinental Gas Pipe Line Corp. v.
U.S.C. §§181 et seq (1970)
Hackensack Meadowlands Development
Provides that shipowners may limit their Commission, 464 F.2d 1358 (3d Cir. 1972),
liability after an accident involving their vessels to cert. denied, 409 U.S. 1118 (1973).
the value of the vessel and its cargo after the acci-
dent. An exception is made for loss of life or bodily Action by natural gas company to enjoin
regional development commission from interfering
injury, in which case liability is limited to $60 per
with an LNG peak shaving facility. Subsequent to
ton of the vessel.
the construction of the facility, New Jersey passed a
Submerged Lands Act 43 U.S.C. §§ 1311 et seq law establishing the Hackensack Meadowlands
(1970) Development Commission. The gas company, wish-
ing to construct an additional storage tank at the
Provides for State resource management of the facility, secured a certificate of public convenience
seabed out to a distance of 3 miles from shore (3 and necessity from the FPC. The Hackensack
marine leagues in the case of the States bordering Meadowlands Development Commission, however,
the Gulf of Mexico). The Federal Government re- refused to issue a permit for the addition. The
tains control over the waters over such lands for Federal courts enjoined the State commission from
purposes of commerce, navigation, national interfering, finding its refusal to grant a permit an
security, and international affairs. unreasonable restraint on interstate commerce.
Appendix D

Congressional Hearings Conducted on


Liquefied Natural Gas

U.S. Congress Senate Committee on Com- System. Hearings, 94th Congress, 1st session,
merce. Hearing on S. 2064, 93d Congress, 2d ses- October 9, 1975. Washington, D. C., U.S. Govern-
sion. 1974. ment Printing Office, 1975. 340 p. serial no.
94-36.
The Committee hearings were held on June 12,
13, and 14. The Bill was introduced by Senators This report delves into the land-use implications
Magnuson and Cotton June 25, 1973, to amend the of the three proposed natural gas systems. The en-
laws governing the transportation of hazardous vironmental as well as social impacts of each of the
materials. The Bill: applications are discussed.
1. “Would provide additional methods of en- U.S. Congress Senate Committee on Interior
forcement, extend regulatory coverage and and Insular Affairs/Committee on Com-
remove existing restraints upon the Secretary merce. The transportation of Alaskan natural
of Transportation to delegate regulatory gas. Hearing, 94th Congress, 2d session, part 1
authority.’ and 2, February 17, 1976. Washington, D. C.,
U.S. Government Printing Office, 1976.1515 p.
2. Review hazardous material statutes and serial no. 94-29.
evaluate Federal agency responsibilities and
jurisdictional overlaps concerning transpor- The purpose of the hearings was to explore
tation of hazardous materials. energy, economic, and environmental policy issues
in connection with the production and transporta-
. S U.S. Congress House Committee on Interstate tion of the Prudhoe Bay gas reserves. The discus-
and Foreign Commerce. Special subcommit- sion revolved around the necessity for additional
tee on investigations. Legislative issues relating gas, gas distribution, and financial arrangements
to the safety of storing liquefied natural gas. for the proposed project.
Hearings, 93d Congress, 1st session. July 10-12,
1973. Washington, D. C., U.S. Government Print- U.S. Congress Senate Committee on Interior
ing Office, 1976. and Insular Affairs/Committee on Com-
merce. The transportation of Alaskan natural
The hearings focused on the Staten Island ex- gas, Hearings, 94th Congress, 2d session, part 3.
plosion February 10, 1973. To obtain legislative in- March 24 and 25, 1976. Washington, D. C., U.S.
formation, the subcommittee investigated: Government Printing Office, 1975.2030 p. serial
1. the enforcement and adequacy of storage- no. 94-29, (Commerce), 94-29 (Interior).
tank safety regulations;
The hearings concentrated on four bills, S. 2510,
2. FPC and OPSO LNG safety responsibilities S. 2778, S. 2950, and S. 3167. S. 2510 was in-
authorized by the Natural Gas Act of 1938 troduced by Senator Gravel on October 9, 1975.
and the Natural Gas Pipeline Safety Act of The bill requires that the FPC make a decision by
1968; June 30, 1976, on the applications posed by El Paso
and Alaska Arctic Gas. S. 3167 also introduced by
3. the question; “Is the state-of-the-art of
cryogenic storage sufficiently advanced to be
Senator Gravel is another attempt to expedite an
FPC decision on the gas pipeline proposals. S. 3167
safe?’
directs the FPC to make a decision and transmit
U.S. Congress House Committee on Interior that decision to the President by January 1, 1977.
and Insular Affairs, Subcommittee on Public By February 1, 1977 the President would have re-
Lands. Alaska Natural Gas Transportation quested agency reports. The reports would be due

99
100 APPENDIX D

by August 1, 1977, and the President’s decision U.S. Congress House Committee on Interior
forthcoming. S. 2778, introduced by Senator and Insular Affairs. Subcommittee on Indian
Stevens, requires the FPC and other Federal agen- Affairs and Public Lands. Transportation of
cies to approve only those gas transportation Alaskan natural gas. Oversight Hearings 95th
systems located in the United States or subject to Congress, 1st session. February 17, 1977 Part 1.
international jurisdiction. S. 2950 introduced by March 17, 18 and 29, 1977 and April 5, 1977
Senator Mondale requires that all appropriate Part 2. Washington, D. C., U.S. Government
agencies provide the necessary permits and ap- Printing Office, 1977.
provals to authorize the construction of the Arctic
Gas pipeline. The Bill waives NEPA procedural re- The purpose of the hearings was to gather
quirement. detailed and comprehensive information on the
three methods of transporting Alaskan natural gas.
U.S. Congress House Committee on Interstate The three proposals are the El Paso Alaskan LNG
and Foreign Commerce. Subcommittee on project, the Alaskan Arctic gas project, and the
Energy and Power. Transportation of Alaskan Alcan or Alaskan Highway project. Representa-
natural gas. Hearings, 94th Congress, 2d session. tives from the gas industry, American and Cana-
May 17-19, 1976. Washington, D.C. U.S. dian labor unions, environmental organizations,
Government Printing Office, 1976. public officials, academicians, and Canadian In-
dians presented their proposals and various argu-
The hearings revolve around 14 separate bills
ments.
which would either expedite administrative pro-
cedures for selecting a delivery system and limit
agency judicial review actions or allow Congress to
select the route.
Appendix E

Proposed Legislation Concerning


Liquefied Natural Gas

H.R. 6844, Dingel (D-Mich.), introduced on May Staff Working Paper No. 1, November 12, 1976,
3, 1977, and referred to the Committee on Inter- prepared by Senate Commerce Committee staff.
state and Foreign Commerce. The bill would: The draft would:
1. direct the Secretary of Transportation to issue 1, require a license from the Secretar y o f
rules and regulations for siting, construction, Transportation for the siting, construction,
and operation of LNG facilities; and operation of LNG facilities;
2. require a permit from the Secretary of 2. prescribe procedures for granting such a
Transportation prior to construction and license;
operation of an LNG facility;
3. direct the Secretary of Transportation to
3. provide for a limited State veto over project prescribe siting criteria for LNG facilities;
approval where a facility would be located in
4. provide for State veto over LNG facilities;
an area with a prescribed population density;
and 5. provides for strict liability, with upper limits,
for LNG accidents; and
4. direct the President to make a 10-year pro-
jection of the need for liquefied natural gas 6. establish a fund to compensate claims over
imports. and above the limits on company liability.

101
U. S. GOVERNMENT PRINTING OFFICE: 19’7’7 O -96-597

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