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THE FACTS ABOUT LNG

Prepared for ~

Prepared by ~
Jeffrey P. Beale, President
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CH·IV International
Baltimore Office Houston Office
1120C Benfield Boulevard 1221 McKinney, Suite 3325
Millersville, MD 21108 Houston, TX 77010
410-729-4255 713-344-2500

CH·IV International Document: RPT-06903-01

Issued June 9, 2006


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Table of Contents

Section Page

1 Introduction to LNG 1

2 History of Major LNG Incidents 1


2.1 Cleveland, 1944 1
2.2 Skikda, 2004 3

3 Mechanics of Gas “Explosions” 4


3.1 Introduction 4
3.2 Ignition of “LNG” 4
3.2.1 Vaporization of LNG 4
3.2.2 Vapor mixing with air 5
3.2.3 Ignition sources 6
3.2.4 Ignition of an LNG vapor cloud 7
3.3 Gas “Explosions” 7

4 Design and Construction of LNG Ships 8


4.1 Ship Design and LNG Cargo System Types 8
4.1.1 Self-Supporting Spherical: 9
4.1.2 Self-Supporting Prismatic Shape: 11
4.1.3 Membrane: 13
4.2 Double-Hull Integrity 15
4.2.1 El Paso Paul Kayser Grounding 15
4.2.2 Collision of the Yuyo Maru No. 10 16
4.2.3 Terrorist Attack on the Limburg Crude Oil Tanker 17

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Table of Contents

Section Page
5 Credible LNG Spill Scenarios 18
5.1 Introduction 18
5.2 LNG Ship Incidents 19
5.2.1 “Worse Case” Fire 19
5.2.2 “Worse Case” Vapor Travel 20
5.2.3 Credible Incidents 21

6 Rebuttal of “The Risks and Danger of LNG” 22

APPENDIX A: SANDIA REPORT 50

APPENDIX B: CABRILLO PORT 52

ABOUT THE AUTHOR 53

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1 INTRODUCTION TO LNG

Development of liquefied natural gas, or LNG, has emerged as one of the most contentious
energy infrastructure issues in recent years. There are several reasonable explanations for
the attention such projects have drawn:
• The regulatory process has encouraged, and sometimes required, public participation.
• The projects are generally of significant size; a project cost of $500 million is not
unusual. It is difficult to ignore projects of such magnitude.
• Hyperbole and sometimes outright lies are common tactics used by the opponents of
such projects in an effort to stop their development.

This paper focuses on the third point. Once rumors, innuendoes or lies start to spread it is
difficult to bring the public back to the truth.

California injury attorney Tim Riley and his wife, Hayden, have produced a video entitled
“The Risks and Dangers of LNG.” The Rileys make numerous statements about LNG that
deserve to be checked against the facts. However, prior to presenting a point-by-point
technical review of the Riley’s information presented in the video we have chosen to first
provide factual background that can be referenced during the various Riley statement
checks. We will cover the following major topics before addressing the Riley video:
• History of Major LNG incidents
• Mechanics of Gas “Explosions”
• Design and Construction of LNG Ships
• Credible LNG Spill Scenarios

2 HISTORY OF MAJOR LNG INCIDENTS

2.1 Cleveland, 1944

Any time the topic of LNG is introduced to a new audience the “Cleveland
Disaster” is bound to surface. It was indeed tragic, but an unbiased review will
show just how far the LNG industry has come from that horrific incident. The East
Ohio Gas Company built the world’s first “commercial” LNG peakshaving1 facility

1
An LNG peakshaving facility liquefies natural gas during the low gas demand times of the year and stores the
LNG. When natural gas is at or near it ‘peak” demand, the LNG is pumped to a given pressure, vaporized and
injected into the natural gas distribution system.

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in Cleveland in 1941. Three small spherical LNG storage tanks were constructed as
part of the original facility. Each was surrounded by cork insulation and a mild steel
outer shell and supported by uninsulated mild steel legs. The facility adjoined a
residential neighborhood.

The facility was run without incident until 1944, when a larger new tank was added.
As stainless steel alloys were scarce because of shortages resulting from World War
II, the new tank was built using a toro-segmented design using low-nickel content
(3.5%) alloy steel. Shortly after going into service, the tank failed. LNG spilled into
the street and storm sewer system. The resultant fire killed 128 people, setting back
the embryonic LNG industry substantially.

The following information is extracted from the U.S. Bureau of Mines report2 on the
incident:

On October 20, 1944, the tanks had been filled to capacity in readiness for the coming
winter months. About 2:15 PM, the cylindrical tank suddenly failed releasing all of its
contents into the nearby streets and sewers of Cleveland. The cloud promptly ignited and
a fire ensued which engulfed the nearby tanks, residences and commercial
establishments. After about 20 minutes, when the initial fire had nearly died down, the
sphere nearest to the cylindrical tank toppled over and released its contents. 9,400
gallons of LNG immediately evaporated and ignited. In all, 128 people were killed and
225 injured. The area directly involved was about three-quarters of a square mile (475
acres) of which an area of about 30 acres was completely devastated.

The Bureau of Mines investigation showed that the accident was due to the low
temperature embrittlement of the inner shell of the cylindrical tank. The inner tank was
made of 3.5% nickel steel, a material now known to be susceptible to brittle fracture at
LNG storage temperature (-260°F). In addition, the tanks were located close to a heavily
traveled railroad station and a bombshell stamping plant. Excessive vibration from the
railroad engines and stamping presses probably accelerated crack propagation in the inner
shell. Once the inner shell ruptured, the outer carbon steel wall would have easily
fractured upon contact with LNG. The accident was aggravated by the absence of
adequate diking around the tanks, and the proximity of the facility to the residential area.
The cause of the second release from the spherical tank was the fact that the legs of the
sphere were not insulated against fire so that they eventually buckled after being exposed
to direct flame contact.

Further, it should be noted that the ignition of the two unconfined vapor clouds of LNG
in Cleveland did not result in explosions. There was no evidence of any explosion
overpressures after the ignition of the spill from either the cylindrical tank or the sphere.
This can be further seen by the fact that two of the original LNG tanks remained intact
despite the nearby fires. The only explosions that took place in Cleveland were limited to

2
“Report on the Investigation of the Fire at the Liquefaction, Storage, and Regasification Plant of the East Ohio
Gas Co., Cleveland, Ohio, October 20, 1944,” U.S. Bureau of Mines, February, 1946.

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the sewers where LNG ran and vaporized before the vapor-air mixture ignited in a
relatively confined volume. The U.S. Bureau of Mines, concluded that the concept of
liquefying and storing LNG was valid if “proper precautions are observed.”

According to a recent study3 by the National Association of State Fire Marshals,


“Had the Cleveland tank been built to current codes, this accident would not have
happened. In fact, LNG tanks properly constructed of 9 percent nickel steel have
never had a brittle crack failure in their 35-year history.”

2.2 Skikda, 2004

On January 19, 2004, a leak in the hydrocarbon refrigerant system at one of the
natural gas liquefaction units (Train 40)4 in Skikda, Algeria formed a vapor cloud
that was ingested into the inlet of the combustion fan of a steam boiler. The
hydrocarbon acted as increased fuel to the boiler causing a rapidly rising pressure
within the steam generating equipment. The rapidly rising pressure quickly
exceeded the capacity of the boiler’s safety valve and the steam drum ruptured,
tearing apart the boiler fire box and housing. The flames from boiler firebox ignited
the leaked refrigerant gas, which was confined by the equipment and structures in
the area producing an explosion and an ensuing fire. The explosion, along with the
shrapnel from the ruptured steam drum, caused further damage to the process piping
and pressure vessels in the immediate area leading to additional flammable fluid
release. The fire took eight hours to extinguish. The explosions and fire destroyed a
portion of the LNG plant and caused 27 deaths and injury to 72 more. No one
outside the plant was injured nor were the LNG storage tanks damaged by the
hydrocarbon explosions. A joint report5 issued by the U.S. Federal Energy
Regulatory Commission (FERC) and the U.S. Department of Energy (DOE) was
issued in April 2004. The findings in the report indicate that:
• There were ignition sources in the process area,
• There was a lack of “typical” automatic equipment shutdown devices required by
U.S LNG design codes, and
• There was a lack of hazard detection devices.

While Trains 10, 20 and 30 had been upgraded in the late 1990s, Train 40, was, in
fact, scheduled for demolition. Train 40 was originally built in 1981 and not well
maintained. The poor maintenance and poor general condition of Train 40 is the

3
Report entitled “Liquefied Natural Gas: An Overview of the LNG Industry for Fire Marshals and Emergency
Responders,” May 2005.
4
LNG production units are referred to as “trains.”
5
“Report of the U.S. Government Team Site Inspection of the Sonatrach Skikda LNG Pant in Skikda, Algeria,
March 12-16, 2004”

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most likely reason why Sonatrach, the owner of the facility, had it scheduled for
demolition.

It is also worth noting that a liquefaction facility has very few similarities to LNG
import terminals. The only similarities are that both facilities have marine LNG
transfer facilities and LNG storage tanks. The components of a liquefaction plant
are mostly involved with the purification and cooling of natural gas, whereas an
import terminal is basically a pumping and heating system that converts low
pressure LNG into pipeline natural gas.

While it must be noted that the Sparrows Pont facility will likely utilize gas-fired
process heaters or a steam boiler as part of its vaporization system, all such
equipment will incorporate combustion air blowers. Gas detectors will be installed
in the inlet to these blowers and shut down the blowers in the event of gas detection.
If this simple installation (required by code in the U.S.) had been installed at the
Skikda plant the incident would not have occurred and no deaths or injuries would
have resulted.

3 MECHANICS OF GAS “EXPLOSIONS”

3.1 Introduction

The composition of LNG varies depending on the gas source and type of processing.
LNG typically contains 85 to 99% methane (CH4). It also may contain ethane
(C2H6), propane (C3H8), some butane (C4H10) and trace amounts of heavier
hydrocarbons. Inert nitrogen (N2) is often present, as well.

3.2 Ignition of “LNG”

In order to be ignited, LNG must first be vaporized (be heated and returned to a
vapor state), mixed with between 5% to 15% air and come in contact with an
ignition source. Looking at each of these criteria:

3.2.1 Vaporization of LNG

LNG will vaporize when its temperature rises above -260°F at


atmospheric pressure. In an LNG terminal the vaporization of LNG is
performed under controlled conditions within a process system. Through
a number of different techniques, LNG is pumped from the LNG tanks to

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a higher pressure and directed to the LNG vaporizer system.6 Heat is


indirectly applied to the LNG converting it to “pipeline” natural gas,
meaning it can be sent directly to the natural gas distribution system to
end-users.

Elsewhere in the LNG terminal, a small amount of LNG vaporization is


taking place within the LNG tanks as a small amount of heat enters the
highly insulated LNG tank causing some of the LNG to “boil” releasing
“boil off gas.” Boil off gas is simply another mixture of natural gas that
can be compressed and mixed with the pipeline gas or used as fuel within
the LNG facility.

Were LNG to be released onto the ground, the heat from the earth would
initially cause very rapid boiling of the LNG. As the ground cools the
boiling rate would reduce. The amount of vapor formed is in direct
proportion to the amount of LNG released; however, the vapor formation
rate is a function of the release rate and surface covered in the release.
The cold vapor will condense most of the water (humidity) in the
surrounding air forming a white vapor cloud. If unhindered, the cloud will
drift in the direction of the wind, further mixing with the air and picking
up heat from both the ground and the air as it moves. As the vapor cloud
warms up, it will become buoyant (lighter than air) and rise into the
atmosphere where it will disperse. Any terrain, obstructions, trees, etc.
will enhance the mixing rate of the vapor and warm air resulting in more
rapid dispersion.

LNG released on water acts very similarly to the initial release on land.
Assuming a large volume of water, the vapor formation rate will remain
high as the surface water that is cooled by the LNG sinks and is replaced
by warmer water.

3.2.2 Vapor mixing with air

As mentioned above, natural gas must be mixed with 85% to 95% air in
order to ignite. Figure 3.2.2 depicts the mixing of gas and air from an
LNG release. Clearly at the point of the release, there is no mixing as the
vapor is boiling off directly from the LNG and is, thus, 100% gas. As the
gas warms, rises and is moved by the wind, mixing with air takes place.
At the innermost part of the cloud the gas composition is well over 15%,

6
LNG is stored in the LNG tanks very near atmospheric pressure. Low pressure, in-tank LNG pumps direct the
LNG through sealed piping in the roof of the LNG tank to the high pressure “LNG sendout” pumps. The high
pressure pumps feed the LNG vaporization system.

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thus not ignitable. Similarly on the outermost fringe, there is too little gas
and it will not ignite. The red lines depict the area where the gas
composition is within the 5% to 15% range. If an ignition source is
present in this area, the gas will ignite.

Figure 3.2.2: Mechanics of LNG Vapor and Air Mixing

At very low wind velocities, the LNG vapor cloud will not move very far,
as there is no driving force. At high wind velocities, the heat from the
wind (air) as well as the turbulent mixing of the wind will rapidly
dissipate the vapor making its travel relatively short. Ideal wind speed for
maximum vapor cloud travel is about 4 miles an hour. At this wind speed
there is minimal mixing of air while the vapor cloud travels; however, the
velocity is only 4 miles per hour meaning that the cloud will not travel
very far, vary fast.

3.2.3 Ignition sources

While, in comparison to some other fuels, natural gas has a slightly wider
combustibility region (5% to 15%), it has a higher ignition temperature
when compared to those same fuels. Clearly, the fuel with the lowest
ignition temperature has the highest potential for finding an ignition
source. For example, unleaded gasoline has an ignition temperature
around 500°F, whereas jet fuel is a little over 400°F. Propane and butane,
depending on their mixture, have an ignition temperature between 900 and
1100°F, whereas natural gas has an ignition temperature between 1100

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and 1200°F. As such, open flames and sparks can ignite natural gas;
however, a held cigarette or car muffler will not.

It is important to note that the combustibility regions for other fuels have a
lower flammability limit (LFL) that natural gas or LNG vapor. For
example, gasoline has an LFL of only 1.4% and propane is 2.1%, meaning
that both can be ignited with significantly lower concentrations in air than
natural gas, (which has an LFL of 5%).

3.2.4 Ignition of an LNG vapor cloud

Referring back to Figure 3.2.2, it can also be seen that only the outer area
of the vapor cloud is ignitable. There will not be an explosion should the
gas be ignited as the flame front on the burning methane in an open
environment has a very slow flame speed (~ 4 mph). This is an extremely
important point that is not disputed by knowledgeable individuals that
have direct experience in the ignition of LNG vapor clouds.7

Once ignited, the thermal radiation (heat) from the burning vapor
generated from a pool of LNG is related to the size of the LNG pool.
However, the larger the fire, the more difficult it becomes for adequate air
to mix with the vaporizing gas for complete combustion. As a result, the
fire associated with a small LNG pool burns very cleanly and consistently
with a near yellow-orange flame (Figure 3.2.4-1), while a fire associated
with a large pool burns orange-red with large black patches (Figure 3.2.4-
2) reflecting the incomplete combustion and resulting in variable thermal
radiation.

3.3 Gas “Explosions”

In order for the ignition of an LNG vapor cloud to result in an explosion, the gas
must first be uniformly mixed with air in the 5% to 15% range, confined in an
enclosed space, and then ignited. Should any one of these requirements be missing,
there will be no explosion.
• Too rich or too lean gas, confined, cannot be ignited and certainly . . . no
explosion.
• 5% to 15% gas mixed and confined, but no ignition source . . . no explosion.

7
The author of this document has witnessed ignitions of LNG vapor clouds on various occasions at LNG fire
training schools. There were no explosions. In fact, the rate at which the flame front burned back to LNG pool
could easily be followed with the naked eye. The Riley video confirms this observation with footage of such
ignition and the voiceover that refers to the “lazy diffusion flame.”

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• 5% to 15% gas mixed in open atmosphere, i.e., not confined, ignition results in a
“slow” burnback to the source of the LNG spill . . . no explosion.

Should gas be mixed in the 5% to 15% range with air, confined in an enclosed space,
and ignited, then an explosion can occur. However one must ask one’s self, where
in an LNG terminal could such conditions exist? The answer, basically, is nowhere.

Figure 3.2.4-1: Fire above a Small LNG Pool Figure 3.2.4-2: Fire above a Large LNG Pool

4 DESIGN AND CONSTRUCTION OF LNG SHIPS

The discussion that follows is intended to give the reader a fuller understanding of the
design of the LNG tanker and how extremely difficult it would be to cause a huge release of
LNG. Further we hope to demonstrate how it would be virtually impossible to cause a large
breach one or more ship LNG tanks without ignition of the first gas released.

4.1 Ship Design and LNG Cargo System Types

There are three basic types of LNG cargo tank designs. It is important to understand
the similarities and differences of these types of tanks in order to establish which
type of cargo tank might result in the greatest volume of LNG spillage in the least
time. The three cargo tank types are: 1) Self-Supporting Spherical; 2) Self-
Supporting Prismatic Shape; and 3) Membrane.

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For all cargo tank types, penetrating one or more LNG cargo tanks requires, at
minimum, the penetration of:
• The ship’s outer hull,
• The 8 to 10 foot space between the outer and inner hulls (the water ballast tanks),
• The inner hull,
• The insulation system around the LNG cargo tank(s),
• The secondary containment of the individual LNG cargo tank,
• The insulation system around the primary containment, and
• The primary containment vessel wall of the individual LNG cargo tank(s).

Figure 4.1 provides a sketch representing the bullet points listed above for a
“membrane-type” ship (See Section 4.1.3).

Figure 4.1 LNG Ship LNG Tank Cross-Section

4.1.1 Self-Supporting Spherical

Figure 4.1.1-1 shows a typical Self-Supporting Spherical LNG carrier.


These ships are immediately recognized by the four or five hemispherical
domes located above the ship’s deck. Figure 4.1.1-2 depicts the general
arrangement of the ship in Figure 4.1.1-1. Figure 4.1.1-3 provides
additional detail on the design and construction of the individual spherical
cargo tanks. The aluminum or steel alloy tanks rest on a cylindrical skirt.
Scale can be estimated based on a beam of approximately 150 feet. Note

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in Figure 4.1.1-2 the draft line relative to the equatorial ring of the LNG
cargo tanks. As the draft line is well below the elevation of the equatorial
ring, impacts at the water line must travel a great distance to impact the
LNG cargo tank. As can be seen in Figure 4.1.1-3, the support skirt of
high tensile steel provides additional protection to the lower section of the
LNG cargo tank from any external penetration, whether accidental or
intentional.

Figure 4.1.1-1: Self-Supporting Spherical LNG Carrier

Figure 4.1.1-2 General Arrangement - Self-Supporting Spherical LNG Carrier

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Figure 4.1.1-3: Spherical Tank Detail

4.1.2 Self-Supporting Prismatic Shape

The Self-Supporting Prismatic Shape LNG cargo tanks conform more


closely to the shape of the ship’s hull than do the spherical LNG cargo
tank designs. The decks of the ships are typically flat looking far more
like a conventional crude oil carrier as noted in Figure 4.1.2-1. Figure
4.1.2-2 shows the general arrangement. Typically there will be three or
four major cargo tanks with a smaller tank near the bow of the ship. The
tanks are built external to the ship and then crane lifted into place. Figure
4.1.2-3 shows how the tanks have a significant amount of horizontal and
vertical stiffeners and bulkheads that greatly add to the strength of each
individual cargo tank.

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Figure 4.1.2-1: Self-Supporting Prismatic Shape LNG Carrier

Figure 4.1.2-2: General Arrangement - Self-Supporting Prismatic Shape LNG Carrier

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Figure 4.1.2-3: Self-Supporting Prismatic Shape Tank Detail

4.1.3 Membrane

The membrane type LNG carrier is double-hulled where the inner hull
provides the integrated support of the LNG cargo tanks. The outer hull is
smooth externally but the inside contains an egg-crate type of structural
steel webs and stiffeners. The inner hull is supported by a similar egg-
crate design. The typical cargo tank has a number of levels of protection
around the cargo:
®
• A welded stainless steel or Invar membrane surrounds the cargo,
• 10 inches of insulation
• A second alloy metal or foil composite membrane
• A foot of insulation around the second membrane
• An inch-thick plate forms the inner hull
• An eight-foot ballast tank between the inner and outer hull
• The inch-thick steel outer hull

Figure 4.1.3-1 provides a picture of a typical membrane ship. Membrane


ships often have a beveled, raised structure above the cargo tanks. Figure
4.1.3-2 shows the general arrangement, which is not significantly different
from the Self-Supporting Prismatic Shape LNG Carrier in basic

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appearance. Figure 4.1.3-3 shows the detailed cutaway of the cargo


containment system and how the cargo tank is integrated into the inner
(“double”) hull.

Figure 4.1.3-1: Membrane LNG Carrier

Figure 4.1.3-2: General Arrangement - Membrane LNG Carrier

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Figure 4.1.3-3: Membrane Tank Detail

4.2 Double-Hull Integrity

The double hull design of LNG ships offers significant protection to the LNG cargo
tanks. The following incidents fully substantiate this assertion:

4.2.1 El Paso Paul Kayser Grounding

In 1979, the El Paso Paul Kayser, loaded with about 125,000 cubic meters
of LNG, was steaming out of the Mediterranean Sea from an Algerian
port. It was traveling at approximately 19 Knots off the coast of Gibraltar
when it struck a rock outcropping below surface and gouged a 750-foot
long scar in its hull (See Figure 4.2.1). What is important to note about
the El Paso Paul Kayser incident is that a loaded LNG ship traveling near
its maximum speed grounded and there was nothing close to a loss of
cargo, much less a breach of an LNG tank. The grounding did not even
penetrate the outer hull. Another ship was brought alongside; the cargo
was pumped out of the El Paso Paul Kayser into the second ship. The El
Paso Paul Kayser was righted and sent to the shipyard for repairs and
returned to service.

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Figure 4.2.1: Hull of El Paso Paul Kayser after Grounding

4.2.2 Collision of the Yuyo Maru No. 10

The Yuyo Maru No. 10 was a liquid petroleum gas (LPG) tanker of very
similar design and construction to an LNG tanker. Due to the similarity in
construction, this incident is included to help illustrate the integrity of
LNG tanks onboard LNG ships. The information below was obtained
from a Japanese marine registry record [bracketed comments have been
added for clarification].
The Motorship “Yuyo Maru No. 10” (gross tonnage of 43,723), laden with
20,831 MT of light naphtha, 20,202 MT of propane and 6,443 MT of butane,
left Ras Tanura, in the Kingdom of Saudi Arabia, for Kawasaki, and the port
of Keihin on October 22, 1974. While the vessel was sailing northward
along the Naka-no Se Traffic Route in Tokyo Bay on November 9, she
collided with the Motorship “Pacific Ares” (gross tonnage of 10,874),
manned with a Taiwanese Master and 28 crew members, laden with 14,835
MT of steel products, en route from Kisarazu for Los Angeles, USA. The
collision occurred about 13:37 hours on the same day slightly northward of
the boundary line of the Naka-no Se Traffic Route.
As a result of the collision, the “Yuyo Maru No. 10” suffered a large hole at
the point of collision, with her cargo naphtha instantly igniting into flames.
The naphtha was carried in its outer ballast tank (between the insulated LPG
tanks and the hull of the ship). [This is effectively what makes up the
“double hull” with LNG ships.] The LPG cargo tank was not penetrated.
[LNG tankers never carry any thing other than air or ballast (water) in these
same tanks.] As a result of the outflow of naphtha overboard, the sea surface
on her starboard side literally turned into a sea of fire. The “Pacific Ares”
showered with fire burst into flames in the forecastle and on the bridge.

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While naphtha, not propane, explosions occurred one after another, attempts
were made to tow the “Yuyo Maru No 10”, outside the bay, but she ran
aground in the vicinity of Daini Kaiho.
She was eventually successfully towed out of Tokyo Bay and sunk south of
Nojima Saki on the afternoon of November 27, thirty-six days after the
original collision, by cannon, air bomb and torpedo attacks staged by the
Maritime Self-Defense Force.

Please note that repeated “cannon, air bomb and torpedo attacks” were
required to sink the ship. Reports indicate that these attacks lasted one
and a half days. The author has seen a black and white film of these
attacks. It appeared that the LPG tanks were for the most part fully intact
prior to the attacks. The ship’s LPG vent stacks were melted down to just
above the decks and on fire indicating that LPG remained within the
storage tanks.

4.2.3 Terrorist Attack on the Limburg Crude Oil Tanker

The Limburg is a double-hulled crude oil ship, meaning that its cargo tank
is the inner hull (unlike LNG ships, which have at least one additional
cargo containment barrier and substantial insulation and structural
systems). On October 6, 2002, the Limburg was attacked by a small boat
carrying an unknown amount of explosives. The Limburg offers insight
into a terrorist attack on a double-hulled ship. The terrorist attack on the
Limburg left the equivalent of a 25 foot diameter hole in the outer hull but
a series of much smaller holes in the inner hull equivalent to a hole about
3 feet in diameter. Figure 4.2.3-1 shows the damage in the side of the
Limburg. Figure 4.2.3-1 shows a close-up of the damage to the inner hull;
note the small holes in the inner hull.

Ironically, the Limburg attack has been used by some to discredit the
worthiness of double-hulled ships, when in actuality the Limburg lost only
4% of its cargo capacity. If one relates the damage to the Limburg to the
additional structure and separation distances inherent with construction of
LNG tankers, it is quite reasonable to expect that had the terrorist attacked
an LNG ship, there would not have been any loss of cargo.

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Figure 4.2.3-1: Damage to Hull of Limburg Figure 4.2.3-2: Close-Up of Hole in Hull of Limburg

It should be self evident that in order to penetrate the outer hull, the inner
hull, and multiple LNG tanks/barriers/insulation, a tremendous amount of
energy will be required. It should, thus, also be obvious that such energy
would also ignite the vapor escaping from the breach of any LNG ship
tank.

5 CREDIBLE LNG SPILL SCENARIOS

5.1 Introduction

In the previous two sections the mechanics of gas explosions and the design and
construction of LNG ships were discussed. This section will lay out why
consequences from credible LNG spills will remain in the immediate vicinity of the
LNG tanker.

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Clear physical facts to take from the preceding sections are that:
1) LNG spills do not explode.
2) Unconfined natural gas (or revaporized LNG) does not explode.
3) Piercing/breaching an LNG ship tank(s) is extremely difficult
4) Other than a very small release of LNG from an incident or terrorist act on an
LNG ship, any large penetration of an LNG ship tank(s) will result in a near
immediate ignition of the first vapor released and a fire in the immediate
vicinity of the ship.

5.2 LNG Ship Incidents

5.2.1 “Worse Case” Fire

Without regard to any probability or assurance of success, assume that


terrorists target an LNG ship. Maybe the terrorist use a small boat laden
with explosives; maybe they use an airplane loaded with explosives;
maybe they use a car directed (somehow) over the guard rail on a bridge
as the LNG ship travels under it. In any of these highly improbably events
the impact is virtually the same.
• Any “explosion” will be wholly tied to the amount of explosives
involved.
• Assuming the explosion results in breaching one or more LNG tanks
on the ship, the first LNG vapor released will be ignited by the
explosion.
• Any LNG spilling out of the tank will be rapidly vaporized by the heat
of the water and the fire. A potentially large fire will exist in the
immediate vicinity of the ship.
• Persons onboard the ship or supporting tugboats will be placed in
substantial potential risk.
• Those persons outside the U.S. Coast Guard’s moving Safety and
Security Zone would face minimal personal risk.
• If the ship is docked at the unloading facility, those persons outside the
fixed safety zone around the LNG facility would face minimal
personal risk.

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5.2.2 “Worse Case” Vapor Travel

Opponents of LNG have hypothesized that the release of LNG from an


LNG ship could result in vapor clouds thousands of feet to many miles in
length. None of these stories provide any substantive explanation of how
the LNG might come to be released in such huge quantities in the first
place, with no ignition source present. The author has a personal
experience8 with one such LNG opponent. Ex-MIT professor James Fay
has for three decades been providing opponents of LNG projects with
vapor travel calculations caused by massive LNG spills on water. Dr.
Fay’s calculations assume that a huge volume of LNG is very rapidly
“dumped” from an LNG ship on the water. Without ignition of the vapor
cloud, his calculations show the vapor traveling for miles. When I met Dr.
Fay, I asked him quite simply, “What is the mechanism that could release
all of that LNG without ignition from the cause of the release?” His
matter-of-fact answer: “I don’t know; I’m not a marine engineer [ship
designer].” Therein lies the fault in most of the horrific LNG spill/vapor
cloud travel scenarios: they totally ignore whether such a massive, rapid,
unignited discharge could possibly occur and instead focus on the possible
consequences of such a discharge. Reason would suggest that if the
probability of a massive, rapid, unignited discharge is non-existent, then
the potential consequence of such a discharge is irrelevant.

For LNG vapor travel to occur where the public is placed at risk, there
must first be a release of LNG significant enough to cause vapor to travel
considerable distances before it all warms up and rises into the atmosphere
and dissipates. Next, there must be no initiating cause of the LNG release
that also resulted in igniting the vapor such as explosives or impact from
another vessel. This eliminates virtually all high energy impacts with the
ship as the vapor would be ignited. Thus, the only way to release
significant quantities of LNG from the ship without ignition would be
through the pumping of the LNG out of the LNG tanks onboard the ship in
transit to or at the LNG terminal. In order for this to occur we must
assume that terrorists are onboard the ship, are in control of the ship and
have knowledge of and access to the LNG pumping and piping systems
and the overrides of the ship’s LNG control systems.

While Transiting Chesapeake Bay:


Without disclosing U.S. Coast Guard safety and security (as well as
operating) protocols onboard an LNG ship transiting the Chesapeake Bay,
the suggestion that a transiting LNG ship could begin offload of the cargo

8
Personal conversation with Dr. Fay, December 10, 2003, Boston, Massachusetts.

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tanks is not credible. For the sake of discussion, however, it is assumed that
terrorists highly trained in the navigation and cargo operations (including the
bypassing of all of the various safeguards) of LNG ships have successfully
begun to pump LNG over the side of a moving LNG ship, thus generating a
vapor cloud. Clearly, the escorting Coast Guard personnel in nearby boats
have to be oblivious to any unusual activity prior to the LNG being released
over the side of the ship. Upon seeing the vapor cloud the Coast Guard will
quickly realize that they are dealing with an intentional spill. At this point,
the Coast Guard’s protocols will certainly call for intentionally igniting the
moving vapor cloud if it should threaten to head in a direction that could
harm human beings before it warms up and rises up into the atmosphere. In
such situation, the ensuing fire would only engulf the area where the LNG is
being pumped. Any persons outside the U.S. Coast Guard’s moving Safety
and Security Zone would face minimal personal risk.
The fire, itself, would remain in the immediate vicinity of the ship as the
LNG release, although at a fairly high rate, would be rapidly vaporized by
the heat of the water and the surrounding fire and quickly consumed by the
fire.

At the LNG Terminal:

The scenario is very similar to the previous discussion. Again, ignoring


Coast Guard safety and security protocols as well as terminal-ship operating
protocols, it is assumed that terrorist have successfully begun to pump LNG
over the side of an LNG ship at the dock. Unlike the vapor cloud scenarios
promoted by opponents of LNG projects, the LNG cannot be instantaneously
unloaded. A typical LNG ship takes 12 to 24 hours to unload. In order to
unload 9% of the cargo9 it would take over an hour, substantially longer than
an assumed instantaneous release. Thus, the unignited vapor cloud travel
would be significantly shorter than the distances published elsewhere. As
with the shipboard release described above, intentional ignition of the vapor
cloud would be required of the standby vessels that patrol the vicinity of the
moored LNG ship and/or shoreside personnel. Once ignited, the gas cloud
would burn back at about 4 miles to hour to the source of the spill.

5.2.3 Credible Incidents

“Credible” LNG spill incidents will be the subject of the risk analyses
performed during the design of the LNG terminal and review of waterway
suitability assessments. The terminal will be designed and operated such
that persons not involved in the operation of the LNG terminal or LNG
ship that are outside the various safety and exclusion zones will not be at
risk for these credible incidents.

9
Based on a discussion in “Brittle Power,” 1982 by Amory B. Lovins and L. Hunter Lovins.

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6 REBUTTAL OF “THE RISKS AND DANGER OF LNG”

Personal injury attorney Timothy Clifford Riley lives in Oxnard Shores near the coast of the
Pacific Ocean in Ventura County. In 2001 a development company named Crystal Energy
envisioned converting an idle oil production platform 11½ miles off the California Coast to
be able to offload liquefied natural gas (LNG) carriers, vaporize the LNG back to its
gaseous state and pipe the gas ashore to an energy craving California.

Shortly after the plan was made public, Mr. Riley began circulating misinformation about
LNG. This “campaign” led to expanding his legal web site to include his perception of the
risks of locating the LNG facility (Crystal Clearwater Port) 11½ miles from his coastal
home. A second offshore LNG project (BHP Billiton’s Caprillo Port) was then announced.
Mr. Riley began adding to his web site any information he could convey as negative about
LNG. At one point (February 2004) his web site was a 158 page long stream of
consciousness pertaining his interpretation of the perils of LNG.

In early 2004, CH·IV International provided Crystal Energy a “fact check” of the 158 page
long web site. This information was used in a public meeting presentation to the residents
of Oxnard. The fact check debunked virtually all of Mr. Riley’s claims about the hazards of
LNG. Mr. Riley was present and offered no objection to the facts presented by Crystal
Energy other than he felt Crystal Energy was impugning him as a lawyer (no lawsuit
followed).

Mr. Riley proceeded to produce “The Risks and Danger of LNG” later in 2004 without
correcting any of the misinformation discredited in the public meeting.

The author has reviewed the video and has categorized the information as presented as one
or more of the following:
Technique 1 - Information presented provides only partial information on a given topic.
Technique 2 - Information presented quotes an incorrect or discredited news story.
Technique 3 - Information presented quotes individuals not qualified to make statements
on which they are quoted.
Technique 4 - Information presented uses information taken out of context from a
reputable source.
Technique 5 - Information presented uses information that is out date, but presenting it as
though it is current.
Technique 6 - Information presented uses non-standard references to exaggerate a point.
Technique 7 - Information presented is simply an incorrect statement.

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One must remember that Mr. Riley is an attorney-at-law and probably a pretty good one.
He was extremely careful throughout the video to protect himself from legal entrapments.
One need only read his “Notices,” “Terms and Conditions” and “Disclaimer” at the bottom
of the first page of his web site [http://www.timrileylaw.com] to understand that he is very
careful in his use of words.

The author has selected 45 of the most glaring incorrect statements or interpretations
presented in the 47-minute video produced by Mr. Riley. The author chose not to point out
the numerous uses of incorrect and provocative terms such as “explosive,” “dangerous” or
simply the emphasis placed on one word or another by the narrators. Each instance is
numbered, followed by the time on the tape where the comment occurred along with a
restatement of what Mr. Riley stated. The last column provides the rebuttal of the comment
along with a reference to the technique Mr. Riley used in providing his misinformation.

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Item Video Topic/


No. Time Quote Refutation

1. 02:15 “Cleveland,” Attorney Riley suggests See Section 2.1. Further, in 1944 there were no LNG design standards. For that matter
that the horrible incident in Cleveland there were no jet planes; no computers; no TV; no microwaves; no video camera, no
in 1944 somehow has relevance to CD, cassette, 8-track, 45 rpm, or even 331/3 records. World War II was ongoing and
today’s LNG facilities. there were only 48 states. Consider the changes in cars alone:

Other than the empathy we can all share with such a horrific event, 1944 Cleveland has
no relevance to the design, construction, operation and safety of LNG facilities today.

Riley Technique 5

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Item Video Topic/


No. Time Quote Refutation

2. 04:00 Skikda, Algeria. 1) See Section 2.2.


Riley Technique 1
1) Attorney Riley claims that Skikda is
an LNG facility similar to LNG
2) We have been unable to find any report that there was any damage to an apartment
import facilities in the United
complex, much less “engulfing it in flames.” There were reported cracked windows
States.
in nearby buildings and not “remote” as suggested in the tape or in the video.
2) He further claims that the Skikda Riley Technique 2
incident blew out windows of a
distant apartment complex 3) Skikda Train 40 is where the incident occurred. Train 40 was in fact scheduled for
engulfing it in flames. demolition. It was trains 10, 20, and 30 that were repaired by a company then
called Kellogg (now KBR), which Halliburton purchased after most of the upgrade
3) Attorney Riley also states that work was completed. We can only surmise that the introduction of “Halliburton” was
Halliburton updated the facility in to draw on the current high negatives surrounding the name of Halliburton.
1999 based on an article in the
Mobile Register. Riley Technique 2

3. 05:05 Attorney Riley claims that LNG could 4) U.S. companies cannot lawfully engage in commerce with the Country of Libya,
come to the United States from Libya. particularly, with energy supplies like LNG.
Riley Technique 7

4. 05:15 Attorney Riley uses the term, “gallons 5) Natural gas is never measured in “gallon” units. Gallon is the unit of liquid measure.
of natural gas.” Natural gas is measured in “million standard cubic feet.” Clearly his use of gallons
is to connote a very large number. Using this logic, 33 million gallons of water
would equal 33 billion gallons of steam!
Riley Technique 6

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Item Video Topic/


No. Time Quote Refutation

5. 05:50 Attorney Riley shows the size of an This point is, in fact, correct. It is clearly intended to show that LNG ships are extremely
LNG ship, comparing it to three football large. By energy transport size, LNG ships are smaller than most. Comparing to other
fields long. ships:
ULCC (crude oil) ships: ~1350 feet long
VLCC (crude oil) ships: ~1140 feet long
Aircraft carriers: ~1100 feet long
Container Ships: ~1100 feet long

LNG ships are about the same size as cruise ships, for comparative purposes or 940 to
980 feet in length. LNG ships are smaller than many of the container ships that visit the
Port of Baltimore. For example, the Colombo Express, below, is 1088 feet long.

Riley Technique 6

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No. Time Quote Refutation

6. 06:10 Attorney Riley states that 33 million While is possible to compare the energy potential of different items in the same units, it
gallons of LNG is equivalent to 55 is entirely incorrect to assume that each item can release its energy at the same rate.
Hiroshima bombs. Turning this logic the other way, 33 million gallons of LNG can heat about 40,000
homes for one year; how many Hiroshima bombs would it take to heat 40,000 homes
for a year? The hazard potential depends not only on the amount of energy stored but
also the rate at which it can be released. Energy released when natural gas is burned
is relatively slow as will be noted later in Item 33, Rebuttal 5) below. On the other hand,
in an explosion such as from an atom bomb, the energy is released with such incredible
speed that it causes a shock wave that travels outward and causes severe damage to
anything in its path.

One way to think of this is to consider a coal mine that contains the same energy
potential as an LNG ship contains (a very modest amount of coal in the scheme of mine
sizes). Coal, like natural gas, releases its energy much more slowly than an atomic
bomb, yet the “energy potential” is there.

Riley Technique 6

7. 06:20 It takes 5 miles to stop an LNG ship. Actually, this is true for any large vessel moving in the ocean at cruising speed.
However, these cruising speeds do not occur anywhere near land, particularly,
approaching the LNG import facility. The fact that it takes 5 miles to stop a ship when it
is traversing the open ocean at cruising speed has absolutely nothing to do with a ship
arriving at a land-based port. A car can travel a 65 miles per hour on the highway, but
one does not pull into a driveway at that speed.

Riley Technique 1 and 4

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8. 06:45 The comment is that the U.S. Coast Any energy storage facility with the potential of what someone has defined as “worst-
Guard Captain of the Port of Savannah case” might typically evacuate all personnel at some point in the evaluation of the
is suggesting that U.S. C.G. personnel emergency. We find absolutely nothing unusual or surprising in such a statement.
should be evacuated in the event of a What Attorney Riley fails to point out is the low credibility of the “worse-case” scenario
worst-case discharge of LNG. It is and what actions the U.S.C.G would take in an emergency situation, including attempts
suggested that somehow this is to remedy, rescue, etc. before evacuation is called for.
unusual.
Riley Technique 1

9. 07:15 Attorney Riley mentions a number of Addressing these one at a time.


things:
1) Mr. Riley makes it sound as though breaching a tank on an LNG ship is a simple
1) The breach of the LNG tank matter. The breach of the tank is discussed at length in Section 4.2. As discussed
there, the severity of a leak and any ensuing vapor cloud is very much a function of
2) The 5 to 15 percent gas and how and where the tank is breached and breaching a tank is no simple matter.
oxygen, and
Riley Technique 4
3) That the vapor cloud can ignite
2) Attorney Riley mentions 5 to 15 percent gas in oxygen. He has misstated the facts;
with a simple spark from a cell
the correct statement is “5 to 15 percent gas in air.” Air is only 21% oxygen.
phone, spark plug, or dragging one
feet across the carpet. Riley Technique 7

3) We do not dispute the ignition sources mentioned, however, this, again, will come
into play later and we will refer back.

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10. 07:35 The discussion about Brittle Power and First, one must understand Brittle Power was originally published in 1982. Although re-
the 9 percent spillage of LNG. published in 2002, there is no indication or suggestion that in fact the book was updated
from its April 1982 discussions when LNG was a minor part of the discussion. The
Brittle Power report, although it mentions the 9 percent of a tanker load, it is completely
silent as to the mechanism whereby so much LNG could be spilled on the water without
immediate ignition. See Section 4.2. The quote from the study mentions that a plume
might extend at least 3 miles downwind on a large tanker spill within 10 to 20 minutes,
requiring wind velocities of 9 to 18 mph. There are no credible simulations today that
would indicate the wind velocities that high could result in a 3 mile vapor cloud. See
Section 3.2.2 on the effect of wind on vapor travel. The claims presented in Brittle
Power are discredited today. Similarly, the comment that an LNG fireball can blow
through a city creating a large number of ignitions and explosions across a wide area,
again, must be understood from the standpoint that LNG does not “blow through a city”
as suggested. Please note the flame spread shown in the video referenced in Item 33.
.

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11. 09:00 The comment from the California CH·IV has been unable to find any information on the original Oxnard study other than
Energy Commission, July 2003, the the quote in the California Energy Commission (CEC) July 2003 White Paper, where the
extraction of the Oxnard City Council full quote is
study shows up to 70,000 casualties
from an LNG accident. “Western (a company desiring to build an LNG import terminal) commissioned risk
assessments for the Los Angeles and Oxnard sites. Both studies found extremely
low safety risk, based on the probabilities of marine and onshore LNG accidents and
bad weather conditions. The Oxnard City Council, however, did its own study, which
considered safety risks under worst-case scenarios. Oxnard’s citizens opposed the
project after the City’s study showed up to 70,000 casualties from an LNG accident
there.”

It must be understood that the CEC white paper was just that; it was presenting
information that had previously been made available without comment or qualification.
However, the CEC followed this study with their January 2005 study10 where they stated
the new maritime security regulations and the general lack of marine experience among
terrorists may reduce the potential for a terrorist attack on a U.S. LNG import terminal.
“In the unlikely event that a missile or other vessel hit an LNG carrier, the conservative
modeling conducted by Lloyd’s Register and DNV suggests that the exposure to
harmful thermal radiation would be limited to distances near the carrier.” The report
goes on with the important point, “The force required to penetrate the carrier’s liquid
tight barriers would likely ignite LNG vapor clouds quickly.” The term here, “would likely
ignite,” will lately be shown in almost every case mentioned later, “would ignite.”

Riley Technique 1, 4 and 5

10
“International and National Efforts to Address the safety and Security Risks of Importing Liquefied natural Gas: A Compendium.”

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No. Time Quote Refutation

12. 09:20 Attorney Riley continues on with the See Section 5.2.2. Riley presents no scientific support for his hypothesis. In fact, there
supposition that a collision that would is none. In any high energy impact with an LNG vessel that is sufficient to pierce the
somehow cause a near instantaneous multiple layers needed to reach the cargo, the resulting vapor would certainly be ignited
release of the full contents of five LNG immediately and therefore would not travel any significant distance from the ship. It is
tanks and then somehow not ignite the even less credible that all five tanks of an LNG tanker could be simultaneously ruptured
vapor cloud and, thus, result in a 30- and release all the cargo nearly instantly without any ignition source associated with the
mile vapor cloud. event.

Furthermore, winds greater than 4 miles per hour will tend to break up a vapor cloud
and dissipate it more rapidly into the atmosphere. For a vapor cloud to travel 30 miles
at 4 miles per hour, it would have to stay intact for seven and a half hours, and the
vapor in the cloud would have to fail to warm up to for seven and a half hours. No
scientific studies have ever come anywhere close to finding that such a scenario is even
remotely possible.

Riley Technique 5 and 7

13. 10:50 Attorney Riley quotes an article from This is one of the best examples of where Attorney Riley, whether he knows it or not is
the September 20, 2004 Norway Post quoting incorrect information. The ship was not LNG, but an LPG ship. What is known
about an LNG ship adrift. is the story served his purpose of trying to suggest that an LNG ship heading towards
rocks might explode. The people quoted in the article who feared the ship would
explode were unfortunately extremely ignorant on the design of the LPG ship. One
should reference Section 4.2.1 above and see what really happens when an LNG ship
moving at cruising speed, not “drifting,” hits a submerged rock outcropping. It is
extremely irresponsible to suggest that an LNG ship would explode upon drifting into
rocks. One only has to understand the structure, the design of an LNG ship to
understand how fallacious such a suggestion is.

Riley Technique 2 and 3

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14. 11:30 CNN News Story, November 2002, Again, Attorney Riley is using a news story and hypes it as there was a real hazard risk
about a nuclear sub colliding with an present. The Norman Lady was not empty. LNG ships never unload all of their cargo
“empty” LNG ship. unless going out of service. The news story suggests that had the ship been loaded it
would have been a much more dangerous situation. This is ridiculous as a submarine
periscope could, at best, only cause minor damage to the outer hull of an LNG ship.

The fact is that a sub and a ship did not actually collide, but the periscope was raised
into the hull of the ship. Yes, there was an LNG ship involved, but no there was no risk,
no safety concern and no hazard was ever present.

Riley Technique 2 and 7

15. 12:05 Mayor Lopez of Oxnard. There is no doubt Mayor Lopez wants to do the best for his city, but he is in effect
exemplifying some of the worst examples of how a leader should speak to his citizens.
Mayor Lopez mentions how he lost sleep because of the potential of siting of an LNG
terminal in the previously mentioned story placing 70,000 lives at risk. Unfortunately,
Mayor Lopez is not qualified to understand the mechanics, nor the physics of LNG. And
although the laws in physics haven’t changed, since that study was performed, much of
our understanding of dense gas dispersion, penetrations of LNG tanks, ignitions of
vapor clouds and so forth have made us far more intelligent on the subject than we
were back in 1972. Unfortunately, he uses the word “nightmare” of an LNG disaster in
his discussion and, again, this is a case where someone not armed with all the facts is
making statements that can only serve to scare the people in his district.

Riley Technique 2 and 3

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Item Video Topic/


No. Time Quote Refutation

16. 12:55 A quote from Congressman Markey of Unfortunately, there is no reference, no backup, no suggestion on what he based this
Massachusetts indicating that LNG judgment. Clearly, items such as chlorine, ammonia, gasoline, propane, tall buildings or
facilities are the most attractive of all mass transit systems pose just as “attractive” targets as LNG and by many analyses far
terrorist targets. more threatening targets.

Riley Technique 3 and 7

17. 13:15 ABC News Story from September Unfortunately, no more details were provided to the story for that. The term “floating
2003. Quoting to the story, suggestion bomb” suggests that somehow the energy content of the ships could be very rapidly
was made that terrorists could seize released, there by causing a pressure wave that is a bomb-like situation. There is no
LNG ships and convert them to floating known way to convert a loaded LNG ship into a bomb. See Section 5.2.
bombs.
Riley Technique 2 and 7

18. 13:25 From the Providence Journal, Again, a quote is taken from a newspaper by an individual not citing technical expertise
September 2004, Lloyd’s executive as to how such a statement could be made. Again, the unknown “specialist’s” quote
likens attack to nuclear explosion. that an LNG tank that will have the force of a small nuclear explosion cannot be justified
under any known credible incident scenario.

Riley Technique 2, 3 and 7

19. 13:50 The science and environmental policy Again, LNG tankers cannot explode. See Section 5.2.1. The only way to explode an
project, where it was stated “next to an LNG tanker would be in fact to fill it with explosives and release the explosive. The LNG
atomic bomb, the most destructive itself cannot cause an explosion such as an atomic bomb. This same discussion went
calamity available is the explosion of a on to talk about showing Cleveland after LNG, suggesting it looked like Hiroshima after
tanker carrying LNG”. the atomic bomb. Please note in the pictures, the two LNG tanks sitting undamaged in
the background. If the explosive force was so great, why were those tanks not taken
out as well?

Riley Technique 3 and 4

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No. Time Quote Refutation

20. 14:50 The discussion around the live fire test Not knowing the arms in questions, nor being an arms experts, the fact that small arms
suggests that small arms, not military are mentioned indicates small penetration. It is very important people understand firing
rifles, can penetrate the containment of any projectile into the side of an LNG ship, even if it penetrates the LNG tanks, will not
LNG ships. result in an explosion. It could result in LNG flowing out of the hole, revaporizing, and
catching fire in the area of the release, but it would not result in explosion or a bomb-like
situation.

Riley Technique 4 and 7

21. 15:20 The discussion of terrorists on board The claims and statements made do not make sense, in terms of understanding the
an LNG ship. design and operation of an LNG tanker. Having people on board with the desire to turn
the LNG ship into a bomb, does not mean that there is a way of turning the ship into a
bomb. Having terrorists on board does not guarantee that there is a way to rupture the
tanks. “Manipulating valves” does not mean there is a way to overpressure the storage
tanks.

However, assume for the moment that valves could be manipulated to overpressure
tanks. The tanks are not pressure vessels but are very low pressure tanks. If
“overpressured” they would release low pressure vapor, not LNG.

Also see Section 5.2

Riley Technique 7

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22. 15:50 The discussion that terrorists can buy See Section 5.2 first.
software online that will teach them
how to maneuver LNG ships and An LNG ship is not particularly maneuverable, especially by inexperienced personnel.
operate the ship. A variety of different When an LNG approaches the shore it is typically attended by at least three tugboats.
claims are made, ranging from But for the sake of the discussion let’s assume that the terrorists maneuvering the ship
maneuvering the ships close to shore can somehow maneuver the ship into a position, where other personnel can release the
to releasing its cargo. LNG. Let’s further assume that the software bought online did in fact teach the
personnel to do all the things required to align the piping, start the pumps and start
releasing cargo. Although the ship may have 33 million gallons of LNG on board, there
is no LNG pump in the world able to deliver all of LNG quickly. Normal unloading time
for a ship that size would be in the 12 to 14 hour range.

It is at this point that some of Attorney Riley’s claims begin to contradict themselves. On
one hand he claims a release of LNG would result in large vapor clouds moving over
cities without ignition. On the other hand, he pointed out earlier, how little it took to
ignite such a vapor cloud.

The reality is, should such a large vapor cloud released by this method approach shore,
the cloud would undoubtedly find an ignition source very quickly (whether by design
protocol or other means) and burn back to the ship. Remember that Attorney Riley
discusses how easy it is to ignite natural gas (such as through a spark plug or even
dragging one’s feet across a carpet); these facts thus eliminate the “vapor cloud
enveloping the city” scenario. As far as risk and hazard damage to a nearby city, the
risk would be greatly diminished once the fire moves out next to the ship. It must be
remembered that an LNG ship draws about 40 feet, so an LNG ship can approach no
closer to the city shoreline than a location where the harbor is at least 40 feet deep.

Riley Technique 3, 4 and 7

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23. 16:30 Pertains to the quote from Richard One must first remember that this event occurred only days after 9/11 and it was hard
Clarke about closing down Boston not to overreact to everything. The author believes that it was prudent to hold back the
Harbor in the days following 9/11, that transit of the first LNG ship in the Boston Harbor after 9/11 until all appropriate safety
is closing Boston Harbor to the transit security issues were addressed, both by the regulatory forces but also in the minds of
of LNG ships. Clarke is quoted as, the people of Boston. Richard Clarke states (without providing any reference to the
“We had also learned that, had one of source) that they had learned had one of the LNG tankers been attacked in the harbor it
the giant tankers blown up in the would have wiped downtown Boston. No one knowledgeable in the design and
harbor, it would have wiped out construction of LNG tankers would have made that statement. Clearly there were
downtown Boston.” concerns over a potential terrorist attack on an LNG ship in Boston Harbor for a variety
of reasons, but none of reasons should have been because of the concern of wiping out
Boston. Because if that possibility exists at all, why have the ships been routinely
coming into Boston Harbor ever since 9/11?

Riley Technique 3 and 7

24. 17:10 Pertains to Richard Clarke’s comments See Section 4.2.3 and 5.2.1.
in the study, that small ships could
cause catastrophic damage, if used to Riley Technique 3 and 7
attack LNG ships.

25. 17:20 U.S. Coast Guard exclusion zone The facts as stated on the Coast Guard Safety and Security Zone are correct. It is that
imposed, in this case, around LNG Safety and Security Zone that is part of the security that prevents small ships from
ships arriving at Boston harbor. getting close to the vicinity of a moving LNG ship. However, the suggestion that that the
moving ship will disrupt fishing and tourism is not supported by the reality. There are
four LNG terminals operating in the United States, most of them have similar moving
Safety and Security Zones. Negative impact on the local fishing and tourism industry
has not been the subject of any significant complaints in their years of operation.

Riley Technique 1 and 4

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26. 18:05 Attorney Riley suggests that small See Section 5.2.
planes can be used by terrorist to
attack LNG facility, ships, et cetera. If a terrorist were to consider using a small plane loaded with explosives to attack a
Similarly, they state that an airplane “soft” target, what other more valuable targets might terrorist choose that would result in
could leave from Oxnard and fly to greater loss of life than an LNG terminal or LNG ship? Clearly schools, hospitals and
Grace. high-rise buildings offer a greater chance of mass deaths.

The graphic of the airplane flying to the Grace Platform shows the target on the Grace
platform, but no suggestion as to what would happen if a small plane hits that platform
11 miles offshore. There is no credible scenario whereby that situation would result in
placing anyone on shore at risk.

Riley Technique 6 and 7

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27. 19:30 Attorney Riley suggests, but does not See Item 6 above.
specifically state, that a small plane
hitting an LNG tanker would be Remember Attorney Riley also pointed out that these ships are over three football fields
equivalent to 55 Hiroshima bombs. in length. If a plane did hit an LNG ship, it could, at most, damage two tanks. Hitting
those two tanks would not cause an explosion. Assuming the airplane was carrying
explosives, which might then tear into the LNG tanks, what is the impact of such a
scenario? There would be a very large fire at the immediate vicinity of the ship, no
pressure wave, and no Hiroshima bomb.

Riley Technique 7

28. 20:10 Attorney Riley suggests the integrity of See Section 4.1 about the robust nature of the LNG ship structure. Note in Section
the double-hull claim by LNG industry 4.2.3 that the Limburg lost only 4% of its cargo capacity in that terrorist attack. Ignoring
experts is intended for the gullible and the conclusion in Section 4.2.3 that a Limburg-like incident involving an LNG ship would
naïve because of the incident involving most likely not result in an LNG tank breach, ioMosaic Corporation of Salem, New
the crude oil ship Limburg and the Hampshire, a provider of safety and risk management consultant services, estimated11
resulting “massive” fire. that had the one-meter hole would lead to a large fire in the immediate vicinity of the
LNG ship. The thermal radiation zone would carry no more than four-tenths of a mile
from the point of release.

Riley Technique 4 and 7

29. 23.22 The Sandia Report, where Attorney Rather than extracting out of context comments from the report,12 it is most valuable to
Riley goes through extracting pieces of go to the key conclusions in the executive summary included in Appendix A.
the report and making just comments
out of context. Riley Technique 4

11
“Managing LNG Risks: Separating the facts from the Myths” 2005
12
“Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water,” December 2004

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30. 24:10 CRS report. Again, Attorney Riley has We feel it is far better to go to the conclusion page and read some of the comments
chosen to extract statements out of there. For example:
context from the 29-page report.
Page 25 - “The LNG industry has a long history of relatively safe operations and has
taken steps to secure its assets against terrorist attacks.”

Page 25 - “Because their security has been subject to intense public scrutiny, new LNG
terminal and tanker operations may be safer than they might have been
without such scrutiny and their citing may be less likely to be challenged at a
later time when construction is already underway.”

Page 25 - (Advice to Congress for whom the report was prepared) “Congress may also
act to improve its understanding of LNG’s security risk,” which we conclude
means that much of the information they have been receiving the wrong
(overly negative) side of the story.

Page 26 - (last paragraph) “Maintaining high levels of security around LNG tankers, for
example, may be of limited benefit if other hazardous marine cargoes are less
well protected.”

Riley Technique 1 and 4

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31. 24:30 The quote from the Sandia report It should be recognized that the Sandia report broke little, if any, new ground. As a
suggesting a vapor cloud could travel matter of fact, the Sandia report mostly gathered available report studies and the like,
over two miles. and summarized them in a single paper. The reference to the “over two-mile vapor
cloud” comes from Table 28 in the Sandia report on page 87 of the 167 page report.
This table, however, was taken from Table VII on Page 58 of a report entitled, “Liquefied
Natural Gas in Vallejo: Health and Safety Issues” published by the LNG Health and
Safety Committee of the Disaster Council, City of Vallejo, January 16, 2003. The
Vallejo reports description of Table VII states: “The first scenario is that of a collision of
an LNG carrier. It ruptures one tank without ignition, spilling the entire contents through
either a one-meter, or five-meter diameter hole on the water.” Most important though is
the sentence that follows, “It is likely a collision violent enough to rupture a tank would
ignite the LNG.” They go on further to say, “This unlikely, but possible event was
considered.”

The author would unequivocally state that a collision violent enough to rupture a tank
would ignite the LNG. See Section 4.2.

Riley Technique 1 and 4

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32. 25:46 Public may be denied access to safety This comment, maybe above all on the video, comes across as completely contradictory
reports. to the concerns about safety. Detailed design information about LNG terminals must
remain out of the public hands for the sake of facility security. Following September
11th, open Internet access to critical energy infrastructure information on the Federal
Energy Regulatory Commission (FERC) sites has been restricted, because these
documents describe LNG facility design details, siting and layout. They also include the
facility’s security plans and security details. It is obvious restricting public access to this
kind of information is required to prevent access by terrorist groups. This is simply a
prudent practice to protect our nation and our citizens. It is too dangerous to allow
terrorists access to the detailed designs of these facilities. It is not about the danger of
the facilities that is being hidden; it is about the danger of allowing unlimited access to
groups of people who want to hurt us.

Riley Technique 4 and 7

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33. 28:23 Attorney Riley’s statement that the The initial comment is that very little of the tape was shown; it was heavily edited, which
myth is that LNG does not explode and made it somewhat difficult to follow the context of what was being presented. Other
his response is “Utter nonsense” and comments:
he proves it with an 1960s vintage
movie footage. 1) At the beginning of the tape, they do show the aftermath of the Cleveland incident.
It is important to note that although there was a large fire and numerous small,
localized explosions due to natural gas being trapped in confined spaces in the
local storm sewers and then igniting, yet there are two LNG tanks that were in the
midst of impacted area can be seen in the picture as fully intact after the small,
localized explosions had all occurred.

2) Referring to the spill of LNG on the water, note the speed of vapor travel. It is quite
slow.

3) When the vapor cloud is ignited, contrary to Attorney Riley’s “utter nonsense”
statement, it can be seen that there was no explosion.

4) There is a comment in the film that vapor travels further than predicted. These films
were made either in 1969, or 1972. In the late 1980s, and early 1990s, the Gas
Research Institute spent considerable money developing a dense gas simulation
model called DEGADIS. DEGADIS much more closely simulates vapor travel on
water or on land.

5) In later footage, ignition of another vapor cloud is shown. Again, no explosion, but
in fact “a lazy diffusion flame” far from what you would get with an explosion.

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33 Item 33 continued 6) The reference to a “major explosion that caught worldwide attention” refers to what
is called a “rapid phase transition” or RPT. RPTs can occur when the liquefied gas
has a very high content of “heavy” hydrocarbons, unlike typical LNG that is
delivered by ships. Very local “explosions” can occur when small pools of the heavy
hydrocarbons nearly instantly convert from liquid to vapor, i.e., rapid phase
transition. The energy released by an equal amount of mass in an RPT is about
1/1500th of the amount of energy that would be released by burning it. Further, it
has been found that the RPT phenomenon does not scale up with the size of the
spill, thus the real risk to personnel or property near an RPT is extremely small. In
the very few cases where RPTs have actually been experienced, the damage is
very localized and, for the most part, fairly insignificant. As such, RPTs in LNG
import facilities are irrelevant in terms of public safety.

7) Toward the end of the film during the summary, there is a mention that, “Vapor
spreads rapidly.” Yet the graphic indicates that the vapor is moving at 2.5 feet per
second, which is about two miles an hour. That in itself is somewhat misleading in
that the vapor will pretty much travel at the velocity of the wind.

8) The last comment to note is the reference to flashback or a burnback, that is once
ignited, the flame will burn back to the source of the LNG spill. This is different than
the images mentioned earlier in the video where it is suggested the flame will move
all around igniting and exploding all over a given area.

Riley Technique 1,4,5 and 7

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34. 33:42 Attorney Riley says we need to know See Section 4.2 and 5.
how far a large vapor cloud will travel.
The basic flaw in this statement is that it assumes a large volume of LNG can be
released essentially instantaneously from an LNG ship without ignition. It is a
consistent belief among those of us in the LNG industry with knowledge of the design of
an LNG ship that there is no mechanism whereby a large penetration LNG ship tank
can occur without ignition. Thereby, the conclusion is that it may be possible through
terrorist acts or accidental collisions to penetrate an LNG ship’s tank, it is not credible to
assume that the LNG will not ignite upon initial release. Thus, the emergency will be
very local to the LNG ship.

Riley Technique 7

35. 33:37 This has to do with the discussion of See Section 2.2
Skikda and the later findings as to the
cause of the explosion at the Skikda The Skikda liquefaction system has very little similarity to an LNG import system other
Liquefaction facility. than both have docks for loading or unloading ships and both have LNG tanks.

Riley Technique 2, 4 and 7

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36. 33:58 Attorney Riley suggests that experts in Mr. Riley’s statements on flammability limits are correct. What Attorney Riley fails to
the industry claim LNG is safe because note in his comparison in addition to flammability limits is the relative ignition
of a narrow flammability limit and then temperatures.
points out that other fuels have lower
flammability limits suggesting that LNG Clearly, the colder a fuel ignites, the more potential there is for ignition sources. For
or natural gas is thereby less safe. example, unleaded gasoline has an ignition temperature around 500°F, whereas jet fuel
is a little over 400°F. Propane and butane, depending on their mixture, have an ignition
temperature somewhere between 900 and 1100°F, whereas methane, CH4, natural gas
has an ignition temperature of something over 1100°F. Whereas Mr. Riley states that
methane has the “greatest likelihood of combustion” of the products listed, we would
state that methane has the least likelihood of combustion for it will see the fewest
sources of ignition due to its higher ignition temperature requirement.

Riley Technique 7

37. 34:14 Attorney Riley is suggesting that All anyone has to do is go to any environmental site and look up the various kinds of
natural gas is not a favorable fuel for fuels to determine that methane (natural gas) is considered one of the cleanest burning
the environment. available fuels. The fallacy in attorney Riley’s discussion here is a suggestion that the
methane itself will not be used as fuel, but simply released to the atmosphere.

Although methane is considered a “global warming gas” by some, unfortunately, the


natural occurring sources of methane (termites, ants, cattle and earth-based)
overwhelm by millions, if not billions of times, any estimates of fugitive emissions from
an LNG operation.

Lastly, suggesting that natural gas is not good for the environment is totally counter to
those countries subscribing to the Kyoto protocol.

Riley Technique 4 and 7

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38. 35:15 Attorney Riley comments that it is Unfortunately, the statement makes no sense whatsoever. The boil-off rate for LNG
shocking that the boil-off rate from an tankers is between 0.15 to 0.25 percent per day. This means that the LNG inside the
LNG tanker is 15 to 25 percent. ship is boiling off (boil-off is nothing more than natural gas). It is captured and either re-
condensed (turned back into LNG) and put back into the tank or used for fuel to power
the ship.

The statement that each LNG tanker burns a hundred tons of fuel per day is true, but
the purpose of the statement by Mr. Riley is unclear, all ships burn fuel.

The next statement is that each LNG tanker produces harmful emissions that will
exceed power plant emissions. Unfortunately, again, Attorney Riley has gone into a
document and extracted information completely out of context. The context of this
report was that an LNG tanker at full steam at sea would have higher emissions than a
once proposed power plant to be located in Vallejo, California. Unfortunately the report
did not quantify the power plant in terms of its size, emission control technologies, fuel
type or anything else. So beyond understanding that this statement was pulled
completely out of context, we have no further rebuttal.

Riley Technique 1, 4 and 7

39. 35:33 LNG is a fuel cocktail with inconsistent If one were merely to look at the compositions of LNG loaded at the 18 or 20 facilities
compositions. around the world that produce LNG, the statement is true. That is, that LNG from
different sources will have different compositions. However, designers of LNG facilities
take into account the acceptable compositional ranges of LNG to come into a given
facility such that, downstream, those compositions will not impact the safe operation of
the import terminal.

Riley Technique 1 and 4

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40. 36:05 The claim that energy officials are It is not the author’s expertise to comment in depth on the domestic production or
claiming natural gas reserves are availability of natural gas. On the other hand, it’s quite clear that LNG will only be
declining. imported if it is a cost-competitive with other sources of natural gas. Most of the energy
officials would look at it not from the standpoint of declining U.S. supplies, but providing
the consumer with a lower cost of fuel.

41. 37:10 The discussion of guinea pigs/ It is, however, unfortunate that Attorney Riley chose to use building a graphic
innovative topics and so forth will not suggesting city blocks and buildings as replicating the size of the offshore facility being
be rebutted at this time as it has no proposed by BHP Billiton (Cabrillo Port). It is surprising and disappointing, given all the
relevance to the Sparrows Point research that Mr. Riley was apparently unable to pull a simple graphic off of BHP’s web
project. site that would give the audience some sense of size and relative design of a floating
receiving terminal. He chose instead to relate the project to “Chicago city blocks” and
17-story buildings. In Appendix B one can see a comparison of Riley’s graphic of
Cabrillo and the developer’s graphic.

Riley Technique 6

For clarification, the Sparrows Point facility will not be using any bay water in processing
the LNG at Sparrows Point, contrary to any impression that might have been left by Mr.
Riley about LNG terminals.

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42. 41:44 Discussion - High-pressure gas Attorney Riley seems to be stating that there should not be high-pressure gas pipelines
pipelines. running across the United States as they currently do today. As with any other energy
fuel, accidents do happen. However, when one reviews the history of the thousands of
miles of high-pressure natural gas pipelines running through the United States, what is
found is a very enviable safety record. On top of that, new pipelines installed today
meet more stringent requirements than those that are in the ground today. Additionally,
corrosion is a concern for underground pipelines and there are numerous procedures
and techniques taken to assure that the outside pipe surface does not corrode.
However, normal natural gas does have certain constituents that could aid in potential
corrosion of the pipe inside surface, such as sulfur-containing compounds and very
small amounts of water. One of the benefits of natural gas produced from LNG is that
the gas has neither water nor sulfur-containing compounds in it. So any minimal
concern about internal pipe corrosion caused by these constituents is completely
mitigated.

Riley Technique 1 and 7

43. 42:29 Attorney Riley states Fluxy’s LNG, The name of the company that owned the pipeline was Fluxy’s LNG. LNG had
which runs Belgium’s network of absolutely nothing to do with the blast.
natural gas pipeline, confirmed a gas
leak caused the blast. However, it Riley Technique 1 and 6
should be noted that “Fluxy’s LNG and
gas leak caused the blast” are
highlighted red. So one would read,
“Fluxy’s LNG gas leak caused the
blast”.

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44. 42:55 Gas leaks in the Washington Gas area. Again, Attorney Riley has taken a misstatement from ABC news and used it to suggest
LNG was the cause of the leak in the rubber seals. The ABC story misstated,
“Washington Gas concludes LNG caused rubber seals within pipe couplings to shrink
and leak”, leaving one with the impression that LNG was in the pipes. In fact, the gas
that was in the pipe, was vaporized LNG, that is natural gas. The vaporized LNG was
lacking heavy hydrocarbons due to the purification process in making LNG.
Washington Gas had in one part of their service area some extremely old piping that
used rubber seals rather than welded or bolted pipe. One reason suggested for the
natural gas leaks is the lack of heavy hydrocarbons resulted in some of these rubber
seals aging more quickly, and preventing them to act as originally designed. As a
result, small gas leaks were noticed by means of individual smelling gas odor at a
variety of areas in the Washington Gas district where the piping had these rubber seals.

Riley Technique 2

45. 43:53 Discussion on seismic conditions. Seismic will not be a concern in a design of the Sparrows Point facility. But tanks will be
designed for the maximum seismic condition, which in Maryland it is a much lower level
of activity than California from which the video is based.

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Appendix A: Sandia Report

From Executive Summary:

1. The system-level, risk-based guidance developed in this report, though general in nature (non
site-specific), can be applied as a baseline process for evaluating LNG operations where there is
the potential for LNG spills over water.

2. A review of four recent LNG studies showed a broad range of results, due to variations in
models, approaches, and assumptions. The four studies are not consistent and focus only on
consequences rather than both risks and consequences. While consequence studies are important,
they should be used to support comprehensive, risk-based management and planning approaches
for identifying, preventing, and mitigating hazards to public safety and property from potential
LNG spills.

3. Risks from accidental LNG spills, such as from collisions and groundings, are small and
manageable with current safety policies and practices.

4. Risks from intentional events, such as terrorist acts, can be significantly reduced with appropriate
security, planning, prevention, and mitigation.

5. This report includes a general analysis for a range of intentional attacks. The consequences from
an intentional breach can be more severe than those from accidental breaches. Multiple
techniques exist to enhance LNG spill safety and security management and to reduce the
potential of a large LNG spill due to intentional threats. If effectively implemented, these
techniques could significantly reduce the potential for an intentional LNG spill.

6. Management approaches to reduce risks to public safety and property from LNG spills include
operation and safety management, improved modeling and analysis, improvements in ship and
security system inspections, establishment and maintenance of safety zones, and advances in
future LNG off-loading technologies. If effectively implemented, these elements could reduce
significantly the potential risks from an LNG spill.

7. Risk identification and risk management processes should be conducted in cooperation with
appropriate stakeholders, including public safety officials and elected public officials.
Considerations should include site-specific conditions, available intelligence, threat assessments,
safety and security operations, and available resources.

8. While there are limitations in existing data and current modeling capabilities for analyzing LNG
spills over water, existing tools, if applied as identified in the guidance sections of this report, can
be used to identify and mitigate hazards to protect both public safety and property. Factors that
should be considered in applying appropriate models to a specific problem include: model
documentation and support, assumptions and limitations, comparison with data, change control
and upgrade information, user support, appropriate modeling of the physics of a spill, modeling
of the influence of environmental conditions, spill and fire dynamics, and peer review of models

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Appendix A: Sandia Report

used for various applications. As more LNG spill testing data are obtained and modeling
capabilities are improved, those advancements can be incorporated into future risk analyses.

9. Where analysis reveals that potential impacts on public safety and property could be high and
where interactions with terrain or structures can occur, modern, validated computational fluid
dynamics (CFD) models can be used to improve analysis of site-specific hazards, consequences,
and risks.

10. LNG cargo tank hole sizes for most credible threats range from two to twelve square meters;
expected sizes for intentional threats are nominally five square meters.

11. The most significant impacts to public safety and property exist within approximately 500 m of a
spill, due to thermal hazards from fires, with lower public health and safety impacts at distances
beyond approximately 1600 m.

12. Large, unignited LNG vapor releases are unlikely. If they do not ignite, vapor clouds could
spread over distances greater than 1600 m from a spill. For nominal accidental spills, the
resulting hazard ranges could extend up to 1700 m. For a nominal intentional spill, the hazard
range could extend to 2500 m. The actual hazard distances will depend on breach and spill size,
site-specific conditions, and environmental conditions.

13. Cascading damage (multiple cargo tank failures) due to brittle fracture from exposure to
cryogenic liquid or fire-induced damage to foam insulation was considered. Such releases were
evaluated and, while possible under certain conditions, are not likely to involve more than two or
three cargo tanks for any single incident. Cascading events were analyzed and are not expected
to greatly increase (not more than 20%-30%) the overall fire size or hazard ranges noted in
Conclusion 11 above, but will increase the expected fire duration.

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Appendix B: Cabrillo Port

Attorney Riley’s graphic of Cabrillo Port:

BHP Billiton’s publicly accessible graphic of Cabrillo Port:

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About the Author
Jeffrey (Jeff) P. Beale, President, CH·IV International

Mr. Beale is the President of CH·IV International of Millersville, MD. Jeff is an internationally known
expert on liquefied natural gas (LNG) system safety, design and operations with almost thirty years of
experience.

Jeff, an aeronautical engineering graduate from Ohio State, entered the natural gas industry with the
Columbia Gas System in 1974. In 1976 he was later promoted to Operations Engineer at the Cove Point
LNG Receiving Terminal. Trunkline LNG Company recruited him in 1979 to set up the engineering
team for the Lake Charles LNG Receiving Terminal in Louisiana and direct the start-up of that facility.
In 1984, he proceeded into the end-user side of the natural gas industry, providing consulting and
technical services to a wide variety of industrial customers for Nalco Chemical Company. The restart on
the Everett Marine LNG Terminal in Boston in 1988 drew him back into the LNG industry where he
performed a variety of roles including project management, business development and technical support.
He is one of only three individuals in the country to have worked at three of the four LNG operating
receiving terminals in the United States. He left Distrigas in 1991 to form CH·IV Corporation. CH·IV
Corporation and MPR Associates of Alexandria, VA formed CH·IV International in early 2001.

As President of CH·IV International, Jeff has overseen a wide variety of international LNG-based projects
covering virtually all aspects of LNG facility design, safety, security, operations and construction.

Jeff has presented and/or authored over 50 articles, papers and publications pertaining to cryogenics,
LNG and LNG vehicles published in various trade journals and conference proceedings. He was featured
as the author of the “Cold Corner” in the “Natural Gas Fuels Magazine” from 1993 through 1996. Jeff
has been an invited speaker and participant in over 30 various U.S. and international LNG, natural gas
and alternative fuel vehicle conferences and trade shows.

Jeff is the author of “Introduction to LNG Safety,” a world-renown book explaining the properties of
LNG and how these properties impact personal and public safety.

Jeff holds U.S. Patents 5,549,142 and 5,582,218, both entitled “Dispensing System for Refueling
Transport Containers with Cryogenic Liquid.”

Memberships include National Fire Protection Association (NFPA) and the Cryogenic Society of
America. He is a member of the NFPA Technical Committee on Liquefied Natural Gas (NFPA 59A)
and a past member of the Gas Research Institute's Project Advisor Group for LNG Safety.

Jeff and his wife of 35 years, Cheri, have two grown children, Jason (29) and Amanda (25). The Beales
make their home in Maryland near Baltimore.

RPT-06903-01 Page 53 June 2006

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