[House Hearing, 110 Congress]
[From the U.S. Government Publishing Office]
SECURING LIQUEFIED NATURAL GAS TANKERS TO PROTECT THE HOMELAND
=======================================================================
FULL HEARING
of the
COMMITTEE ON HOMELAND SECURITY
HOUSE OF REPRESENTATIVES
ONE HUNDRED TENTH CONGRESS
FIRST SESSION
__________
MARCH 21, 2007
__________
Serial No. 110-19
__________
Printed for the use of the Committee on Homeland Security
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COMMITTEE ON HOMELAND SECURITY
BENNIE G. THOMPSON, Mississippi, Chairman
LORETTA SANCHEZ, California, PETER T. KING, New York
EDWARD J. MARKEY, Massachusetts LAMAR SMITH, Texas
NORMAN D. DICKS, Washington CHRISTOPHER SHAYS, Connecticut
JANE HARMAN, California MARK E. SOUDER, Indiana
PETER A. DeFAZIO, Oregon TOM DAVIS, Virginia
NITA M. LOWEY, New York DANIEL E. LUNGREN, California
ELEANOR HOLMES NORTON, District of MIKE ROGERS, Alabama
Columbia BOBBY JINDAL, Louisiana
ZOE LOFGREN, California DAVID G. REICHERT, Washington
SHEILA JACKSON LEE, Texas MICHAEL T. McCAUL, Texas
DONNA M. CHRISTENSEN, U.S. Virgin CHARLES W. DENT, Pennsylvania
Islands GINNY BROWN-WAITE, Florida
BOB ETHERIDGE, North Carolina MARSHA BLACKBURN, Tennessee
JAMES R. LANGEVIN, Rhode Island GUS M. BILIRAKIS, Florida
HENRY CUELLAR, Texas DAVID DAVIS, Tennessee
CHRISTOPHER P. CARNEY, Pennsylvania
YVETTE D. CLARKE, New York
AL GREEN, Texas
ED PERLMUTTER, Colorado
VACANCY
Jessica Herrera-Flanigan, Staff Director & General Counsel
Todd Gee, Chief Counsel
Michael Twinchek, Chief Clerk
Robert O'Connor, Minority Staff Director
(II)
C O N T E N T S
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Page
STATEMENTS
The Honorable Bennie G. Thompson, a Representative in Congress
From the State of Mississippi, and Chairman, Committee on
Homeland Security
Oral Statement................................................. 1
Prepared Sttement.............................................. 2
The Honorable Peter T. King, a Representative in Congress From
the State of New York, and Ranking Member, Committee on
Homeland Security.............................................. 2
The Honorable Gus M. Bilirakis, a Representative in Congress From
the State of Florida........................................... 42
The Honorable Christopher P. Carney, a Representative in Congress
From the State of Pennsylvania................................. 40
The Honorable Peter A. DeFazio, a Representative in Congress From
the State of Oregon............................................ 43
The Honorable Al Green, a Representative in Congress From the
State of Texas................................................. 67
The Honorable James R. Langevin, a Representative in Congress
From the State of Rhode Island................................. 35
The Honorable Sheila Jackson Lee, a Representative in Congress
From the State of Texas........................................ 46
The Honorable Christopher Shays, a Representative in Congress
From the State of Connecticut.................................. 37
Witnesses
Panel I
Mr. H. Keith Lesnick, Director, Office of Deepwater Port
Licensing, Maritime Administration, Department of
Transportation:
Oral Statement................................................. 15
Prepared Statement............................................. 17
Mr. J. Mark Robinson, Director, Office of Energy Projects,
Federal Energy Regulatory Commission:
Oral Statement................................................. 19
Prepared Statement............................................. 21
Rear Admiral Brian M. Salerno, Director, Inspection and
Compliance, U.S. Coast Guard, Department of Homeland Security:
Oral Statement................................................. 8
Prepared Statement............................................. 10
Mr. Jim Wells, Director, Energy, NRC, Natural Resources and
Environment, Government Accountability Office (GAO):
Oral Statement................................................. 3
Prepared Statement............................................. 5
Panel II
Mr. Ron Davis, President, Marine Engineers' Beneficial
Association:
Oral Statement................................................. 49
Prepared Statement............................................. 51
Phani Raj, PhD, President, Technology & Management Systems, Inc.:
Oral Statement................................................. 55
Prepared Statement............................................. 57
Appendixes
Appendix A: For the Record
The Honorable Bob Etheridge,Prepared Statement................. 77
Appendix B: Additional Questions and Responses
Responses from Mr. Ron Davis................................... 79
Responses submitted by Mr. Mark E. Gaffigan, Acting Director,
Natural Resources and Environment, Government Accounting
Office (GAO)................................................. 84
Responses from Phani Raj, PhD.................................. 87
Responses from Mr. J. Mark Robinson............................ 97
Responses from RADML Brian M. Salerno.......................... 99
SECURING LIQUEFIED NATURAL GAS TANKERS TO PROTECT THE HOMELAND
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Wendesday, March 21, 2007
U.S. House of Representatives,
Committee on Homeland Security,
Washington, DC.
The committee met, pursuant to call, at 11:21 a.m., in Room
311, Cannon House Office Building, Hon. Bennie Thompson
[chairman of the committee] presiding.
Present: Representatives Thompson, DeFazio, Jackson Lee,
Langevin, Carney, Green, King, Shays, Dent, Brown-Waite,
Bilirakis, McCarthy, and McCaul.
Chairman Thompson. [Presiding.] The Committee on Homeland
Security will come to order.
The committee is meeting today to receive testimony on
``Securing LNG Tankers to Protect the Homeland.''
Natural gas accounts for about one-fourth of all energy
consumed in the United States. The Department of Energy
predicts that the United States will have to increase imports
by 600 percent in the next 25 years to fulfill demand.
To meet this demand, energy companies have submitted 32
applications to build new terminals for importing liquid
natural gas in 10 states and five offshore areas. Today, there
are only five import terminals.
The dramatic increase in terminals will assist in meeting
the demand, but it will also increase the number of potential
terrorist targets. We must ensure that these new facilities and
tankers are adequately secured.
Many agencies within the administration have a role to play
in this endeavor. I look forward to hearing from our government
witnesses today of the steps each has taken to improve the
security of LNG transportation.
Additionally, the men and women who crew these tankers are
the critical eyes and ears of the system. I applaud the
Maritime Administrator's initiative in increasing the number of
U.S. mariners on LNG tankers.
I look forward to hearing more about how we can increase
U.S. presence on these tankers.
I am also interested in hearing from the Coast Guard about
the impact of increased amount of LNG traffic and what it will
have on it as an agency.
Coast Guard assets are aging by the day. I am concerned
about whether or not the Coast Guard has the assets to meet
this growing mission.
I recognize that Admiral Allen has set a course to fix the
Coast Guard's Deepwater program, but I want to know if this
course correction will occur before additional LNG facilities
come online.
Finally, I am interested in learning from the Government
Accountability Office about its recommendations to fix the
conflicting assessments of the specific consequences of an LNG
spill.
Mr. Wells's written testimony is correct. Access to
accurate information will play a critical role in developing
risk assessments for LNG placement decisions. The continued
absence of this information is troubling and must be
rectified.\1\
The chair now recognizes the ranking member of the full
committee, the gentleman from New York, Mr. King, for an
opening statement.
[The statement of Mr. Bennie G. Thompson follows:]
Prepared Statement of the Honorable Bennie G. Thompson, Chairman,
Committee on Homeland Security
Natural gas accounts for about one-fourth of all energy consumed in
the United States The Department of energy predicts that the United
States will have to increase imports by 600% in the next 25 years to
fulfill demands. To meet this demand, energy companies have submitted
32 applications to build new terminals for importing liquid natural gas
in 10 states and 5 offshore ares.
Today, there are only 5 import terminals. The dramatic increase in
terminals will assist in meeting the demand, but it will also increase
the number of potential terrorist targets. We must ensure these new
facilities and tankers are adequately secure.
Many agencies within the Administration have a role to play in this
endeavor. I look forward to hearing from our government witnesses today
of the steps each has taken to improve the security of LNG
transportation.
Additionally, the men and women who crew these tankers are the
crucial eyes and ears of the system. I applaud the Maritime
Administrator's initiative in increasing the number of U.S. mariners on
LNG tankers. I look forward to hearing more about how we can increase
U.S. presence to these.
Coast Guard assets are aging by the day, and I am concerned about
whether or not the Coast Guard has the assets to meet this growing
mission. I recognize that Admiral Allen has set a course to fix the
Coast Guards's Deepwater Program, but I want to know if this course
correction will occur before the additional LNG facilities come on
line.
Finally, I am very interested in learning from the Government
Accountability Office about its recommendations to fix the conflicting
assessments of the specific consequences of an LNG spill. Mr. Wells'
written testimony is correct--access to accurate information will play
a crucial role in developing risk assessments for LNG placement
decisions. The continued absence of this information is troubling and
must be rectified.
Mr. King. Thank you, Mr. Chairman. Thank you for yielding
me the time. Thank you for calling this hearing and also for
the closed session which we just had, which was also extremely
interesting and illuminating.
I basically concur with everything you said in your opening
statement.
The fact is the United States does consume more energy per
capita than any country in the world. We definitely will have
to make greater use of LNG. We definitely need more LNG
facilities in this country.
At the same time, the issue arises whether or not we are
able to secure those facilities, whether or not we have the
resources to secure them. What is being done to make sure that
there is security?
Certainly, near my own district there is the proposed
Broadwater facility, which of course is causing a considerable
amount of controversy.
So this is an issue which is going to be increasing many-
fold over the next 5 years, 10 years, 15 years, 20 years, and
to me, there is no doubt that we need the LNG. We have to be
increasing facilities.
But at the same time, we have to ensure that our government
is able to provide us with a level of security in the post-9/11
world in which we live.
So with that, I look forward to the testimony and yield
back the balance of my time.
Chairman Thompson. Thank you very much.
Other members of the committee are reminded that, under
committee rules, opening statements may be submitted for the
record.
I welcome our first panel of witnesses. Our first witness,
Mr. Jim Wells, is director of energy, natural resources
environment team of the GAO.
Our second witness, Real Admiral Salerno, assumed his
duties as director of inspections and compliance at the U.S.
Coast Guard headquarters in May of 2006.
Our third witness, Mr. Keith Lesnick, is the director of
the Office of Deepwater Port Licensing at the Maritime
Administration.
And our fourth witness is Mr. Mark Robinson, who is with
the Federal Energy Regulatory Commission and has been director
of the Office of Energy Projects since 2001.
Without objection, the witnesses' full statement will be
inserted in the record.
I now ask each witness to summarize his statement for 5
minutes, beginning with Mr. Wells.
STATEMENT OF JIM WELLS, DIRECTOR, ENERGY, NRC, NATURAL
RESOURCES AND ENVIRONMENT, GOVERNMENT ACCOUNTABILITY OFFICE
Mr. Wells. Thank you, Mr. Chairman, members of the
subcommittee.
We at GAO are pleased to discuss the results of our
released report on the public safety consequences of a
terrorist attack on a tanker carrying LNG.
As you know, there is a lot of consternation about how we
meet our increasing energy needs for natural gas at the same
time that we can ensure public safety and security.
The supply of natural gas, as you referenced, in the future
will be brought to us as LNG by tanker imports. Today we bring
in our ports about two tanker ships every 3 days.
Industry is asking to build new or expanded existing
terminals in 10 states and offshore. Going forward, this type
of tanker traffic will grow by over 400 percent.
My testimony at this hearing summarizes the results of one
of three GAO reports that this committee has asked for. A
classified report on maritime security was discussed this
morning in the closed briefing.
Our second report we are talking about today is a
summarization of existing research and the existing knowledge
on the consequences of an LNG spill.
Because some additional studies, research studies, are
classified, we will be issuing a separate classified report
with related findings at a later date.
The GAO report focuses on the effects on water and not on
land or at the shore facilities. GAO reviewed six unclassified
studies conducted since 9/11.
The GAO report summarizes their findings as they relate to
the heat impact of an LNG fire, the possible potential hazards
of a large LNG spill and the reported conclusions on explosion
potentials.
These studies were conducted for differing purposes, used
multiple scenarios, numerous assumptions, and relied heavily on
computer modeling, since no real LNG event or large-scale fire
has occurred to date.
While there is a general agreement on the type of effects
of an LNG spill, the results are different enough to create
conflicting assessments of specific consequences, creating
uncertainty for regulators and the public.
These results are not just academic. The Coast Guard, for
example, uses them to make risk-informed decisions on how to
adequately protect and assess the waterways used by these
tankers.
GAO went further and documented the opinions of 19 experts
from industry, academia, government, consultants and experts
with explosive and spills experience.
These experts generally agreed on the public safety impacts
of an LNG spill, but they did disagree on specific conclusions
of some government studies and suggested future research
priorities.
They agreed on three main points. The most likely public
safety impact of an LNG spill is the heat impact of a fire.
Explosions are not likely to occur in the wake of an LNG
spill unless the LNG vapors are in a confined area, and that
some of the hazards, such as freeze burns and asphyxiation, do
not pose a hazard to the public.
However, not all experts were in agreement with the
commonly used one to 1.25-mile proper heat zone hazard zone,
with about half believing this number was about right, and
others evenly split on whether the distance was too
conservative or not conservative enough.
Experts also did not agree with some of the government
conclusions that only three of the five LNG tanks on a tanker
would be involved in a cascading failure.
Finally, the experts suggested priorities to help guide
future research aimed at clarifying these uncertainties about
heat impact distances, cascading failures including large-scale
fire experiments, large-scale spill experiments on water, and
the potential for cascading failures of multiple LNG tanks.
Knowing that DOE has recently funded a 2-year study
involving large-scale LNG fire experiments addressing some, but
not all, of the research priorities that I have identified here
today, the experts and GAO have recommended that DOE consider
expanding the scope of its existing work.
In closing, Mr. Chairman, it is important to know the
public safety consequences of future LNG shipments. Access, as
you said, to accurate information is critical for the Coast
Guard, for FERC, for DHS as they make important decisions about
where and when and how to expand LNG facilities.
If the existing research underestimates, the public is
exposed to inappropriate risk. If the research overestimates,
we incur costly mitigation measures and we potentially lose the
availability of a critical, valuable energy resource going
forward.
DOE needs to go further. They need to prioritize the scope
of their future research. And they need to settle some of these
uncertainties.
I will stop here, Mr. Chairman. Thank you.
[The statement of Mr. Wells follows:]
Preppared Statement of Jim Wells
Mr. Chairman and Members of the Committee:
I am pleased to be here to discuss the results of our recently
released report on the public safety consequences of a terrorist attack
on a tanker carrying liquefied natural gas (LNG).\1\ As you know, LNG
is a supercooled liquid form of natural gas, which, if spilled, poses
potential hazards, such as fire, asphyxiation, and explosions. U.S.
imports of LNG, now about 3 percent of total U.S. natural gas supplies,
are projected to be about 17 percent of U.S. supplies by 2030. To meet
this increased demand, energy companies have submitted 32 applications
to federal regulators to build new terminals for importing LNG in 10
states and 5 offshore areas. Access to accurate information about the
consequences of LNG spills is crucial for developing risk assessments
for LNG siting decisions. Despite several recent modeling studies of
the consequences of potential LNG spills, uncertainties remain about
the risks such spills would pose to the public. One of these studies,
conducted by Sandia National Laboratories (Sandia) in 2004, is used by
the Coast Guard to assess the suitability of waterways for LNG tankers
traveling to proposed LNG facilities. In this context, DOE has recently
funded a new study that will conduct small--and large-scale LNG fire
experiments to refine and validate existing models that calculate how
heat from large LNG fires would affect the public.
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\1\ GAO, Maritime Security: Public Safety Consequences of a
Terrorist Attack on a Tanker Carrying Liquefied Natural Gas Need
Clarification, GAO-07-316 (Washington, D.C.: Feb. 22, 2007). This
report was prepared at the request of this Committee, the House
Committee on Energy and Commerce, and Representative Edward J. Markey.
---------------------------------------------------------------------------
My testimony today summarizes the results of our report.
Specifically, I will (1) describe the results of recent unclassified
studies on the consequences of an LNG spill and (2) identify the areas
of agreement and disagreement among experts concerning the consequences
of a terrorist attack on an LNG tanker. To address these issues, we
examined six unclassified studies of the consequences of LNG spills. We
also convened a Web-based panel of 19 experts to identify areas of
agreement and disagreement on LNG spill consequence issues. Because
some additional studies are classified, we will be issuing a separate
classified report with related findings at a later date.
Summary
The six unclassified studies we reviewed all examined the heat
impact of an LNG fire but produced varying results; some studies also
examined other potential hazards of a large LNG spill and reached
consistent conclusions on explosions. Specifically, the studies'
conclusions about the distance at which 30 seconds of exposure to the
heat could burn people--also termed the heat impact distance--ranged
from less than 1/3 of a mile to about 1-1/4 miles. These variations
occurred because, with no data on large spills from actual events,
researchers had to make numerous modeling assumptions to scale up the
existing experimental data for large LNG spills. These assumptions
involved the size of the hole in the tanker, the number of tanks that
fail, the volume of LNG spilled, key LNG fire properties, and
environmental conditions, such as wind and waves. Three of the studies
also examined other potential hazards of an LNG spill, including LNG
vapor explosions, asphyxiation, and the sequential failure of multiple
tanks on the LNG vessel (cascading failure). All three studies
considered LNG vapor explosions unlikely unless the vapors were in a
confined space. Only the Sandia study examined asphyxiation and
concluded that asphyxiation did not pose a hazard to the general
public. Finally, only the Sandia study examined the potential for
cascading failure of LNG tanks and concluded that only three of the
five tanks on a typical LNG vessel would be involved in such an event
and that this number of tanks would increase the duration of the LNG
fire.
Our panel of 19 experts generally agreed on the public safety
impact of an LNG spill, disagreed on specific conclusions of the Sandia
study, and suggested future research priorities. Experts agreed on
three main points: (1) the most likely public safety impact of an LNG
spill is the heat impact of a fire; (2) explosions are not likely to
occur in the wake of an LNG spill unless the LNG vapors are in confined
spaces; and (3) some hazards, such as freeze burns and asphyxiation, do
not pose a hazard to the public. However, the experts disagreed with a
few conclusions reached by the Sandia study that the Coast Guard uses
to assess the suitability of waterways for LNG tankers going to
proposed LNG terminals. Specifically, all experts did not agree with
the study's 1-mile estimate of heat impact distance resulting from an
LNG fire: 7 of 15 thought Sandia's distance was ``about right,'' 8 were
evenly split on whether the distance was ``too conservative'' or ``not
conservative enough,'' and 4 did not answer this question. Experts also
did not agree with the Sandia National Laboratories' conclusion that
only three of the five LNG tanks on a tanker would be involved in a
cascading failure. Finally, experts suggested priorities to guide
future research aimed at clarifying uncertainties about heat impact
distances and cascading failure, including large-scale fire
experiments, large-scale LNG spill experiments on water, the potential
for cascading failure of multiple LNG tanks, and improved modeling
techniques. DOE's recently funded study involving large-scale LNG fire
experiments addresses some, but not all, of the research priorities the
expert panel identified.
Background
As scientists and the public have noted, an LNG spill could pose
potential hazards. When LNG is spilled from a tanker, it forms a pool
of liquid on the water. As the liquid warms and changes into natural
gas, it forms a visible, foglike vapor cloud close to the water. The
cloud mixes with ambient air as it continues to warm up, and eventually
the natural gas disperses into the atmosphere. Under certain
atmospheric conditions, however, this cloud could drift into populated
areas before completely dispersing. Because an LNG vapor cloud
displaces the oxygen in the air, it could potentially asphyxiate people
who come into contact with it. Furthermore, like all natural gas, LNG
vapors can be flammable, depending on conditions. If the LNG vapor
cloud ignites, the resulting fire will burn back through the vapor
cloud toward the initial spill. It will continue to burn above the LNG
that has pooled on the surface--this is known as a pool fire. Small-
scale experiments to date have shown that LNG fires burn hotter than
oil fires of the same size. Both the cold temperatures of spilled LNG
and the high temperatures of an LNG fire have the potential to
significantly damage the tanker, causing a cascading failure. Such a
failure could increase the severity of the incident. Finally, concerns
have been raised about whether an explosion could result from an LNG
spill.
The Federal Energy Regulatory Commission is responsible for
approving applications for onshore LNG terminal sitings, and the U.S.
Coast Guard is responsible for approving applications for offshore
sitings. In addition, the Coast Guard reviews an applicant's Waterway
Suitability Assessment, reaches a preliminary conclusion on whether the
waterway is suitable for LNG imports, and identifies appropriate
strategies that reduce the risk posed by the movement of an LNG tanker.
Studies Identified Different Distances for the Heat Effects of an LNG
Fire, but Agreed on Other LNG Hazards
The six studies we examined identified various distances at which
the heat effects of an LNG fire could be hazardous to people. The
studies' results about the distance at which 30 seconds of exposure to
the heat could burn people ranged from less than 1/3 of a mile (about
500 meters) to about 1--1/4 miles (more than 2,000 meters). The
studies' variations in heat effects occurred because (1) different
assumptions were made in the studies? models about key parameters of
LNG spills and (2) the studies were designed and conducted for
different purposes. Since no large-scale data are available for LNG
spills, researchers made numerous modeling assumptions to scale up the
existing experimental data for large spills. Key assumptions made
included hole size and cascading failure, waves and wind, the volume of
LNG spilled, and the amount of heat radiated from the fire. For
example, studies made assumptions for the size of the hole in the LNG
tanker that varied from less than 1 square meter up to 20 square
meters. Additionally, the studies were conducted for different
purposes. Two studies were academic analyses of the differences between
LNG and oil spills; three specifically addressed spills caused by
terrorist attacks, which was a concern in the wake of the September 11
attacks; and the final study developed appropriate methods for
regulators to use to estimate heat hazards from LNG fires. Results of
these studies can be found in our report being released today.
Some studies also examined other potential hazards, such as
explosions, asphyxiation, and cascading failure, and identified their
potential impacts on public safety. Three studies examined the
potential for LNG vapor explosions, and all agreed that it is unlikely
that LNG vapors could explode if the vapors are in an unconfined space.
Only one study examined the potential for asphyxiation following an LNG
spill if the vapors displace the oxygen in the air. It concluded that
fire hazards would be the greatest problem in most locations, but that
asphyxiation could threaten the ship's crew, pilot boat crews, and
emergency response personnel. Finally, only the Sandia study examined
the potential for cascading failure of LNG tanks and concluded that
only three of the five tanks would be involved in such an event and
that this number of tanks would increase the duration of the LNG fire.
Experts Generally Agreed That the Most Likely Public Safety Impact of
an LNG Spill Is the Heat Effect of a Fire, but That Further Study Is
Needed to Clarify the Extent of This Effect
The 19 experts on our panel generally agreed on the public safety
impact of an LNG spill, disagreed with specific conclusions of the
Sandia study, and suggested future research priorities.\2\
Specifically:
---------------------------------------------------------------------------
\2\ We considered experts to be ``in agreement'' if more than 75
percent of them indicated that they completely agreed or generally
agreed with a given statement. Not all experts commented on every issue
discussed.
---------------------------------------------------------------------------
Experts agreed that the main hazard to the public from a
pool fire is the heat from the fire, but emphasized that the exact
hazard distance depends on site-specific weather conditions;
composition of the LNG (relative percentages of methane, propane, and
butane); and the size of the fire.
Eighteen of 19 experts agreed that the ignition of a vapor
cloud over a populated area could burn people and property in the
immediate vicinity of the fire. Three experts emphasized in their
comments that the vapor cloud is unlikely to penetrate very far into a
populated area before igniting.
With regard to explosions, experts distinguished between
explosions in confined spaces and in unconfined spaces. For confined
spaces, such as under a dock or between the hulls of a ship, they
agreed that it is possible, under controlled experimental conditions,
to induce explosions of LNG vapors; however, a detonation--the more
serious type of vapor cloud explosion--of confined LNG vapors is
unlikely following an LNG spill caused by a terrorist attack. For
unconfined spaces, experts were split on whether it is possible to
induce such explosions under controlled experimental conditions;
however, even experts who thought such explosions were possible agreed
that vapor cloud explosions in unconfined spaces are unlikely to occur
following an LNG spill caused by a terrorist attack.
Our panel of 19 experts disagreed with a few of the Sandia study's
conclusions and agreed with the study authors' perspective on risk-
based approaches to dealing with the hazards of potential LNG spills.
For example:
Seven of 15 experts thought Sandia's heat hazard distance
was ``about right,'' and the remaining 8 experts were evenly split as
to whether the distance was ``too conservative'' (i.e., larger than
needed to protect the public) or ``not conservative enough'' (i.e., too
small to protect the public). Officials at Sandia National Laboratories
and our panel of experts cautioned that the hazard distances presented
cannot be applied to all sites because of the importance of site-
specific factors. Additionally, two experts explained that there is no
``bright line'' for hazards--that is, 1,599 meters is not necessarily
``dangerous,'' and 1,601 meters is not necessarily ``safe.''
Nine of 15 experts agreed with Sandia's conclusion that
only three of the five LNG tanks on a tanker would be involved in
cascading failure. Five experts noted that the Sandia study did not
explain how it concluded that only three tanks would be involved in
cascading failure.
Finally, experts agreed with Sandia's conclusion that
consequence studies should be used to support comprehensive, risk-based
management and planning approaches for identifying, preventing, and
mitigating hazards from potential LNG spills.
The experts also suggested priorities for future research--some of
which are not fully addressed in DOE's ongoing LNG research--to clarify
uncertainties about heat impact distances and cascading failure. These
priorities include large-scale fire experiments, large-scale LNG spill
experiments on water, the potential for cascading failure of multiple
LNG tanks, and improved modeling techniques. As part of DOE's ongoing
research, Sandia plans to conduct large-scale LNG pool fire tests,
beginning with a pool size of 35 meters--the same size as the largest
test conducted to date. Sandia will validate the existing 35-meter data
and then conduct similar tests for pool sizes up to 100 meters. Of the
top 10 LNG research priorities the experts identified, only 3 have been
funded in the DOE study, and the second highest ranked priority,
cascading failure, was not funded. One expert noted that although the
consequences of cascading failure could be serious, because the extreme
cold of spilled LNG and the high heat of an LNG fire could damage the
tanker, there are virtually no data looking at how a tanker would be
affected by these temperatures.
Conclusions
It is likely that the United States will increasingly depend on LNG
to meet its demand for natural gas. Consequently, understanding and
resolving the uncertainties surrounding LNG spills is critical,
especially in deciding where to locate LNG facilities. While there is
general agreement on the types of effects of an LNG spill, the study
results have created what appears to be conflicting assessments of the
specific heat consequences of such a spill.
These assessments create uncertainty for regulators and the public.
Additional research to resolve some key areas of uncertainty could
benefit federal agencies responsible for making informed decisions when
approving LNG terminals and protecting existing terminals and tankers,
as well as providing reliable information to citizens concerned about
public safety.
To provide the most comprehensive and accurate information for
assessing the public safety risks posed by tankers transiting to
proposed LNG facilities, we recommended that the Secretary of Energy
ensure that DOE incorporates the key issues the expert panel
identified, particularly the potential for cascading failure, into its
current LNG study.
DOE concurred with our recommendation.
Mr. Chairman, this concludes my prepared statement. I would be
happy to respond to any questions that you or Members of the Committee
may have.
Chairman Thompson. Thank you very much, and we will
probably get back into that during the questions.
I now recognize Rear Admiral Salerno to summarize his
statement for 5 minutes.
STATEMENT OF REAR ADMIRAL BRIAN M. SALERNO, DIRECTOR,
INSPECTION AND COMPLIANCE, U.S. COAST GUARD, DEPARTMENT OF
HOMELAND SECURITY
Admiral Salerno. Good morning, Mr. Chairman and
distinguished members of the committee. I am Rear Admiral Brian
Salerno, director of inspections and compliance at Coast Guard
headquarters.
It is my pleasure to appear before you today to discuss the
Coast Guard's role in providing for the safety and security of
liquefied natural gas vessels and facilities and the recently
completed General Accountability Office reports on petroleum
and LNG tanker security.
In coordination with other federal agencies and state and
local stakeholders, the Coast Guard plays a major role in
ensuring all facets of marine transportation of LNG are
conducted safety and securely and that the risks associated
with the operation of LNG vessels, shoreside terminals, and
offshore deepwater ports are managed responsibly.
LNG vessels have an impressive safety record over the last
45 years. Since the inception of LNG shipping in 1959, there
have been over 40,000 LNG shipments around the world but very
few serious accidents, and those accidents which have occurred
have not resulted in a breach of cargo tanks.
LNG vessels and other vessels transporting liquefied
hazardous gases in bulk are built and inspected to the highest
engineering and safety standards as established in the
International Code for the Construction and Equipment of Ships
Carrying Liquefied Gases in Bulk, known more simply as the IGC
Code.
Today there are over 200 LNG foreign-flag vessels operating
worldwide. They are crewed by some of the most highly trained
officers and merchant seamen afloat.
In response to the terrorist attacks of 2001, the Maritime
Transportation Security Act of 2002 was enacted. It required a
robust maritime security regime for both vessels and
facilities.
These security requirements closely parallel the
International Ship and Port Facility Security Code, or ISPS.
Under ISPS, vessels in international service, including LNG
vessels, must have an international ship security certificate.
To achieve the international ship security certificate by
its flag state, the vessel must develop and implement a threat-
scalable security plan that, among other things, establishes
measures for access control, cargo handling and delivery of
ship stores, surveillance and monitoring, security
communications, as well as security incident procedures and
training and drill requirements.
Additionally, like all deep draft vessels calling in the
U.S., LNG vessel operators must provide the Coast Guard with a
96-hour advance notice of arrival and include information on
the vessel's last ports of call, crew identities and cargo
information.
That information is vetted to detect any concerns or
anomalies. The Coast Guard conducts pre-entry security
boardings of LNG vessels during which Coast Guard personnel
conduct security sweeps of the vessel and ensure it is under
control of proper authorities during its intended transit.
In order to protect the LNG tanker and other vessels
carrying especially hazardous cargoes from external attack,
these vessels are escorted by armed Coast Guard and other law
enforcement vessels through key port areas.
By acting as a deterrent against a potential attack against
the vessel, these escorts reduce the risk to nearby population
centers from the consequences of an attack.
Coast Guard efforts are often augmented by other government
agencies and the facility operators' private security forces,
which also conduct activities such as waterway patrols and
surveillance.
The combined efforts of federal, state, local and private
assets contribute to the overall local LNG port risk mitigation
plan.
The Federal Energy Regulatory Commission, FERC, has the
siting authority for shoreside LNG terminals. However, the
Coast Guard is a cooperating agency in the preparation of
FERC's environmental impact statement associated with the
siting of the facility.
Additionally, the local Coast Guard captain of the port
must assess and make a determination regarding the suitability
of the waterway for the proposed vessel transits, ensuring that
full consideration is given to the safety and security of the
port, the facility and vessels transporting LNG.
The process involves the local area Maritime Committee and
the Harbor Safety Committee and includes identification of the
mitigating measures to responsibly manage the safety and
security risks identified during the suitability assessment.
The assessment also includes an analysis of the optimal mix
of federal, state and local resources in addition to private
resources needed to implement any necessary risk mitigation
measures.
The Coast Guard continues to analyze resource allocation
and resource needs in light of the potential growth of the LNG
industry in the U.S.
This new work may be accommodated through reallocation of
existing resources, expanding the use of other government
agency and private security forces to conduct security
operations, or requesting new resources. All of these options
are under consideration.
It is important to note that there are other hazardous
cargoes that the Coast Guard regulates to ensure safety and
security. Moreover, there are 11 other missions for which the
Coast Guard is responsible to execute.
Our prevention and protection strategies are aimed at
ensuring the highest risk situations receive the highest level
of protection. This is an ongoing process.
As you are aware, the GAO recently concluded two reports.
One examined current security practices for energy commodity
tankers, including LNG, and the Coast Guard had extensive
interaction with GAO in the drafting of this report and has
formally concurred with all of GAO's recommendations.
The second report is a comprehensive review of the existing
LNG consequence studies. As DOE was the principal federal
agency interacting with GAO, the Coast Guard had minimal input
into this study.
However, we do agree that additional studies are needed to
further examine potential consequences of an LNG spill and
fire, particularly in the areas identified by the expert panel.
Thank you for the opportunity to discuss the Coast Guard's
role in LNG. I will be happy to answer any questions.
[The statement of Admiral Salerno follows:]
Prepared Statement of RADML Brian Salerno
Introduction
Good morning Mr. Chairman and distinguished members of the
Committee. I am Rear Admiral Brian Salerno, the Director of the
Inspection and Compliance Directorate at U.S. Coast Guard Headquarters.
It is my pleasure to appear before you today to discuss the Coast
Guard's role in providing for the safety and security of Liquefied
Natural Gas (LNG) vessels and facilities, and how the Coast Guard is
cooperating with other Federal Agencies on this important national
issue.
As the Federal Government's lead agency for Maritime Homeland
Security, the Coast Guard plays a major role in ensuring all facets of
marine transportation of LNG, including LNG vessels, shoreside
terminals and LNG deepwater ports, are operated safely and securely,
and that the risks associated with the marine transportation of LNG are
managed responsibly. Today, I will briefly review the applicable laws
and regulations that provide our authority and the requirements for the
safe and secure operation of the vessels, shoreside terminals and
deepwater ports. I will also describe how the Coast Guard is working
with the other Federal entities here today, as fellow stakeholders in
LNG safety and security.
LNG Vessel Safety
The Coast Guard has long recognized the unique safety and security
challenges posed by transporting millions of gallons of LNG or
``cryogenic methane.'' LNG vessels have had an enviable safety record
over the last 45 years. Since international commercial LNG shipping
began in 1959, tankers have carried over 40,000 LNG shipments and while
there have been some serious accidents at sea or in port, there has
never been a breach of a ship's cargo tanks. Insurance records and
industry sources show that there were approximately 30 LNG tanker
safety incidents (e.g. leaks, groundings or collisions) through 2002.
Of these incidents, 12 involved small LNG spills which caused some
freezing damage but did not ignite. Two incidents caused small vapor
vent fires which were quickly extinguished.
Today, there are over 200 LNG vessels operating worldwide and
another 100 or so under construction. While there are no longer any US
flag LNG vessels, all LNG vessels calling in the U.S. must comply with
certain domestic regulations in addition to international requirements.
Our domestic regulations for LNG vessels were developed in the 1970s
under the authority of the various vessel inspection statutes now
codified in Title 46 United States Code. Relevant laws providing the
genesis for LNG vessel regulation include the Tank Vessel Act (46
U.S.C. 391a) and the Ports and Waterways Safety Act of 1972, as amended
by the Port and Tanker Safety Act of 1978 (33 U.S.C. 1221, et. seq).
Regulations located in Title 46, Code of Federal Regulations (CFR) Part
154, ``Safety Standards for Self-Propelled Vessels Carrying Bulk
Liquefied Gasses,'' specify requirements for the vessel's design,
construction, equipment and operation. Our domestic regulations closely
parallel the applicable international requirements, but are more
stringent in the following areas: The requirements for enhanced grades
of steel for crack arresting purposes in certain areas of the hull,
specification of higher allowable stress factors for certain
independent type tanks and prohibiting the use of cargo venting as a
means of cargo temperature or pressure control.
All LNG vessels in international service must comply with the major
maritime treaties agreed to by the International Maritime Organization
(IMO), such as the International Convention for the Safety of Life at
Sea, popularly known as the ``SOLAS Convention'' and the International
Convention for the Prevention of Pollution from Ships, popularly known
as the ``MARPOL Convention.'' An addition, LNG vessels must comply with
the International Code for the Construction and Equipment of Ships
Carrying Liquefied Gases in Bulk, known as the ``IGC Code.''
Before being allowed to trade in the United States, operators of
foreign flag LNG carriers must submit detailed vessel plans and other
information to the Coast Guard's Marine Safety Center (MSC) to
establish that the vessels have been constructed to the higher
standards required by our domestic regulations. Upon the MSC's
satisfactory plan review and on-site verification by Coast Guard marine
inspectors, the vessel is issued a Certificate of Compliance. This
indicates that it has been found in compliance with applicable design,
construction and outfitting requirements.
The Certificate of Compliance is valid for a two-year period,
subject to an annual examination by Coast Guard marine inspectors, who
verify that the vessel remains in compliance with all applicable
requirements. As required by 46 U.S.C. 3714, this annual examination is
required of all tank vessels, including LNG carriers.
LNG Vessel Security
In addition to undergoing a much more rigorous and frequent
examination of key operating and safety systems, LNG vessels are
subject to additional measures of security when compared to crude oil
tankers, as an example. Many of the special safety and security
precautions the Coast Guard has long established for LNG vessels
derived from our analysis of ``conventional'' navigation safety risks
such as groundings, collisions, propulsion or steering system failures.
These precautions pre-dated the September 11, 2001 tragedy, and include
such measures as special vessel traffic control measures that are
implemented when an LNG vessel is transiting the port or its
approaches, safety zones around the vessel to prevent other vessels
from approaching nearby, escorts by Coast Guard patrol craft and, as
local conditions warrant, coordination with other Federal, state and
local transportation, law enforcement and/or emergency management
agencies to reduce the risks to, or minimize the interference from
other port area infrastructure or activities. These activities are
conducted under the authority of existing port safety and security
statutes, such as the Magnuson Act (50 U.S.C. 191 et. seq.) and the
Ports and Waterways Safety Act, as amended.
Since September 11, 2001, additional security measures have been
implemented, including the requirement that all vessels calling in the
U.S. must provide the Coast Guard with a 96-hour advance notice of
arrival (increased from 24 hours advance notice pre-9/11). This notice
includes information on the vessel's last ports of call, crew
identities and cargo information. In addition, the Coast Guard now
regularly boards LNG vessels at-sea, where Coast Guard personnel
conduct special ``security sweeps'' of the vessel and ensure it is
under the control of proper authorities during its port transit. In
order to protect the vessel from external attack, LNG vessels are
escorted through key port areas. These armed escorts afford protection
to the nearby population centers by reducing the probability of a
successful attack against an LNG vessel. These actions are in addition
to the safety and security oriented boardings previously described.
Of course, one of the most important post-9/11 maritime security
improvements has been the passage of the Maritime Transportation
Security Act of 2002 (MTSA). Under the authority of MTSA, the Coast
Guard developed a comprehensive new body of security measures
applicable to vessels, marine facilities and maritime personnel. Our
domestic maritime security regime is closely aligned with the
International Ship and Port Facility Security (ISPS) Code. The ISPS
Code, a mandatory requirement of the SOLAS Convention, was adopted at
the IMO in December 2002 and came into effect on July 1st 2004. Under
the ISPS Code, vessels in international service, including LNG vessels,
must have an International Ship Security Certificate (ISSC). To be
issued an ISSC by its flag state, the vessel must develop and implement
a threat-scalable security plan that, among other things, establishes
access control measures, security measures for cargo handling and
delivery of ships stores, surveillance and monitoring, security
communications, security incident procedures, and training and drill
requirements. The plan must also identify a Ship Security Officer who
is responsible for ensuring compliance with the ship's security plan.
The Coast Guard rigorously enforces this international requirement by
evaluating security compliance as part of our ongoing port state
control program.
Shoreside LNG Terminal Safety and Security
Presently there are six shoreside LNG terminals in the U.S. and
U.S. Territories: the export facility in Kenai, AK; and, import
terminals in Everett, MA; Cove Point, MD; Elba Island, GA; Lake
Charles, LA; and Penuelas, PR. Under Title 33, CFR Part 127, the Coast
Guard has responsibility for the facility's waterside ``marine transfer
area'' and the Department of Transportation's Pipeline and Hazardous
Materials Safety Administration has responsibility for shoreside
portion of the facility. The safety requirements regulated by the Coast
Guard in the marine transfer area include electrical power systems,
lighting, communications, transfer hoses and piping systems, gas
detection systems and alarms, firefighting equipment, and operational
matters such as approval of the terminal's Operations and Emergency
Manuals and personnel training.
The recently promulgated ``Maritime Security Regulations for
Facilities,'' found in Title 33 CFR Part 105, were developed under the
authority of MTSA. These regulations require the LNG terminal operator
to conduct a facility security assessment and develop a threat-scalable
security plan that addresses the risks identified in the assessment.
Much like the requirements prescribed for vessels, the facility
security plan establishes access control measures, security measures
for cargo handling and delivery of supplies, surveillance and
monitoring, security communications, security incident procedures and
training and drill requirements. The plan must also identify a Facility
Security Officer who is responsible for ensuring compliance with the
facility security plan. The six existing U.S. LNG terminals were
required to submit their security plans to the Coast Guard for review
and approval in 2003 and full implementation of the plans was required
by July 1, 2004. These reviews have been completed, and the terminals'
compliance with the plans has been verified by local Coast Guard port
security personnel through on-site examinations. In contrast to our
safety responsibility, whereby our authority is limited to the ``marine
transfer area,'' our authority regarding the security plan can,
depending upon the particular layout of the terminal, encompass the
entire facility.
Shoreside LNG Terminal Siting
The issue of constructing new shoreside LNG terminals has been
controversial, due in large part to public concerns over both perceived
and actual risks to the safety and security of LNG vessel operations.
Under the Natural Gas Act, the Federal Energy Regulatory Commission
(FERC) has permitting authority, including safety review of facility
siting, for LNG terminals onshore and within state waters. The Coast
Guard is not involved in any aspect of determining or approving the
shoreside facility's location.
However, the Coast Guard plays an important role in the siting
process once it has begun. Along with an application to the FERC, an
owner or operator who intends to build a new shoreside LNG facility, or
who plans new construction on an existing facility, must submit a
``Letter of Intent'' to the Coast Guard Captain of the Port (COTP) in
whose zone the facility is located (in accordance with by 33 CFR
127.007). This letter must provide information on: the physical
location of the facility; a description of the facility; the
characteristics of the vessels intended to visit the facility and the
frequency of visits; and, charts that show waterway channels and
identify commercial, industrial, environmentally sensitive and
residential areas in and adjacent to the waterway to be used by vessels
enroute to the facility, within 15.5 miles of the facility.
The COTP reviews the information provided by the applicant and
makes a determination on the suitability of the waterway for LNG
vessels. Factors considered include: density and characteristics of
marine traffic in the waterway; locks, bridges or other man made
obstructions in the waterway; the hydrologic features of the waterway,
e.g., water depth, channel width, currents and tides, natural hazards
such as reefs and sand bars; and underwater pipelines and cables. If
the waterway is found suitable and after the Coast Guard meets all of
its National Environmental Policy Act (NEPA) requirements, the COTP
will issue a Letter of Recommendation (per 33 CFR 127.009).
Both the Coast Guard and the FERC recognize that the ``Letter of
Recommendation'' process, which dates from 1988, does not, in its
current form, adequately take into account the security concerns of our
post 9/11 environment. Also, the existing regulations are focused
primarily on conventional navigation safety risk management issues such
as traffic density, hydrologic characteristics of the waterway, etc.
They do not focus on port security risk management issues, and in
particular, they do not directly require an analysis of the
consequences of an LNG spill on the waterway proposed for vessel
transits.
To address this problem, on February 10, 2004, the Coast Guard
entered into an Inter-Agency Agreement (IAA) with FERC and RSPA to work
in a coordinated manner to address issues regarding safety and security
at shoreside LNG facilities, including terminal facilities and tanker
operations, to work together, avoid duplication of effort, and to
maximize the exchange of relevant information related to the safety and
security aspects of LNG facilities and the related maritime concerns.
Soon after the completion of the IAA, work began on a more detailed
guidance document for use by the involved agencies. On 14 Jun 05, the
Navigation and Vessel Inspection Circular (NVIC) 05-05, Guidelines on
Assessing the Suitability of a Waterway for LNG Marine Traffic, was
published to provide guidance on how to conduct and validate a Waterway
Suitability Assessment so that full consideration is given to the
safety and security of the port, the facility, and vessels transporting
the LNG. Simply put, it established a uniform national process for
conducting port-specific risk and waterway suitability assessments.
Under the NVIC 05-05 guidelines, since the Coast Guard is also a
cooperating agency for the preparation of the FERC's Environmental
Impact Statement, this guidance assists the Coast Guard in obtaining
all information needed to assess the proposed LNG marine operations and
fulfill its commitment to FERC to provide input to their Environmental
Impact Statement (EIS). Once completed, the Coast Guard can adopt
FERC's EIS to meet its NEPA obligations associated with the subsequent
issuance of the COTP Letter of Recommendation.
The Waterway Suitability Assessment (WSA) process put forth in the
NVIC uses a risk management approach to developing mitigation measures
for the hazards introduced to the affected waterway due to the nature
of LNG. The NVIC requires the applicant to conduct a risk analysis of
the waterway and propose mitigating measures. In addition, the
applicant is required to do an analysis of the resources necessary to
perform the proposed mitigation measures. This WSA process usually
begins very early in the process, typically during the FERC's pre-
filing period.
In addition to an evaluation of conventional navigation safety
risks, a critical part of the WSA is an analysis of an LNG spill on the
waterway and the thermal effects from a resulting pool fire. The
analysis includes the application of the hazard distances and zones of
concern established by the spill consequence models described in the
2004 Sandia National Labs Report.
Once the WSA is completed by the applicant, it is submitted to the
Coast Guard and reviewed and validated by key stakeholders at the port,
such as the Area Maritime Security Committee and the Harbor Safety
Committee, and other local port stakeholders. In previous cases, there
have even been public meetings and workshops during the development and
validation of the WSA and the public is encouraged to provide comments.
When the Coast Guard's WSA validation process is complete, the COTP
makes a preliminary determination regarding the suitability of the
waterway, whether the waterway can accommodate the proposed traffic and
whether there is sufficient capability within the port community to
responsibly manage the safety and security risks of the project. This
preliminary determination is communicated to the FERC in a Waterway
Suitability Report (WSR).
The WSR report conveys the assessment and analysis conducted by the
applicant during the WSA process and it usually includes risk
mitigation measures that the COTP determines is necessary for the
vessel to safely and securely transit to the proposed facility. Once
FERC receives the WSR, the report is incorporated into the EIS. FERC
addresses the environmental impacts of the proposed vessel transits on
the waterway, the environmental impacts of the proposed risk mitigation
measures and the public safety and environmental impacts of a LNG spill
and fire on the waterway.
Once the FERC's EIS is published, it is subsequently reviewed by
the Coast Guard's environmental specialists. If it is acceptable and
meets all of the Coast Guard's NEPA requirements, the Coast Guard
issues a Record of Decision that adopts the EIS for our Letter of
Recommendation process.
Upon completion of the Record of Decision, the COTP issues a
``Letter of Recommendation'' to the owner or operator of the proposed
facility, and to the state and local government agencies having
jurisdiction, as to the suitability of the waterway for the proposal
(33 CFR 127.009).
The Coast Guard is also working on the regulatory changes in 33 CFR
Part 127 necessary to bring the existing ``Letter of Intent'' and
``Letter of Recommendation'' regulations up to date, specifically by
requiring the waterways management information to be submitted to the
COTP at the time of FERC ``pre-filing'' or conventional application,
and adding specific requirements for a port security assessment, in
addition to the waterways management information, to be presented to
the COTP for evaluation.
LNG Deepwater Ports: Authority and Agency Relationships
The Coast Guard's authority to regulate Deepwater Ports (DWPs)
derives from the Deepwater Port Act of 1974 (DWPA). The regulations
pertaining to the licensing, design, equipment and operation of DWPs
are found in Title 33 CFR Subchapter NN (Parts 148, 149 and 150).
Originally pertaining only to oil, MTSA amended the DWPA to include
natural gas. This Act allows for the licensing of DWPs in the Exclusive
Economic Zone, outside of state waters, along all maritime coasts of
the United States. The Secretary of the Department of Homeland Security
(DHS) and the Secretary of DOT delegated the processing of DWP
applications to the Coast Guard and the Maritime Administration
(MARAD), respectively. MARAD is the license issuing authority and works
in concert with the Coast Guard in developing the Environmental Impact
Statement, while the Coast Guard has primary jurisdiction over design,
equipment and operations and security requirements.The DWPA established
a specific time frame of 330 days from the date of publication of a
Federal Register notice of a ``complete'' application to the date of
approval or denial of a DWP license. Among other requirements, an
applicant for a DWP license must demonstrate consistency with the
Coastal Zone Management Plan of the adjacent coastal States.
The Coast Guard and MARAD, in cooperation with other Federal
agencies, must comply with the requirements of the National
Environmental Policy Act in processing DWP applications within the
timeframes prescribed in the Deepwater Port Act. To date the Coast
Guard has received a total of 15 DWP applications, including four that
have already been licensed: Louisiana Offshore Oil Platform, Chevron-
Texaco's Port Pelican project, Excelerate Energy's Gulf Gateway
project, and Shell's Gulf Landing. Recently, the Maritime Administrator
has issued Records of Decisions for three others: Freeport
McMoRan's Main Pass Energy Hub, Suez's Neptune project and
Excelerate Energy's Northeast Gateway. The latter two are off the coast
of Massachusetts and the others are all offshore of Louisiana. Only the
Gulf Gateway has been built so far. Three have been withdrawn and six
others are in various stages of processing. We are anticipating between
two and four additional applications within the next several months.
To expedite the application review process, and more efficiently
coordinate the activities of the numerous stakeholder agencies, the
Coast Guard entered into a Memorandum of Understanding (MOU), involving
more than a dozen agencies, including FERC, NOAA, the Army Corps of
Engineers and the Environmental Protection Agency.The MOU obliges the
participating agencies to work with each other and with other entities
as appropriate, to ensure that timely decisions are made and that the
responsibilities of each agency are me these responsibilities include:
assessing their particular role in the environmental review of DWP
licenses; meeting with prospective applicants and other agency
representatives to identify areas of potential concern and to assess
the need for and availability of agency resources to address issues
related to the proposed project.
LNG Deepwater Ports Safety and Security
While conventional crude oil DWPs have been in operation around the
world for many years, LNG DWPs are an emerging concept. Currently,
there is only one in operation, off the coast of Texas. There are a
variety of different designs under development that borrow from designs
and technology that have been time-tested in the offshore energy and
the LNG industries. Proposals include ship-shaped hull designs similar
to existing Floating Production, Storage and Offloading (FPSO) units,
platform based storage and regasification units, gravity based
structures, and innovative docking structures that attach directly to
the LNG carrier to serve as both a mooring and offloading system.
Because this is a new concept, the Coast Guard's regulations apply a
``design basis approach, rather than mandate a series of prescriptive
requirements. Under a ``design basis'' approach, each concept is
evaluated on its own technical merits, using relevant engineering
standards and concepts that have been approved by recognized vessel
classification societies and other competent industrial and technical
bodies. In addition, the Coast Guard's DWP regulations require that all
LNG DWPs develop and implement a security plan that, at a minimum, will
addresses the key security plan elements provided in Title 33 CFR Part
106, ``Maritime Security: Outer Continental Shelf Facilities.'' A risk
and consequence analysis is completed as part of the risk mitigation
strategy and security measures are developed between the applicant and
the Coast Guard local Captain of the Port.
Thank you for giving me this opportunity to discuss the Coast
Guard's role in LNG safety and security and our relationships with
other stakeholder agencies. I will be happy to answer any questions you
may have.
Chairman Thompson. Thank you, Admiral.
The next witness is Mr. Lesnick, to summarize his statement
for 5 minutes.
STATEMENT OF H. KEITH LESNICK, DIRECTOR, OFFICE OF DEEPWATER
PORT LICENSING, MARITIME ADMINISTRATION, DEPARTMENT OF
TRANSPORTATION
Mr. Lesnick. Good morning, Mr. Chairman and members of the
committee.
I am pleased to have the opportunity to testify before you
today to discuss the dramatic growth in U.S. liquefied natural
gas imports, the deepwater port licensing program, and plans to
increase the employment of U.S. mariners within this highly
specialized and vital energy sector.
While worldwide natural gas is in plentiful supply, the
United States holds less than 4 percent of world reserves. And
by the year 2025 our LNG imports are projected to increase
eightfold.
And today, the United States finds itself competing in a
global market for our energy resources. Advances in vessel
size, technologies, and the rapid expansion of the worldwide
LNG fleet have made importing energy more efficient, cost-
effective and available to emerging worldwide markets.
The Maritime Administration, by delegation from the
secretary of transportation, is the lead federal agency for
licensing offshore LNG and oil terminals.
In processing deepwater port license applications, the
Maritime Administration works in concert with the U.S. Coast
Guard and numerous federal, state and local agencies.
At the conclusion of the applicant's review process, the
Maritime Administration issues a record decision approving or
denying a deepwater port license.
To date, 15 LNG deepwater port applications have been filed
and six projects have been approved. When ultimately
constructed and operating, they will all represent over one-
fourth of the nation's total gas capacity.
The deepwater port mandates the expedited licensing of
deepwater oil and LNG terminals seaward of U.S. territorial
waters.
And while this program has made significant progress,
numerous logistical hurdles remain to the timely construction
of offshore LNG-receiving facilities that will be required to
meet our growing energy needs.
For example, local opposition to the construction of LNG
terminals is growing, compounding the already difficult task of
locating suitable gas-receiving sites.
We are working to overcome these obstacles and meet
congressional directives that clearly mandate the increased
U.S. involvement in the safe and efficient transportation of
LNG to our nation's shores.
In 2006 Congress amended the Deepwater Port Act and
directed the secretary of transportation to develop and
implement a program to promote the transportation of LNG to the
United States on U.S.-flag vessels and give top priority to
applications that use U.S.-flag vessels in their operations.
The act also requires that applicants provide the nation of
registry for and the citizenship of officers and crews serving
on vessels transporting LNG to U.S. deepwater ports.
In response to these legislative directives, the Maritime
Administration developed a voluntary deepwater port manning
program to promote the utilization of U.S. seafarers and
accommodate the forecasted international LNG manning shortfall.
We are already seeing results. Last December, the Maritime
Administration announced an innovative public-private U.S.
crewing partnership with Suez Energy, the first official
partnership of this kind within the international LNG industry.
Since that time, three additional companies have
voluntarily joined this initiative. These agreements represent
sound public policy, increased safety, security, improved
transportation efficiencies, and provide vital training and
employment opportunities for U.S. mariners in the LNG industry.
By the year 2010 the global LNG carrier fleet is expected
to grow by over 200 vessels. This expanded fleet will require
as many as 10,000 additional seafarers and offer tremendous
employment opportunities for U.S. mariners.
However, if we do not act quickly, the magnitude of this
shortage may negatively impact the LNG industry's excellent
safety record.
To alleviate this growing worldwide manpower shortage, we
have engaged the nation's maritime industry in an effort to
ensure a reliable supply of U.S. citizen mariners for LNG
service.
We are working with the U.S. Merchant Marine Academy, state
maritime academies and other training facilities to develop and
expand innovative LNG educational programs.
Our specific goal is to provide immediate training and
employment for U.S. citizens in the LNG tanker fleet.
The licensing of deepwater ports also contributes to the
Department of Transportation's strategic goal of improved
mobility and reduced congestion by limiting the number of mega-
LNG tankers entering our nation's port facilities.
Clearly, the construction of deepwater port terminals
enhances transportation safety and security by isolating
terminals away from congested land-based port facilities.
And finally, the maritime administrator is required to
consider the national interest in the issuance of a deepwater
port license.
My agency considers the safe, secure and efficient
transportation of an environmentally friendly source of energy
vital to the nation's interest.
We are proud of the deepwater port licensing program and
our efforts to encourage the employment of qualified U.S.
citizens. And I will be happy to respond to any questions that
you might have.
[The statement of Mr. Lesnick follows:]
Prepared Statement of H. Keith Lesnick
Good Morning, Mr. Chairman and Members of the Committee. I am
pleased to have the opportunity to testify before you today and to
discuss the dramatic growth in U.S. Liquefied Natural Gas (LNG)
imports, the deepwater licensing program, and the Department of
Transportation and the Maritime Administration's plans to increase the
employment of U.S. mariners within this highly specialized and vital
energy sector.
While worldwide natural gas is in plentiful supply, the United
States holds less than 4 percent of world reserves. During 2006, about
84 percent of all natural gas consumed in the United States was
domestically produced. By the year 2025, as demand increases, domestic
production is only expected to account for 79 percent of consumption.
To accommodate this shortfall, LNG imports are projected to increase
eight-fold to 4.4 trillion cubic feet per year.
Importing LNG will serve to relieve the Nation's growing energy
needs by diversifying energy sources. Deepwater ports are necessary to
enhance the Nation's ability to import LNG from world wide sources. The
Energy Information Administration's recently released Annual Energy
Outlook 2007 states U.S. energy consumption projected for the year 2025
will be about 23 percent higher than it was in 2006.
As a consequence, the United States finds itself in a situation
unlike any we have experienced before. There is strong international
competition from China, Japan, and Korea for energy resources. Advances
in vessel size to transport oil and LNG, the number of LNG carriers,
and advances in LNG transfer technology have made importing energy ever
more efficient and cost effective.
Numerous logistical hurdles remain, however. Local opposition to
the construction of LNG terminals is growing, compounding the already
difficult task of locating suitable gas receiving sites. At present,
the continental United States has 5 operational LNG import terminals--1
is a deepwater port located 116 miles off the coast of Louisiana. The
combined capacity of the five terminals is equal to six percent of the
Nation's gas consumption. Clearly, the Nation's growing need for
imported natural gas necessitates greater investment in the
infrastructure required to accommodate energy needs. As such, the
Maritime Administration's Deepwater Port licensing program is designed
to facilitate the licensing, construction, and operation of deepwater
oil and LNG terminals located seaward of U.S. territorial waters.
In 2002, the Deepwater Port Act was amended to expand the Secretary
of Transportation's existing authority to include authority to issue
licenses for offshore natural gas terminals. (The permitting of LNG
facilities onshore and in state waters remain under the jurisdiction of
the Federal Energy Regulatory Commission.) The Maritime Administration,
by delegation from the Secretary of Transportation, is the lead federal
agency for licensing offshore LNG and oil terminals. The Secretary of
Transportation delegated authority over ``pipeline maters'' to the
Pipeline and Hazardous Materials Safety Administration. In processing
of Deepwater Port license applications, the Maritime Administration
works in concert with the U.S. Coast Guard, numerous federal agencies,
and state and local governments. At the conclusion of the application's
environmental review process, the Maritime Administration makes a final
license approval determination through the issuance of a Record of
Decision. The Record of Decision incorporates the reasons behind the
Maritime Administration's decision to issue or deny a license. The
Record of Decision also enumerates the various conditions of licensure
that govern the operation of the deepwater port facility.
To date, 15 LNG Deepwater Port applications have been filed and 4
licenses have been issued. If all applications under consideration by
the Maritime Administration were constructed and operating at full
capacity, they would represent over a quarter of the Nation's total gas
capacity.
Congress amended the Deepwater Port Act through the Coast Guard and
Maritime Transportation Act of 2006, to direct the Secretary of
Transportation to develop and implement a program to promote the
transportation of LNG to the United States on U.S.-flag vessels. The
Act further directed the Secretary to give top priority to applications
that use U.S.-flag vessels in their operations. The Act also requires
that applicants provide the nation of registry for, and the citizenship
of officers and crew members serving on vessels transporting LNG to
U.S. deepwater ports. The Maritime Administration interprets this
requirement to include those international LNG tankers providing gas to
the deepwater facilities licensed by the Agency.
Therefore, in responding to these legislative directives, the
Maritime Administration is in the process of developing a voluntary
deepwater port manning program to encourage employing highly trained
and skilled U.S. mariners to meet the current and forecasted demand for
professional mariners in the international LNG shipping industry.
We are already seeing results from our efforts. Last December, the
Maritime Administration announced an innovative public-private
partnership with SUEZ Energy--the first official partnership of its
kind within the international LNG industry. Under this agreement, SUEZ
will provide training and employment opportunities for U.S. citizen
officers, cadets, and unlicensed mariners aboard their tanker fleet and
at both of their planned deepwater port terminals off the coasts of
Boston and Florida. Additionally, Excelerate Energy has entered into a
similar agreement for the Northeast Gateway deepwater port facility in
Massachusetts Bay and for its existing facility in the Gulf of Mexico.
In January 2007, a Louisiana-based applicant, Freeport-McMoRan Energy,
also committed to work with the Maritime Administration to develop
programs to train and employ U.S. mariners on LNG vessels servicing
their Main Pass Energy Hub facility being planned off the coast of
Louisiana.
These agreements represent sound public policy--increased safety,
security, and improved transportation efficiencies--and they open up
vital training and employment opportunities for U.S. mariners in the
LNG industry. The Maritime Administration intends to continue to reach
similar voluntary agreements with our pending and future deepwater port
applicants and all energy companies serving the Nation's international
maritime markets.
It is estimated that as many as 3,700 to 5,000 additional mariners
may be needed by next year. The magnitude of this manpower shortage
will only serve to negatively impact this industry's excellent safety
record. Over the last 5 years the global LNG carrier fleet grew by 73
percent, from 128 to 222 vessels. And, an additional 133 LNG vessels
are scheduled for delivery to service the global LNG trades by 2010.
This expanded fleet will require as many as 10,000 additional
seafarers, of whom almost 3,000 will be licensed officers--and, offers
tremendous employment opportunities for both licensed and unlicensed
U.S. mariners. This dramatic increase also comes at a time when we are
already experiencing a greater demand for seafarers in general due to a
dramatic increase in international trade.
The worldwide LNG tanker fleet currently lacks a single U.S.-flag
vessel. As a direct result, few U.S. mariners have the opportunity to
gain vital hands-on experience in this growing industry. Clearly, the
lack of U.S.-flag LNG tankers translates into a lack of job
opportunities for U.S. citizens. It is the Maritime Administration's
goal to help correct this situation and provide U.S. mariners
opportunities in an industry vital to our energy and security needs.
The Maritime Administration strives to ensure a reliable supply of
U.S. citizen mariners to serve on LNG vessels calling at U.S. energy
receiving facilities. The Agency is working with the U.S. Merchant
Marine Academy, state maritime academies, and other training facilities
to develop and expand innovative educational programs. Specifically,
the goal is to provide immediate employment for entry level mariners,
both licensed and unlicensed, into the LNG industry upon graduation and
courses for the retraining and/or recertifying of current mariners who
are sailing on vessels other than LNG--permitting them to transition
into LNG service.
Ultimately, employing highly trained and skilled licensed U.S.
mariners will help alleviate the growing worldwide shortage of
professional mariners confronting the international LNG shipping
industry. It will also serve to help maintain the industry's excellent
safety record by maintaining the LNG officer pool. U.S. mariners are
highly skilled in the operation of steam plants used on the majority of
LNG vessels and are experts in operating other marine main propulsion
systems, such as diesel, diesel electric, and gas turbines. In
addition, America's maritime officers unions continue to train their
members to the highest industry standards in LNG technologies.
It is also important to note that from an economic and competitive
perspective, the growing worldwide shortage of trained and qualified
LNG ships' officers has created an opportunity for U.S. officers to
work aboard foreign-flag LNG vessels. International vessel operators
are dramatically increasing the wages and benefits offered to foreign
officers to keep or attract their services, thus narrowing the gap
between the wages and benefits paid to Americans and those paid to
their foreign counterparts.
The licensing of deepwater ports also contributes to the Department
of Transportation's strategic goal of improved mobility and reduced
congestion by limiting the number of mega LNG tankers entering our
Nation's port facilities. The construction of deepwater port terminals
enhances transportation safety by isolating terminals away from
congested population areas.
The Maritime Administrator is required to consider the national
interests in the issuance of a deepwater port license. The Maritime
Administration considers the safe, secure, and efficient importation of
an environmentally friendly source of energy vital to the Nation's
economic growth.
We are proud of the Deepwater Ports Licensing Program and our
efforts to encourage employing qualified U.S. citizens to work aboard
the vessels serving the energy sector.
I want to thank the Members of the Committee and Chairman Thompson
in holding this hearing today and I am happy to respond to any
questions that you may have.
Chairman Thompson. Thank you for your testimony.
I now recognize Mr. Robinson to summarize his testimony for
5 minutes.
STATEMENT OF J. MARK ROBINSON, DIRECTOR, OFFICE OF ENERGY
PROJECTS, FEDERAL ENERGY REGULATORY COMMISSION
Mr. Robinson. Thank you, Mr. Chairman. My name is Mark
Robinson. I am director of the Office of Energy Projects.
Our office is responsible for approximately 2,500 non-
federal dams, their safety and security, their licensing and
their administration; the siting of natural gas pipelines; the
siting of electric transmission lines; and, more significantly
for this group, the authorization and the ongoing safety and
security of LNG terminals in the U.S.
My testimony is going to go into three areas, the siting of
those terminals, which includes the review of the tankers
associated with those tankers; the tanker safety record, which
the admiral has already mentioned today; along with the GAO
report and our general agreement with that, with some
clarification.
When it comes to siting LNG terminals, safety and security
are integral to every aspect of that in our review.
We have a very well-choreographed review of LNG terminal
safety and security that we do with the Department of
Transportation and the Coast Guard.
It starts before the authorization occurs at the commission
with a pre-filing process that the Congress has dictated that
we ensure occurs with every LNG terminal siting activity that
we do.
The pre-filing process involves all the federal agencies,
state agencies and local citizens that exist around the
terminal. Everything is above the board. Everything is on top
of the table. There are no secrets involved. And that does
include how the facilities are going to be maintained and safe.
This is performed along with our environmental impact
statement as we prepare that, with public meetings and public
discussion. Some of your areas--we have actually had meetings
in your areas on LNG facilities that are proposed.
If the commission does, in fact, authorize one of these LNG
terminals, then we go into the pre-construction phase of our
review process.
We look at detailed design drawings that include exactly
where safety equipment would be, safety monitors would be in
place. More than 100 safety monitors are typically imposed at
any LNG terminal.
Those are all reviewed, ensured that they are properly
sized and spaced. And no construction is allowed until that
review and authorization has occurred.
One other thing that does happen in the pre-construction
phase is that there is the development of an emergency response
plan.
That emergency response plan identifies who would do what
if there was, in fact, some action that occurred either at the
terminal or at the docks, who is responsible for the boats, who
pays for them.
There is a cost-sharing plan developed with the local
entities on who does pay for things such as extra police
patrols or maritime patrols. This is done with the Coast Guard
and worked out prior to any construction being allowed.
If construction does initiate, then we do inspections about
every 8 weeks or so to make sure the project is constructed
with all the safety equipment that we have required through
about a 3-year construction period.
If that occurs to our specification, we will then do the
third authorization on the LNG terminal, which is to allow it
to, in fact, operate.
We have had experiences in each of those areas where we
have not granted that authorization either at the authorization
phase at the commission, or at the construction phase, or at
the operation phase.
Ultimately, the commission has vested in our office the
right to take whatever action is necessary to protect life,
health and property. And we take that very seriously, and we do
take those actions.
On tanker safety, I think the only thing I would like to
mention, since the admiral pretty much covered that in terms of
its excellent record, is that the commission does ensure that
they understand what measures would be taken to allow a tanker
to safety come in, in a fashion that would protect the public.
If they don't have confidence in that, that goes into the
siting decision and whether or not the commission would, in
fact, authorize a plant.
To date, working very closely with the Coast Guard, we have
managed to review and be satisfied that for those plants that
we have authorized, tankers can, in fact, come into the
terminal and do that safely.
Finally, I would like to briefly discuss the GAO report. I
am very pleased that much of the GAO findings are consistent
with the findings that we have made repeatedly in our EISs;
namely, that it is very unlikely that there would ever be any
type of an explosion associated with unconfined LNG vapor--in
fact, we would probably term that somewhere resting between
improbable and impossible, and I would be more than happy to
discuss that--that there would be no risk to the public in
terms of asphyxiation or freeze burns, and that the most likely
consequence of an LNG event would be a pool fire.
As far as the distance that the radiant heat effect of a
pool fire would extend to, GAO cited that as a disagreement
among the experts.
I would like to note that 11 out of the 15 experts either
agreed with our estimates or thought we were too conservative,
meaning that our estimate of the extent of the consequence zone
is overly stated.
I tend to agree with the latter, because when I--we did the
ABSG study, which is one the studies reviewed. When I gave
directions to the staff on how to conduct that study, I asked
them to make sure wherever there was uncertainty to take the
most conservative position that we could take. And we have done
that.
The research that GAO indicated should occur we agree with.
We think that that will result in a shrinkage of the
consequence zones.
Ultimately, we have a policy of--we are constantly raising
the floor on LNG safety and security, and we will continue to
do that. We think it can be and is a safe and secure fuel
source for America.
Thank you very much.
[The statement of Mr. Robinson follows:]
Prepared Statement of J. Mark Robinson
My name is J. Mark Robinson and I'm Director of the Office of
Energy Projects (OEP) at the Federal Energy Regulatory Commission (FERC
or Commission). I am here as a staff witness and do not speak on behalf
of any Commissioner. Our office is responsible for non-federal
hydroelectric licensing, administration, and safety; siting of electric
transmission lines; certification of interstate natural gas pipelines
and storage facilities; and, more significantly for today's session,
authorization and oversight over the construction, operation, and
safety of on-shore and near-shore Liquefied Natural Gas (LNG)
terminals. We also share security responsibilities for these facilities
with the U.S. Coast Guard (Coast Guard), which has primary
responsibility under the Maritime Transportation Security Act of 2002.
I want to thank you for this opportunity to speak today and to
specifically address how we ensure the safety and security of LNG
import facilities and the related LNG shipping. Overall, the safety
record of the industry is commendable. LNG terminals in the United
States have never had an LNG safety-related incident that harmed the
public or the environment. Similarly, no shipping incidents have
occurred worldwide that resulted in a significant loss of cargo during
the almost 50 years of LNG transport. I will first describe the
measures we use to provide for safe and secure LNG import terminal
siting, construction and operation. Next, I will briefly address the
measures taken to ensure the continuing safe history of LNG shipping.
And finally, I will comment on the GAO report.
Safety, Security and Siting of LNG Import Terminals
Be assured that consideration of public safety is our highest
priority when fulfilling our Congressional mandate under the Natural
Gas Act to regulate facilities for the importation of natural gas. The
Commission has been proactive in addressing safety concerns and
rigorously applies high safety standards to these projects. When
projects meet our safety standards and are found to be in the public
interest, the Commission will approve them. If a proposed project falls
short of these standards, the Commission will reject it, as was done
with the proposed Keyspan LNG Terminal Project in Providence, Rhode
Island.
The excellent safety record of the LNG import facilities in the
U.S. extends over the past 35 years. The siting and oversight of LNG
facilities is governed by a comprehensive scheme of federal regulation
that guarantees that the FERC and other federal agencies work together
to ensure public safety. The FERC's LNG project review process works to
address all siting and operational issues with the full participation
of the federal and state agencies, and the public, and, only after that
comprehensive review, attempts to ensure the timely development of
necessary energy infrastructure. Once in operation, FERC oversight and
inspection is an on-going process for the life of the facility.
Every aspect of our engineering and siting review, and our
coordination with the Coast Guard and the U.S. Department of
Transportation (DOT), is geared toward assuring that a facility will
operate safely and securely. This review may be broken into three
distinct phases: pre-authorization review; pre-construction review; and
pre-operation review.
Pre-Authorization Review--During the pre-authorization phase,
Commission staff addresses the safety and security of an LNG import
terminal by reviewing facility designs and ensuring that the proposal
includes a number of design and operational features. FERC regulations
require that from the early stages of project development, potential
applicants meet with FERC staff to describe the proposal and solicit
guidance on required design features. At this point, we make sure that
DOT and the Coast Guard are aware of new projects or proposed
expansions. These meetings provide the opportunity for FERC staff to
offer suggestions related to the environmental, engineering and safety
features of the proposal and review conceptual designs. These
activities occur over at least a six month time span during the
mandatory pre-filing period required by the Energy Policy Act of 2005
and are detailed in the FERC's regulations under Title 18 of the Code
of Federal Regulations (CFR) Sec. 157.21.
Based on this input from FERC staff, the project sponsors continue
to develop the front-end-engineering-design (FEED) to be filed as part
of the formal application for the proposed LNG facility. The design
information, which must be contained in the formal application, is
extensive and is specified by 18 CFR Sec. 380.12 (m) and (o). In order
to ensure that the filings are complete, FERC publicly issued ``Draft
Guidance For Filing Resource Reports 11 ( Reliability and Safety) & 13
(Engineering and Design) For LNG Facility Applications'' in December
2005. This document clarified the level of detail required for the
engineering submittal so FERC staff can adequately assess the safety,
operability, and reliability of the proposed design. Areas for specific
guidance and clarification include:
the level of detail, including a requirement for a
hazard design review, necessary for the FEED submitted to the
FERC;
LNG spill containment sizing and design criteria for
impoundments, sumps, sub-dikes, troughs or trenches;
design spills to be used in the calculation of thermal
and flammable vapor exclusion zones; and
use of the Coast Guard's Navigation and Vessel
Inspection Circular 05-05 and the waterway suitability
assessment process.
The level of detail required to be submitted in the proposed design
will require the project sponsor to perform substantial front-end
engineering of the complete facility. The design information is
required to be site-specific and developed to the extent that further
detailed design will not result in changes to the siting
considerations, basis of design, operating conditions, major equipment
selections, equipment design conditions, or safety system designs
considered by the FERC during the review process. The required
information must include all features necessary for commissioning,
start-up, operation and maintenance of the facility, including details
of the utility, safety, fire protection and security systems. Novel
designs require additional detail for proof of concept.
A complete FEED submittal will include up-to-date piping and
instrumentation diagrams (P&IDs). Information on these drawings allows
FERC staff to begin assessing the feasibility of the proposed design.
Adequate P&IDs will include:
equipment duty, capacity and design conditions;
piping class specifications;
vent, drain, cooldown and recycle piping;
isolation flanges, blinds and insulating flanges;
control valves and operator types (indicating valve
fail position);
control loops including software connections;
alarm and shutdown set points;
shutdown interlocks;
relief valve set points; and
relief valve inlet and outlet piping size.
Once an application is formally made to the Commission, FERC staff
performs a detailed review of the information supporting the proposed
LNG facility design. Since the enactment of the Energy Policy Act of
2005, no later than 30 days after the application filing, the agency
designated by the Governor of the state where the terminal is proposed
may file an advisory report on state and local safety considerations.
Before issuing an order authorizing an applicant to site, construct,
expand, or operate an LNG terminal, the Commission shall review and
respond specifically to the issues raised.
During the analysis of the application, FERC staff compiles
pertinent technical information to assess the design of the LNG
facility. Although operability and reliability of the proposed design
are considered, our primary focus is on the safety features that must
be built into the system. This review is performed prior to any
Commission approval and evaluates the safety of:
the LNG transfer systems;
storage tanks and process vessels;
pumps and vaporizers;
pressure relief, vent and disposal systems;
instrumentation and controls;
spill containment systems;
hazard detection and control systems; and
emergency shutdown systems.
Each LNG import terminal must have an extensive array of hazard
detection devices to provide an early warning for the presence of
combustible gases, fires, or spills of LNG and activate emergency shut-
down systems. Using the submitted design, FERC staff assesses the
conceptual hazard detection system, which typically consists of
combustible-gas detectors, fire detectors, heat detectors, smoke or
combustion product detectors, and low temperature detectors. Typically,
each facility will have over 100 of these types of detectors.
Use of these active systems to automatically shutdown equipment,
and other passive safety protections, such as impoundments, are
reviewed to ensure that appropriate safety provisions are incorporated
in the plant design. A detailed layout of the passive spill containment
system showing the location of impoundments, sumps, sub-dikes,
channels, and water removal systems is evaluated to allow FERC staff to
assess the feasibility of the location, design configuration,
dimensions, capacity and materials of construction for this system. In
accordance with Title 49 of the Code of Federal Regulations,
Sec. 193.2181, these spill containment systems must accommodate 110
percent of an LNG tank's maximum liquid capacity.
Active hazard control systems consisting of strategically placed
dry chemical extinguishers; carbon dioxide or nitrogen snuffing
equipment; high expansion foam systems; and fire-water systems
throughout the terminal are evaluated in accordance with Federal
regulations and good engineering practices. A detailed layout of the
fire water system showing the location of fire water pumps, piping,
hydrants, hose reels, and auxiliary or appurtenant service facilities
is reviewed for adequacy.
In addition, each storage or process area containing LNG must be
surrounded by an impoundment structure to contain and limit potential
spills associated with that equipment. Based on the size and location
of these impoundments, the project sponsor must establish exclusion
zones around the facility so that the effects from potential LNG pool
fires and flammable vapors from an unignited LNG spill do not pose a
hazard to the public. In accordance with Title 49 CFR Sec. 193.2057 and
193.2059, and in conjunction with the National Fire Protection
Association 59A LNG Standards, thermal radiation and vapor dispersion
exclusion zones are calculated by FERC staff based on spill scenarios
and heat flux levels. The operator must be able to legally control land
uses within any portion of these zones extending beyond the terminal
site to prevent damaging effects of an LNG pool fire or a flammable
vapor mixture from impacting public safety.
Further, during the pre-authorization phase and beyond the
cryogenic design review, each application for an LNG facility is
subject to a detailed review by the FERC staff of numerous other
studies and reports that the applicants are required to complete. These
include:
seismic analyses;
fire protection evaluations;
threat and vulnerability assessments; and
Operation and Maintenance manuals.
The information used for the pre-authorization review is gathered
from the application, data requests, and a Cryogenic Design Technical
Conference held with the applicant's design team. This meeting allows
FERC staff and company engineers to discuss specific engineering-
related issues. Representatives from the Coast Guard and DOT, as well
as state and local fire marshals, are invited to attend. Although the
Coast Guard is generally in attendance to address facility issues, the
issues specifically related to LNG vessel transit are dealt with during
the Coast Guard's separate waterway suitability assessment (WSA)
process.
The staff's conclusions and recommendations on the proposed design,
including all safety measures, are presented in the Safety section of
the publicly-released FERC environmental assessment or environmental
impact statement (EIS). Ultimately, these recommendations have appeared
as conditions in Commission Order approving the project. In addition to
design considerations, the Order may also contain other LNG-specific
standard conditions that pertain to the safe operation and security of
the facility. If the Commission decides that a project would be safe,
is in the public interest, and authorizes it, continued review would
occur during the pre-construction phase.
Pre-Construction Review--If a project sponsor receives a Commission
Order and decides to pursue the project, it will engage the services of
an Engineering, Procurement, and Construction (EPC) firm to commence
detailed engineering of the facility. This process results in a ``final
design'' that usually contains further development or minor refinements
to the approved FEED on file with the FERC. For these modifications,
the FERC Order requires the project sponsor to request approval for the
change, justify it relative to site-specific conditions, explain how
that modification provides an equal or greater level of protection than
the original measure; and receive approval from the Director of OEP
before implementing that modification. For more significant changes,
the project sponsor would be required to file an amendment or a new
application, initiating another extensive review at the Commission.
The final design will typically include hundreds of pages of
detailed engineering drawings and specifications for every area and
piece of equipment in the facility including the marine platform,
transfer lines, tanks, sumps, pumps, compressors, vaporizers, and
blowers. Only after FERC staff has reviewed the final design for a
particular facility component to ensure it complies with all the safety
conditions of the Order and that it conforms to the approved design on
file, will authorization to construct that component be granted. We
review large scale issues such as the facility's final plot plan and
location of equipment, tanks, and impoundments to verify that all
exclusion zones remain in compliance with siting regulations. These
final review checks will also confirm that the number, location, type,
and size of hazard detection and hazard control equipment match or
improve upon the approved design and that redundancy, fault detection,
and fault alarm monitoring exist in all potentially hazardous areas and
enclosures.
Prior to entering the detailed design phase, project sponsors
perform a hazard and operability study of the initial design. This
study is intended to identify potential process deviations that could
occur during operation and lead to personnel injury or equipment
damage. The analysis proceeds by systematically identifying possible
causes for operational deviations and the consequences of these
deviations at numerous locations in the regasification process. Areas
of concern typically include equipment failures, human failure,
external events, siting issues, previous incidents, and safeguard or
control failures. These causes and consequences are in turn used to
evaluate the inherent safeguards in the design and to identify suitable
design modifications as required. Examples of the additional safeguards
that are required are: detection systems, prevention systems,
procedural safeguards, active and passive safety equipment, emergency
response procedures, and secondary containment.
During the pre-construction phase, FERC staff will review this
study as well as review all piping and instrumentation diagrams,
including every valve and thermocouple, to make sure that the overall
safety of the final design provides an equal or greater level of
protection as the original design approved by the FERC.
Furthermore, the design of some facility components such as the
foundation of the LNG tanks will be reviewed by geotechnical experts
who determine if the foundation structure is capable of safely
supporting the load of a full LNG tank, even during seismic events.
In accordance with the Energy Policy Act of 2005, Commission Orders
authorizing an LNG import terminal require the project sponsor to
develop an Emergency Response Plan (ERP) in consultation with the U.S.
Coast Guard and state and local agencies. Prior to any construction at
the facility, this plan, which must also include cost-sharing
provisions for safety and security, must be approved by the Commission.
The ERP must include written procedures for responding to: emergencies
within the LNG terminal; emergencies that could affect the public
adjacent to an LNG terminal; and emergencies that could affect the
public along the LNG vessel transit route. The ERP must be prepared in
consultation with the Coast Guard and state and local agencies, and it
must be approved by the Commission prior to any final approval to begin
construction at the terminal site.
Commission engineering staff reviews each ERP to ensure that the
appropriate state and local agencies have been involved in preparing
the plan, that the local Coast Guard Marine Safety Office has been
consulted and concurs, and that the following topics are completely
addressed:
Structure of the incident management organization of
the LNG terminal; and name, title, organization, and phone
number of all required agency contacts;
Procedures for responding to emergencies within the
LNG Terminal--identification of the types and locations of
specific emergency incidents that may reasonably be expected to
occur at the LNG terminal due to operating malfunctions,
structural collapse, personnel error, forces of nature and
activities adjacent to the terminal;
Procedures for emergency evacuation adjacent to the
LNG Terminal and along LNG vessel transit route; detailed
procedures for recognizing an uncontrollable emergency and
taking action to minimize harm to terminal personnel and the
public; procedures for the prompt notification of appropriate
officials and emergency response agencies based on the level
and severity of potential incidents; and the sequence of such
notifications;
Plans for initial and continuing training of plant
operators and local responders; and provisions for annual
emergency response drills by terminal emergency personnel,
first responders, and appropriate federal, state and local
officials and emergency response agencies; and
Documentation that the required consultation with the
Coast Guard and state and local agencies has been completed
through correspondence with consulting agencies, and minutes or
notes of coordination meetings.
In addition, both the Energy Policy Act of 2005 and Commission
Orders authorizing LNG terminals require that the ERP include a Cost-
Sharing Plan identifying the mechanisms for funding all project-
specific security costs and safety/emergency management costs that
would be imposed on state and local agencies. The cost-sharing plan
must specify what the LNG terminal operator will provide to cover the
cost of the state and local resources required to manage the security
of the LNG terminal and LNG vessel, and the state and local resources
required for safety and emergency management, including:
Direct reimbursement for any per-transit security and/
or emergency management costs (for example, overtime for police
or fire department personnel);
Capital costs associated with security/emergency
management equipment and personnel base (for example, patrol
boats, fire fighting equipment); and
Annual costs for providing specialized training for
local fire departments, mutual aid departments, and emergency
response personnel; and for conducting exercises.
The cost-sharing plan must include the LNG terminal
operator's letter of commitment with agency acknowledgement for
each state and local agency designated to receive resources.
FERC and other federal agencies work with state and local entities,
as well as the general public, to ensure that all public interest
considerations are carefully studied and weighed before a facility is
permitted and allowed to begin construction and operate, and that
public safety and the environment are given high priority. No
construction may commence until the Director of OEP finds that all
safety requirements have been met.
Pre-Operation Review--Once construction of the project has been
authorized to begin, Commission staff inspects each site at least once
every eight weeks to ensure that project construction is consistent
with the designs approved during the pre-authorization and pre-
construction review phases.
During these inspections, Commission staff physically examines the
entire site to verify the ongoing construction activities in each area.
Staff confirms that the locations of individual process equipment under
construction are in accordance with the approved site design, ensuring
that the safe distances required between property lines, equipment, and
facilities are being maintained. Staff verifies that all site activity
and equipment under construction comply with the conditions of the
Order that are applicable for that phase of the project. Commission
engineers also meet with the owner's project design engineers to
discuss any modifications or design refinements that may result from
the detailed design phase of development - for example, adjustments
considered necessary as a result of equipment vendor specifications or
other insights realized during construction.
In addition, staff reviews both the owner's and the EPC firm's
quality assurance plans to verify that rigorous and stringent quality
control inspections are being conducted by both parties during all
phases of the construction process. Inspections must apply to equipment
and components being fabricated at manufacturing sites, material and
equipment received at the construction site, specific assembly or
fabrication methods employed during construction, and also the
continuous verification of the precision and quality of all structural
work carried out during the construction process.
Staff reviews all of the non-conformance reports generated by the
project's quality control inspectors and how these incidents have been
satisfactorily resolved. These deviations from the intended quality of
work are evaluated by FERC staff to ensure that the final quality of
the work will meet or exceed design requirements. Problems of
significant magnitude are required to be reported to the Commission
within 24 hours.
During the later stages of the typical three-year construction
period, FERC staff monitors the EPC contractors' efforts to commission
(i.e., test and start-up) the various process systems and equipment
throughout the terminal in preparation for the commencement of
commercial operations. Commission staff is actively involved in the
commissioning phase to verify that the final, constructed facility
complies with the design authorized by the Commission Order, and that
the project sponsor has complied with all conditions. This review
includes verification that all of the cryogenic design recommendations
in the Order applicable to the facility's pre-construction and
construction phases have been fulfilled. Multiple on-site inspections
are performed to confirm the construction and location of all plant
equipment, process systems, and safety systems, including:
Verifying LNG spill containment structures for
completion of walls, piping, correct slope, size, materials
used, sump pumps, and instrumentation for cold detection
shutoff, and confirmation that proper materials have been used
to complete containment;
Checking critical instrumentation against the P&IDs
with the actual piping, valves, and controls; and the
instrument readouts, controls, and alarm/shutdown functions in
the plant control room;
Confirming that all required hazard detection devices
(combustible gas, fire, smoke, low temperature) have been
installed, including an examination of the cause and effect
diagrams and instrument locations for appropriate redundancy
and ``alarm'' and ``shutdown'' conditions. The physical
inspection also evaluates detector location and orientation for
blind spots that may require additional hazard detection
devices;
Confirming that all dry chemical, carbon dioxide, or
other fire extinguishing units/bottles have been installed. The
devices are checked to confirm proper weight and areas have
been covered;
Confirming that all critical pressure relief valves
have been installed, have proper discharge orientation, and
vent collection systems are operable;* Confirming that the
entire firewater system is in place, including monitors,
hydrants, pumps, screens, deluge and water supply, and has been
tested for operation;
Checking each LNG storage tank's equipment including
elevation bench marks, rotational devices, liquid level gauges,
pressure and vacuum relief valves, and discretionary relief
valves for proper installation and confirming that all
permanent covers have been installed. After cool-down, the fill
lines and tank penetrations are inspected for presence of
excessive low temperature conditions;
Checking critical, required alarms and shutdowns,
including set points (e.g., tank foundation temperatures, send-
out temperature shutdown set points) within the plant's Control
Room and satellite control centers;
Confirming that all temporary construction structures
have been removed and the facility complies with National
Electrical Code Division requirements; and
Confirming that the plant's Emergency Shutdown System
has been tested and is fully operational, including that all
required systems have been tied into it.
Prior to operation, each LNG tank is hydrostatically tested to
gauge the tank's ability to handle expected loads. During the
hydrostatic test, the FERC Order will require the project sponsor to
include a reliable measurement system to monitor any deflections in the
tank foundation or structure during the hydraulic test. At a minimum,
this system must include as many monitoring points as is necessary so
that sag, warping, tilt, and settlements can be monitored. Tolerances
for sag, tilt, and shell warping must meet or exceed the limits
specified by the tank manufacturer. In this manner, the strength of the
tank is thoroughly examined under loads similar to what will be
experienced in actual operation. The final design review will ensure
that adequate plans for such testing are in place for all facility
components.
As part of the pre-commission inspection, FERC staff also reviews
the Start-up Manual, Safety Plan Manual, and Operations and Maintenance
Manuals applicable to the installation. This review includes verifying
that the terminal staff has received the necessary training to operate
the plant or new systems, if an existing plant is being expanded. We
confirm that the plant has employed the required staffing with a level
and function appropriate for the facility.
FERC staff confirms that all plant security systems are in place
(personnel, cameras, and other equipment), and that the Facility
Security Plan is current. This review also includes confirming that all
spare equipment that was authorized is on site and properly installed.
FERC staff also checks the entire facility site to ensure that all
recommended environmental mitigation measures including erosion and
sediment controls are in place, are being properly maintained, and that
the company is making prudent steps to ensure that the site is properly
stabilized for the operational life of the facility (e.g., installation
of shore line stabilization mats and rip rap).
Prior to operation, FERC staff also reviews the facility security
to ensure compliance with the authorized design. Principal concerns are
compliance with the DOT regulations, as well as sufficient levels of
security provided by surveillance cameras; intrusion detection systems;
security fencing; and on-site access control plans.
Only after all of the above-identified inspections and reviews have
been successfully completed would FERC staff recommend that the
terminal is ready for operations. The Director of OEP must issue a
letter to the company that authorizes commencement of service from the
facility.
Prior to operation, the terminal must also satisfy other federal
agency requirements. For example, the facility must have a Facility
Security Plan approved by the Coast Guard and a Vessel Transit
Management Plan prepared by the Coast Guard and port stakeholders.
FERC oversight continues after an LNG import terminal project
commences commercial operations. In fact, the Office of Energy Projects
was reorganized to specifically create a Branch that is dedicated to
ensuring that all FERC requirements, including safety and security
measures, are complied with throughout the life of the project. Each
LNG facility under FERC jurisdiction is required to file semi-annual
reports to summarize plant operations, maintenance activity and
abnormal events for the previous six months. LNG facilities are also
required to report significant, non-scheduled events, including safety-
related incidents (e.g., LNG or natural gas vapor releases, fires,
explosions, mechanical failures, unusual over-pressurization, major
injuries) and security-related incidents (e.g., attempts to enter site,
suspicious activities near the plant site or around the marine
terminal), as soon as possible but no later than within 24 hours. In
addition, FERC staff conducts annual on-site inspections and technical
reviews of each import terminal throughout its entire operational life.
The inspection reviews the integrity of all plant equipment, operation
and maintenance activities, safety and security systems, any unusual
operational incidents, and non-routine maintenance activities during
the previous year. Ultimately, the Director of the Office of Energy
Projects has the authority to take whatever measures are necessary to
protect life, health, property or the environment.
We are proud of our track record working with DOT, the Coast Guard,
states agencies, and with all interested stakeholders on these
projects, and we are committed to continuing LNG's outstanding
operational performance.
The Safe History of LNG Shipping
In addition to ensuring safe and secure terminal sites, FERC
coordinates closely with the Coast Guard to ensure the safety and
security of the LNG vessel transit to the import facility. Under our
pre-filing regulations, applicants are required to prepare a WSA, which
is reviewed by the Coast Guard and members of the local Area Maritime
Security Committee. The Coast Guard convenes a working group consisting
of members of the local Area Maritime Security Committee, federal
agencies, state and local law enforcement, state and local
firefighters, maritime and security professionals, and key port
stakeholders throughout the port area.
Under Coast Guard supervision, this group, through a series of
focused meetings, brings together its viewpoints to form a consensus on
appropriate measures and mitigation needed to manage responsibly the
safety and security risks posed by LNG marine traffic. At these
meetings, FERC staff serves as the LNG technical advisor to the working
group, provides insight from our participation in other waterways, and
assists in identifying credible hazard scenarios. The group's detailed
recommendations from the meetings are presented to the Coast Guard to
assist in the Captain of the Port's review of the applicant's WSA.
Based on its review, the Captain of the Port will make a preliminary
determination on the suitability of the waterway. This determination
will be presented to the FERC in the Coast Guard's Waterway Suitability
Report.
The Waterway Suitability Report, filed with the Commission,
preliminarily determines whether the waterway is suitable for LNG
vessel transits, from both a safety and security perspective, and
identifies additional resources that may be required. The results of
this analysis are incorporated into the draft EIS and released for
public comment. The 45-day comment period usually includes a public
meeting near the proposed facility and along the pipeline route. In
this manner, after public comment has been received and the final EIS
is published, the Commission has a complete record on the suitability
of the waterway and potential resource requirements prior to deciding
whether to approve a particular LNG import terminal.
Since the beginning of commercial operations in 1959, LNG carriers
have made over 46,000 voyages worldwide without a significant release
of cargo or a major accident involving an LNG carrier. In no instance
has an LNG cargo tank been breached either by an accidental or
intentional event.
Any LNG carriers used to import LNG to the United States must be
constructed and operated in accordance with the International Maritime
Organization's (IMO) Code for the Construction and Equipment of Ships
Carrying Liquefied Gases in Bulk, the International Convention for the
Safety of Life at Sea, as well as 46 CFR Part 154, which contain the
United States safety standards for vessels carrying bulk liquefied
natural gas. Foreign flag LNG carriers are required to possess a valid
IMO Certificate of Fitness and a Coast Guard Certificate of Compliance.
LNG carriers are well-built, robust vessels employing double-hull
construction, with the inner and outer hulls separated by about 10
feet. The LNG cargo tanks are further separated from the inner hull by
a layer of insulation approximately one-foot thick. As required by the
IMO conventions and design standards, hold spaces and insulation areas
on an LNG carrier are equipped with gas detection and low temperature
alarms. These devices monitor for leaks of LNG into the insulation
between primary and secondary LNG cargo tank barriers. In addition,
hazard detection systems are also provided to monitor the hull
structure adjacent to the cargo tank, compressor rooms, motor rooms,
cargo control rooms, enclosed spaces in the cargo area, specific
ventilation hoods and gas ducts, and air locks.
Even in the few instances worldwide where there have been
incidents, the integrity of LNG vessel construction and safety systems
has been demonstrated. One of the more significant incidents involved
the El Paso Paul Kayser which grounded on a rock in the Strait of
Gibraltar during a loaded voyage from Algeria to the United States in
June 1979. Extensive bottom damage to the outer hull and the ballast
tanks resulted; however, the cargo tanks were not damaged, and no cargo
was released.
There have been a few other instances where LNG ships have
grounded. In 1980, the LNG Taurus grounded near the entrance to Taboata
Harbor, Japan. The grounding resulted in extensive bottom damage, but
the cargo tanks were not affected and no cargo was released. The ship
was refloated and the cargo was unloaded. In 2004, the Tenaga Lima was
grounded on rocks, due to a strong current while proceeding to open sea
East of Mopko, South Korea. The ship's shell plating was torn open and
fractured over an approximate area of 20--by 80-feet. Internal breaches
allowed water to enter the insulation space between the primary and
secondary membranes. However, the ship was refloated, repaired, and
returned to service. Although damage was incurred when these LNG ships
were grounded, their cargo tanks were never penetrated and no LNG was
released.
In another incident, the Norman Lady was struck by the nuclear
submarine USS Oklahoma City while the submarine was rising to periscope
depth near the Strait of Gibraltar in November 2002. The LNG carrier
sustained only minor damage to the outer layer of its double hull but
no damage to its cargo tanks.
More recently, the Khannur had a cargo tank overfill into the
ship's vapor handling system during unloading at Everett,
Massachusetts, in 2001. Approximately 100 gallons of LNG were vented
onto the protective decking over the cargo tank dome resulting in
several cracks. After inspection by the Coast Guard, the Khannur was
allowed to discharge its cargo. In 2002, the Mostaefa Ben Boulaid had
LNG spill onto its deck during loading operations in Algeria. The
spill, which was believed to be caused by overflow, caused brittle
fracturing of the carbon steelwork. The ship was required to discharge
its cargo and proceed to dock for repairs. Although all these incidents
resulted in an LNG release, there were no injuries in any of these
incidents.
The most recent incident occurred in 2006 when the Golar Freeze
moved away from its docking berth during unloading in Savannah,
Georgia. The powered emergency release couplings on the unloading arms
activated as designed, and transfer operations were shut down,
preventing release of significant amounts of LNG or any structural or
environmental damage. After inspection and onsite clearance by FERC
staff and the Coast Guard, the arms were reactivated and transfer
operations resumed without incident.
The low number of LNG tanker incidents can be attributed to the
careful handling of the tankers, as well as safety and security
procedures used in the ports. The transit of an LNG vessel through a
waterway is strictly controlled by the Coast Guard to prevent
accidental or intentional incidents that could damage the vessel or
endanger the public. Entry into a port typically involves Coast Guard
requirements such as:
96 hours advance notification of arrival and the
vessel crew manifest;
Coast Guard boarding of the LNG Vessel for an
inspection of the ship safety system;
Moving safety/security zones around the LNG vessel;
Armed and unarmed escorts;
Tug escort to assist with turning and mooring
operations;
Safety and security zones around the terminal dock
while the vessel is berthed;
Accompaniment by a state-licensed pilot; and
Inspection of the dock safety systems before
commencing cargo transfer.
With these operational measures, the transit of LNG carriers has
been demonstrated to be safe along the waterway from the berthing area
to the territorial sea.
GAO Report [No GAO-07-316]: ``Public Safety Consequences of a
Terrorist Attack on a Tanker Carrying Liquefied Natural Gas Need
Clarification.''
I am encouraged that the GAO report reached many of the same
conclusions on LNG hazards which we have published in each FERC
environmental impact statement. The findings of the GAO expert panel
concur with FERC staff's assessment of the potential public safety
consequences of a terrorist attack on an LNG tanker regarding:
unconfined vapor cloud explosions;
freeze burns;
asphyxiation; and
rapid phase transitions (RPTs).
These phenomena do not pose a significant hazard to the on-shore
public during a large-scale LNG spill. Natural gas vapors (primarily
methane) can detonate if contained within a confined space, such as a
building or structure, and ignited. However, unconfined methane-air
mixtures have been ignited but not detonated in experiments. Although
the addition of heavier hydrocarbons influences the tendency of an
unconfined vapor cloud to detonate, the possibility for detonation of a
large unconfined vapor cloud is unrealistic due to precise timing,
necessary mixing, and required amount of initiating explosives.
Similarly, the public is not at risk from freeze burns or
asphyxiation. Clouds from an LNG spill would be continuously mixing
with the warmer air surrounding the spill site. Dispersion modeling
estimates that the majority of the cloud would be within 25 degrees
Fahrenheit of the surrounding atmospheric temperature, with colder
temperatures closest to the spill source and away from the public. In
addition, the majority of the cloud would be below concentrations which
could result in oxygen deprivation effects, including asphyxiation,
with the highest methane concentrations closest to the spill source.
The report also focused on potential impacts from RPTs. Our
project-specific EISs include a discussion of this issue. While RPTs
can occur during a spill on water, impacts would be limited to the area
within the pool and would be unlikely to affect the public. The
overpressure events observed during experimentation have been
relatively small, estimated to be equivalent to several pounds of TNT.
Although such an event is not expected to cause significant damage to
an LNG vessel, it could increase the rate of LNG pool spreading and the
LNG vaporization rate for a spill on water.
FERC staff also concur with the GAO report on the potential for a
boiling liquid expanding vapor explosion (BLEVE). While it may be
theoretically possible, the low storage pressure, use of insulation,
and installation of relief valves on both onshore LNG storage tanks and
LNG carriers render the possibility of a BLEVE unlikely for LNG as it
is normally transported and stored.
The report further states that the most likely public safety impact
from an LNG spill would be from heat associated with a pool fire. FERC
staff has also analyzed this issue in the course of project specific
reviews and has reached that same conclusion. In its 2004 report,
Sandia considered scenarios likely to breach an LNG cargo tank. Events
ranged from accidental collisions, groundings, rammings, sabotage,
hijackings, attacks with small missiles and rockets, and attacks with
bulk explosives. These types of events which could potentially lead to
a large LNG spill would likely be accompanied by a number of ignition
sources. Surrounding impacts would be from an LNG pool fire, and
subsequent radiant heat hazards, rather than the formation of a large
unconfined vapor cloud. Each of our EISs describes those potential
impacts on the local waterway.
As stated in the 2004 Sandia report, the most significant impacts
to public safety and property exist within approximately 500 meters
(1,640 feet) of a spill due to thermal hazards from a fire, with lower
public health and safety impacts beyond 1,600 meters (approximately 1
mile). We believe the Sandia report and FERC's site-specific analysis
are a reasonable and conservative basis to examine potential impacts
from an LNG tanker fire.
The GAO study reports four experts thought the Sandia distance
calculations were ``too conservative''; four thought ``not conservative
enough''; seven thought ``about right.'' Although the report
characterizes this as disagreement, the majority of the panel (11 of
15) responded that the calculations were either accurate or overly
conservative.
Although FERC staff generally agrees with the material presented in
the GAO report, further explanation of some information is necessary.
For instance, the report mentions that an LNG vapor cloud is visible,
but natural gas vapors are colorless. The fog-like appearance usually
associated with an LNG vapor cloud results from condensation of water
vapor in the air due to the lower temperatures of the cloud. However,
appearance of this visible water vapor does not necessarily reflect the
flammable portion of the cloud. In addition, the report states that LNG
fires burn hotter when the maximum flame temperature of methane is
nearly the same as other fuels. Radiant heat from a large-scale LNG
pool fire is assumed to be greater than other common hydrocarbon fuels
based on the results of small-scale fire measurements. However, it has
not been proven that this effect would scale up to larger fires. Oxygen
deprivation and smoke generation in a larger fire may lead to lower
surface emissive power.
In each EIS, FERC staff includes site-specific modeling done with
the methodology developed for FERC by ABS Consulting. In areas of
uncertainty due to the lack of large-scale field data, the FERC model
uses conservative assumptions (i.e., resulting in longer hazard
distances). These conservative assumptions concern: calculation of the
pool spread; determination of the pool fire flame height; and use of a
higher surface emissive power. Our results have been in agreement with
the Sandia guidance zones of concern, and support the conservative
nature of the calculations.
Cascading failure of the LNG storage tanks, addressed by Sandia in
its previous examination of currently operating LNG carriers, was
another topic of disagreement among the experts. Sandia stated that the
events would not likely involve more than two or three cargo tanks. As
stated in the 2004 Sandia report, the nominal hole size of an
intentional breaching scenario would be no more than 5--to 7-m2, which
is the appropriate range we use in the FERC staff EIS for calculating
potential hazards from spills. For a breach of a 7 m2 in a single tank,
the fire duration would be approximately 10 minutes. Whereas smaller
hole sizes could result in fires lasting over 1 hour. While the
expected fire duration from cascading tank failure would increase, the
overall fire hazard was not expected by Sandia to increase by more than
20 to 30 percent. GAO recommended that further study of this issue
could be undertaken by Sandia. We concur that further study on
cascading mechanisms may clarify if the subsequent failure of the
fourth and fifth cargo tanks would occur over time with the most
probable consequence of further extending the duration of the fire.
Related to cascading failure mechanisms are the effects such an
event may have on a pool fire (i.e., whether it would increase the
duration of the event, increase the size of the pool fire, or lower the
radiant heat due to increased smoke generation). Current knowledge of
the physical properties associated with an LNG spill are based on
small-scale (<35 meter diameter pool) tests. How the data collected
from small-scale pool fires can be extrapolated to the potentially
large-scale cargo releases is a subject of much debate among the
modeling community. Quantifying the physical properties of large-scale
LNG spill should be a priority. This will allow analysts to refine the
consequence models and generate more consistent results. Sandia
currently has this effort underway with the Advanced LNG Pool Fire
Testing Program.
Initial experimental results are expected in a few months, and the
large-scale experiments are planned to be complete by August 2008. The
initial results of these experiments will determine better correlations
for the flame height and mass fire behavior which could be expected
during larger fires. The large-scale tests will result in better data
on vapor production rates, smoke generation, and surface emissive
power. In a separate effort, Sandia is also applying its threat
analysis and spill probability methodology to LNG tankers larger than
those previously studied. The research is designed to provide an
estimation of the sizes of breaches, including hole size, spill volume,
and number of tanks breached, for membrane-designed ship classes
ranging from 216,000 m\3\ to 267,000 m\3\. These are representative of
LNG ships that are currently being designed, constructed and proposed
for use at LNG facilities in the United States. Presently, each Order
issued by the Commission requires the applicant to prove that staff's
modeling of hazards for those large tankers is accurate. They must do
this and get approval from the Director of OEP prior to accepting the
larger size ships.
We will use this new data to enhance our modeling capabilities for
determining possible consequence areas resulting from a successful
intentional attack on an LNG tanker. FERC staff has always committed to
modify our analyses, when appropriate, as new data and improved
modeling technologies are developed.
I believe that this research is beneficial and necessary and will
provide more exact information and technical details. Removing the
uncertainty inherent in modeling phenomena will result in more accurate
models. However, in current areas of uncertainty, we have made
conservative assumptions. FERC staff believes the refined models will
likely show smaller consequence areas. FERC, and along with it, the
Coast Guard and DOT have a competent understanding of the risks and how
to mitigate them effectively to ensure public safety.
In conclusion, LNG is a commodity which has been and will continue
to be transported safely in the United States. The U.S. Coast Guard,
the U.S. DOT and FERC are committed to ensuring that safety. As a
matter of policy, the Commission is committed to continually raising
the bar on energy infrastructure safety. As new safety measures,
improved monitoring equipment, and enhanced safety and security
protocols are developed, the Commission will ensure that LNG remains a
safe and secure fuel source for the country.
Chairman Thompson. Thank you very much, Mr. Robinson. I
thank you and all the witnesses for your testimony.
I will remind each member that he or she will have 5
minutes to question the panel.
I will now recognize myself for the first 5 minutes.
Mr. Lesnick, it is my understanding that the maritime
administrator is working with individual companies to increase
the number of U.S. mariners on LNG tankers.
How many companies have agreed to increase their number of
U.S. mariners at this point?
Mr. Lesnick. At this point in time, I think it is four,
Congressman.
Chairman Thompson. Four out of----
Mr. Lesnick. Four out of perhaps any number that--there are
numerous companies that deliver LNG to the United States.
Chairman Thompson. For the record, share with the members
of the committee just what the maritime administrator is
proposing for each LNG tanker that comes on our shores.
Mr. Lesnick. Well, essentially, when we began the program,
it is just dealing with the offshore facilities, Mr. Chairman.
But what we have done is we have asked each applicant to
agree voluntarily to provide a certain level of U.S. licensed
and unlicensed crew on every vessel that is delivering gas to
one of the deepwater port facilities.
What happened with Suez Energy is that when they entered
into that agreement with us, they also entered into an
agreement to provide the same level of U.S. crews on all of the
tankers coming to all of their facilities into the United
States.
We are working now with British Gas and with Shell. We
don't specifically have offshore facilities with the same type
of agreement.
Chairman Thompson. Okay. Well, I guess my point is what is
the percentage the administrator----
Mr. Lesnick. Twenty-five percent of the licensed and 10
percent of the unlicensed mariners aboard the vessel, every
vessel coming in.
Chairman Thompson. Okay. Is there any effort to increase
that percentage?
Mr. Lesnick. There will be efforts to do that once we meet
that particular quota.
Chairman Thompson. So you are saying only four companies
have agreed so far.
Mr. Lesnick. So far, but there are more--there are at least
three additional ones that are interested in doing such. We are
in conversations with them.
Chairman Thompson. Well, now, are the ones who are not--who
have not agreed--are they allowed to come and utilize the
facilities?
Mr. Lesnick. At present, we only have one operating
deepwater port, sir. When they are all--yes, they will be
allowed to use the facilities.
Chairman Thompson. They will be.
Mr. Lesnick. Yes.
Chairman Thompson. Does the administrator have any plans to
deny the use because they won't hire American to a certain
percentage on the ships?
Mr. Lesnick. Under the Deepwater Port Act, we wouldn't have
the authority to do that, sir.
Chairman Thompson. So basically you are saying the
administrator is just using his influence to get the
percentages?
Mr. Lesnick. What we do is we give priority processing to
people who agree to this manning agreement. And we are also
working with applicants to actually re-flag vessels, LNG
tankers, to the U.S. flag.
Through that priority, they get moved to the front of the
queue in terms of the license application process, and that has
enticed them, along with all of the security and political
pressures attached to that. It has enticed other companies to
agree to do the same thing.
They understand that there is a shortfall and that there is
going to be a worldwide shortfall, and they need Americans on
board all of those vessels. They are seeking U.S. crews.
Chairman Thompson. Well, personally, I think it is a good
idea to hire Americans, you know, and would have no problem
making that part of the requirements. And I guess we will look
at that at some point.
Admiral is there a reason why the TWIC identification card
at this point is only applied to U.S. mariners and not
everybody who is coming in?
Admiral Salerno. Yes, sir. The provisions of MTSA, which
required the credential, the transportation worker
identification credential for mariners, applies to U.S.
mariners. It does not extend to foreign mariners.
So there is no requirement or mandate in law to require
that for foreign mariners.
Chairman Thompson. So in other words, we vet the Americans
who come but everybody else on the ship--we don't vet them.
Admiral Salerno. Sir, there is other dimensions to this.
For other people on--everybody that is arriving in the U.S. is
vetted through a security protocol.
Not everybody will have a TWIC, but they will be vetted
through the 96-hour advance notice protocol.
Chairman Thompson. I understand that, but if TWIC is for
people who are somehow handling hazardous cargo, why--I mean,
do you see a value in vetting everybody under TWIC who is on
that ship?
Admiral Salerno. Sir, the TWIC is intended for people who
have unescorted access to facilities and to secure areas of a
vessel.
If a foreign mariner were to come ashore into a facility
and to be granted access into a secure area, he would have to
be escorted. So he would not need a TWIC to be escorted, but
that can be covered within the facility security plan.
Also, as I mentioned, each ship under the international
code is required to have its own security plan, which we
verify, that is in place and that there is a ship security
officer on board the ship that makes sure that the plan is
followed.
So there are security provisions that apply to the ship and
to the mariners on that ship.
Chairman Thompson. I guess my point, though, is if that is
in place, why give Americans the extra level of vetting that
you don't give other individuals?
Admiral Salerno. Sir, the expectation is that with a TWIC,
a U.S. mariner would be able to have unescorted access through
a facility and to areas of a vessel operating within our
waters.
It is to have additional freedoms, if you will, by virtue
of having that TWIC that would not be granted to a foreign
mariner through a U.S. facility.
Chairman Thompson. Thank you.
I yield to the ranking member.
Mr. King. Thank you, Mr. Chairman.
Admiral Salerno, would you describe what the rules of
engagement are regarding the use of deadly force to protect an
LNG shipment? And has deadly force ever been used or a weapon
ever been discharged?
Admiral Salerno. To answer your last question first, sir,
deadly force has not been used. It is authorized in conformity
to Coast Guard instructions, commandant policy.
Generally speaking, we only use as much force as is
necessary to compel compliance. If we can use nonlethal means,
that is what we will do if we can protect the ship.
Only if there is an imminent danger of loss of life either
to our own crews or to another person would deadly force be
used. But our crews are trained in judgmental shooting and
proper procedures for the use of that force.
Mr. King. Mr. Robinson, can you tell me how many new LNG
projects are being considered by FERC?
Mr. Robinson. We have nine under review right now.
Mr. King. And maybe you mentioned this in your testimony,
but approximately how long does that process take? I mean, is
there any standard? Is there any guideline you use?
Mr. Robinson. If everything goes well, the pre-filing
process--which, again, is legally mandated--we like to see that
accomplished in 8 months to 10 months, something in that time
frame.
The application, once it is on file--we authorize the
facility within 11 months, but we don't have a standard where
we have to meet that.
We also have projects that we have been looking at--as an
example, the port of Long Beach in California--for about 3
years now. We won't go to the commission for authorization
until we have a complete record, to include the record on
safety and security for each facility.
Mr. King. Have you had any companies withdraw their
application?
Mr. Robinson. We have had companies approach us and talk to
us about an LNG facility and then withdraw from that proposal.
Once somebody has reached pre-filing, they have usually spent a
considerable amount of money at that point, and they pursue
their application.
We have had no one withdraw once they got into a formal
application with the commission.
Mr. King. Once the process is started, are there
modifications undertaken? I mean, is that standard, or, I mean,
can it be adjusted as it goes along, or is it--
Mr. Robinson. It is adjusted from day one as it goes along.
And just as an example, almost every authorization the
commission issues has--not almost. Every authorization the
commission issues has a list of requirements and modifications
to what is proposed.
Typically that runs 70 or 80 very specific requirements
that are imposed upon a terminal operator.
Mr. King. Do you get much resistance or they pretty much do
what they are told? I mean, you know, are you definitely
holding the upper hand? I guess what I am talking about--you
know, when you are dealing with the industry--
Mr. Robinson. I have had the opportunity to hold tankers
offshore because I wasn't satisfied that a particular valve was
installed correctly.
I have stopped work on projects and held complete work
forces off for a week while we reviewed soldier beam
installation for tanker design.
No, we have no problem protecting life, health and property
and we have the authority to do it.
Mr. King. How would you compare the compliance record or
the cooperation, let's say, between LNG and the oil industry?
Mr. Robinson. Well, I don't have that much experience in
the oil industry, but as far as the cooperation with the LNG
industry, we have never met any resistance.
And along with that, the Congress was good enough to give
us the authority through the Energy Policy Act of 2005 to fine
our companies $1 million a day if they don't comply with our
requirements.
Mr. King. So long as I have you here today, is there
anything you can tell me about Broadwater?
Mr. Robinson. Currently the status of that offshore
facility--and we do the authorization for offshore facilities
in state waters such as Broadwater.
We have issued a draft environmental impact statement. That
included the water suitability report that was prepared by the
Coast Guard. I personally was involved in about five public
meetings on Long Island and Connecticut post-draft EIS.
We are now reviewing the thousands of comments that we have
received on that project and will treat each and every one of
them--respond to them. That will take us some time. We don't
have a time frame right now for the final EIS and commission
order.
Mr. King. Thank you, Mr. Robinson.
I yield back, Mr. Chairman.
Chairman Thompson. Thank you very much.
We now recognize the gentleman from Rhode Island, Mr.
Langevin.
Mr. Langevin. Thank you, Mr. Chairman.
Gentlemen, I want to thank you for your testimony here
today.
I have been following and been involved with the LNG issue
for quite some time now. We have an LNG facility in my home
state, my district, in downtown Providence which is located
right in the heart of a very densely populated area.
There was a proposed expansion of that facility not too
long ago which was denied for a variety of reasons, I think
less because of safety and security reasons as it was dealing
with the actual infrastructure, things that needed to be
changed in order to accommodate the facility. It is an older
facility and such.
I didn't agree necessarily that safety concerns were taken
into account in the way they should be, but--and there is also
the Weaver Cove facility that is near my district, and we are
by--the tanker ships would need to go by areas in my district
if that facility were to be expanded.
But let me turn to a couple questions I have. As we
continue to increase our reliance on natural gas, I certainly
understand that we will need to establish new and also enlarge
existing LNG import facilities throughout the country.
However, I believe that we must carefully coordinate these
efforts with our expected demand. So to this end, it is crucial
that proposed facilities be examined using a regional approach
rather than on a case-by-case basis.
And let me give you an example. Again, in my home state of
Rhode Island, there was a proposal to expand an LNG facility in
Providence, and there was also this proposal to build a
facility at Weaver's Cove in Fall River, Massachusetts--that is
less than 20 miles away--that FERC was considering at the same
time.
Now, each of these proposals was considered on its own
merit independent of the other proposed facilities within the
region.
Though FERC, again, ultimately denied the Providence
proposal, I understand that other LNG facilities are under
consideration in the New England area, raising the prospect of
numerous tanker shipments along populated coastlines with no
greater coordination among the proposals.
So my question, to start with Mr. Robinson, would you
please explain to us why FERC has not yet adopted a regional
approach? And do you think that we should only consider each
proposal independently? Or do you think that regional aspects
should be taken into consideration as well?
And if I could also on this same point, Mr. Wells, in light
of the findings of your recent report, what would you say about
adopting a regional approach for building new LNG facilities?
And I would like to give the entire panel the chance to
answer this question as well, going back to Mr. Wells.
And again, should we adopt a more regional-based approach
to determining where new LNG facilities should be located to
promote a more comprehensive approach to security?
And I will start with Mr. Robinson.
Mr. Robinson. Thank you. We do look at regional issues when
we site an LNG facility.
As an example, for the KeySpan project, the one that we did
turn down for safety reasons--it was very specifically for
those reasons that we did reject that application--I think we
looked at something on the order of 14 other sites that were in
three other states in that area to see if there were any other
facilities that might have superior characteristics, and
concluded that in that instance there certainly were, because
we denied that application.
As to regional planning in general, ultimately--and I have
been siting energy infrastructure for almost 30 years now. When
it comes to siting a piece of energy infrastructure, be it a
dam, an LNG facility, a pipeline or transmission line, it
always comes down to those local concerns and the local issues
that people have who would be near that facility.
Those are what have to be treated, and that is what the
commission takes very seriously.
A regional planning effort in that context--I think it
would be difficult for a group to ultimately conclude that this
is the best site, when they are approaching it from a regional
perspective, because they don't know the details of that
specific site.
Ultimately, you have to do a site-specific analysis and
assessment to see if, in fact, that is correct. That is why the
commission takes the approach that it does. We understand that
all facilities will not be constructed. The market ultimately
will dictate what gets built and what doesn't.
But what the commission does is make sure that they believe
that they have the information necessary to determine if it is
in the public interest to allow a site to be constructed at
that particular point.
Mr. Langevin. Mr. Wells, could you comment?
Mr. Wells. Clearly, GAO over the years has had experience
in assessing the success or failure of various regulatory
approaches and permitting approaches.
You can pick and choose the issues where we have had
piecemeal approvals that have involved local issues and have
not been as desirable in the actual approval process.
We have had successes in regional approaches, particularly
in electricity. Whether you agree or disagree with deregulation
in the electricity market, regional approaches have achieved
successes.
You would think as we move forward into the future that we
would be able to bring some lessons learned in terms of what
works and what doesn't work and maybe have a combined approach.
But typically, in the Federal Regulatory Agency, we see a
tendency to stick with what you have always done.
Mr. Langevin. Do either of the other two gentlemen care to
comment?
Admiral Salerno. Sir, from the Coast Guard perspective, we
evaluate each of the applications presented to us on a case-by-
case basis, not from a standpoint of deciding which is the best
site.
We look at the applicant's package and we make the
assessments for navigational safety, the security concerns and
so forth.
As was mentioned, there is approximately 40 applications
submitted. Probably only a dozen or so will actually be built.
So the determination as to the best regional location would
probably come after our assessment.
Mr. Lesnick. We are a market-driven--deciding is market
driven. However, the Deepwater Port Act itself is unique in the
fact that the governor of the adjacent coastal state has the
right to approve or deny the application, and also approve it
with conditions.
And that usually provides safeguards for the local state
and the region in terms of exactly where a siting is going to
occur.
Mr. Langevin. I see my time has expired. I have got some
other questions for the record I will submit with regard to
safety and what weight safety issues go into making a
determination about where to site or if a site should be
approved. But again, my time has expired.
I thank the chairman, and I yield back.
Chairman Thompson. Thank you very much.
I now yield to the gentleman from Connecticut, Mr. Shays.
Mr. Shays. Thank you, Mr. Chairman. Thank you for holding
this hearing.
And, gentlemen, thank you for your service to our country.
I have been one who believes that while we don't feel that we
are safer today, we are. We just had a very false sense of
security in the past.
But saying we are safer doesn't mean we are safe. And I
know that you all are working every day to have that happen.
I would just like to encourage you publicly to make sure
that you are blunt as can be when you are in the public forum
about the risk, because--and I will just quickly make this
analogy.
We all knew we had problems at Walter Reed Hospital. There
were reports about it. But frankly, when I had hearings about
it, and others, the press wasn't there, and nobody paid any
attention.
And then when there was a graphic picture of mold on a
wall, the lightning struck. And then all of a sudden the press
is saying where were we. And a lot of us were trying to address
that issue.
I want to know if the concern about LNG plants is
overblown. I look at these--and there are different types of
tankers, correct? I see some that have the ball, and I see some
that look straight.
Somehow the ones with the spheres look more frightening,
and are they the older model? A nodding of heads won't get the
answer here.
Admiral Salerno. Sir, there are different designs, but
essentially they are all meant to meet the same performance
criteria.
Mr. Shays. And by performance, security as well?
Admiral Salerno. Actually, the design of the ship, the
containment of the cargo, the double-hulled design, all of--
regardless of the design, they are all meant to perform----
Mr. Shays. Now, everyone who is a politician has opposed
the location of an LNG plant everywhere around the world--in
the United States, excuse me, practically. I don't want to
over--but certainly, we have on Long Island Sound.
And I take that position--I take that position because I
want us to deal with the energy problem in total, and then I am
open to looking at a lot of things like offshore drilling. I am
willing to look at nuclear. I am willing to look at everything.
But I want to see us deal with being more efficient with
what we have before we start robbing the bank--not robbing the
bank--before we start using our savings account. My view is
let's spend the money better and then let's decide.
And I feel a little guilty, frankly, as someone who lives
in Connecticut, New England, where I feel like we are at the
end of the pipeline, and we are constantly saying no to more
energy supply and so on.
So I am being honest with you about where I am coming from.
When I am told that the LNG plant in Long Island would endanger
someone within a mile radius, I then think well, here in
Providence or in Boston, and I say, ``My God, that is the
target.'' I mean, we are wondering, that is the target.
I want you to tell me how dangerous are these facilities--
these ships, excuse me, and the facilities where they connect,
but basically the ship. The flame is hot. I am told it is
extremely hot, very efficient.
And while you wouldn't get an explosion, you would get a
huge flame, a fire. I am told the bigger--there is projection
that the larger the fuel that the less likely of a more intense
fire because it would conflict, that it would--you might have
more smoke than fire.
Tell me what your studies tell you and what your experience
tells you.
Mr. Wells. I will start by saying your description of the
conclusions reached by the few somewhat small number of studies
confirm what you just said in regards to what the computer
modeling tells them may exist, which falls into the gap that we
have addressed in asking the Department of Energy to address.
Much of these conclusions and results are speculated based
on assumptions and modeling techniques, and we are asking the
Department of Energy to do the type of research to actually do
a better job of assessing the consequences of a large fire,
bigger spill volumes, larger holes in hulls, to, in fact,
determine if that conclusion is valid.
Mr. Shays. I am more interested in--and I am just going to
ask for a comment, but I am more interested in, say, a
shoulder-fired missile, a portable air defense missile, you
know, manual--I am more interested in that type of terrorist
activity.
But let me go down the line here, if you have something to
add.
Admiral Salerno. Sir, in light of the threats that were
identified in the report, certainly, a standoff weapon is one
of the concerns that we would have.
But I think as the report pointed out--and I think we could
say this in a non-SSI environment--the likelihood that--
Mr. Shays. No, I am going to ask you to--I will make the
judgment here. If there is a terrorist attack using a manual--
you know, handheld rocket, what is our determination?
Admiral Salerno. The determination would be the
consequence--the damage to the vessel would be less than a
suicide attack.
Mr. Shays. Okay. Oh, I am sorry, suicide would be a ship
coming up with more explosives?
Admiral Salerno. Similar to a----
Mr. Shays. Well, then let me add--I mean, a terrorist
attack as opposed to something that happened because they ran
aground or something.
Admiral Salerno. No, that is the way I meant it, sir.
Mr. Shays. I am sorry.
Admiral Salerno. Comparable to the attack on the USS Cole.
Mr. Shays. I got you. Fair enough.
Yes, sir?
Mr. Lesnick. In terms of the damage done, that would be for
someone else to assess, other than--but one of the reasons we
remotely site these facilities is that is one of the reasons
these sites are put offshore, so far offshore.
Mr. Robinson. Your question was is it overblown. It depends
on where your information comes from. Certainly, if you read
the popular press, it is completely overblown.
If you read the analyses that go into each of the projects,
the very lengthy analyses that go in, I think you will get a
clear picture of what the potential risks are.
As an example, the recent press on the GAO report--one of
the headlines I saw was ``LNG Explosion Burns People One Mile
Away.'' The GAO report was very clear that explosions were
unlikely. Again, I phrased it somewhere between improbable and
impossible.
So even though in the popular media you will see explosions
all the time, that is just not the case.
Burns One Mile Away--what they are talking about there are
second-degree burns at a mile distance, if you hold your
exposed skin up for 20 seconds to 30 seconds and don't move it.
If you have clothes on, you are protected.
So the way it comes across in the media is everybody will
be burned up to a mile out, when actually we are talking about
just move away within 20 seconds to 30 seconds and you won't
have a burn.
I think there is a difference between where you pick up
your information and how it is portrayed.
Mr. Shays. Thank you.
Let me just make a summary comment, if I could, Mr.
Chairman.
If you tell the American people the truth, they will have
you do the right thing.
The problem we have in this whole dialogue is in some cases
they have a fear that may not be warranted, and in other cases,
based on reports that you have stated to us under closed
meeting, they have a lack of knowledge of things that they
should fear.
Our struggle needs to be to tell the American people the
truth and then they are going to push us to do the right thing.
Thank you, Mr. Chairman.
Chairman Thompson. Thank you very much.
We now yield to the gentleman from Pennsylvania, Mr.
Carney.
Mr. Carney. Thank you, Mr. Chairman.
And, gentlemen, thank you for coming in today. We
appreciate it. I have just a couple of questions.
First, for Mr. Wells, and this is a quick one. You
mentioned in your opening statement that there is a classified
report that is almost ready, available soon?
Mr. Wells. Available soon to people that have the national
security clearance. That is correct.
Mr. Carney. So like guys like us on the committee--
Mr. Wells. Can, in fact, hear the results and answer
Congressman Shays's most recent question.
Mr. Carney. Very good. Do we have a time frame, kind of a
date certain on that?
Mr. Wells. I don't have a date certain. It is with the
intelligence agency now for classification, so it is pretty
much finished. We are just getting the clearances.
Mr. Carney. Very good. Okay.
Chairman Thompson. Well, I guess, let me take it a little
bit--as soon as it is ready, will you notify the committee so
we can schedule a time for the briefing?
Mr. Wells. Absolutely, Mr. Chairman.
Chairman Thompson. Thank you.
Mr. Carney. The unfortunate reality is that the committee
has been promised reports that now, in some cases, are a couple
of years past due. I am not saying that is your case, Mr.
Wells.
Mr. Wells. Thank you.
Mr. Carney. We are especially sensitive right now on this
sort of thing. Certainly, I am.
This is a general statement for--or question, rather, for
you all. We have learned that there are up to 32 applications
for new LNG facilities. I don't know if they are all going to
come to life. Probably not.
But do we have the resources available to protect many more
facilities?
Admiral?
Admiral Salerno. We are very mindful of the fact that there
will be a number of new facilities coming online, and certainly
the question of resources is something that is before us.
We are looking at that very, very closely. In recent years,
we have, in fact, looked at the overall requirements for our
presence in ports, not only for LNG but for dangerous cargoes
generally, and in the past have had requests submitted
successfully for additional resources.
Mr. Shays. Would the gentleman yield? Would you mind,
just----
Mr. Carney. Yes, Mr. Shays, I yield.
Mr. Shays. Isn't the honest answer ``no''?
Admiral Salerno. Sir, we are assessing the risks on that.
Mr. Shays. Isn't the honest answer ``no'' based on what we
heard previous? Isn't that the honest answer? I will just leave
it hanging.
I don't want to take your time.
Admiral Salerno. Honestly, sir, it is on the table.
Mr. Shays. I think that is a punt, and I don't think it is
an honest answer. I am sorry.
And I thank the colleague. I am sorry to interrupt.
And I hope the chairman gives him more time.
Mr. Carney. Thank you, Mr. Shays.
Mr. Lesnick, what do you think? From your perspective, do
we have the resources available at the Coast Guard?
Mr. Lesnick. From my interaction with the Coast Guard----
Mr. Carney. Right.
Mr. Lesnick. --in terms of the applications that we have on
the table right now, yes.
Mr. Carney. Okay.
Mr. Lesnick. But I know how hard they work through this
whole process.
Mr. Carney. Mr. Robinson?
Mr. Robinson. Yes. I would like to bring in one other
aspect here that goes directly to this, and I mentioned it
earlier. Once a project is authorized--you have 30 to 40
applications--however many are out there.
But once a project is actually authorized, before they can
start construction they have to develop an emergency response
plan which identifies the resources, and who is going to pay
for them, and where they are going to come from to ensure the
safety and security of that facility.
That is done with the Coast Guard. There is about a 3-year
period post-construction authorization to build the plant out.
During that period, resources are acquired. The Coast Guard,
our licensee, the locals, paid for as directed by this plan.
At the point that a tanker would come in, if the safety
facilities are not in place, we wouldn't allow the plant to
start operating, and I am sure the Coast Guard wouldn't allow a
tanker to come in if they didn't have the facilities to ensure
its safety as it came in.
So it is not like there is just an authorization and
everything is there. You wouldn't want those facilities there
before it is authorized. You have to bring them on as you
approach actual operation. And we have a plan in place to make
sure that happens.
Admiral Salerno. If I could just add to that, that is very
much in our thinking and in our method of operation that we
look at other partner agencies within the port, because there
are concurrent responsibilities and jurisdictions, as well as
to the private sector, because they have a role in providing
security resources as well.
And it is that composite mix that really goes into our
assessment of whether it is suitable for a vessel to operate in
a port area.
Mr. Carney. Well, I appreciate that. I guess I do go back
to Mr. Shays's point. It sounds like the answer is no.
Does the Coast Guard--or are the LNG facilities or the
applications--is that what drives Coast Guard growth?
Admiral Salerno. As part of the review process, what the
captain of the port will do is assess the security needs, and
figure out what are the resources required and can he meet
those requirements with his own resources and with other agency
resources.
That is absolutely essential in the assessment. And
overall, within the Coast Guard, if we cannot meet those
requirements, obviously that may drive the need for more
resources.
However, we also have to look at our ability to shift
resources internally before we get to the point where we decide
that we do, in fact, need more resources.
Mr. Carney. Okay.
Thank you, Mr. Chairman.
Chairman Thompson. Thank you very much.
Very rarely do I find a committee offering to help and help
is denied. I just want to put that on the record. Clear, if the
15 applications that we had on file were approved, 3 years out,
based on what I heard, we would have 15 more LNG facilities
that obviously would have to meet the requirements.
I would hope that in meeting the requirements we would not
delay ships coming in because we don't have help to do the
inspections.
And I think if somebody--and maybe, Admiral, what I would
like for you to do for the committee is looking at the 15
applications, will you provide us what assets, being personnel
as well as boats, that would be needed to support those 15
applications that we presently have on file?
We will now go to Mr. Bilirakis of Florida for 5 minutes.
Mr. Bilirakis. Thank you, Mr. Chairman.
All ships carrying LNG that come into the U.S. ports must
have additional safety measures you have described. This is for
the admiral.
My understanding is that when these ships leave their
initial port of call they are unaware of their final
destination, which is determined by market demand.
At what point does the Coast Guard confirm that these ships
meet U.S. safety standards? And if they do not, are they turned
away?
Admiral Salerno. Sir, the 96-hour advance notice of arrival
gives us that ability to make sure that the ships meet all of
the required safety, environmental and security standards.
That applies to every ship coming to the U.S. Now, in
reality, there is relatively few ports that supply LNG to the
United States. The primary one by ship is Trinidad and Tobago.
Algeria is a second.
We frequently or routinely see the same ships over and over
again, so they become very much a known quantity. We have
frequent interaction with them. We inspect these ships on a
regular basis.
In many cases, we send Coast Guard inspectors to ride the
ships from the loading port to the port of destination in the
United States. That gives us a great deal of familiarity with
the operations on the ships, the nature of the crews.
Additionally, the crew members on many of these ships are a
different caliber than we see on many other merchant ships.
They tend to be long-term employees of the companies that
employ them. They are very highly trained.
The companies invest a lot of time in training in these
people. They tend to keep them for a long time, because of the
sophistication of the ships. So our confidence level not only
in the maintenance of the ships but in the crewing of the ships
is very high.
Mr. Bilirakis. Thank you.
In 2005 the Coast Guard received 14 new boats to meet the
port and waterway security mission. Four went to LNG vessels.
Were there any resources requested in fiscal year 2006,
2007 or in your proposed 2008 budget to meet the expected
growth in the LNG industry?
Admiral Salerno. You are correct on the fiscal year 2006
request. And for 2007 and 2008 there was not a request, and we
are evaluating future needs based on the anticipated growth in
LNG and other dangerous cargoes.
Mr. Bilirakis. Thank you, Mr. Chairman.
Chairman Thompson. Thank you very much.
We now recognize Mr. DeFazio for 5 minutes.
Mr. DeFazio. Thank you, Mr. Chairman.
To Mr. Lesnick, we have had a discussion of the resources
that are available to the Coast Guard. What about the resources
available to your agency? Do you have adequate staffing and
expertise to process this crush of applications and do all of
the work necessary?
Mr. Lesnick. At the moment, Congressman, we don't have a
line item in our budget for this program. We take it out of the
pie.
We have attempted to try to keep a certain portion of the
fees for this so that we could use it to support the staff. So
it can become difficult at times in this sense, but we have
been able to, you know, keep up with the load so far.
Mr. DeFazio. Okay. So the answer is ``no.''
I know it is hard. You know, you have--you know, OMB is
listening, you know. I mean, we had one honest head of--you
know, the Army Corps of Engineers secretary for a short period
of time, a former member of Congress.
And when he came before the Transportation Committee and
Infrastructure Committee and admitted his budget was
inadequate, totally inadequate, to meet the critical needs, he
was fired.
I hope you gentlemen don't feel that kind of pressure
operating in an environment that has to do with national
security from this administration.
And so, you know, I would say that, you know, Mr. Shays's
line of questioning and others--and to the admiral, and knowing
the Coast Guard, the Coast Guard does not have a budget that is
optimal to perform this task and provide maritime security.
I am not going to put them on the spot, but I am going to
make that as an assertion. And I have been on and off the Coast
Guard Committee for more than 20 years. And now we hear that
MARAD doesn't have the resources it needs, and that causes me
concern.
Mr. Lesnick, you said something else that puzzled me,
something about governors of adjoining states having veto
authority over siting. What was that?
Mr. Lesnick. Under the Deepwater Port Act, Congressman, the
governor of the adjacent coastal state has the ability to
approve or deny or approve the application with conditions any
deepwater port application.
And in doing so, normally, they set conditions into the
license that protect the state's interests in the operation of
the port.
Mr. DeFazio. Okay.
Well, then I would turn to Mr. Robinson from FERC. Now, if
California proposed putting an LNG facility offshore, my
governor could veto it in Oregon. But an LNG company can
propose to put an LNG facility in Oregon, and my governor has
no say, is that correct?
As I understand the changes mandated by the Energy Act, it
is up to FERC whether or not that facility can be sited. My
governor does not have veto power. Is that correct?
Mr. Robinson. Does not have veto power similar to the
Deepwater Port Act. However, the state does have authority
under the Coastal Zone Management Act to withhold that permit.
If it is withheld, no site can be constructed.
Mr. DeFazio. Withhold it under what conditions?
Mr. Robinson. Under inconsistencies with the state's plan
for preserving the coast.
Mr. DeFazio. And does the state have to make a legal case
or can they make an assertion? What is the level of proof?
Mr. Robinson. They have to follow the state's procedures
for issuing or denying a coastal zone permit, whatever those
state's procedures may be.
Mr. DeFazio. Okay. And if a state makes that finding, then
FERC cannot----
Mr. Robinson. FERC cannot issue an authorization for the
facility.
Mr. DeFazio. Okay. All right. Let me ask another question.
Is it ideal to build an LNG facility very remote from the
projected point of demand?
I mean, is it a good idea to locate something in another
state and then build a land line for, say, 800 miles or 1,000
miles to the preferred market for that LNG? I mean, do you
think that is optimal? Or maybe we should locate the LNG
facility closer to the end point.
Mr. Robinson. I think a combination of both. We have
existing infrastructure which allows the transport of natural
gas from distant sources. I mean, we grew up with the gulf
production.
Mr. DeFazio. Right, but this is to build an entirely new
pipeline.
Mr. Robinson. But to build a new pipeline from there--I
think that would probably be cost-prohibitive. If you can
locate an LNG facility in a load center, it clearly has
economic and reliability aspects to it that are very positive.
Mr. DeFazio. And what about the FERC approval process for a
very lengthy new pipeline crossing thousands of privately owned
parcels of land?
Mr. Robinson. We do that. I mean, we are currently in the
midst of looking at whether or not to authorize the Rockies
West and Rockies East pipeline, which is a combined 1,500
miles, bringing new gas out of the Rockies to the load centers
in the East.
Mr. DeFazio. Right. But of course, we don't have much
option. If the gas comes out of the mountains, you have got to
go there to get it.
Mr. Robinson. That is correct.
Mr. DeFazio. But with LNG, you could take it to a different
place.
Mr. Robinson. That is why there is such interest in
bringing LNG terminals into the load centers.
Mr. DeFazio. Okay. Because in my case, California doesn't
want an LNG facility, so they want to locate it halfway up my
state, and then build a pipeline that extends for about 800
miles or 1,000 miles down to California to serve the California
market.
And you are saying that would be cost-prohibitive in your
estimation.
Mr. Robinson. No, it depends on what they will pay for the
gas. And California pays a good deal for the gas, because they
are at the end of the pipe.
Mr. DeFazio. Right. Okay.
If we could just--if the chair would indulge us for a
moment, I just want to return to--again, having served on the
Coast Guard and Maritime subcommittee for many years, and as
raking member for a while.
It is mentioned in the deepwater application--or Mr.
Lesnick mentioned about the preference for U.S.-flag vessels.
We will hear about that later.
But it says provide the nation of registry for and the
citizenship of officers and crew members serving on vessels
transporting LNG to deepwater ports.
What does the nation of registry for mean, Admiral? Does
that mean we know who actually owns that ship?
Admiral Salerno. Sir, the nation of registry just simply
indicates where the vessel is registered, what flag it flies.
Mr. DeFazio. And it has nothing to do with where the ship
is from or who owns it.
Admiral Salerno. It is not an indication of ownership.
Mr. DeFazio. Okay. Now, are we able to pierce the veil now?
I understood that supposedly we were creating more transparency
for ownership post-9/11, because in the pre-9/11 world Osama
bin Laden could own a fleet of freighters that are registered
at Malta.
And I have been to Malta and asked the registrar there if
he would please reveal the ownership of vessels to me, and he
said, ``Absolutely not. We keep that secret.'' Has that
changed?
Admiral Salerno. We do track ownership, managing owners, of
each vessel. Often, as I am sure you are aware, the owners are
owned by other entities.
Mr. DeFazio. Right.
Admiral Salerno. And that does become somewhat difficult to
pierce the veil, as you say, but I think we have gotten
somewhat better in the past few years. But certainly----
Mr. DeFazio. But wouldn't it be desirable to just have an
outright requirement that the U.S. would sponsor at the IMO
that would say we want to know who the ultimate owner of each
and every ship that is going to call on the United States is?
Wouldn't that be a good thing to know? I mean, I am really
not comfortable with the idea Osama might own a fleet out
there.
Admiral Salerno. Sir, I could probably get back to you on
the record----
Mr. DeFazio. Okay.
Admiral Salerno. --for the extent of our knowledge on that,
on how we pierce that veil.
Mr. DeFazio. Right. Okay. And then I won't belabor it again
since I brought it up in the other session, but it is not--and
that is the not really knowing who the crews are outside of
those on these LNGs, and we will get into that another time.
Thank you, Mr. Chairman, for being so tolerant.
Chairman Thompson. Thank you very much.
We will now yield to the gentlelady from Texas, Ms. Jackson
Lee, for 5 minutes.
Ms. Jackson Lee. Mr. Chairman, thank you so very much.
Thank the witnesses. And bells have begun to ring, so let
me be as focused as I can, coming from one of the largest ports
in the world, the port of Houston.
This is a vital, vital concern to me. And whenever I am in
front of the Coast Guard or they are in front of me, I take it
upon myself to again thank them for work that is usually unsung
and sometimes not noted, the vitality of your work.
And let me applaud you for what I think will be part of the
annals of history of the heroic work in Hurricane Katrina. And
I know you continue to do that every day.
To Mr. Wells, let me just--I noticed that part of your
research had to do with acknowledging that in the LNG tankers
it might be more susceptible to fire as opposed to explosion,
if I am hearing or reading correctly.
And if not, just clarify that, because we are here dealing
with terrorism and homeland security. What is the danger of an
LNG as it relates to a terrorist attack, a tanker?
You had your study--were you able to assess that?
Mr. Wells. The available research that has been conducted--
we were focused on LNG threats to public safety. It is clearly
the fire potential, and there was consensus among the experts
it is extremely unlikely and very difficult to effect an
explosion in an unconfined space.
Clearly, the research indicates there are other energy
commodity vessels, like LPG, that have even greater explosive
capability than LNG.
Ms. Jackson Lee. Well, Mr. Chairman, just on that note, I
hope that we will take it to the next step of exploring
additional research, because I think this is a vital question.
And let me move quickly.
Mr. Wells, do you have an assessment as to whether the
Coast Guard--GAO has an assessment--needs or has enough
resources as relates to this issue with the LNG tankers?
Mr. Wells. Fortunately, as an audit agency and oversight
agency reporting to the Congress, we are not involved in the
resource allocation decisions by the Congress.
But clearly, GAO has work that is in reporting form that
will talk about the Coast Guard's achievement of their current
mission or not achieving getting everything done with their
existing resources.
And couple that with the increasing demands, it is
certainly going to be challenging for them to figure out a way
to get the necessary resources to meet the needs.
Ms. Jackson Lee. Thank you very much. That answers it. They
have needs and they have responsibilities, and they may not
have matching resources.
Admiral Salerno, let me just ask the pointed question.
Again, I think it is important. We are here to help. Do you
have enough resources, as was just indicated, to meet the
mission and responsibilities that you have?
Admiral Salerno. Let me answer that in a couple ways. We
are assessing that. We are doing a number of things. And as was
just indicated, the overall port security mission is broader
than just LNG.
Ms. Jackson Lee. Well, Admiral, because the time is going,
can you indicate that you don't think you have enough resources
but you are assessing it?
Admiral Salerno. We are assessing. We are looking at risk
across the board, through all dangerous cargoes.
Ms. Jackson Lee. And you may not have enough, but you want
to assess it before you tell us.
Admiral Salerno. We want to fully characterize the risk and
then take a look at where we have our resources placed to see
if they can be reallocated. And then if we are short, then
obviously we would look at----
Ms. Jackson Lee. That is a good soldier, Admiral, and I
really do respect you. I don't think you are going to find that
you have enough resources.
But let me ask you whether or not you know the countries
that we receive LNG from. And also, are these countries
compliant with the International Ship and Port Facilities
Security Code? Do you know the countries?
Admiral Salerno. Yes, ma'am.
Ms. Jackson Lee. Are they compliant?
Admiral Salerno. Yes, they are.
Ms. Jackson Lee. All of them, Nigeria, Algeria?
Admiral Salerno. We have visited--the primary is Trinidad
and Tobago and Algeria, and we have sent Coast Guard teams to
those countries and assessed that.
Ms. Jackson Lee. Would you provide this committee with a
report on that? I am not sure whether we have that. I would
appreciate it. I am only moving because I need to move--I would
like a report on that, sir. And you have added Trinidad, so
that is good.
Are you concerned about the frequency and the nationality
of stowaways that have been confirmed on international vessels,
particularly from international ports? And have they been
vetted by the U.S. Coast Guard?
Admiral Salerno. We are concerned about stowaways. We have
procedures in place to deal with them. Part of our port visits
overseas--and we visit about--on tap to visit about 150
different countries--is to look at the security systems in
place.
Ms. Jackson Lee. You are on tap. Have you visited those
countries or are you in the process of visiting?
Admiral Salerno. In the process. We visited about over 70
countries so far. And part of our assessment is the security
measures at the facility.
Ms. Jackson Lee. And have you vetted the stowaways? Have
you been able to--once they get off, or----
Admiral Salerno. When stowaways are detected--and
typically, they are reported by the ship's crews at sea, so we
know in advance of----
Ms. Jackson Lee. And are you there to receive them?
Admiral Salerno. There is a Coast Guard and Customs and
Border Protection response.
Ms. Jackson Lee. I would that you would need more money
just to go to 150 countries. This is my last question.
According to your testimony, the Maritime Administration is
working to develop and expand LNG training programs so as to
provide immediate employment for entry-level mariners, both
licensed and unlicensed.
Can you provide us with information about this training?
Mr. Lesnick. Yes. We are working with the state academies,
one of which would be in your state----
Ms. Jackson Lee. Absolutely.
Mr. Lesnick. --and the federal maritime academy and the
union training schools to get a curriculum together to stand
up----
Ms. Jackson Lee. What is your time frame for that?
Mr. Lesnick. It is almost immediate. They were already
ready to go. These new manning agreements that we have been
signing----
Ms. Jackson Lee. Will we have some of those in the school
that is in my area?
Mr. Lesnick. Yes, Congresswoman.
Ms. Jackson Lee. And do you have the resources to add for
this training?
Mr. Lesnick. The state schools could use additional
resources to provide that.
Ms. Jackson Lee. Mr. Chairman, I think there is a lot of
work that we could do in helping the Coast Guard.
And I do think there is a question of resources, and I
would like to join you in your leadership in helping with the
training and helping with some of the ports that are going to
need additional resources for the Coast Guard.
With that, I yield back. I thank you.
Chairman Thompson. Thank you, Madam Jackson Lee. I look
forward to working with you, too. There is no question about
the need for additional resources.
Let me thank the panel for your testimony here before the
committee.
Let me say, before our second panel, we have about six
votes to take before we can come back. So we are probably
looking at about an hour from now. Do you want to say 2
o'clock?
Okay, about 2 o'clock we will reconvene for panel two. The
committee is recessed.
[Recess.]
Chairman Thompson. We have talked with Ranking Member King,
who has indicated it would be all right to start until he
comes.
We would like to reconvene this hearing and welcome our
second panel. I welcome the panelists, Mr. Ron Davis and Dr.
Phani Raj, to the audience.
Mr. Davis has served as MEBA's district and national
president since early 2002. He began his seagoing career in the
Navy, which included time in Vietnam. He also sailed on MEBA
contracted ships from 1978 to 1991, when he was elected to
union office.
Dr. Raj--I hope I am pronouncing it--all right, thank you
very much--has over 30 years of experience working in the LNG
field. He has authored over 80 technical reports and 50 papers
in this highly complex area. He was also one of the experts GAO
consulted during the audit that we heard about from the
previous panel.
Without objection, full statements will be inserted into
the record. I now ask each witness to summarize his statement
for 5 minutes, beginning with Mr. Davis.
STATEMENT OF RON DAVIS, PRESIDENT, MARINE ENGINEERS' BENEFICIAL
ASSOCIATION
Mr. Davis. Thank you, Chairman Thompson. The safe and
secure transportation of liquefied natural gas to the United
States is of critical importance, and we all appreciate your
holding this hearing.
For 137 years, MEBA has represented Coast Guard-licensed
deck and engineering officers serving in the commercial and
government fleets. Despite our presence in nearly every aspect
of the maritime industry, there are practically no Americans
employed on LNG ships today.
The worldwide demand for LNG is increasing at such a
tremendous rate that it is very difficult for the maritime
industry to keep up. It took over 40 years for the LNG fleet to
reach 200 vessels. It is now expected that the fleet will hit
300 vessels by 2010, just 3 years away.
With this rate of expansion, there is an increased demand
for qualified mariners. Right now, the international fleet is
facing a severe shortage of qualified crews.
The various ship operators have even resorted to poaching
officers from each other, paying over $20,000 a month for
qualified officers.
As the size of the fleet expands, the qualified mariner
pool shrinks. There is a significant chance that the standard
of education will suffer and mariners with substandard training
will begin taking these jobs.
That puts our nation at risk. If this shortage is not
addressed, it will only be a matter of when, not if, a major
safety incident takes place.
Security is the major concern as well. As you know, a
number of studies discuss terrorist attacks on LNG tankers.
MEBA believes that the greatest threat to an LNG tanker would
come from a knowledgeable crew member deliberately sabotaging
the vessel.
Therefore, we must ensure the proper vetting for LNG crews.
Because there is no uniform, completely trustworthy system for
vetting foreign mariners, this is next to impossible under the
current system.
Background checks of the level of thoroughness conducted on
Americans by the Coast Guard and TSA are only performed on
Americans and not foreign crews.
While the Coast Guard does require crew lists from vessels
entering U.S. ports, they have no real way to be sure that
those foreign crews on board are who they say they are.
U.S. merchant mariners receive their credentials to work
from the Coast Guard. Foreign mariners do not. U.S. mariners
undergo extensive background checks through the FBI. Foreign
mariners do not.
U.S. mariners are vetted through the National Driver Record
Database. Foreign seafarers are not. U.S. mariners will be
subject to terrorism background checks through TSA. Foreign
seafarers are not.
Finally, U.S. merchant mariners are U.S. citizens or
persons lawfully admitted for permanent residency. The mariners
crewing these ships are not.
My solution to this problem is a simple one. Use U.S. crews
on LNG vessels calling on U.S. ports. Americans are available,
well-trained, economical and thoroughly vetted.
Putting Americans on board these ships will go a long way
to ensuring the safety and security of these vessels both at
home and abroad.
The United States is the leading producer of mariners. All
of the state and federal training academies and union training
schools have added or updated their LNG courses.
The Calhoun MEBA Engineering School, for instance, recently
installed a state-of-the-art vessel and LNG simulator. Right
now, MEBA has a pool of qualified and experience senior LNG
mariners who are ready, willing and able to sail LNG ships.
And as I have already stated, we undergo the most rigorous
background checks in the maritime world. Despite all of this,
it has been extremely difficult for Americans to break back
into the LNG trade.
Foreign prejudice against American mariners is rampant.
Congress has recognized this and has taken steps to assist us.
Thanks in part to these efforts, several operators have
agreed to expand their LNG crews to include U.S. citizens,
including Suez LNG, Freeport McMoRan and Excelerate Energy,
which I must commend.
I am pleased to announce that MEBA has recently signed a
memorandum of understanding with Excelerate Energy that will
allow our members to sail on their international fleet of LNG
tankers.
This is a major step forward for the U.S. merchant marine
and we look forward to a continued long-term relationship with
Excelerate. We hope the other operators soon follow suit.
We have made progress, but we can't afford to rest here.
The responsible operators I have mentioned are only a portion
of the LNG industry. Congress must continue to press for
Americans on board LNG vessels, and MEBA offers any assistance
you may need in this endeavor.
The American merchant marine is known as the fourth arm of
defense. Why not use us? Why not put us on LNG ships?
Thank you.
[The statement of Mr. Davis follows:]
Prepared Statement of Ron Davis
Thank you Chairman Thompson and Ranking Member King, and thank you
to the rest of the Committee for inviting me to speak before you today.
I would specifically like to thank you for allowing us the opportunity
to discuss the unique issues we face in safely and securely
transporting Liquefied Natural Gas to the United States.
My name is Ron Davis, and I am the President of the Marine
Engineers? Beneficial Association. The MEBA is the nation's oldest
maritime labor union, representing deck and engineering officers
licensed by the United States Coast Guard. Our mariners serve in a
variety of capacities in the commercial, government owned and operated,
and domestic fleets, as well as in shore side employment.
The MEBA was proud to take a leading role in the development of the
transportation of LNG by ocean tank vessel in the 1970s. Our members
crewed U.S. flag LNG vessels until 2001. Today, however, not a single
LNG tanker flies the American flag, and none of these vessels are
crewed by Americans. We feel that this represents a serious threat to
America, and we have been working to restore American mariners aboard
this important segment of the maritime community.
Need for Shipboard Import of LNG to the United States
According to the Federal Energy Regulatory Commission, U.S. natural
gas demand is expected to increase by 40% by 2025 to 30.7 trillion
cubic feet (TCF).i However, domestic supply, which has not
equaled demand for many years, will only increase by 14.5%. Without
intervention, our natural gas supply will not keep pace with industry
and the public's demand. Mr. Jeff Wright, Chief of the Energy
Infrastructure Group, Office of Energy Project, Federal Energy
Regulatory Commission cites the following reasons for this situation:
Decline in the United States' underground domestic gas
reserves;ii
Canada's problems with flattening gas production
in the Western Canadian Sedimentary Basin (WSCB) and its need
to fulfill its own demands;iii and
Continuation of Mexico's growing economy with Mexico
keeping an increasing share of its natural gas to meet its
future demands.iv
This means the United States cannot rely solely on natural
gas produced in North America. Therefore, LNG will need to be imported
to the United States on oceangoing LNG tankships.
Thorough Vetting of U.S. Merchant Mariners Provides Unmatched
Shipboard and Deepwater Port Security
All LNG entering the U.S. is carried on foreign flag ships operated
by either non-U.S. citizen mariners, or aliens who are not lawfully
admitted to the United States for permanent residence. Unlike foreign
seamen:
U.S. Merchant Mariners receive their credentials to
work from the U.S. Coast Guard;
U.S. Merchant Mariners undergo extensive background
checks performed by the Federal Bureau of Investigation;
U.S. Merchant Mariners are background checked through
a National Driver (vehicle) Record database;
U.S. Merchant Mariners will also be subject to
jurisdiction of the Transportation Safety Administration (TSA)
where they will be vetted through a terrorist watch database in
order to receive a Transportation Worker Identification Card
(TWIC).
U.S. Merchant Mariners are citizens of the United
States or aliens lawfully admitted for permanent residence.
American mariners undergo a stringent and thorough vetting and
credentialing process. Our Coast Guard-issued license is considered
accurate (with regard to identity of the holder) and valid with respect
to the qualifications and ability of the individual mariner. Moreover,
the document is relatively tamper-proof. Each mariner goes through an
extensive background check by several federal agencies including the
Coast Guard, Federal Bureau of Investigation and now with the TWIC
coming into effect, the Transportation Security Administration.
While foreign mariners may be required to comply with their
government's regulations as well as international standards, the
validity of some of the credentials is suspect. A few years ago,
International Transport Workers Federation President, David Cockroft,
purchased an authentic Panamanian first officers certificate and sea
book despite no practical maritime experience. The Seafarers'
International Research Centre at the University of Wales investigated
the issue of fraudulent qualifications. Its preliminary findings
revealed 12, 653 cases of forgery in 2001.
Federal and state government, local municipalities and the
communities surrounding LNG import terminals can be assured, that with
American mariners, the LNG vessels are manned by professional seafarers
who have the integrity and the training necessary for the safe
transport of LNG.
Congress Recognizes Need for U.S. Mariners
Congress has recognized the security that U.S. mariners bring to
LNG vessels and has taken steps to promote enhanced security. Last
year's Coast Guard Authorization bill included language that gave
priority application processing to companies seeking LNG terminal
licenses if they commit to using American crews, and it also directed
the Maritime Administration to find ways to promote the use of
Americans in this sector.
Problems in Growth of Demand for LNG and with Incoming Generation
of LNG Officers
On June 20, 2006, Reuters reported that a growing global demand for
liquefied natural gas and tight supply of specialized tankers and crew
create a risk of dangerous lapses in standards of security. See, Darwin
(Reuters), LNG Demand Growth Risks Fall in Shipping Standards, June 20,
2006.
Setting aside the security issue of foreign mariners, the United
States must take into consideration the risks involved with poorly
trained, insufficiently qualified and questionably vetted mariners who
may deliver LNG to its shores. For instance, Yea Byeon-Deok, professor
and LNG initiative coordinator of the International Association of
Maritime Universities, recently stated at a conference in Australia:
``Nobody knows what would happen if a significant accident occurred on
a large LNG carrier. All we can say is that a 100,000 ton tanker has
four times the energy potential of the atomic bomb used to hit
Hiroshima. . . Many sub-standard vessels have begun to appear as demand
for LNG increases, while there is a chronic shortage of experienced
crew.''
New orders for construction of LNG vessels imply a need for 3,575
officers over the next three years, Professor Yea said, of which 60%
would need to be at senior or experienced level. Yea warned that
``recruitment and training were falling dangerously short of
requirements to staff complicated vessels which could make dramatic
targets for potential terror attacks.'' Reuters, June 20, 2006. Mr. Yea
pointed out that the growth in ``flag of convenience'' ships which fly
alternative flags to the country of ownership, allow the owners to
avoid taxes, quality control and labor regulations which evidences
deteriorating standards.
The younger generation of sea-going deck and engineering officers
is withdrawing from the industry prematurely. These junior officers are
showing less and less interest in continuing to go to sea and they are
typically leaving for shore-side positions prior to taking on senior
level seagoing positions. This has made it difficult for ship owners
and operators to ensure a sustained supply of senior officers. There is
as of yet no effective means to counter this tendency. This data is
based on a report in the U.S. Coast Guard Journal of Safety at Sea,
Proceedings regarding the international (non-U.S. Merchant Mariner)
pool of shipboard officers.
The U.S. Merchant Marine was not considered in the aforementioned
report. Indeed, had the U.S. Merchant Marine been considered, the
resulting report would have shown that there is a vibrant and growing
U.S. Merchant Mariner pool resulting in part by investments made in the
passenger, freighter and tanker vessel maritime sectors. Moreover, it
makes sense to staff LNG vessels delivering cargo to the United States
with U.S. merchant mariners. U.S. merchant mariners are true patriots
and care about their country--they would not be ``for hire'' foreign
personnel with little or no connection to America other than a job that
provides a paycheck. U.S. Coast Guard licensed officers and crew
provide answers and solutions to many of the safety and security
concerns surrounding the importation of LNG.
Wide Scale Officer Shortage is Resulting in Foreign Ship
Operators ``Poaching'' LNG Officers; Poor Training; Steep
Decline in Safety and Security; and Violations of International
Law
As reported in numerous articles and studies conducted by leading
international maritime trade publications including Tradewinds and
Fairplay, LNG owners and operators are lashing out at each other with
allegations of ``poaching'', conducting insufficient training in
violation of ISM Code as well as failing to properly check past
employment references.
The sudden and sustained surge in global demand for liquefied
natural gas and the worldwide shortage of mariners with LNG and steam
experience is leading to predictable results. Ship managers seem
willing to do whatever they can to get their ships fully crewed in the
face of a growing wide-scale officer shortage. ``The industry had
previously grown slowly, so companies were able to train manpower and
expand operations at a comfortable rate of two to three ships every two
years,'' Keith Bainbridge, director of LNG Shipping Solutions, told
Fairplay magazine in 2005 ``But where an industry experiences 40--50%
growth within a couple of years, it will split at the seems,'' he
predicts.v
This manpower crisis is made even worse by new ship managers
entering the LNG trade. A Fairplay article titled, Poaching War for
Crew Erupts, cited the ``voracious appetite for scarce manning
resources, both at sea and onshore. This has created severe competition
among LNG owners.''vi
The Society of International Gas Tanker and Terminal
Operators LTD (SIGTTO) has recognized the acute shortage and the
reaction by some. ``A short-term answer for an LNG vessel operator is
to ``poach'' crew from another such operator but, clearly, the long-
term answer is training, training, and further training. SIGTTO
members, as much as anyone, wish for the quite unique safety record of
LNG shipping to be preserved. The influx of new personnel into the
industry is of concern, especially if there is a temptation by a
minority of operators to ``cut corners'' and put officers into
positions of responsibility on a LNG carrier before they have been
properly trained.''vii
In an article titled Officer Crunch Sparks Safety Alarm,
Anglo Eastern Ship Management's training director Pradeep Chawla states
that ``intense pressure to promote more maritime officers is resulting
in inexperienced officers making more mistakes and more dangerous
situations on board. The training director noted that, ``shortages have
made it harder to retain officers because manning agents use higher
wages to lure away experienced seafarers, especially in LNG/LPG and
other specialized trades.'' xiii Moreover, not all companies
train officers, with many resorting to poaching.
The crewing crunch is giving rise to new and dangerous theories of
crewing to meet the sustained demand. ``Some operators are
contemplating an airline-style approach, training their crew units to
ever-higher standards and frequently rotating them among vessels. That
would fly in the face of an industry that had, until last year, been
characterized by its conservatism on crewing and had viewed rapid crew
rotation as a threat to safety.'' The article mentions that with the
shortage, there is an ``increasing incidence of crews of strangers
being cobbled together with precious little time to develop mutual
trust and overcome their natural fear of blame.''
In an article titled Near Calamities in Cargo Operations, Fairplay
details two case studies, on international vessel crewing practices, to
illustrate the dangers of new crew members who are unfamiliar with the
vessel or on-board procedures. ``In both incidents, one of the factors
that contributed to the near calamities was the fact that one or more
of the crewmembers involved were new to the ship and unfamiliar with
all aspects of the vessel.'' ``The importance of learning the
idiosyncrasies of a particular vessel cannot be overstressed, and even
when crew are transferred to sister ships they should not assume that
every feature of the ships will be the same.'' As noted above, short
cuts in manning and ``inventive'' solutions to crew shortages can prove
to be a recipe for disaster.ix
The consequences of crewing instability and poaching can also
lead to serious deterioration of the relationship between mariner and
management. ``There has to be a management team in which officers can
pick up the phone and discuss problems openly, rather than hiding them
until it is too late'' says Simon Pressly, GM of Dorchester Marine, an
LNG vessel operator in a Fairplay article. The author continues with
the observation that, ``Unfortunately, with poaching so rampant, the
dangerous lack of crew continuity is likely to continue until operators
start making the requisite investments in manpower training.'' x
Tradewinds states that the LNG-crewing shortage is giving
rise to some serious shortcomings that are a direct threat to the
industry's safety record and are in violation of the International
Safety Management (ISM) Code. Some operators and ship managers are
employing senior-level ship's officers that were terminated from
employment by competing companies due to poor performance and substance
abuse.xi
On another front, big international shipping companies and
ship management firms are feeling the LNG crewing pinch. Some operators
are enticing LNG shipboard officers to switch companies by offering
wages at 30%--40% higher than what has been paid in the past--and
officers are switching companies and leaving their former employer in
crisis. Some companies are offering over $18,000 a month (in wages
only, not including benefits) to attract qualified LNG
officers.xii
All decision makers and stakeholders involved with the
importation of LNG to the United States must take notice of what is
going on in the international market. With growing natural gas demands
and some 50-plus applications on the books for LNG import terminals,
the American people need to be assured that the most highly trained and
experienced personnel are transporting security sensitive LNG to the
United States. There is no room for error when it comes to liquefied
natural gas. Like no other time in history, the economics are in place
whereby the U.S. Merchant Marine can economically and safely deliver
LNG cargo; provide a stable pool of mariners for the long term; provide
the highest amount of training; and comply with all U.S. and
international laws.
International Consequence: Insurance Underwriters Deeply Concerned
with Inexperienced Crews Aboard LNG Vessels
A recent article titled LNG Ships Facing Premium Boost details the
nervousness of the insurance industry as the LNG fleet suffers through
poorly managed growing pains. ``Underwriters appear to be changing
their view of LNG vessels, which have traditionally been regarded as
particularly well managed, despite being costly and potentially
hazardous.'' Now, higher insurance premiums are the prospect for LNG
vessel owners as a result of ``a big deterioration in the claims record
of the world gas fleet.'' Marsh, the largest insurance brokering group
issued a report concerning claims of more than $400 million run up by
the LNG fleet.xiii
Higher insurance premiums are in prospect for owners of LNG
carriers after a spate of claims including operational incidents have
left insurance underwriters facing big losses according to
Marsh.xiv Marsh reports that risk profile is increasing due
to a shortage of crew with LNG experience.xv
With 200 LNG vessels in service and over 100 on order, Marsh
identifies a number of factors associated with the rapid growth as
adding to the risk profile of the gas-ship fleet including shortage of
crews with LNG-carrier experience and new owners entering the market
with the intention of trading vessels on the spot market rather than
traditional long term charters.xvi
The shortage of mariners in the international fleet is dire.
It is abundantly clear, therefore, that the U.S. Merchant Marine must
enter the market.
International Reaction: Responsible Shipping Ministries React
to Manning Shortcuts and Abuse; Use of National Flag Vessels
Promoted By Major Importers
Some of the world's largest importers of LNG, Japan and Korea, are
an increasingly powerful consumer of LNG, have made registry of LNG
ships a matter of national maritime policy. ``Japan transported about
43% of its total LNG import of 59.1 million tons in 2003 on Japanese
owned and controlled ships. Similarly, Korea transported about 61% of
its LNG imports of 19.3 million tons in the same year on Korean
controlled ships. In the combined import of Japan and Korea, third-
party owned ships constituted only 8.3 percent,'' says a shipping
industry representative.xvii It is notable that Japanese and
Korean controlled vessels are in respectable registries and do not cut
corners on crewing in order to compete on the world market.
India's Shipping Ministry has attempted to rejuvenate its merchant
marine by requiring Indian manning and Indian registry for LNG vessels
importing to the Indian coastline. However, another branch of the
Indian government, the Indian Ministries of Commerce and Petroleum &
Natural Gas, has prevailed in the internal battle, handing India a set
back in its efforts to build a domestic flagged LNG fleet.
Conclusion
With 97% of all cargo imported to United States being carried on
vessels that are not registered under the American-Flag and not crewed
by U.S. citizens, one would think that the safe and secure
transportation of security sensitive cargo would be a serious concern.
More to the point, at this time 100% of all Liquefied Natural Gas that
enters the United States is carried on ships staffed by non-U.S.
citizen mariners. The MEBA strongly believes that the use of American
mariners is a critical component to the safe and secure importation of
LNG to the United States.
With this in mind, some responsible corporate citizens in the LNG
sector have recently agreed to expand their crewing practices to
include U.S. citizen crews on LNG tankers. These companies, Suez LNG/
Neptune, Excelerate/Northeast Gateway and Freeport-McMoRan, must be
commended. We must also praise Maritime Administrator Sean Connaughton
and the Maritime Administration for their efforts to promote American
mariners on LNG tankers. Without their help, the progress made with
these companies would have been much more difficult.
We look forward to working with Congress and the Administration
moving forward to further protect our communities and maritime
infrastructure.
------------------------
i Annual Energy Outlook 2005, Energy Information
Administration, U.S. Department of Energy, February 2005, Table 13.
ii Mr. Wright cites the Annual Energy Outlook 2005, Energy
Information Administration, U.S. Department of Energy, Table 13, which
reaches the conclusion that production from conventional underground
gas deposits is projected to decline between now and 2025. This decline
is somewhat offset by increased gas production from non-conventional
domestic gas sources (most notably coal-bed methane), increased
production from deep water sources (greater than 200 meters) in the
Gulf of Mexico, and commencement of deliveries of Alaska gas to the
lower 48 states. The Alaskan volumes are problematic according to Mr.
Wright, because there has been no application to construct necessary
infrastructure to transport the gas, and the timeline from application
to first delivery is approximately 10 years.
iii The National Energy Board of Canada states, the Western
Canadian Sedimentary Basin (WSCB) accounts for more than 90% of the gas
production in Canada and for about 23% of North American natural gas
production annually. In the last few years, gas production from the
WSCB appears to have flattened after many years of growth, leading to
increased uncertainty about the ability of industry to increase or even
maintain current production levels from the basin over the longer term.
See, Canada's Conventional Natural Gas Resources: A Status Report,
National Energy Board, April 2004, pp. 9--10.
iv Exports of gas to Mexico have increased greatly in the
last few years. These exports do not constitute a large out-flow of gas
at present. However, the Mexican economy is growing and if it continues
to grow, its demand for natural gas will increase and require the
United States to import an increasing amount of gas to meet, not only
domestic needs, but also the needs of Mexico. In other words, what
Mexico imports and shares today by way of natural gas, Mexico may not
be able share later. Jeff Wright, Chief, Energy Infrastructure Policy
Group, Office of Energy Project, Federal Energy Regulatory Commission,
Fall 2005.
v Poaching War for Crews Erupts, Fairplay International
Shipping Weekly, February 24, 2005.
vi Id.
vii SIGTTO News, September 2005, p.5.
viii Poaching War for Crews Erupts, Fairplay International
Shipping Weekly, February 24, 2005.
ix Near Calamities in Cargo Operations, Fairplay
International Shipping Weekly, December 1, 2005.
x Poaching War for Crews Erupts, Fairplay International
Shipping Weekly, February 24, 2005.
xi LNG Crewing Shock, Tradewinds, February 25, 2005
xii Philippines Dangles $18,000 Carrot, Tradewinds, January
9, 2006; See also, LNG Wage Anger, Tradewinds, November 4, 2005;
Officer on $320,000 a year, claims Sigtto, Tradewinds, November 4,
2005.
xiii Tradewinds, Insurers Get LNG Jitters, LNG Ships Facing
Premiums Boost, March 17, 2006
xiv Id.
xv Id.
xvi Id.
xvii Foreign Flag Vessels May Bring Down LNG Import Costs,
The Hindu Business Line, December 13, 2005.
Chairman Thompson. Thank you very much, Mr. Davis.
Dr. Raj, please summarize your statement for 5 minutes,
please.
STATEMENT OF PHANI RAJ, PhD PRESIDENT, TECHNOLOGY & MANAGEMENT
SYSTEMS, INC.
Mr. Raj. Thank you, Mr. Chairman. Mr. Chairman, members of
the committee, it is a privilege and high honor for me to be
invited to testify before this committee.
I come before you to share some of my knowledge on issues
concerning liquefied natural gas, or LNG, and the public's
concern on its hazards.
My research, both experimental and modeling of the behavior
of hazardous materials, including LNG, have been funded by U.S.
government agencies.
The LNG industry, to whom I have provided and continue to
provide consulting services, has recently funded some LNG fire
research jointly with the United States Department of
Transportation.
The testimony I am presenting today is based on my
professional and scientific experience and was entirely
prepared by me.
However, I wish to acknowledge for the record that my
professional time and expenses for preparation and appearance
before this committee is being underwritten by the Center for
Liquefied Natural Gas, CLNG, which is a coalition of entities
active in the LNG industry.
Mr. Chairman, in regard to LNG issues, I wish to make the
following six observations. One, the LNG industry is one of the
safest industries, very enviable record of safety for over 40
years.
Worldwide, there have been over 40,000 shipments of LNG to
ports that have high marine traffic, and many of which are also
near populated areas.
In the U.S., millions of gallons of LNG have been
transported, imported, handled, gasified, and have provided
energy to the public, all with the industry's exemplary record
of safety.
In the 40 years that this activity of supplying the vital
energy needs of the country has been going on, not a single
person of the public has been injured or suffered a fatality by
any LNG incident.
Also, the total number of worker casualties in the LNG
industry in the entire world over the last 40 years of
operation can perhaps be counted on one's fingers.
Number two, LNG, propane, gasoline, jet fuel and other
hydrocarbon fuels, are all members of the hydrocarbon fuel
family. The combustion properties of LNG and other hydrocarbons
have more in common than in their differences.
A large LNG fire will be very similar in radiant heat
emission characteristics to a large fire of propane, gasoline,
jet fuel, et cetera, all of them forming very smoky fires.
Currently used LNG hazard assessment models have layer upon
layer of conservative calculations, making the predicted
distances to hazard substantially more than what it would
likely be in reality.
This is due to lack of information on how large spills, and
especially large fires, behave. All we have now are data from
small tests.
Our confidence in extrapolating these large spill phenomena
is low, and this leads to variations in predictions by
different researchers.
Larger LNG pool fire tests that are being planned will
provide the necessary framework for the development of
realistic fire models.
Number four, other research that are equally important as
pool fire tests and modeling should be undertaken to determine
the type and magnitude of other hazards which may, under
certain circumstances, become the more important hazard
scenarios rather than the pool fire.
These include, for example, water-LNG interaction, water
intrusion into LNG tanks, and considerations of a fireball type
of burning. The overall combined hazard may be, however,
smaller than predicted if only the pool fire is considered.
Focusing only on the consequences of a perceived worst case
rather than the overall risk from an activity will result in
poorly utilized and improperly allocated resources, not to
speak of the economic penalties that may result.
Risk analysis as a tool is being increasingly utilized in
the U.S. for decision making, but only in bits and pieces. The
single important reason for the lack of universal adoption of
risk-based decision making is the lack of standards for the
levels of risk that are acceptable to society.
Mr. Chairman, in summary, the LNG industry operates very
safely. Further research and its results will lead not only to
enhancing our knowledge for better evaluations of safety but
also help to educate the public on the real issues.
Mr. Chairman and members of the committee, I thank you for
this opportunity to testify before your committee. I will be
happy to answer any questions.
[The statement of Mr. Raj follows:]
Prepared Statement of Phani Raj, PhD
Mr. Chairman, Mr. King, Members of the Committee, it is a privilege
and high honor for me to be invited to testify and share my knowledge
on liquefied natural gas (LNG) safety related to accidental or
intentional breach of cargo tanks in a LNG vessel.
Introduction
I come before you as a researcher in the field of LNG safety with
over 30 years of experience in conducting experiments, analyzing the
test results and developing mathematical models for the behavior of LNG
upon its release into the environment and the hazards it may pose. My
research projects related to LNG have been funded primarily by US
Federal agencies (US Coast Guard and US Department of Transportation)
and to a lesser extent by the LNG industry. I was one of the members of
the research team (and the principal author of the technical report)
that conducted the field experiments in mid 1970s to understand the
different behavior phenomena associated with the release of LNG on
water, including that of the pool fire on water and its radiant heat
emission characteristics. This series of tests, which to this day
remains as the only comprehensive set of experiments on water, was
funded by the United States Coast Guard, and conducted in the US Navy
testing facility in China Lake, CA. Many of the mathematical models
used today are in one way or other based on the findings from this
series of tests, though the test sizes were of a modest scale compared
to sizes of postulated spills to which the models are being applied
now. My recent research, sponsored jointly by the Pipeline & Hazardous
Materials Safety Administration (PHMSA) of the US Department of
Transportation and Distrigas of Massachusetts, LLC (DOMAC), has been to
evaluate the data from the largest LNG fire experiment to date and
model the characteristics of very large LNG pool fires and their
radiant heat effects. This research and the model developed are based
on the data from larger size LNG fire tests conducted in France in
1987. The model and the findings, which have been published in a peer
reviewed technical journal, indicate that large LNG fires behave quite
differently than the smaller scale fires (used in China Lake tests)
and, in fact, radiate less heat per unit fire area. Other research that
I am currently involved in includes the determination of the tolerance
(without injury) of human beings to LNG fire radiant heat exposure, and
the degree of protection provided by ordinary civilian clothing and
other intervening objects to the public from the effects of radiant
heat from a large LNG fire.
In my capacity as a scientist and researcher in the field of LNG
behavior modeling, I have (i) provided consulting support to the
Government agencies, the LNG industry, Standards setting bodies, (ii)
testified before administrative and regulatory proceedings, (iii)
presented many scientific research findings before peer groups,
responded to the safety questions from the public in public hearings,
(iv) trained firemen and first responders on the properties and
behavior of LNG, and (v) authored a number of technical publications in
reputable journals. I also serve on the LNG Standards Committee of the
National Fire Protection Association (NFPA), which has developed a
consensus standard on LNG facility design, LNG handling and storage,
and personnel training requirements. Parts of this standard, especially
on LNG fire hazard assessment and protection, have been incorporated in
federal regulations.
I review below some of the important questions that have been
raised in scientific forums and public debate on LNG behavior and
safety and provide my views on the subject. My testimony below will:
(i) Comment on the exemplary safety record of the LNG industry
both in the US and worldwide
(ii) Highlight some of the LNG properties that have an impact
on potential hazards and compared them with properties of other
common fuels,
(iii) Discuss the knowledge related to what is known and
unknown in mathematical modeling to predict adverse public
impact distances from LNG releases,
(iv) Identify immediate and near term research needs to fill
the gaps in our knowledge, and,
(v) Argue that results based on risk analyses and not those
based on the consideration of a single scenario (however large
the hazard) should form the basis of policy decision-making
related to LNG activities. This discussion includes, briefly,
the current LNG regulatory requirements in the U.S. and
potential for improvements in assessment techniques that may
lead to a more balanced and efficient use of resources.
Safety Record of the LNG Industry
LNG industry has operated safely both in the US and worldwide for
over six decades. There is no technical or operational reason why this
exemplary record will not continue. New technologies, application of
results of careful research, and continued personnel training are
expected to contribute to the enhancement of the safety record.
In the U.S., LNG has been used in peak shaving operations
(liquefying pipeline natural gas during periods of low demand, storing
the liquid, and re-gasifying it to meet peak demand, generally during
winter months) for over 60 years. Trans-continental shipments of LNG in
ocean-going tankers started in 1959. The worldwide demand for LNG has
grown significantly since the 1960s and today over 150 LNG ships safely
deliver the liquid to ports in many countries (including the US, Japan,
France, et al) in some of the busiest and most congested ports of the
world near population centers. The safety record of the LNG industry is
enviable and unmatched by any other comparable industry--not a single
injury or fatality to a member of the public for over 50 years and
extremely low rates of injury even among the workers in the industry.
Over 45,000 tanker shipments have occurred world wide to date, without
any significant LNG spills (other than very minor leaks through pipe
gaskets, overfilling of tanks, and spills during make and break of the
unloading arms).
The industry is highly regulated in the US and has to meet very
strict mechanical design, personnel training and low public impact
standards. The ships are built to international standards, are of
double hull design (and have been from the very beginning of the
industry). The US Coast Guard inspects every LNG vessel that visits a
US port before it enters the port. This inspection includes a check of
safety emergency systems, interview with personnel, review of ship's
records and a security assessment. In addition, the US Coast Guard
(specifically, USCG Sector Boston) has mandated certain exclusion zones
in the fore, aft and sides of an LNG ship in transit to minimize
collision risks with other vessel traffic in the port. The shore-based
operations and facilities of LNG terminals come under the purview of
the US DOT regulations and are inspected annually for safety. In
addition, the design of storage tanks and other systems in the facility
have to conform to the industry consensus standard, namely, the
National Fire Protection Association's ``Standard for the production,
Storage, and Handling of Liquefied Natural Gas, (NFPA 59A).'' The DOT
regulations also stipulate the training requirements for industry
personnel. Last but not the least, every one of the LNG terminal
facilities in the US has to prepare and follow a security plan to
thwart any potential sabotage or terrorist acts. This level of scrutiny
and regulatory oversight, in addition to the industry's self interest
to operate extremely safely, has been the principal cause of the safety
success story. As mentioned earlier, no other energy industry has such
an outstanding safety record. However, the price for an exemplary
safety record is eternal vigilance, personnel training and
implementation of advanced technologies.
LNG properties that have an impact on potential hazards and
comparison with properties of other common fuels
LNG burning properties are not very different compared to similar
properties of other commonly used hydrocarbon fuels. Large LNG fires
will be very similar in radiant heat emission characteristics to large
fires of propane, gasoline, jet fuel, etc.
LNG is natural gas cooled at atmospheric pressure to a low
temperature of --260 F. It consists, mainly, of methane and few
percent by volume of ethane and propane and traces of other
hydrocarbons and nitrogen. Methane is a member of the saturated
hydrocarbon group of chemicals, which includes ethane, propane, butane,
pentane, octane (the principal constituent of gasoline). Each molecule
of a hydrocarbon fuel consists of carbon and hydrogen atoms combined in
specific proportions. The combustion properties of all hydrocarbon
fuels are very similar. For example, the heat produced when a pound of
any one of these saturated hydrocarbons is burned in air \1\ is the
about the same, namely 20,000 Btu (within 5%). Also, the pounds of
air required to burn completely one pound of any of these fuels are
also about the same, namely, 15.5 ( 3%), except for methane, which
requires a larger quantity of air. The consequence of the similarity in
combustion properties is that the fires all of these fuels should have,
within 100 oF, the same temperature, methane fires being the least
hot. This observation has been demonstrated by carefully conducted
laboratory experiments with different fuels.
---------------------------------------------------------------------------
\1\ In sufficient quantity of air which contains the chemically
required amount of oxygen to react with the hydrocarbon for complete
combustion (called the ``stoichiometric'' amount).
---------------------------------------------------------------------------
The implication of the above observation is that methane (LNG)
fires are no different in temperature than other fuels that the
industrial society uses. All fires emit heat in the form of radiant
heat (``infrared radiation'') and the amount of energy emitted is
dependent on the fire temperature. The question, therefore, is why
methane (or LNG) fires are considered to be more ``hazardous'' or
``hot?'' This has to do with one additional phenomenon that occurs in
burning, namely, production of soot particles (unburned carbon) in a
fire. The higher the number of carbon atoms in the fuel molecule (as in
gasoline or diesel fuel) the greater is the production of soot
particles during the process of burning. That is, a methane fire will,
all other conditions being the same, produce a smaller amount of soot
in a given size fire than in a fire burning a heavier oil. The soot
particles produced tend to form a mantle or shroud around the fire. The
larger the density of the soot particles in the mantle, the higher is
the absorption of the radiant heat emitted from inside the fire and the
lower is the magnitude of the heat emitted to the surroundings. The
soot layer acts as a ``heat blocker'' much the same way as a smoked
glass does to visible light. In the case of smaller fires, this
blocking of heat emission is smaller because of the lower soot amount
produced. The fire from the burning of methane -which has a single
carbon atom in the fuel molecule and which produces the least amount of
soot- will therefore appear ``brighter'' or ``hotter'' to an observer
outside the fire. However, as the methane fire size increases a lot
more soot is produced, forming a black shroud around the fire, like
fires of ``heavier'' hydrocarbons.. This reduces the overall radiative
heat emission to the outside. Therefore, when the fire sizes become
large (such as hundreds of feet in diameter), the distinction between
fires of different hydrocarbon fuels tends to diminish and they all
look about the same (with small differences in the amount of radiant
heat emitted to the outside). That is, LNG is clean burning in
relatively small size fires but as its size becomes large it burns
``dirty.'' Exhibit 1 shows a 13 m diameter LNG fire on water observed
in the tests conducted at China Lake. The smoky aspects of a large LNG
fire is seen in Exhibit 2, which shows the 35 m diameter LNG fire in
the tests conducted in 1987 at Montoir, France. The latter fire is the
largest LNG fire tested to date.
4. Immediate and near term research needs to fill the gaps in our
knowledge
4A. What is known and unknown in mathematical modeling to predict
adverse public impact distances from LNG releases
The models that are being currently used in LNG hazard assessment
have layer upon layer of conservative calculations, making predicted
distance to hazard substantially more than what it may be in reality.
New sets of larger LNG pool fire tests and other equally important
research will provide the necessary framework for the development of
realistic models with which to assess the hazards from potential LNG
release scenarios from ships.
To a large extent the fire hazard assessment models used currently
are based on the data and findings from tests such as China Lake
experiments. These test sizes were of a modest scale compared to sizes
of postulated spills to which the models are being applied now. There
is considerable uncertainly in the scale-up and applicability to larger
LNG releases.
The extent of the potential hazard zone surrounding a LNG release
depends upon a number of factors including the quantity and rate of LNG
release, the location of release (onto water or land), the
environmental conditions and mitigating circumstances and the type of
behavior of interest (dispersion and subsequent ignition of a vapor
cloud, a pool fire, or other type of behavior of concern). Our
knowledge of and confidence in modeling some types of LNG behavior,
even in the case of very large spills, are good and in other cases they
are very limited or lacking. The gaps in our knowledge of applicability
to larger LNG releases make it difficult to model the entire sequence
of events as a system and estimate the magnitude of the final
consequence.
There are four distinct steps in modeling the consequences of
release of any hazardous material, including LNG. These steps include,
(i) the quantitative description of the details of the source and the
modification that the released material may undergo in the immediate
vicinity of release location due to its interaction with air or water.
(ii) the description of behavior of the released material in the
environment (burning as a pool fire, dispersion of vapor in the
atmosphere and later burning as a vapor fire, rapid phase transition-
RPT, etc) and quantification of the hazardous effects caused by the
behavior, (iii) the enhancement or reduction of the hazardous effects
due to interaction with the atmosphere and, finally, (iv) calculation
of the effects on people or structures using the appropriate
susceptibility criteria for such hazards (or alternatively, calculating
the distance from the release where the hazards are below acceptable
levels).
In the case of scenarios of potential LNG release from tankers,
there are significant uncertainties and unknowns in the first step
itself, namely source modeling. This has a significant impact on the
overall hazard prediction. The calculation of the rate of discharge of
LNG from a specified size hole on the side of a ship's tank is
relatively straight forward, when such a hole is above the water line.
Other phenomena may also occur, which substantially reduce the overall
flow rate. One such is the creation of a vacuum condition in the tank
leading to intermittent discharge (``glug-glug'' type of flow as from
an inverted bottle). Our knowledge to calculate the LNG outflow and the
water inflow rate in the case the hole is either at or below the water
line should be supplemented. The physics of mixing of LNG outflow with
the water inflow, and mixing of water entering the tank with the LNG
inventory in the tank (causing rapid evaporation and exacerbating the
tank pressure condition), are some of the potential phenomena that have
not been studied carefully. The calculations of how fast LNG comes out
and in what form (liquid, vapor, liquid drops) are extremely difficult
and full of uncertainties. Currently, there are no experiments to guide
us to model the flow when the hole is at or below water line.
Performing a chain of calculations using only a single scenario of
release cannot be the last word on the extent of the public hazard,
however conservative the assumptions may be. A whole spectrum of events
and their consequences needs to be considered.
The GAO report has identified cascading tank failures due to heat
or the contact of cryogenic liquid and carbon steel as another issue.
The conditions under which these cascading tank failures may occur and
resultant effects on the hazards are not clearly understood. Therefore,
there are considerable uncertainties in describing the rate and
quantity of LNG released and the form in which it may be released
depending upon the locations and sizes of holes in the two hulls of the
ship.
The vapor formed by the release of LNG (into or on water) is most
likely to be ignited, close to the ship, from hot metals or electrical
sparks (static or cut cables). In all current generation models it is
assumed that all released LNG will form an expanding-vaporizing pool on
the water surface sustaining a pool fire. Modeling the spread of the
pool given the volume of the liquid LNG in the pool (or the rate of
volume entering the pool) is reasonably well established. However, what
is not known precisely is how much of the LNG flowing out of the tank
actually pools on the surface. A large jet of LNG pouring out from an
elevated hole plunging into water can penetrate the water column to a
significant depth, fragment by both mechanical and thermal interaction
with water, form small droplets of LNG most of which will vaporize \2\
by the time they rise to the surface leaving only a fraction of the
release to form a floating liquid pool. There are two main consequences
of this. One is that the large vapor volume released could burn as a
fireball near the ship. (A fireball puts out significantly higher heat
(per unit area) but for a considerably shorter duration than a pool
fire). The second possible outcome is that the vapor produced within
the water column together with the vapor produced by the spreading LNG
pool on water burns in a pool fire. The diameter of this pool fire
would be far less than if all released liquid pooled on the water
surface. Both of these phenomena have direct effect on the calculated
hazard distance. No experiments have been conducted to understand the
effects of LNG jet plunging into the water and the consequent fireball,
pool fire or other types of burning.\3\
---------------------------------------------------------------------------
\2\ My own recent analysis of the phenomenon of a LNG jet plunging
into deep water indicates that depending upon the LNG plunging velocity
into the water surface 50% or higher fraction of the released liquid
could vaporize in the immediate vicinity of the release leaving only a
smaller volume of liquid to spread on the water surface.
\3\ I, however, noticed in the China Lake tests that the higher the
spill rate (in gpm) of LNG the higher was the burning rate, the taller
was the fire and the quicker it went out.
---------------------------------------------------------------------------
A fire poses hazards due to the emitted radiant heat. Radiant heat
is the heat felt by a person (or an object) outside the fire and at
some distance from the fire so that the heat is not due to direct
contact with the hot gases in the fire. This is the ``heat'' that one
experiences when facing a fire in a home fireplace. The radiant heat
emission from a fire is generally quantified by a parameter called the
``emissive power,'' which is the average amount of heat energy
``leaving'' a unit nominal surface area of the fire and is expressed in
units of kW/m\2\ or Btu/hr ft\2\. The higher the emissive power the
brighter a fire will appear and the farther one needs to be from the
fire to be safe. The emissive power of LNG fires has been measured in
relatively small-scale field tests. Most of these small fires burn
bright (as seen in Exhibit 1). It is known that emissive power value is
fire size dependent. A large body of current generation models used for
LNG fire hazard distance evaluations assume that irrespective of the
fire size the emissive power remains essentially the same (and high),
leading to the prediction of uncomfortably large hazard distances from
large spills of LNG.
As argued earlier (and shown in Exhibit 2), large LNG fires become
smoky, very similar to other fuel fires. All smoky fires have a region
close to the bottom where the smoke mantle has not formed and where the
hot ``bright'' parts of the fire are visible from which can emanate
high radiant heat fluxes. The height of this region decreases as the
size of the fire increases. The black (cold) smoke mantle enveloping
the fire absorbs the radiant heat emission from the inner regions of
the fire resulting in substantially less radiant heat energy being
released to the areas outside the fire. In the case of large LNG pool
fire on water the burning regions close to the water could be hot but
the overall emissive power will be less than that from a smaller size
fire. In addition, the hot region close to the water will result in
inducing high vaporization of water, locally. The water vapor thus
formed just around the base of the fire may contribute to absorbing the
radiant heat emission in addition to, being sucked into the fire and
affecting the combustion chemistry to make the fire cooler and less
radiative. None of these phenomena have been studied quantitatively in
any controlled, large-scale experiments. We do not know how smoky very
large LNG fires will be and what the height of the lower ``bright''
burning zone would be or what the mean emissive power will be. A
theoretical model developed using the principles of combustion physics
and validated against the best available data from the 35 m LNG fire
experiments (the largest fire to date) seems to indicate that the mean
emissive power of large LNG fires from ship spills may be only about a
1/3 as radiative as smaller fires. If this is true, the hazard
distances predicted from current models will have to be reduced by
almost a factor of 2. Certainly, more research and large pool fire
experiments on water are needed to get definitive data. I concur with
the GAO recommendation on the need for this research.
Some people analyzing LNG hazards from ship releases are concerned
with cascading failures of tanks due to external fires or interactions
of the cryogenic LNG with metal structure of the ship. In fact, the GAO
report recommends that research be conducted on this potential failure
phenomenon. I agree with this recommendation, in principle, provided
the types of research performed are realistic representations of the
conditions following LNG release from a single tank. The heat from a
pool fire may not result in further tank failures. The potential for
cryogenic liquid-carbon steel interaction will depend upon a number of
variables including the extent to which water is present, the location
of contact between the hull plate and the liquid, whether such a
contact will result in the immediate fracture of a part of the plate
and the draining of the cryogenic liquid reducing the possibility of
further contact, the engineered naval architectural designs that
maintain the integrity of the ship structure even when a part of the
structure fails, etc.
It is my opinion that heat from even a LNG pool fire impinging on
the outer hull plate of the ship will be insufficient to cause further
tank failures. This opinion is based on the following reasons; (i)
there are at lest two historical records of incidents involving ships
carrying refrigerated liquefied fuels which were exposed to intense and
very long duration (hours) hydrocarbon fires impinging on the hulls and
deck plates, yet suffered no failures of the cryogenic liquid tanks,
(ii) the ships were of smaller size than current day LNG vessels;
because of shorter dimensions, the smaller vessels are relatively more
vulnerable to heat transfer from the fire to the tanks (and yet the
tanks did not fail), (iii) the calculated lifetime of a LNG pool fire
is of the order of minutes within which the total heat transfer to a
massive ship structure would not affect the hull integrity (especially
since the outer hull is also cooled by sea water), and (iv) the LNG and
hydrocarbon fires have the same temperature as discussed earlier. The
cases I cite are the incidents with ``Yuyo Maru # 10'' and the ``Gaz
Fountain.''
In November 1974 the Yuyo Maru No10, a 47,300 m\3\ tank capacity
ship carrying refrigerated LPG in insulated tanks with ballast tanks
filled with naptha (a fuel very similar to gasoline) was underway in
Tokyo harbor. It was hit broadside by 15,500dwt steel products carrying
ship ``Pacific Ares,'' The collision resulted in one of the wing tanks
of Yuyo Maru being punctured and releasing naptha on to both the water
and the deck of the colliding ship.\4\ The naptha pool ignited
immediately and the resulting fire caused damage to both the LPG
carrier and the colliding vessel. The naptha fire on the sea engulfed
the ships for more than 4 hours. The LPG vapors were released through
the normal relief valves and no boiling liquid expanding vapor
explosion (BLEVE) occurred nor did a leak of liquid propane occur nor
any tank failure.
---------------------------------------------------------------------------
\4\ William de Barry Thomas, Spectacle Blurs Issues, Hazardous
Cargo Bulletin, p 23, October 1984.
---------------------------------------------------------------------------
The other incident refers to Gaz Fountain. This ship, designed to
carry both LNG and LPG, was hit in the Persian Gulf during the Iran/
Iraq war in October 1984 by three air-to-surface Maverick missiles,
which caused extensive damage on the deck of the ship.\5\ The ship at
that time was carrying LPG. Intense and long lasting fire resulted on
the deck. Propane vapors burned through a gash in the tank roof as a
large vent fire. No tank failure or release of refrigerated liquid
propane resulted nor did any of the tanks undergo a BLEVE type of
failure.
---------------------------------------------------------------------------
\5\ J.A. Carter, Salvage of Cargo from war damaged Gaz Fountain,
paper presented at the 1985 Gastech Conference, Nice, France, 1985.
---------------------------------------------------------------------------
Other researchers have postulated the failure of LNG ship tanks due
to fire heat exposure leading to a LNG tank explosion (due to BLEVE).
As indicated above, no such explosions have occurred in tanks of ships
carrying refrigerated liquefied petroleum gas (LPG) even after being
subjected to intense fires on the outside. For a BLEVE to occur the
liquid in a tank must be heated to temperatures well beyond its normal
boiling temperature (and therefore higher pressure in the tank) and the
tank has to be suddenly depressurized by, say, the sudden rupture of
the tank wall. The rapid depressurization results in the production of
large volumes of vapor, which may ignite and form a large fireball and
the pressure waves created may hurl pieces of the tank to some
distance. The higher the pressure in the tank at rupture the worse will
be the effect of a BLEVE including the throw of the pieces of the tank
to distances up to 10 mile. BLEVE incidents have occurred in
pressurized (LPG) rail tank cars or relatively small LPG storage tanks
in which the pressure is normally about 105 psig and the tank will
withstand pressures up to 375 psig before rupturing. Large tanks have
not exhibited the BLEVE type of explosive rupture;The smaller the tank
and the higher the pressure it can withstand the greater is the
likelihood for the occurrence of a BLEVE.
One can conclude that a BLEVE is extremely unlikely in a LNG ship
tank when one considers the conditions necessary for such an event to
occur. First, the volume of liquid in each tank of a LNG carrier is
large (25, 000 m3). To heat such a massive amount of liquid to any
temperature significantly higher than its normal boiling temperature
requires significant amount of heat to be input. The calculated
lifetime of a LNG pool fire (caused by the rupture of another tank)
generally ranges from a few minutes to, at best, 15 minutes. Over this
burning time it is difficult to transfer significant quantity of heat
to the LNG in the tanks. Second, the LNG tanks are well insulated and
separated from the outer hull by a large (at least 2 m wide) inter-hull
ballast space, which impedes heat transfer from the fire to the tank
wall. Third, the tanks are provided with relief valves, which will
ensure that no significant rise in the pressure occurs. Further more,
because of the size of the LNG tank the roof of the tank will not be
able to withstand any significant increase in pressure () before being
damaged. Last but not the least, actual experience with large ships
carrying refrigerated fuels (LPG and butane) in tanks similar to those
in LNG carriers indicates that even though they were subject to fires
lasting several hours no BLEVE resulted. Therefore, in my opinion, the
consideration of BLEVE as a potential public hazard phenomenon in the
scenario of an accidental or intentional release from a LNG ship is
addressing a non-problem.
4B. Areas that require additional research and why
Other research that may be as important as pool fire tests and
modeling needs to be performed to determine the type and magnitude of
other hazards, which may, under certain circumstances, become the
dominant hazard scenario(s) rather than a pool fire. These include
water-LNG interaction, water intrusion into LNG tanks and
considerations of a fireball type of burning.
There are two most likely scenarios resulting from a large release
from a LNG ship. These are (i) the formation of a LNG pool fire on
water (initially expanding but reaching later a steady size) and, (ii)
the potential formation of a large fireball type burning due to the
immediate ignition of the large volume of vapor produced rapidly and
locally from the LNG jet-water interaction. Whether such interaction
could lead to localized and flameless rapid phase transition
explosions, (RPT), should be investigated. A RPT together with LNG jet
penetration into the water column together with the occurrence of a RPT
can result in a very large volume of vapor bring thrown high up in the
air leading to the formation of a fireball if ignited. The recent GAO
report has recommended the investigation of the radiant heat emission
and smoke production characteristics of large LNG pool fires on water.
I am in agreement with GAO on this recommendation. However, the results
of a pool fire test series alone will not provide all of the knowledge
required to perform a credible public safety assessment. Therefore, I
recommend the conduct of the following types of experiments followed by
modeling to properly estimate the potential hazard areas from different
types of similar magnitude phenomena. (These recommendations are
complementary to those of the GAO).
1. Large LNG pool fire of sizes up to 100 m in diameter on
(deep) water? the objective of these tests should be to
understand the variation of the fire dynamics, smoke production
characteristics and radiant heat emission change from bottom to
top of LNG fires as the fire size increases.
2. Plunging LNG jet interaction with water (of significant
depth) to understand the phenomenon of depth of penetration,
jet fragmentation, rate of vaporization and fraction of liquid
spilled that will eventually pool on the water surface. This is
an equally important phenomenon to consider since in some
situations most of the spilled LNG may evaporate in the water
column and the pool formed may be so small as to not pose
significant pool fire hazard compared to, perhaps, other
phenomena like a fireball type of burning.
3. Ignition tests with a plunging LNG jet into water to see if
a fireball results (and if so the conditions under which it
happens) or whether a fire similar to a pool fire but with
substantially large fire plume results due to very high gas
release rates in the ``pool.''
4. Viewing a LNG Pool fire (or even a large natural gas fire)
from a distance of several hundreds of meters up to 2 km on a
very large expanse of water and measuring the absorption of the
radiant heat in the atmosphere. Current calculations of LNG
heat absorption by the intervening atmosphere are based on the
assumption that the fire radiates like an ideal black body.
However, LNG fires are known to be band emitters of radiation
in exactly the right frequency where the water vapor (and to
some extent the carbon dioxide) in the atmosphere absorbs. Such
a definitive test conducted on water will provide a basis for
taking into consideration the beneficial (and mitigative)
aspects of the atmosphere. Unfortunately, some of the models
used in calculating hazard distances either incorrectly model
the atmospheric absorption or do not consider it at all. Such
omission is not excusable when the predicted hazard distances
are in hundreds of meters (up to 2 km).
5. The interaction of the LNG outflow and the water inflow
(simultaneously) to understand what may happen if the
postulated hole location in the ship's tank is at or below the
water line. The flow situation and the effects of large
quantity of water intrusion into a tank filled with LNG are
complex and need to be studied. Such a phenomenon may need to
be considered in hazard calculations.
5. Results from risk assessments rather than from a single
postulated scenario should be the basis of policy decision making.
Risk analysis as a tool is being increasingly utilized in the US
for decision-making, but only in bits and pieces. The single important
reason for the lack of universal adoption of risk-based decision making
is the lack of standards for the levels of risk that are acceptable to
society.
It is my opinion that policy decisions should be made after
evaluating all possible scenarios of releases, their likelihood of
occurrence, the levels of consequences associated with each scenario
and considering the effects of either natural mitigation processes or
man made technological or procedural systems. Absent such an approach,
the focus will always be on the largest, most incredible types of
releases, whether they have ever a chance of occurrence or not.
Preparing for and managing resources required to respond to emergencies
involving events that occur with very low probabilities is a
misapplication of resources.
It is very commendable that the report by Sandia \6\ recognizes
that risk analysis must be the basis of overall assessment rather than
the consequences of a single worst-case event. In fact, this report has
provided a template on how one should perform a risk assessment;
unfortunately, since the process has not been quantified with a
specific example, the public seems to be focusing on the results from
the theoretical assessment of the consequences only. Many other federal
agencies have long recognized the usefulness of risk-based approach.
However, it has been slow in ``permeating'' to the LNG industry
regulations. The US Coast Guard requires the performance of Waterway
Suitability Assessment, for LNG ship passage to a port, based on a risk
consideration approach. The US DOT has in its Pipeline Integrity
Management regulations the requirements for performing risk based
assessments. The NFPA LNG Committee is considering providing, as an
alternative Standard for compliance, a risk based standard.\7\ The
European regulators have successfully used the risk-based approach to
permitting LNG and other petrochemical facility siting for over a
decade.
---------------------------------------------------------------------------
\6\ Hightower M., L. Gritzo, A. Luketa-Hanlin, J. Covan, S.
Tieszen, G. Wellman, M. Irwin, M. Kaneshige, B. Melof, C. Morrow, and
D. Ragland, Guidance on Risk Analysis and Safety Implications of a
Large Liquefied Natural Gas (LNG) Spill Over Water, Sandia National
Laboratory Rep.# SAND2004-6258, U.S. Department of Energy, Washington,
DC, Dec 2004.
\7\ The full membership of this NFPA 59A Committee is considering
this recommendation and verbiage provided by its sub-committee. If
approved, this alternative standard would be incorporated into the 2009
edition of the NFPA 59A Standards.
---------------------------------------------------------------------------
One of the important recommendations I would offer this august body
is to consider setting up acceptability standards for levels of risk
that are suitable for siting industrial activities and for continuing
such operations. Risk cannot be considered in a vacuum; it has to be
based on comparative scales. There is substantial body of literature on
this topic.
Conclusions
1. LNG industry has operated safely both in the US and
worldwide for over six decades. There is no technical or
operational reason why this exemplary record will not continue.
New technologies, application of results of careful research,
and continued personnel training are expected to contribute to
the enhancement of the safety record.
2. LNG burning properties are not very different compared to
similar properties of other commonly used hydrocarbon fuels.
Large LNG fires will be very similar in radiant heat emission
characteristics to large fires of propane, gasoline, jet fuel,
etc.
3. The models that are being currently used in LNG hazard
assessment have layer upon layer of conservative calculations,
making predicted distance to hazard substantially more than
what it would likely be in reality. New sets of larger LNG pool
fire tests will provide the necessary framework for the
development of realistic models with which to assess the fire
hazards from potential LNG release scenarios from ships.
4. Other research that may be as important as pool fire tests
and modeling needs to be performed to determine the type and
magnitude of other hazards, which may, under certain
circumstances, become the dominant hazard scenario(s) rather
than a pool fire. These include water-LNG interaction, water
intrusion into LNG tanks and considerations of a fireball type
of burning.
5. Focusing only on consequences of perceived worst cases
rather than on the overall risk from an activity will result in
poorly utilized and improperly allocated resources, not to
speak of the economic penalties that may result.
6. Risk analysis as a tool is being increasingly utilized in
the US for decision-making, but only in bits and pieces. The
single important reason for the lack of universal adoption of
risk-based decision making is the lack of standards for the
levels of risk that are acceptable to society.
Mr. Chairman and Members of the Committee, I thank you for the
opportunity to testify before your Committee.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
.epsChairman Thompson. Thank you very much.
I thank both of you gentlemen for offering your testimony,
and I remind each member that he or she will have 5 minutes to
question the panel.
I now recognize myself for the first 5 minutes.
Mr. Davis, there were some questions earlier about the
maritime administrator's initiative to increase the number of
U.S. mariners on LNG tankers. Just for the record, do you
support that?
Mr. Davis. Absolutely. I think that the maritime
administrator is doing a fantastic job. I think he recognizes
that this is an important part of homeland security.
And I think that he believes, as I do, that what better
people to be watching out for the United States than U.S.
citizens.
Chairman Thompson. If this committee recommended to
Congress that the administrator's initiative becomes law,
requiring LNG tankers to have a certain minimal percentage of
U.S. mariners, could we over time be able to provide those
qualified persons to work on those LNG facility ships?
Mr. Davis. Yes, Chairman Thompson. As it currently stands--
we had a fleet of vessels, LNG vessels, operating for over 20
years with the American flag on it, which MEBA was on board and
were the officers on board, and the Seafarers International
Union was the crew on board.
And those ships were taken and put a foreign flag on them
for economic purposes, and we eventually lost all of our jobs
on them.
We still have a pool of mariners that essentially could
walk on board the ships today--they would need a little bit of
recency training and to get familiarized with any new vessels
that are out there.
But in a very short period of time--and I am talking weeks,
not months--we could essentially start crewing up vessels. So
my answer to that is yes, as well as the absolutely wonderful
schools that we have around the country.
We have the federal maritime school at Kings Point. We have
the state schools at various states around the country, as well
as the union schools, including my own in eastern Maryland.
Chairman Thompson. Thank you very much.
Dr. Raj, the GAO report highlights the fact that experts
still disagree on the consequences of an LNG spill. Why do you
think that disagreement exists? And kind of share that with the
committee, if you would.
Mr. Raj. Certainly, Mr. Chairman. The disagreement arises
simply because of lack of knowledge. We have so far done tests
on water, especially back in the 1970s, in which I was involved
myself, spills on water where the size of the fire was about 50
feet maximum diameter.
But we are postulating scenarios based on ship spills that
will go something like 1,000 feet in diameter, so there is a
tremendous scale-up of the information from a 50-feet size
experiment to a 1,000-feet diameter fire.
We have recently come across, for example, information when
the size of the fire is doubled from 50 feet to 100 feet it
behaves completely differently. It completely becomes smoky
fire and seems very much--looks very much like a gasoline fire.
What has happened is people who know of those have used
those models, whereas the people who do not know about this
have used the older models, thinking that the fire is very
bright. So we come up with substantially different estimates of
the hazard.
So I think it is a matter of lack of knowledge of really
the behavior of LNG as we increase the size. And we are
applying some very limited information that we have at the
moment.
Chairman Thompson. Has any of your research looked at
potential economic consequences of spills? Or you just limited
the research to just what would happen in the spill area?
Mr. Raj. I have personally not undertaken any economic
assessments. My field of research has been limited to
understand the science part of it. But I am sure there are
people who can understand the economic impacts if any such
accidents do occur.
Chairman Thompson. Well, and I think one of the things we
want to consider is obviously the danger, but you know,
terrorists would just as well like to keep a port out of
business for a week or two, and that would be an absolute
significant incident also associated with a spill or that
particular incident.
So I think part of our challenge is how do we look at all
the consequences associated with the handling of LNG. Clearly,
we want to know the hazards initially, but we also want to look
at economic conditions that relate to it also. But I thank you
for that.
The other point that I want to talk to you, Mr. Davis,
about is you have heard testimony that over time we will be
bringing more LNG facilities online. And that will also require
more and more people working in the facilities.
So just like if the administrator's philosophy of more
people on board ships become American, if we somehow can codify
that, what happens if we bring 10 new facilities online and we
will need additional ships for that?
Do you see a problem with getting the necessary American
citizens to work at those facilities also?
Mr. Davis. Well, first, I think that the simple answer is
no. If there are jobs for Americans, we will train them. We
will fill the jobs when we have competent people to do that.
But what I would like to say is in regards to land-based
facilities that right now, there is no oversight on the vessel
crewing issue for any ships to come into a land-based facility.
MARAD has no say in that.
It is interesting that MARAD has some input into the
permitting process with the ships going to an offshore
location, to a buoy set up offshore, but as far as the land-
based, for example, you can have a terminal right in the middle
of a city, for example, which is certainly exposure to a lot of
people.
Now, the Coast Guard has 96 hours to essentially make sure
that Joe Smith or whoever the name is that is given to them--
that they are supposedly cleared through their database.
But basically, what they are not able to do is they are not
able to--what MARAD is not able to do is have any say
whatsoever in the crewing on board the ships that come into a
land-based facility as it stands right now under the law.
Chairman Thompson. Thank you, because that distinction was
not made in testimony from the other panel. And I think that is
absolutely beneficial.
I will yield now to the gentleman from Houston, Texas,
which, as you know, has a significant port operation going on
there.
Mr. Green?
Mr. Green. Thank you, Mr. Chairman. And I want to thank you
for hosting this important meeting.
I thank the witnesses for taking the time to be with us
today. And I have been gratified and edified by what you have
said.
So let me start by asking first, for my edification, how
does the process work of having our mariners actually get to
the ships? I am concerned about the logistics in that. What
happens such that we can place our people on their ships? I am
new to this. I am a neophyte on the committee.
Mr. Davis. Well, as far as--you are talking on current
ships, foreign-flag ships right now, American ships? I am not
quite sure--
Mr. Green. Well, you indicated that you thought that our
mariners would be better suited because of their training to be
on these vessels. So how do we get them there logistically
speaking, if you don't mind?
Mr. Davis. Well, logistically, a company--if a company's
ship right now comes into the United States, we can--wherever
it comes in and docks, we can just go ahead and put our people
on there. Or if they are out at anchorage, we could send them
out by boat.
Or it is not uncommon at all for Americans to fly overseas
and board a vessel overseas, and that is where they join the
vessel.
Now, what is going on in this industry is that there is a
tremendous amount of new construction that is taking place.
Many, many ships, well over 100 ships, which is a tremendous
amount of ships, are being manufactured in other parts of the
world.
The best way to familiarize people with these ships and to
become trained on these ships is to actually participate--
toward the end of the shipyard period as the ship nears
completion, to actually go to that shipyard and participate at
that point in time in the operations, because all the systems
on board the ship are then tested and all before the ship is
put into commission.
That is the best way. But I mean--logistically, for new
ships, the very best way. Older ships, all you have to do is
fly people over to--fly Americans that are trained in LNG,
which we do have--fly them overseas and put them on ships and
they will take the ship to the United States and back to load
again, discharge, and back and forth.
And third case scenario is the ship is already here in the
United States at an LNG facility or at an anchorage or a dock--
is we make the proper arrangements essentially to take people
down to the ship either by boat or take them down in the car.
Mr. Green. And is this process something that is employed
in other places in the world, or would we be the first to
initiate it?
Mr. Davis. No, as far as putting people on board vessels--
Mr. Green, you are from Houston.
Mr. Green. Yes.
Mr. Davis. And I am very familiar with the Houston Ship
Channel down there, and this is just standard procedure that we
would do with any of the ships that--we are not on any of the
international ships--international flag ships that come into
Houston.
But the American flag ships that come into Houston--this is
all our standard procedure of what we do there.
And if an American flag ship that was overseas in a port
overseas--say it was in South America getting some oil, and
they essentially came up a crew member short because an
American on there got sick, we would fly a crew member down
from Houston, put him onboard the ship in South America, and
then he would bring the ship up to Houston, to the refinery in
Houston.
Mr. Green. If we imposed this type of requirement, could
other ports, seeing this, conclude that because we now have
ships coming to our port from the United States perhaps we
would want to have some of our people on their ships?
Mr. Davis. That is certainly possible, but right now, the
United States--97 percent of all the shipping that comes into
and out of the United States is carried on flags other than
United States flag ships.
So out of every 100 ships that comes into the United
States, three of them are manned by Americans with a United
States flag. The other 97 are foreign-flagged from some other
country.
Many of them are what we call flags of convenience, which
are essentially flags that are licensed to a state that may not
even have a port in it, but it has essentially big monetary tax
breaks for a shipping company.
Mr. Green. Dr. Raj, are you commenting at all, or are you
in disagreement with what Mr. Davis is saying? Or are you just
here to help us to understand the consequences of having the
LNG handled inappropriately such that we have an explosion of
some type?
Mr. Raj. I am not competent, Mr. Green, to respond or--you
know, I have not studied the problem. I am not an expert in
this, and I don't have the background.
So my expertise is really to understand what happens when
LNG gets released.
Mr. Green. All right. Are you familiar with the Houston
Ship Channel?
Mr. Raj. No, I have not been to the Houston Ship Channel. I
am aware of it and heard many things about it.
Mr. Green. Well, let's just take this hypothetical. In a
ship channel, which is usually fairly narrow, if we have an
explosion, how long--what is the duration, generally speaking--
the chairman got into this with you--for cleanup such that that
ship channel will be traversable again from the point of the
explosion, assuming that it is one that will incapacitate the
vessel?
Mr. Raj. I do want to mention that I agree with the GAO in
their report that explosion from an LNG ship is a perhaps
extremely unlikely scenario. LNG as a liquid does not explode.
And LNG spills--if there is a fire, the fire is fairly
short-lived and everything that gets released will be burned
away or just literally go up in smoke. So there would be
nothing left in the water as a cleanup of the material that got
spilled.
There may be other debris from the ship itself, or so on,
and my expectation--and, you know, I don't have background in
that area, but I will just expect that the port will be
operational within hours, if not a day or two, because there is
no cleanup kind of things that is required which would shut the
port down.
Mr. Green. Thank you, Mr. Chairman. I yield back.
Chairman Thompson. Thank you.
Just taking off from Mr. Green's comment, has your
research, Doctor, taken in any potential acts of terrorism
associated with an LNG tanker?
Mr. Raj. No, sir. I have not specifically looked at
terrorism. My expertise starts when there is a release, however
the release is caused.
Chairman Thompson. So if, say, as we had to happen in
Yemen, where terrorists ran into the side of a ship with a lot
of explosives, do you have any research or do you know of any
research as to what the results of those kinds of terrorist
acts potentially could be up on an LNG ship?
Mr. Raj. I can only speculate, because--engineering
judgment and science-based speculation, for two reasons. One is
I can formulate what will happen to LNG when it gets released
from tat kind of a situation where there is an explosive
breakage of the hulls of the ships.
But I also want to refer you to the information I have
provided in my testimony on two actual incidents that happened
in years past with large ships which were not hit by a
terrorist but nevertheless they were subject to very high heat
from flames.
This happened in Tokyo Harbor where a ship carrying
material called LPG, which is liquefied petroleum gas or
liquefied propane, which is pretty similar to LNG, was involved
in a t-bone collision accident with another ship, and there was
no explosion or anything.
In fact, what was released was a material similar to
gasoline which was held in the side tanks of the ship, and the
ships--both ships were cooked in the fire caused by the
gasoline, the naphtha, released for 4 hours, and there were no
explosions of any kind, other than burning. And the Japanese,
in fact, had to tow that ship after 3 days and sink it with a
lot of effort.
The other incident that I am aware of is the one that--a
ship that was hit by a maverick missile, surface-to-air
missile--air-to-surface missiles in the Iran-Iraq war. And even
there, when the missiles penetrated the hull of the ship, the
deck of the ship, there were really no explosions or anything.
So that is about all the knowledge we have at this time. We
do not have experiments to really simulate exactly the
situation that you have asked.
Chairman Thompson. Well, do you think it would be
worthwhile for us to have the experiments and the modeling that
could probably give us some answers to some of these questions?
Mr. Raj. Some of them, yes, indeed. I think it would be
very worthwhile, and I have alluded to them in my testimony.
Chairman Thompson. Thank you. Because part of it is the
safety of LNG as it is, but the other is whether or not we can
secure that LNG from a potential terrorist attack. And if we
can, how do we do it? And heaven forbid, if we don't, what are
the consequences?
And how do we marshal the resources to respond to it in a
manner that is coordinated and part of the strategic plan that
we found out we don't have at the agency right now? And I will
assume we will have it shortly. But we just keep our fingers
crossed until we do.
But that is part of the dilemma, and I can appreciate the
testimony. I was not real happy with the Coast Guard and DHS's
testimony that more assets and equipment is at this point not
needed.
I can't for the life of me see how, with the potential for
these many facilities coming online--for us not to have need
for more men and equipment.
I know the Coast Guard is good, but I don't think you can
be two places at one time. And that is kind of my thought. And
Ranking Member King and others have kind of indicated similar
opinions. And so we will be looking at that.
I now yield to the gentlelady from Texas.
Ms. Jackson Lee. Thank you, Mr. Chairman.
And let me thank the witnesses on the second panel. This
has been an important dialogue.
One of the comments that I make and will continue to make
in these hearings is that we have been lucky since 9/11. We
have certainly made substantial improvements. We have awakened.
But I can assure you, as the dust settles on any potential
tragic incident, if they look to the lawmaking body, certainly
this committee will be in the eyesight of those who will ask
the question why.
So we may be not finger pointing, but we may be looking
under the hems of garments, and behind cracked doors, and
turning on lights, and people will scratch their head and say,
``We have been doing it this way for a long time. Why?''
And I think it is simply because before the Yemen boat
incident, if you will, who would have ever thought? A little,
small boat--sounds like a fantasy story--goes up to a big, huge
ship and 19 or so sailors are dead.
So, Mr. Davis, let me ask you to speculate, because
frankly, some would say, ``Well, he hasn't looked at the recent
accounting pluses and minuses of the Coast Guard.''
But just because you represent those who are a part of this
marine industry, and I imagine you have encountered the Coast
Guard and looked at the vastness of the area in which they
operate--because your, if you will, members are probably
engaged in a lot of what the Coast Guard is involved in.
If you had to just look, would you think that there are
enough resources in the Coast Guard--and I am going to ask you
some other questions about--I think you made a point in your
testimony that there should be more of your membership on
ships.
But just tell me, if you had to speculate, would you--could
you feel comfortable in analyzing whether there is seemingly
the Coast Guard--or the Coast Guard seemingly is doing all the
work they need to do and could stand more resources? Mr. Davis?
Mr. Davis. I am happy to answer that question. Thank you
for asking it. I have, I guess, two ways that I would like to
answer the question.
The first kind of dovetails into a little bit of the
previous question that the chairman had asked, and that is
essentially the--I just feel it is my obligation at this point
in time to state to this committee that in regards to terrorism
with a ship, whether it be an LNG ship or any other type of
ship, the most vulnerable place that you have on the ship is
the crew.
It is the crew that controls the ship. One or two engineers
down in the engine room can take control of the ship, can
control the steering of the ship, can control the speed of the
ship, can have the ship going 20 knots up the Houston, ship
channel or into New York Harbor or places in confined areas.
They can ram the ship into bridges, Golden Gate Bridge. You
name it--Verrazano Bridge, down in Houston. Anywhere they want,
they can point this thing.
Terrorists are not going to start some small fire that
these tests and such have taken on. Terrorists are going to
look for the most damage they can possibly do.
They are going to direct--if they are going to use a ship
for a weapon, it is going to be directed to do the absolute
worst amount of damage, which will be stationary objects as
well as perhaps other ships.
And probably none of these studies have done a study of an
LNG ship being deliberately smashed into another ship of highly
flammable explosive types of materials.
The barges that are down in the--coming up the Houston Ship
Channel--unbelievable, some of the things that are in those
barges.
So to answer your--I just felt I needed to tell homeland
security about this. It is the people on board the ship who
ultimately control that ship. That is number one, and that is
why--
Ms. Jackson Lee. Could you hold your point for 1 second? So
that means, in addition to the point you have made, to accept
Mr. Raj's limitations by being encouraged that more research
needs to be done in a vast area, because obviously terrorists
are not going to pinpoint to us what they might do.
Mr. Davis. Absolutely. There is no doubt about it. And you
can't look at it as an isolated ship. You have to look at all
the surrounding possible targets around there, how this could
be done in such a matter.
I mean, we do have nuclear power plants that are on rivers
and bays and such. So there are certainly many possibilities,
yes.
Ms. Jackson Lee. It is my understanding that your
organization and Excelerate Energy have entered into a
memorandum of understanding. Can you provide us with
information about the MOU?
Mr. Davis. Yes. We have entered into an agreement between
MEBA and Excelerate Energy that we will supply American
officers for the Excelerate vessels.
They made a commitment--Excelerate made a commitment to the
maritime administrator, I believe, for 25 percent of the crews
basically to be American, and that they intend to crew these
ships up with American officers. That is deck officers and
engineering officers.
And we will integrate--right now, apparently, the ships
have Belgian officers on board them, and we will integrate in
there and take our experienced people that have LNG experience
and integrate them onto these ships and get their recency and
get their familiarization with this particular--each ship has
its own idiosyncracies--and become familiar with that, and work
together with the Belgian officers.
And as Excelerate's fleet expands, perhaps at some point in
time it may be all Americans on one ship and all Belgium on
another, or something like that. I don't know.
The final details of that I don't really know, because we
are still in an exploratory process, because this is new for
both Excelerate and for MEBA. But I would like to commend them.
This is a major step forward, and we are very pleased that they
have done this.
Ms. Jackson Lee. You have got a little piece of paper next
to you. Do you need to check on that?
Or, Mr. Chairman, would you indulge me to finish my
question? I am sorry.
Do you need to----
Mr. Davis. Well, just that Excelerate has made a commitment
for their ships worldwide and not just for their ships that
come into the U.S.
Ms. Jackson Lee. Well, let me just say that being one that
appreciates internationalism and working with our foreign
allies, I am sensitive that we work worldwide.
But I like what you have just indicated, and we might want
to look at, as long as it is not proprietary, this MOU, because
I think you are asking for more of our officers to be on
foreign ships, to have a more integrated system, if you will,
which can also play into this whole idea of security.
And I don't know why we would be afraid of that. We have to
do it in a way that speaks to our internationalism. But I think
it would be a valuable approach to take. This MOU seems to be
an advanced idea.
In my last hearing, I asked about more training for your
officers or for officers and I need your voice on that.
I think it is important that we get on the same page, that
we give more training as it relates to security, terrorism,
prevention thereof to our officers and have the resources to do
so.
Would that be helpful to the individuals you represent?
Mr. Davis. Yes. We have our own school, but most of our
people have come from one of the state schools or the federal
maritime academy, including Texas A&M.
Ms. Jackson Lee. I am glad you said that, in Texas, and
near Houston.
Mr. Davis. In fact, I have been speaking with Texas A&M
recently about some joint projects, joint training projects,
between MEBA and them. We haven't come to any agreement or
finalized anything, but we are discussing it.
The maritime administrator has also been proactive with
this. He asked all the CEOs of all the schools, federal, state,
and the presidents of the labor unions that have training
schools to please come to MARAD and sit down with him and
discuss how we can train Americans for this specialized LNG
training.
And we did meet, and we have an ongoing committee meeting,
and we are all working together and cooperating together to
fill the possibility of jobs that we see coming down the road
of putting Americans on these ships. So, yes.
Ms. Jackson Lee. I appreciate it.
Mr. Raj, let me bring my questioning to a close by posing
two combined questions to you. And I heard you discuss
research, and you made the very, I think, forward-thinking
point that additional research is required.
And I think it is, because you have talked about safety,
but as I said to you, the question why will be asked, and I
would say God forbid, were we to see a terrorist act.
And so can you tell us why research has not been done and
what approach we can--well, I think there should be sort of a
firm approach to homeland security that this needs to be done
and the appropriate researchers need to be engaged.
But while you are answering that question, though you have
noted the exemplary record that the LNG tankers have had, some
60 years or so, couldn't you envision, as I have just heard Mr.
Davis give us a wake-up call with some scenarios that he has
offered, that it is vulnerable to terrorism, and that we should
be mindful and watchful, and research would be warranted so
that we can be prepared?
Mr. Raj. Congresswoman, yes, I think you really hit the
point. Research is needed to understand really what happens,
and how it happens is an equally important part, as the
chairman pointed out. And those are the areas that really need
attention.
One of the questions you asked is why was not research done
all these years. I think the answer to that--research was done
in the mid 1970s when LNG was considered to be one of the
energy resources for this country, and for a variety of reasons
the industry did not take off. In fact, a couple of them almost
went bankrupt.
And the revival of the industry is fairly recent in a
sense, in the last 10 years or so. And with that, there is a
lot more traffic in the world, a lot more traffic in the United
States. And certainly, of course, 9/11 has added a new
perspective and concern.
I do want to mention one other thing. In my testimony, I
have gone into great length to compare some of the other
hydrocarbons that we deal with every day--gasolines, propane
and so on.
In my opinion, LNG is no different from them in the
properties and, you know, hazardous properties. So we do not
only have to be concerned with LNG--you know, our assessments,
but also with the other materials which have similar
properties.
Ms. Jackson Lee. And you would think that we should not
ignore the fact that a terrorist act could happen, but we need
to generate the research, not only LNG but some of the other of
the gases--propane, et cetera--that would be as susceptible to
some act.
Mr. Raj. Absolutely, because, you know, the price for
freedom, as we all know, is eternal vigilance, and vigilance in
this case includes understanding what would happen and prevent
it from happening, and if it happens be responsive in emergency
response.
Ms. Jackson Lee. Mr. Chairman, profound eternal vigilance,
I think, is a good not for me to yield back.
But I just want to offer on the record--and it may sound
redundant, but let me just offer it in any event. Before 9/11,
none of us could imagine individuals learning to take off in
planes and not have any training to land.
And our first response for any of us who were looking awake
or looking at the T.V. or seeing the reruns and hearing the
initial responses as we listened to the tapes coming back was
that it was an accident, that there must be a plane crash.
Isn't it a little plane going into the towers initially?
We had no understanding of that. And then my recollection
is that we had a tragedy with an Egyptian pilot, if I recall,
that has never been explained, I think, that flew one of the
planes in New York and either wanted to commit suicide or--
whatever, but it was a human act.
So things that we have never heard of have happened, and we
need to get the vulnerability assessment studies, more
research, more training.
And, Mr. Davis, I think you have gotten hold of a good
idea, and I would hope that if your document is not
proprietary, I would like to have an opportunity to review it
and begin to look at it as a model.
Mr. Chairman, I yield back. Thank you for this hearing.
Chairman Thompson. Thank you very much, Ms. Jackson Lee.
I want to thank the witnesses both for their expert
testimony as well as their response to the question. We are
just beginning the process of looking into this area. We will
have more hearings on this.
So I hope you won't feel that we will be imposing on you
from time to time to come back and share your information with
us.
It is the new kid on the block. It is coming. We have to be
able to respond to whatever the challenge is, both if it is
manpower, if it is safety. As you know, permitting of these
facilities is question one, and it is always around safety. But
now we have to add security to it.
And the notion is whether or not from a government
standpoint we can inspect them in real time, or are we going to
have LNG tankers lined up, because we only have so many people
around to do inspections.
So those are some of the questions that this committee will
have to grapple with.
I want to compliment our MARAD administrator for being
forthright in trying to negotiate putting American citizens on
these particular ships. Hopefully we can move a little faster
now that we know we can, over time, train the people to manage
the facilities. So we will look forward to it.
Again, let me thank the witnesses for their testimony.
Hearing no further business, the committee stands
adjourned.
[Whereupon, at 3:54 p.m., the committee was adjourned.]
APPENDIX A
For the Record
Prepared Statement of the Honorable Bob Etheridge, a Representative in
Congress From the State of North Carolina
I want to thank Chairman Thompson for convening this important and
timely hearing. As energy prices have skyrocketed, alternative sources
of energy and means of transportation for that energy. Liquid natural
gas (LNG) will increasingly be used to diversify America's energy use,
as shown by the recent upswing in applications for LNG facilities. As
this gas will be transported under pressure in tankers traveling close
to our shoreline, it is important that we ensure the public's safety as
we increase the use of this fuel. This hearing is part of the Committee
on Homeland security's vital work to make sure that the technologies
and procedures in place are protecting the public.
Last week's Government Accountability Office (GAO) report on the
possible effects of a terrorist attack on a LNG tanker is a useful
first step in identifying the threat and putting procedures in place to
counter that threat. I look forward to hearing the testimony from the
GAO experts today. I also will listen with interest to the officials
from the Maritime Administration (MARAD) and Federal Energy Regulatory
Commission (FERC) who are charged with licensing safe and secure LNG
facilities. I want to be certain that the procedures in place take the
possibility of a terrorist attack into account and require planning and
security against that threat. I am pleased to see that the Director of
Inspection and Compliance of the U.S. Coast Guard is here to give
testimony as well, as the role of the Coast Guard in siting and
approving LNG facilities includes emergency response planning and
operational command in the event of an accidental or intention
disaster.
Again, I thank Mr. Thompson for his leadership, and our witnesses
for their time in coming to speak with the Committee on this important
issue. I look forward to the testimony and discussion as we work
together to keep America Safe.
Appendix B
----------
Additional Questions and Responses
Questions From Honorable Bennie G. Thompson, Chairman, Committee on
Homeland Security
Responses From Ron Davis
Question 1: Do you support the Maritime Administrator's initiative
to increase the number of U.S. mariners on LNG tankers? What else
should be done?
MEBA fully supports Administrator Connaughton's initiative to
increase the number of American mariners on LNG tankers. His efforts
have been a major factor in persuading LNG vessel operators to begin
using United States merchant mariners on their vessels.
We believe that the primary reason he has been successful is
because plays a role in the permitting process of all deepwater LNG
ports. However, does not play a role in the permitting process for land
based terminals, which is overseen by the Federal Energy Regulatory
Commission and the Coast Guard, neither of whom have a statutory duty
to promote the U.S. maritime industry, as MARAD does.
We believe that should play a role in the permitting process for
on-shore (land based) terminals similar to the one they play with
deepwater terminals.
We also believe that the federal government should look into the
feasibility of legislating a minimum crewing standard for LNG Tankers,
including a requirement that 50% of the Officers be U.S. Merchant
Mariners within a five-year period.
Question 2.: How will the increase of mariners improve the security
of the LNG tankers?
Thanks to the in-depth vetting process that currently exists for US
mariners, having them present on LNG tankers will help lower the threat
of deliberate sabotage of the vessel by a knowledgeable member of the
crew. This kind of an intentional incident is, in our opinion, the
greatest threat to LNG tankers, and the most likely scenario that would
result in loss of life or property. We can be sure that US mariners are
who they say they are, and that they are adequately trained and loyal.
This is not something we can be certain of with foreign crews.
In addition, with U.S. Mariners the LNG vessels they will have a
stake in the security of the vessel while it is overseas loading LNG.
All shipboard LNG is delivered from foreign countries and sometimes
from politically unstable nations. U.S. Mariners care about their
country and will have a vested interest in keeping a keen ``watch'' on
the gangway, mooring lines and other areas that stowaways or terrorists
could attempt to board.
The actual security vetting that U.S. Mariners undergo is
extensive:
U.S. Merchant Mariners receive their credentials to
work from the U.S. Coast Guard;
U.S. Merchant Mariners undergo extensive background
checks performed by the Federal Bureau of Investigation;
U.S. Merchant Mariners are background checked through
a National Driver (vehicle) Record database;
U.S. Merchant Mariners will also be subject to
jurisdiction of the Transportation Safety Administration (TSA)
where they will be vetted through a terrorist watch database in
order to receive a Transportation Worker Identification Card
(TWIC).
U.S. Merchant Mariners are citizens of the United
States or aliens lawfully admitted for permanent residence.
As I wrote in my written testimony, foreign seafarers are not held
to these standards.
Question 3.: It is my understanding that the MEBA Calhoon
Engineering School already has LNG training available for U.S.
mariners. Please provide us with information about this training.
The Marine Engineers' Beneficial Association operates a world
renowned training facility, the Calhoon MEBA Engineering School (CMES),
in Maryland. The school is fully accredited and certified by the U.S.
Coast Guard and Det Norske Veritas (DNV), one of the world's leading
classification societies.
The MEBA training facility trains both deck and engineering
officers and has recently installed a edge Bridge Simulation System
designed and built by USA. The simulator is one of the newest and most
sophisticated systems of its type in the world.
The interactive program allows students to simultaneously control
simulated ships utilizing any of 56 different types of vessels in over
20 different ports. In addition to the ten ships that can be controlled
within one scenario, instructors can further intensify the simulation
by implanting multiple controlled ships into the scenario. Unlike many
existing bridge simulators, each station, operating a different type of
vessel (including LNG vessels), can interact with every other station
simultaneously. The LNG cargo simulation program allows students to
dock, load and discharge LNG vessels.
Moreover, the computerized system even encompasses the terminal-
side operations of an LNG facility. It accommodates upgrades to adapt
to ever-evolving Coast Guard and International Maritime Organization
training and testing requirements.
The Calhoon MEBA Training School prides itself in developing and
offering courses before the need becomes apparent in the U.S. maritime
industry. Relevant courses meeting today's LNG training needs include
Liquefied Gases (LNG). This course has been part of the MEBA training
core since 1975. It provides U.S. Coast Guard Licensed Deck and Engine
Officers with the knowledge to safely and efficiently transport LNG.
This LNG course is a USCG prerequisite for employment aboard LNG
carriers. The class includes comprehensive lecture, lab work, and
computer training as well as LNG science, engineering systems, cargo
systems, stability, and safety. This course complies with the IMO Code
for the LNG Vessels.
Our school provides comprehensive lecture and computer-based cargo
handling simulator training, including LNG science, engineering
systems, cargo systems, interfaces, rules and regulations, and safety.
I have provided a copy of a presentation that fully outlines our
LNG instruction at CMES along with this testimony.
Question 4.: How are U.S. mariners regulated versus foreign
mariners?
Under international law, each flag state is permitted to regulate
mariners sailing on vessels documented under their flag. Generally
speaking, many states claim to adhere to the minimum standards set by
the lnternational Maritime Organization. Their regulations are reviewed
and supposedly enforced by their own equivalent of the Coast Guard.
However, because of the large number of ``flags of convenience'', which
offer little or no oversight or regulation, there is a large
discrepancy between how mariners are regulated in the United States and
how they are regulated elsewhere.
While foreign mariners may be required to comply with their
government's regulations as well as international standards, the
validity of some of the credentials is suspect. A few years ago,
lnternational Transport Workers Federation President David Cockroft
purchased an authentic Panamanian first officers certificate and sea
book despite no practical maritime experience. The Seafarers'
lnternational Research Centre at the University of Wales investigated
the issue of fraudulent qualifications and in its preliminary findings
revealed 12,653 cases of forgery in 2001.
Federal and state government, local municipalities and the
communities surrounding LNG import terminals can rest assured that with
American mariners the LNG vessels are manned by professional seafarers
who have the integrity and the training necessary for the safe
transport of LNG.
Question 5.: Is there a worldwide shortage of LNG mariners? If so,
what can be done to close this gap?
Yes. According to a variety of sources, as I mentioned in my
written testimony, there is a worldwide shortage of LNG mariners. And
with over one hundred vessels expected to enter the trade in the next
few years, it will only get worse.
We believe that an easy way to close the gap is to use the
available pool of mariners in the United States. At the same time, we
must do our best to entice young men and women to join the ranks of the
maritime industry by going to sea. This means increased attention to
our federal and state maritime academies and promotion of the industry.
There are numerous articles cited in my written testimony regarding
the international crewing crisis as it relates to LNG. To illustrate
some of the concerns and the frequency with which the subject of the
worldwide shortage is reported, the international trade journal Daily
News published an article on April 4, 2007 that states:
SINGAPORE--04 April--Rapid growth of LNG shipping has forced vessel
operators to cream off senior officers from other ship types, causing a
serious shortage of trained and quality crew, warned Anglo Eastern Ship
Management quality and training director Chawla today. Speaking after a
presentation at the Sea Asia conference in Singapore, Chawla said
monthly wages for masters of LNG ships now stand at $18,000--20,000,
with some even being offered $22,000. ``There is no fresh pool of
officers to man LNG vessels. The entire LNG crew today have been
recruited from other ships (mainly LPG vessels) and re-trained,'' he
told Fairplay. Anglo Eastern manages four LNG vessels and is set to
take on more. However, Chawla noted that the manager has an average
crew retention rate of 10 years. The vicious circle of shortage has
seen rapid promotions with the result that many senior on-board
personnel have no hands-on experience, he said. Training methods have
to change to adapt to this worrying position, Chawla observed.''
In the end, shipping companies by nature traditionally wait until
the very last minute to make appropriate changes to their crewing
modules. This should not and cannot be the practice for LNG
importation.
Question 6.: According to Mr. Lesnick's written testimony, an
additional 133 LNG vessels are scheduled for delivery to service the
global LNG trades by 2010. This expanded fleet will require as many as
10,000 additional seafarers. Where will the companies find this
additional personal if there is already a shortage? What impact will
this shortage have on security?
This is a good question. The answer is unclear at this time. The
likeliest scenario is that the companies will put increased pressure on
their crewing agents, who will in turn begin to accept poorly trained
or unqualified seafarers to crew the ships. This represents a
significant threat to both safety and security. As the high standards
that have always existed in the LNG sector begin to slip because of the
shortage, the likelihood of an accident or intentional incident
increases.
This scenario is unacceptable, especially considering that there
are qualified Americans available for employment, and the United States
is a leading producer of entry-level mariners. The international
maritime community's deeply engrained prejudice and preconceived
notions about US merchant mariners remains a major impediment to
getting our mariners these jobs.
Question 7.: Do you support the Maritime Administrator's initiative
to increase the number of U.S. mariners on LNG? If so, what else should
be done?
Question 8.: It is my understanding that MEBA and Excelerate Energy
have entered into a Memorandum of Understanding. Please provide us with
information about this MOU.
On Tuesday, March 14, 2007, MEBA President Ron Davis signed a
Memorandum of Understanding (MOU) with Excelerate Energy for the
utilization of M.E.B.A. deck and engineering officers their liquefied
natural gas (LNG) carriers. The MOU, which recognizes MEBA as the
exclusive supplier of U.S. officers, involves Excelerate opening its
vessels and terminals worldwide to our members in order to achieve
recency qualifications to serve as officers in the LNG trade. In
addition, once qualified, MEBA officers will begin to mix into the
fleet as shipboard deck and engineering officers.
Excelerate has two partners related to its LNG shipping. One is the
Belgium based NV that operates the LNG tankers and the other is the
Norway based Skaugen Petro Trans that operates LNG Terminals. MEBA will
be providing officers for both shipboard and terminal side operations.
There are still details that are being worked out. For instance, we
are currently working with appropriate government agencies and
embassies for the purpose of licensing acceptance for U.S. Coast
licenses and qualifications international flag LNG vessels. In
addition, we are working with Excelerate's partner NV on taxes, benefit
structure, and qualification documentation.
On May 8, 2007, Excelerate, and Skaugen will be visiting our
training facility in Maryland. We expect that MEBA members will be on
Excelerate's vessels operating worldwide before the end of the year.
The following is an article from the April issue of Lloyd's List,
one of the leading maritime industry trade publications regarding the
deal:
Excelerate Energy's ``landmark'' US crewing agreement will apply to
all the company's vessels, the innovative US liquefied natural gas
shipping operator has confirmed, writes Tony Gray. Last month,
Excelerate reached an agreement with the Marine Engineers' Beneficial
Association union under which it would employ US citizens as deck and
engineering officers. Excelerate vice president Jonathan Cook said the
intention was ``to integrate US mariners on all our ships''. The
company's fleet comprises three regasification vessels and one
newbuilding. Mr. Cook said Excelerate planned to integrate US mariners
into the crews of the vessels, and not undertake a complete
replacement. Existing crews comprise European officers and Filipino
ratings.
Mr. Cook said the decision was not taken because Excelerate
considered US seafarers to be superior, ``We believe there will be a
shortage of mariners, especially officers, and think that the US is an
excellent source for qualified mariners.'' He explained that the US had
``excellent training facilities'' from maritime academies to union
training schools. ``We believe the competency of the existing crews is
excellent and have been very impressed with their capabilities and Mr.
Cook said. ``We expect that all of our crew will perform to the highest
standards regardless of nationality.'' Mr. Cook said Excelerate's
partner, Belgian gas shipping specialist was ``very supportive'' and
``happy to be working together with us on this There were no plans at
this time to change the flag--Belgium--under which the vessels sailed.
Cook said it would be ``premature'' to comment on the cost of employing
US officers compared with existing arrangements as ``details are being
discussed and worked out.''
Questions from the Honorable Peter T. King, Ranking Member, Committee
on Homeland Security
Question 9.: As you know, the Maritime Administration has begun
providing priority licensing to platforms that promise to provide
training opportunities for U.S. merchant mariners. How long does it
take for a merchant mariner to become truly proficient in LNG systems?
What does the qualification process involve?
To be considered truly proficient in LNG systems we must specify at
what level the officer will be working. A junior officer may be deemed
to have met the standards of training after completing a combination of
classroom and practical training. This may only take months to achieve.
However, it could take as long as 1--2 years of experience working with
expert senior officers to demonstrate the expertise to be considered
truly proficient. Additionally, to build a senior officer through USCG
License upgrades, specific specialized training and practical
experience it would require approximately 7--10 years time.
Question 10.: Where are merchant mariners trained on LNG systems?
Are there currently any training facilities in the United States?
At this time, all six of the state maritime academies and the
federal maritime academy at King's Point all provide basic LNG training
courses for their students. In addition, union training schools such as
the Calhoon School have extensive training programs for LNG. MEBA has
been teaching and training LNG technologies since the mid-1970's.
Question 11.: You mention in your written testimony that younger
junior officers are leaving the industry prematurely. We see this in
government from time to time, including within the Department of
Homeland Security. Why are these talented young seafarers leaving? Is
it a generational phenomenon? How can we keep this talent?
My testimony addressed the issues international fleet (foreign
flag) junior officers leaving the industry before they reach senior
level officer status thereby exacerbating the crisis. I placed this in
the testimony to show that if the United States does not address the
international crewing pinch now, then we are leaving ourselves open for
a disaster later. All of my testimony and citations to reports and
articles were based on what is going on in the international fleet. The
international community did not take into consideration that the United
States has a vibrant and growing pool of U.S. mariners ready, willing
and able to sail in the LNG trade. Basically, until recently, the
international maritime community forgot that the United States still
has a merchant marine.
Question 12.: If we required all LNG vessels calling on U.S. ports
to be crewed by U.S. merchant mariners, what happens if a ship, not
originally destined for the United States, wants to come to the U.S.
because of market demands on LNG? Should we turn them away?
It is quite common in the maritime industry to replace or add crew
members while the vessel is between final destinations. Generally, the
company would fly the replacement crew to a port somewhere along the
route the vessel is taking before it reaches its final destination, and
exchanges the crews as necessary.
Right now, many of the vessels operating in the LNG trades are
plying established routes, so the likelihood of their being diverted is
low. For those ships operating on the ``spot'' market, they generally
expect scenarios like this and plan for them appropriately. There would
be no need to turn away a vessel, because there would be multiple
opportunities to get qualified US crews in a reasonable amount of time.
Question 13.: Can you perhaps give us some insight into the vetting
process of some of the current LNG crews? I understand it varies from
country to country. The actual security vetting that U.S. Mariners
undergo is extensive:
U.S. Merchant Mariners receive their credentials to
work from the U.S. Coast Guard;
U.S. Merchant Mariners undergo extensive background
checks performed by the Federal Bureau of Investigation;
U.S. Merchant Mariners are background checked through
a National Driver (vehicle) Record database;
U.S. Merchant Mariners will also be subject to
jurisdiction of the Transportation Safety Administration (TSA)
where they will be vetted through a terrorist watch database in
order to receive a Transportation Worker Identification Card
(TWIC).
U.S. Merchant Mariners are citizens of the United
States or aliens lawfully admitted for permanent residence.
Under international law, each flag state is permitted to regulate
mariners sailing on vessels documented under their flag. Generally
speaking, many states claim to adhere to the minimum standards set by
the International Maritime Organization. Their regulations are reviewed
and supposedly enforced by their own equivalent of the Coast Guard.
However, because of the large number of ``flags of convenience'', which
offer little or no oversight or regulation, there is a large
discrepancy between how mariners are regulated in the United States and
how they are regulated elsewhere.
While foreign mariners may be required to comply with their
government's regulations as well as international standards, the
validity of some of the credentials is suspect. A few years ago,
International Transport Workers Federation President David Cockroft
purchased an authentic Panamanian first officers certificate and sea
book despite no practical maritime experience. The Seafarers'
International Research Centre at the University of Wales investigated
the issue of fraudulent qualifications and in its preliminary findings
revealed 12,653 cases of forgery in 2001.
Question 14.: The Coast Guard and the rest of the intelligence
community continue to tell us that the biggest threat to vessels is
that of a small boat attack--a Cole or a scenario. You argue that it is
the insider threat. What are your sources?
The United States Department of Energy commissioned a study which
determined that one of the most likely threats associated with the
carriage of LNG is an international (deliberate) act of terrorism by a
crewmember working aboard and LNG tanker. See the report conducted by
Sandia National Laboratories titled, ``Guidance on Risk Analysis and
Safety Implications of an LNG Spill Over Water.'' The report was issued
to the public in January of 2005 and can be found at:
http://www.fossil.energy.gov/programs/oilgas/storage/lng/
sandia_lng_1204.pdf
The Sandia report utilized available intelligence and historical
data to establish a range of potential, intentional tank breaches that
could be considered possible and credible. This included an evaluation
of insider and hijacking attacks on ships and also external attacks, as
well. The Sandia report is clear that the most devastating scenarios
involving an LNG tanker are those occurring as a result of an
intentional incident.
As a Licensed Chief Engineer for Steam, Diesel and Gas Turbine
vessels, I know how a ship operates and the ease with which a
knowledgeable crew member can take control of a vessel from remote
locations Especially in today's world of automation and computer
controls, which have reduced the crew needed to safely operate a
vessel, it is relatively easy for a member of the crew, intent on
causing a disaster and with no regard for his own personal safety, to
cause an intentional incident like the one I described in my oral
testimony.
Question 15.: The GAO, Coast Guard, and FERC have all testified
this morning as to the excellent safety record of LNG vessels. Does
MEBA have reason to question this assessment?
Not at all. In fact, the MEBA was instrumental in the establishment
of this safety record in the earliest days of the LNG trade. We
recognize that the LNG sector of the maritime industry has the best
safety record. Our desire is to ensure that this remains the case.
With the increased number of vessels and the widely acknowledged
crewing shortages, we believe that this excellent safety record is in
jeopardy. This is why we feel it critical that we persuade the
international maritime community to look to the United States as part
of the solution to this ongoing problem. If we don't take steps now to
address this looming problem, we make the possibility of a major
accident or incident more likely, and that is a risk we cannot afford
to take.
The point being is that transportation of LNG worldwide is a
rapidly expanding marine service. This growth has never happened so
quickly before, or in a segment of the maritime industry that is
technically so different from other segments. The shipboard
transportation of LNG has a great safety record. This is due in large
part because of the 40 years it took for the international LNG fleet to
reach 200 vessels. It may only take 5 more years for the LNG fleet to
increase by 100 or more LNG tankers. Thus proper vetting and training
are critical factors for consideration. The United States will most
likely be importing LNG at a very increased rate over the next several
years and we need to be prepared.
Questions from the Honorable Bennie G. Thompson, Chairman, Committee on
Homeland Security
Responses submitted by Mark E. Graffigan
Question 1: According to your testimony, uncertainties still exist
concerning the risks LNG spill would pose to the public. Why do these
uncertainties still exist?
Response: A large LNG spill from a poses a number of potential
hazards, the most likely of which is a large fire, which could
potentially bum the public. Scientists measure the heat from such a
fire by calculating the distance at which 30 seconds of exposure to the
heat could cause second-degree burns (termed the heat hazard distance).
The uncertainty surrounding this distance is evidenced by the range of
estimates identified by the empirical studies conducted to date: from
about 500 meters (less than mile) to more than 2,000 meters (about 1-
114 miles). Since there have been no large-scale LNG spills or large
spill studies have relied on models to determine the heat hazard
distance. Researchers had to make numerous modeling assumptions
including key fire properties, the size of the hole in the tanker, the
number of tanks that fail (cascading failure), the volume of LNG
spilled, and environmental conditions, such as wind and waves. Without
data on large-scale LNG spills, different studies used different
parameters for each of these assumptions, which resulted in different
heat hazard distances.
Question 2: In your testimony you state that additional research to
resolve some key areas of uncertainty could benefit federal agencies
responsible for informed decisions when approving LNG terminals and
protecting existing terminals. Please provide us with information on
this much needed additional research.
GAO Response: Additional research resolve some key areas of
uncertainty (particularly involving dangers from fire) could benefit
federal agencies responsible informed decisions when approving LNG
terminals and protecting existing and tankers, as well as providing
reliable information to citizens concerned about public safety. Our
panel of experts identified several areas of research needed. The
highest-ranked research needs are listed in table 1 below:
Table 1: Expert Panel's Ranking of Need for Research on LNG
Rank Research area Description Funded in DOE's
study
------------------------------------------------------------------------
1 Large fire A large fire may
phenomena behave
differently than
a small fire by
breaking into
several small,
short flames,
rather than
remaining as a
single, large
fire. This
behavior could
reduce heat
hazard distances
by a factor of
two or three.
Research could
this effect.
------------------------------------------------------------------------
2 Cascading Cascading failure
failure is the sequential
failure of
multiple LNG
storage tanks on
an LNG tanker
potentially due
to cold, spilled
LNG or the heat
from an LNG fire.
Research could
determine the
likelihood of
cascading failure
after an LNG
spill.
------------------------------------------------------------------------
3 Large-scale Self-explanatory
spill testing
on water
------------------------------------------------------------------------
4 Large-scale fire Self-explanatory
testing
------------------------------------------------------------------------
5 Comprehensive Comprehensive
modeling: modeling would
interaction of model all phases
physical of an LNG spill
processes together, rather
than creating
separate models
for each process
(vapor
dispersion,
ignition of the
vapors, etc.)
------------------------------------------------------------------------
6 Risk An assessment of
tolerability the level of risk
assessments the public would
tolerate
(potentially
community
specific)
------------------------------------------------------------------------
7 Vulnerability of An assessment of
containment how vulnerable
systems (hole LNG tankers are
size) to attack
------------------------------------------------------------------------
8 Mitigation Research into
techniques techniques that
could be used to
mitigate the
consequences of
an LNG spill
------------------------------------------------------------------------
9 Effect of sea Self-explanatory
water coming in
as LNG flows
out
------------------------------------------------------------------------
10 Impact of wind, Research to
weather, and determine how
waves wind, weather,
and waves would
impact existing
models of LNG
spills and fires
------------------------------------------------------------------------
Source: GAO.
Although DOE has recently funded a study that will address LNG
fires, study will address 3 of the top 10 issues--and not second-
highest ranked issue-that our panel of experts identified as
potentially affecting public safety. To provide the most comprehensive
and accurate for assessing the public safety risks posed by tankers
transiting to proposed LNG facilities, we recommended that DOE
incorporate the key issues identified by the expert panel into its
current LNG study. In particular, we recommended that DOE examine the
potential for cascading failure of LNG tanks in order to understand the
damage to the hull that could be caused by exposure to extreme cold or
heat. DOE agreed with our and recommendation.
Question 3: You have recommended that the Department of Energy
incorporate the key issues identified by the panel into their upcoming
report. What else should be done?
GAO Response: We believe that a study which addresses the key
issues identified by our panel of experts will significantly improve
the understanding of the consequences of an LNG spill. DOE should
ensure that the results of this research are available to and used by
decision makers.
Question 4: Do you think that the Coast Guard, the Maritime
Administration, and the Federal Energy Regulatory Commission have the
personnel and assets needed to oversee the additional 32 LNG
facilities?
GAO Response: As part of our work on the consequences of LNG
spills, we did not analyze the personnel or assets of these three
agencies.
Question 5: As part of the audit, you convened a Web-based panel of
19 experts. How did you select these experts?
GAO Response: We identified the 19 experts from a list of 51 who
had expertise in one or more key aspects of LNG spill consequence
analysis. In compiling this initial list, we sought to achieve balance
in terms of area of expertise. In addition, we included at least one
author of each of the six major LNG studies we reviewed, that is,
studies by National Laboratories; Consulting; Quest Consultants Inc.;
Pitblado, et al.; James Fay (Massachusetts Institute of Technology);
and William (National Oceanic and Atmospheric Administration). In
researching each candidate, we gathered and reviewed resumes,
publication and major related publications from the experts identified
on the initial list.
Specifically we sought: (1) broad experience in all facets of LNG
spill consequence modeling (LNG spill from hole, LNG dispersion,
vaporization and pool formation, vapor cloud modeling, fire modeling,
and explosion modeling); (2) experience in conducting physical LNG
experiments; and (3) specific experience with areas of particular
importance, such as LNG explosion research.
Question 6 Do you think that the Coast Guard, the Maritime
Administration, and the Federal Energy Regulatory Commission have the
personnel and assets needed to oversee the requested 32 LNG facilities?
GAO Response: As part our work on the consequences of LNG spills we
did not analyze the personnel or assets of these three agencies.
Question 7: According to your testimony, these experts did not
agree on several key issues. It has been over 5 years since 9/11, why
is there still disagreement amongst the experts concerning the security
on LNG tankers?
GAO Response: Our expert panel members primarily included
scientists and engineers who were experts in the areas of LNG
experiments, modeling LNG dispersion, LNG vaporization, fire modeling,
and explosion modeling. These experts do not have specific expertise in
the area of security.
The key areas of disagreement on the consequences of LNG spills
primarily involved heat hazard and cascading failure conclusions of the
Sandia study. Specifically, 7 of 15 experts thought Sandia's heat
hazard distance was ``about right,'' and the remaining 8 experts were
evenly split as to whether the distance was ``too conservative'' (i.e.,
too small to protect the pulic). Experts who disagreed with the
distance in the Sandia study generally disagreed with some of the
assumptions Sandia used in its models.
Only 9 of 15 experts agreed with Sandia's conclusion that only
three of the five LNG tanks on a tanker would be involved in cascading
failure. Many of the experts who disagreed with Sandia's conclusion on
cascading failure noted that the Sandia study did not explain how it
reached this conclusion.
Questions from the Honorable Peter T. King, Ranking Member, Committee
on Homeland Security
Question 1: Why is it important to study large pool fires? Why is
the current data insufficient? How has the Department of Energy
received your recommendations? Will you be following up with them
following their 2008 tests?
GAO Response: No LNG spills resulting from a cargo tank rupture
have occurred. In the 1970s and 1980s, experiments to determine the
consequences of a spill examined small LNG spill of up to 35 meters in
diameter. Following the terrorist attacks of September 11, 2001,
however, many experts recognized that an attack on an LNG tanker could
result in a large spill-a volume of LNG up to 100 times greater than
studied in past experiments, with uncertain effects.
Since then, a number of studies have reevaluated safety hazards of
LNG tankers in light of a potential terrorist threat. Because a major
LNG spill has never occurred, studies examining LNG hazards rely on
computer models to predict the effects of spills, often focusing on the
properties of LNG vapor fires. Small-and large-scale LNG fire
experiments are needed to refine and validate existing models to
accurately calculate the heat hazards of large LNG fires. Our panel of
experts recommended new LNG tests for fires between 15 meters and 1,000
meters with a median recommended size of 100 meters. Some experts also
raised the issue of whether large LNG fires will stop behaving like one
single flame but instead break up into several smaller, shorter flames
and whether large fires will produce sufficient smoke to partially
shield the heat from the LNG fire.
DOE agreed with our and recommendation. GAO will follow up on the
implementation of this recommendation.
Question 2: The GAO report refers to the possibility of a LNG
explosion as ``unlikely.'' Would the GAO consider such an explosion
more or less "likely" than gasoline?
GAO Response: Our panel of experts agreed that (1) the most likely
public safety impact of an LNG spill is the heat impact of a fire and
(2) explosions are not likely to occur in the wake of an LNG spill,
unless the LNG vapors are in confined spaces. For confined spaces, the
experts agreed that it is possible, under controlled experimental
conditions, to induce an explosion of LNG vapors; however, they agreed
that a detonation--the more severe type of explosion--of confined LNG
vapors is unlikely following an LNG spill caused by a terrorist attack.
For unconfined spaces, such as a spill from a ship onto water, our
experts were split on whether it is theoretically possible to induce
such explosions; however, even experts who thought such explosions were
possible agreed that explosions in unconfined spaces are unlikely to
occur following an LNG spill caused by a terrorist attack.
We did not specifically ask our panel of experts about whether an
LNG explosion is more or less ``likely'' than gasoline, or any other
commodity, explosion. However, we did ask our panel of experts to rate
the risk to public safety posed by an attack on tankers carrying
various energy commodities. The results of their ratings are included
in Table 2 below.
Table 2: Expert Panel Comparison of Risk Posed by Energy Commodities
Experts were asked ``In your opinion, what is the risk to public safety posed by an attack on tankers carrying
each of the following energy commodities?'' The numbers in the table are a count of how many experts selected
each possible response (i.e. ``little to none,'' ``little,'' etc.)
Liquefied natural Heating Jet Liquefied
Answer gas Crude oil Diesel Gasoline oil fuel petroleum gas
Little to None 1 2 1 0 1 1 0
----------------------------------------------------------------------------------------------------------------
Little 3 10 11 5 11 6 1
----------------------------------------------------------------------------------------------------------------
Medium 6 3 3 8 3 6 4
----------------------------------------------------------------------------------------------------------------
Large 3 0 0 2 0 2 5
----------------------------------------------------------------------------------------------------------------
Very Large 2 0 0 0 0 0 5
----------------------------------------------------------------------------------------------------------------
Did not answer 4 4 4 4 4 4 4
this question
----------------------------------------------------------------------------------------------------------------
Ten of 15 experts identified a large to very large risk associated
with an attack on a liquefied petroleum gas tanker; whereas, only 5 of
15 rated LNG as a large to very large risk. In comparison, only 2 of 15
experts rated gasoline as a large to very large risk.
Questions from the Honorable Bennie G. Thompson, Chairman, Committee on
Homeland Security and the Honorable Peter T. King, Ranking Member,
Committee on Homeland Security
Responses from Phani K. Raj,PhD
Question 1: In your written testimony, you state additional
research is required. Why hasn't this research already been completed?
Response: In any industry research is an ongoing activity simply
because the nature, type of questions and underlying reasons for
additional investigations change continually.
In the case of the LNG industry, there was considerable research
and assessments conducted in the US in 1970s and in early 1980s because
the industry was just beginning to grow. The research, while initially
focused on understanding LNG hazards, quickly was refocused on
prevention of accidents and mitigation. With this change in the
emphasis, small-scale test results were deemed acceptable, especially
since large releases were discounted as being engineered out or of such
a low probability of occurrence as not to pose a risk to society. The
US Coast Guard promulgated regulations to control vessel traffic in
harbors and required safe separation distances between a LNG ship and
other vessels. This virtually eliminated the possibility of accidents
in LNG shipping in and around harbors. The promulgation of the
consensus industry standard, NFPA in 1969 and the federal regulations
in 49 CFR, part 193 in late 1970s and for designing and operating LNG
facilities together with the safe de facto operation of LNG facilities
and shipping (world-wide) provided an assurance of public safety. The
same was true for LNG industry in Europe with the promulgation of the
EN1473 regulations. Some additional experimental research was continued
in England (on heavy gas dispersion) and in France (on pool fire).
However, by the time of late 1980s and for the rest of the 1990 decade
no funds were invested by either government agencies or the industry in
conducting substantive research because of the reduced importance of
LNG in the energy economy of the world. In fact, many of the data from
late 1980s tests went un-reviewed and unpublished because of lack of
research funding.
Since 9/11/2001 a new dimension of concern from LNG storage and
transportation has been added to the public safety debate. Terrorism
caused releases and their effects have opened up new concerns both in
how much and how large a LNG spill may occur and on the consequences
such releases pose to the public. Such concerns are expressed for
releases from LNG ships in or near harbor entrances, more than for
land-based terminals (thanks to successful terrorist attacks on ships
like USS Cole and the crude oil tanker SS Limburg). Because of the
possible scenarios of release caused by intentional acts, new potential
hazards have been identified for LNG releases, which may or may not be
larger than the hazards previously examined. These hazards, therefore,
need to be investigated both mathematically and experimentally. That
is, new research is therefore essential. In addition, the underlying
premise of large holes being created by intentional attacks on LNG
ships needs to be reviewed by a knowledgeable and cleared independent
peer review panel to ensure that all aspects of the issue have been
investigated and that the assumptions on which the hazard distance
estimates have been developed are credible.
As indicated earlier, some of the data from tests conducted in late
1980s were not analyzed fully to understand the extent of hazards posed
by large LNG (pool) fires. Only recently has it been realized that
large LNG fires do not pose as large a threat as envisioned from the
data of small fire tests of the 1970s. It is now known that large LNG
fires burn with evolution of significant quantity of black smoke
forming a shroud outside and around the burning inner core of the fire.
The smoke layer prevents the heat from radiating out of the fire.
However, the quantification of the extent of smoke production, the
height of the burning zone, the variation of the heat emission from the
various parts of the fire with height) are not all known with the
degree of precision needed for proper estimation of the hazard area
surrounding large LNG pool fires. Therefore, additional research in the
form of conducting large LNG pool fires is needed.
In addition, the release scenario associated with a terrorist
attack (involving the formation of large gaping holes on the two hulls
and the tank of a LNG ship) leads to certain phenomena that have not
been understood or researched before. These include (i) the potential
leak of LNG into the hold space and the possible detrimental effect of
the interaction of the cryogenic liquid with the ship's structural
members leading to metal cracking and multiple tank failures, (ii) the
rapid and very large rate of release of LNG onto the water surface, its
plunging into the water column, its high evaporation locally and rising
to the water surface of both a large volume of vapor and liquid. The
un-evaporated liquid would then spread as a pool on the water surface,
(iii) the effect of wind and waves affecting the motion and evaporation
of the pool with and without sustaining a fire on top, (iv) the
transient nature of the pool spread and the characteristics of the fire
on top of it, etc. These phenomena also need be assessed by conducting
experiments of the appropriate size.
In summary, while a considerable amount of LNG related research
activities occurred in 1970s and the postulated circumstances and
causes of potential releases in the 2000s are different and
consequently their effects could be different. Hence, additional
research is necessary.
Question 2: The GAO report highlights the fact experts still
disagree on the consequences of a LNG spill. What is the root of this
disagreement? Will consensus reached on this important issue?
Response: As discussed in response to question 1, there are a
number of phenomena related to a LNG release that are incompletely
understood and need additional research to provide information with
which to make scientifically valid extrapolations to real situations.
The sizes of postulated LNG releases, either on land from storage
tanks or on water from LNG ships, from accidents or deliberate
terrorist actions are substantially larger (by factors of 20 to 30)
than any controlled tests performed to date. For example the largest
test performed to understand the behavior of LNG pool fires on water
are of about \1\ 5 m in diameter, whereas the postulated sizes of LNG
pool fires occumng from spills from ships (due to intentional acts) can
range from 300 m to 450 m in diameter. Therefore, in order to the
consequences of large spills, considerable extrapolation of the results
from small scale tests need to be made. This is where the disagreements
amongst the scientists occur, because, the mathematical models used by
different groups describe the largsscale phenomena differently. Some
include additional physical phenomena that have been observed in other
fuels, some do not; one group makes very conservative assumptions
(essentially to overcome scientific ignorance), while another group
assumes it knows how to extrapolate from smaller scale test data to
larger scale. That is, scientific extrapolation involves significant
issues of interpretation of existing data, assumptions regarding
changes in the behavior characteristics (for example, the
characteristics of large LNG fires) and consideration or lack thereof
of certain other phenomena of interest (atmospheric absorption of
radiant heat, effect of obstructions, clothing in reducing heat
effects).
In addition to the extrapolation of the effects of known phenomena
with LNG behavior there are other causes for disagreements. The
calculation of potential hazard (areas) from the release of LNG
requires the consideration of three important elements, namely, (i) the
description of the source; that is, the location, size and other
characteristics of the hole, the rate of release of LNG given the hole
characteristics, the interaction of LNG release with its immediate
environment (water, land, etc), the sizes of pool or vapor cloud
formed, (ii) description of the behavioral mode pf the LNG; that is,
immediate ignition or not, burning as a pool fire, fire ball or
unignited vapor cloud dispersion, probabilities of ignition of the
dispersing vapor cloud with distance from the source, the type of
burning of the vapor cloud, passive burning vs. energetic burning with
the formation of a blast wave, etc, characteristics of the fires
produced in terms of size, duration of existence, radiant energy
output, etc, and (iii) description of the effects of fires or other
hazards; including the radiant energy absorption in the atmosphere, its
attenuation by intervening structures, clothing on persons; effects of
radiant heat flux on a person, ability of a person to take corrective
action and finally, the effects of any active mitigation activities
instituted by the emergency responders. As can be seen, there are so
many dimensions to evaluating the potential hazards. Therefore,
depending upon what behavioral aspects are included in an analysis, how
correct the description of the individual phenomenon is, and the
correctness of extrapolation of small-scale test data (for those
phenomena for which data exist), researchers can come up with different
set of predicted areas of hazard.
Therefore, it can be surmised that the root causes of disagreement
among experts are (a) the nature of the problem itself and the extent
to which the details of various phenomena are considered in any
analysis, (b) validity of scenarios and the underlying assumptions,
which lead to prediction of large scale releases, and (c) the
variability in the science of extrapolation of small test data to
larger scale phenomena, especially when some of the behavioral aspects
of nature that occur in the large scale do not show-up in the small
scale tests. For example, a technical peer panel of experts with proper
technical and classified credentials will need to validate the result
that very large holes are created by intentional attacks and not by
ship-to-ship collisions event though the latter involves substantial
energies. The magnitude of the source represented by the hole size
forms the very basis of all other hazard assessment results. As to the
question of whether consensus will ever be reached among the experts on
this important issue, I will have to say that while convergence of
approaches to evaluating the hazards for a given set of specified
scenarios may be achieved in the future (especially with additional
experiments on several scenarios for which we have, at present, limited
or not data at all), I would not say that consensus on all issues will
ever be possible. This is just the nature of scientific debate. In
addition, the external circumstances may change, dictated by unforeseen
circumstances (as indeed happened between the 1980s and 2000s by the
interjection of terrorism as a force to contend with), technological
improvements that may negate some of the ``scenarios'' currently being
considered by some experts and not by others, and changes in regulatory
requirements. Therefore, it would be difficult to expect a 100
consensus among all experts on all issues in this field, or any other
field for that matter.
Question 3: In your written testimony you state that the LNG
industry has operated safely both in U.S and worldwide for over six
decades and that there is no technical operational reason this record
will not continue. There is one reason why this record could be broken
and that is terrorism. Do you believe that terrorists will be
unsuccessful in targeting LNG ships? If so, why?
Response 3: I want to address two aspects in my answer to the above
question. The first is the presumption that LNG ships are attractive
targets to terrorists. The second is whether LNG ships can be
successfully targeted. I do not believe that on either of the above two
criteria, LNG ships form attractive and successful targets.
It is my considered opinion, based entirely on commonsense judgment
and scientific training, that an LNG ship does not form an attractive
target to terrorists. If one studies the modus operandi of terrorism,
it is clear that it is always based on the need to make a big
``splash'' either by affecting (injuring or killing) the largest number
of people or attacking a target that represents a national ``symbol''
of some sort. The train and subway bombings in London, Madrid and
Mumbai and the hotel bombings in Bali all represent the former type
whereas US World Trade Center bombings in 1993 and the attack on
represent both types of targets. A LNG ship or an installation is
neither national symbol nor will a large LNG release from a ship cause
mass casualties in nearby populations. The principal effect of concern
in the case of LNG release is the radiant heat effects of the fire,
whose effects can be, relatively easily, defeated or minimized by
sheltering, hiding behind buildings or initiating other mitigation
measures. That unfortunately, is not the case for a number of other
soft targets where people gather in large numbers (sports arenas, big
office buildings, mass transit, etc) or from chemical facilities that
store or produce chemicals that once released can affect a large number
of people.
LNG is a fuel very much like other hydrocarbon fuels that are used
in the US in much larger quantities and transported in more numerous
ships. The fire effects of all fuels are about the same, especially
when one considers the characteristics of very large pool fires. We
have to assume, with reasonable amount of certainty, that terrorists do
considerable research (as was evident from the 9/11 tragedy) on the
science required, technical outcome, and the or symbolism of the target
before selecting a target. It is reasonable to assume that only a
target, which promises to be vulnerable and successful in the attack
will be selected; that is, a terrorist wants the best for the (the
unfortunate pun is intended here). Having said that, it is evident that
there are other less well protected energy and chemical targets that
may be more susceptible and closer to population centers than a LNG
ship. On a sheer opportunity, availability and comparative effects
basis, it is my opinion that LNG ships do not form a target that would
be high on the list of ``attractive'' targets for terrorists. In fact,
my above conclusion is similar to the conclusion in a relatively recent
report by the GAO.\1\ To quote the GAO,
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\1\ GAO Homeland Security, Voluntary Initiatives are Underway at
Chemical Facilities, but the Extent of Security Preparedness is
Unknown. U.S. General Accounting Office, GAO-03-439, March, 2003.
---------------------------------------------------------------------------
Flammable chemicals fewer people because the distance the substance
travels tends to be shorter, and
. . . chemical facilities present an attractive target for
terrorists intent on causing massive damage because facilities house
toxic chemicals that could become airborne and drift to surrounding
areas Alternatively, terrorists could steal chemicals, which could be
used to create a weapon capable of causing harm.
The recent book \2\ by Stephen Flynn has also pointed out how many
vulnerable, high damage ratio targets of interest there are in the US,
which if attacked can result in significant harm to the public, both
physically and economically. It is therefore, my considered opinion
that an LNG ship neither provides the opportunity nor forms an
attractive target, either from the perspective of causing mass
casualties or disrupting the nation's economic activity.\3\
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\2\ Stephen Flynn, ``The Edge of Disaster,'' Random House
Publishers, New York, 2007.
\3\ If a LNG ship is attacked and all its cargo is burned, a
substantial loss will result to the owner of the ship and the cargo
owner. But that will hardly disrupt the nation's long-term economic
welfare. Short disruptions in port and natural gas supplies could
occur, however.
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The second part of the question is whether terrorists will be
unsuccessful in targeting LNG ships. Sandia report \4\ indicates that,
``Risks from intentional events, such as terrorist acts, can be
significantly reduced with appropriate security, planning, prevention,
and mitigation.'' Of course, what it does not say is that there are
currently appropriate security, prevention, and mitigation regulations
in place.'' The security planning, prevention and mitigation, are
required to be implemented under the US Coast Guard regulations.\5\
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\4\ Hightower M., L. Gritzo, A. Luketa-Hanlin, J. Covan, S.
tieszen, G. Wellman, M. Irwin, M. Kaneshige, B. Melof, C. Morrow, and
D. Ragland, ``Guidance on Risk Analysis and Safety Implications of a
Large Liquefied Natural Gas (LNG) Spill Over Water,'' Sandia National
Laboratory Rep.# SAND2004-6258 U.S. Department of Energy, Washington, p
77, Dec 2004
\5\ Waterway Suitability Assessment, Navigation and Vessel
Inspection Circular 05-05, U.S. Coast Guard, Washington, June 2005.
---------------------------------------------------------------------------
With the current security regime that ``surrounds'' a LNG ship when
it is underway or anchored in a port, I do not see how a terrorist can
successfully attack the ship as to cause substantial damage. The US
Coast Guard is on record \6\ stating that shoulder fired missiles will
not damage LNG ships. The only other way a LNG ship could be attacked
is by a fast boat or a dinghy loaded with explosives that can actually
approach the ship, and set off the explosives in very close proximity
of the ship. [As pointed out in my written direct testimony presented
to this Committee, a LNG ship has two hulls separated by at least a 2 m
(6 ft) separation distance. Such a double hull construction provides
considerable protection against LNG releases from scale attacks]. If
the boat bomb scenario is credible, one expects this to occur in or
near a port because a port represents a high population density (and
that is what a terrorist may be interested in causing damage to). This
scenario of attack, at least, in US may be an extraordinary feat to
achieve. For example, every LNG ship that makes a port call into Boston
Harbor is escorted by a flotilla of US Coast Guard and other law
enforcement vessels manned by armed personnel. A terrorist boat must
get through this gauntlet; the chance of success is therefore very
small to essentially zero. As I argued earlier, a terrorist will seek
to maximize his success for his efforts and, therefore, may redirect
his attention towards other softer and less well guarded targets that
will produce comparable, if not, greater casualties than those
resulting from an attack on a LNG ship. While, I cannot state
categorically that an attempt at a LNG ship will not be made or if made
will not cause some damage to the ship, I can state with a good deal of
certainty that the probability of a successful attack on a LNG ship in
the harbor waters of any US port is extremely small. This statement is
based entirely on my judgment as an engineer and my practical
experience in conducting field experiments and suffering failures in
best-laid test plans executed with cooperation and help from the best
professionals. Success in any mission, however well planned, is not
guaranteed under the best of circumstances, let alone when it is
actively and vigilantly opposed.
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\6\ Testimony by Vice Admiral Solerno before the Homeland Security
Committee of the US House of Representatives, March 21, 2007.
Question 4: According to your written testimony, focusing only on
consequences of perceived worst cases rather than on the overall risk
from activity will result in poorly utilized improperly allocated
resources. I disagree with this assessment. We should be concerned
about the worst-case scenario. Why you recommending otherwise?
Response 4: Mr. Chairman, it was not my intent in the testimony to
suggest that worst-case scenarios should not be considered in hazard
assessment. My point was that a worst-case scenario alone, without
consideration of its chances of occurrence (in comparison with other
activities that our society is subject to involuntarily or accepts
voluntarily), cannot and should not form the only basis of a regulatory
decision-making. I will elaborate this contention below.
The true potential for harm by any activity, industrial or
personal, can be gauged only by a process of comparing the range of
detrimental effects of that activity with other similar activities
undertaken either by the society at large or by an individual by own
volition. This approach is termed the ``Risk Analysis.'' Risk analysis,
which presents a true measure of the both economic and physical
problem, considers a spectrum of events, their probabilities of
occurrence and their detrimental effects. This is in contrast to a
worst-case analysis, which only highlights a situation where the
ability of people to actively or passively manage the situation once it
is very limited. In the case of an industrial plant when one focuses on
the very worst case, one is not looking at the possibility of it
occurring with any degree of certainty within the lifetime of a plant.
Focusing only on the worst case and trying to obtain solutions to it
tantamount to making the risk zero, which is impossible. In the words
of late Sen. Moynihan, The function of risk assessment, is not drive
risks to zero, which would rarely be possible, but to illuminate
choices, costs and priorities. The first discovery in applying risk
assessment to the real world is that zero risk is not a prudent
objective.'' \7\
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\7\ Quotation attributed to US Senator Daniel Patrick Moynihan by
William (past Administrator of EPA) in the foreword to the book ``Human
and Ecological Risk Assessment; Theory Practice, ``Edited by Dennis
Paustenbach, A John & Sons Publication, New York, 2002.
---------------------------------------------------------------------------
If worst case scenarios were the only basis of public policy and
regulatory regimes then many of the activities that we, as a human
society and the US as an industrial society, would not be able to
undertake. For example, there have been at least two major disasters
involving explosives and detonable cargo transported in ships leading
to many fatalities.\8\ Yet explosives and other chemicals that explode
do get transported every day in ships and vehicles that drive through
populated areas. Similarly, airline disasters have killed many people
over the past 100 years, yet billions of people have traveled and
continue to travel in airplanes without fears. There have been dam
bursts, chemical releases, and other industrial accidents, all of which
can be termed ``worst-case'' occurrences resulting in associated public
injuries and fatalities. After every disaster the safety systems are
improved and systems to prevent future happenings are incorporated in
the design. No single industry has been prevented from participating in
the economic activity or has been stopped by regulations anywhere in
the world because of these historical occurrences. This is because the
regulatory process has understood that while the ``risk'' has to be
minimized, and efforts must be made to reduce the chances of ``worst-
case'' scenarios from occurring, there is no way to completely
eliminate them.
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\8\ The first one occurred in the port of Halifax in 1917 in an
ammunition carrier, ``Mount Blanc.'' The second incident occurred in
1947 in Texas City, involving two ships (``Grandcamp'' and ``High
Flyer'' loaded with ammonium nitrate fertilizer, which exploded.
---------------------------------------------------------------------------
If worst-case scenarios are the only guiding principles for a human
society to function, all activities will have to stop and progress, as
we know it, will not exist. In the context of the LNG industry and the
associated activities, I provide the following examples of the impact
of ``worst-case'' analysis.
In a recent DFEISEIR \9\ related to the siting of a
LNG import facility in the Port of Long Beach (PoLB) it is
stated (by considering only the worst case scenarios) that the
best guess frequency of a terrorist attack on a LNG plant is of
the order of once in 150,000 years. This conclusion is based on
the statistics of all chemical facilities in the US and
historically realized or thwarted attacks. Considering that LNG
plant is well guarded and that the infrastructure (tanks) is
much more robust compared to those in chemical plants, it can
be argued that a successful attack on a LNG storage tank
leading to the release of its entire inventory is smaller than
once in 1- 1/2 million years. This scenario of the release of
entire contents of the storage tank and its effect will
constitute the worst-case condition.
---------------------------------------------------------------------------
\9\ http://elibrary.fere.gov/idmws/search/results.asp: Draft
Environmental Impact Report for the Long Beach LNG Import Project under
CP04-58 et al., FERC, 10/07/2005,
---------------------------------------------------------------------------
The odds of a LNG release as described are about the same as the
odds of a large asteroid (of size greater than 1 km in diameter)
hitting the earth (approximately, once in one thousand to once in a
million years).\10\ The consequences of such an asteroid hitting the
earth will spell a disaster of proportions that have never been
experienced by human beings. However, the public does not seem to be
concerned at all but is pursuing all activities, industrial, personal
or political without much regard to this worst-case scenario.
---------------------------------------------------------------------------
\10\ http://geo.arc.nasa.gov/sge/jskiles/fliers/all_flier_prose/
asteroid_toon/asteroid_toon.html
---------------------------------------------------------------------------
Consider another example a more probable and highly
disastrous asteroid hitting the earth. In December 2004 scientists
announced \11\ that a space rock named 2004 (of diameter 1/4 mile or
400 m) had about a 1-in-40 or 2.6 % chance of striking Earth on April
13, 2029.\12\ The asteroid is large enough to cause considerable local
or regional damage were it to hit the planet. What are we doing about
this potentially a very large catastrophe?--nothing. That is because
the problem is so huge that unless a very large magnitude of resources
are imposed nothing much can be done to prevent the accident.
Fortunately, the situation with regard to LNG shipping is far better.
Steps have been taken to minimize, with human innovativeness, with
intelligence information and technology, the occurrence of such very
large disasters.
---------------------------------------------------------------------------
\11\ http://www.space.com/scienceastronomy/
astroid_update_041227.html
\12\ Recent news reports on the internet allude to other scientific
assessments, which indicate that this asteroid will come close to the
earth, but will not collide with the earth in 2029; the same asteroid
will make another pass in 2035, but the risk of collision with the
earth cannot be calculated at this time.
---------------------------------------------------------------------------
The case of preparing and planning response procedures only on the
basis of very large, catastrophic scenarios of LNG release without
considering the evaluation of smaller ``accidental'' or other ``smaller
attack'' scenario releases leads to misallocation of resources and
leads to ineffectiveness. Should a relatively small incident occur, it
is human nature to respond with the and only plan developed on the
basis of the scenario, which will affect a very large number of people.
Such a plan may call for massive evacuation or at the very least
require informing a very large number of people on what to do, in a
very short time. Such approaches will only exacerbate the problem
resulting in physical as well as communication gridlocks, not to speak
of the wrong information it conveys to people.
In my recent assessment of the consequences of potential release
scenarios at the Everett, MA LNG facility, the emergency responders of
the city of Everett (The Fire Chief and the Police Chief) requested me
to consider only those scenarios that are realistic, credible and
exclude the scenario of release of the entire contents of the LNG tanks
(40 million gallons) because it represents an extremely incredible
event (an event that had the probability of occurring, if at all, once
in a million years or more). This is because of the realization that
the release of the entire contents of even the smaller of the two tanks
(15 million gallons) would be an incredible event, the response to
which would take an extremely large amount of financial, equipment and
manpower resources that neither the city of Everett nor the surrounding
communicates could afford to tie up. Therefore, while the worst-case
scenario may be considered for analysis, it cannot form the only basis
of any decision-making including for emergency response.
Over the past 30 years of safely transporting LNG in highway trucks
there have been three instances in which the LNG trucks overturned (due
to traffic accidents) without leaking LNG. In all of these instances
the local authorities chose to shut arterial highways for over 8 hours
creating traffic havoc, inconvenience, lost economic opportunities and
direct expenses, all on a scale completely The reason for this is
simple; the emergency responders today are taught (incorrectly, in my
opinion) that LNG is very dangerous and they are always taught to
expect the ``worst.'' As a scientist I can state that a gasoline road
tanker in a similar situation will be far worse both from the
perspective of the potential for a spill (gasoline tankers are less
strongly built than LNG tankers), fire and explosion and other vehicles
and people in the vicinity. Yet, I have never heard of highways being
shut down for whole day due to a traffic accident involving a gasoline
tanker without fire or spill.. This is because, gasoline is widely used
and its hazards, normal or worst case, are accepted by the society.
A recent report by Sandia National Lab (4) recognizes
the limitations of conducting just a worst-case analysis related to LNG
shipping and concludes:
Because costs to prevent and mitigate the potential consequences of
an extreme event such as an LNG spill can be extensive, performance-
based risk management approaches can be used to ensure that public
safety and property are effectively protected.
Therefore, Mr. Chairman, it is my considered opinion that analysis
alone should not be the basis for any regulation or decision-making. It
has to be considered in the context of other events associated with the
activity of concern and has to be viewed from the perspective of the
risk posed by a spectrum of events, their likelihood of occurrence and
the hazards they cause.
Questions from the Honorable Peter T. King, Ranking Member, Committee
on Homeland Security
Ouestion 1: You mention in your written testimony that the
mathematical modeling used today is based on data that is 30 years old,
and that you're concerned about the ``scale.'' Can you explain why a
smaller LNG spill or fire might behave differently than a larger LNG
spill or fire?
Response 1: There are a number of phenomena related to LNG release
(especially from a ship) that have to be modeled before a calculation
of the overall hazard from the release can accurately be made. The
models applicable to these phenomena may be broadly as, (i) Source
models, (ii) LNG behavior models, and (iii) Hazard-effect models. A
majority of the experimental research conducted to date has focused on
understanding and quantifying LNG behavior phenomena (such as the
characteristics of pool fires, vapor fires, vapor cloud explosions,
etc). Not much experimental work has been undertaken to model or
describe either the ``source'' or the effects that constitute hazard to
people and objects. To a very limited extent laboratory test data exist
on radiant heat effects on the human skin. Only theoretical models
exist for the source and characterizing hazard effects.
The principal concern in regard to hazards from a LNG spill is the
effect of a fire. As the GAO has indicated in its report,\13\ the
formation of a large pool fire on water and the radiant heat emission
(and its effect on people) is the single most important issue in LNG
hazards analysis. A number of pool fire studies were conducted in 1970s
in the US and up to 1987 in Europe. The largest sizes of pool fires
tested in the US are, 6 m (20 ft) diameter on land and 15 m (50 ft)
diameter on water. In Europe the largest pool fire on land tested was
35 m (115 ft) diameter on an insulated concrete dike.
---------------------------------------------------------------------------
\13\ ``Public Safety Consequences of a Terrorist Attack on a Tanker
Carrying Liquefied Natural Gas Need Clarification,'' Report GAO-07-316
to Congressional Requesters, US Government Accountability Office,
Washington, February 2007.
---------------------------------------------------------------------------
The less than 50 ft diameter LNG fire tests showed a very clean
burning, highly radiative yellow colored fire. These types of fires
were found to radiate heat energy at a high level over \14\ all of the
visible size of the fire. However, as the size increased by just a
factor of about 2 (from 15 m diameter to 35 m diameter) the fire
characteristics were found to be completely different in that the
larger fire produced copious amounts of black soot which shrouded much
of the surface of the fire resulting in substantially reduced emission
of heat from the fire. In addition, it was noticed that the heat output
from the fire was not uniform from bottom to again due to the effects
of smoke.
---------------------------------------------------------------------------
\14\ The radiant heat output from a fire is generally expressed as
its ``Emissive Power'' or ``Radiance'' and is measured in units of
energy radiated per unit ``ideal'' surface area of the fire and
expressed in either kW/m\2\ or Btu/hr ft\2\. The fire is considered as
a cylindrical body (even though the flame has many folded surfaces) and
it is the surface of this cylindrical envelope that is considered in
defining the emissive power.
---------------------------------------------------------------------------
The conventional wisdom as to why large fires behave differently
(and put out less net radiant heat than small fires) are based on the
following observations:
(i) As the size of the fire increases, it becomes more and more
difficult for air to diffuse to the center of the fire in time
so that the fuel vapor burns efficiently and completely. The
reduction in burning efficiency (or the burning chemistry)
results in the formation of black soot in such an amount as to
start shrouding the fire from the outside.
(ii) The fuel vapor emanating from the boiling liquid pool
surface forms a bubble of gas in the bottom core of the fire.
This gas bubble has the capacity to absorb the heat from the
fire above and thus reduce the amount of heat that gets passed
on to the liquid for evaporation. Both of these phenomena are
size dependent phenomena that do not occur in smaller (less
than 20 m) fires but are pronounced in fires larger than about
30 m.
(iii) Once the diameter of the fire increases above a certain
critical value (and what this critical value is for LNG pool
fires is at present unknown), the fire no longer bums as a
single unit but instead breaks up into several individual and
distinct collection of columns of fire. This phenomenon, which
is observed in forest fires when a very large area is burning,
is termed the ``mass fire.'' The air for burning no longer
comes from the sides but from the top in the form of downdrafts
feeding individual columns. This is an extremely complicated
phenomenon, which has not been observed in any of the largest
LNG fire experiments to date (35 m diameter tests in France).
If this should occur in LNG pool fires, the result would be a
much shorter vertical extent of the fire and, hence, a much
reduced hazard distance.
The significance of the large fire phenomena on the overall hazard
distance can be described as follows.
In general the larger the LNG fire diameter the larger
is the distance from the fire to a specified level of hazard
(in kW/m\2\ in heat flux level). However, for a specified level
of hazard the ratio of the hazard distance to the diameter
decreases substantially for larger fires compared to the value
for smaller fires. This is primary due to the less radiative
characteristics of a larger sooty fire.
Since hazard distances from large LNG pool fires
result in large distances, the absorption of radiant heat by
the intervening atmosphere becomes very important in reducing
the radiant heat to the objects. The reduction in hazard
distance to diameter ratio of larger fires is therefore due to
both the sootiness of the fire as well as due to the
significance of the atmospheric absorption.
In large fires the emissive power varies significantly
from the base to the top of the fire. The bottom parts of the
fire are more radiative than upper parts of the fire. Hence, if
the lower parts are masked (either by a wall or by some other
obstruction), then the reduction in the hazard distance will be
very significant.
In the case of a larger LNG pool fire on water, the
high radiative emission from the bottom parts of the fire will
result in the water surface near the fire to be heated to such
an extent that it produces significant amount of water vapor.
The thus generated water vapor will act as an additional and
significant absorber of radiant heat emission from the bottom
parts of the fire resulting in substantial reduction in the
hazard distance.
Question 2: As an expert in the study of LNG, can you take a moment
to compare the different dangers between LNG and gasoline? Is LNG so
much more dangerous than gasoline? Does it fire faster?
Response 2: Gasoline and LNG (methane) are fuels that belong to the
saturated hydrocarbon chemical group. The combustion properties of all
saturated hydrocarbon fuels are very similar. For example, the heat
produced when a pound of any one of these saturated hydrocarbons is
burned in air \15\ is the about the same, namely 20,000 Btu (within
5%). Also, the pounds of air required to bum completely one pound of
any of these fuels are also about the same, namely, 15.5 ( 3%) except
for methane, which requires a larger quantity of air. The consequence
of the similarity in combustion properties is that the fires all of
these fuels have, within 100 F the same temperature. (The laboratory
measured fire temperature in a gasoline fire is 3580 F and that in a
methane fire is 3410 F)
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\15\ In a quantity of air (called the ``stoichiometric'' amount),
which contains the chemically required amount of oxygen to react with
the hydrocarbon for complete combustion.
---------------------------------------------------------------------------
Itemized below are comparisons of important gasoline and methane
properties that have a bearing on the extent of hazard that each fuel
poses. Also included are discussions on the effect of each property on
the overall hazard.
Vapor flammabilitv limits in air: The gasoline limits
are 1 % to 7.6 %, whereas the methane limits are 5% to 15%.
This means that gasoline vapors are flammable even at very low
concentrations posing a larger vapor area of hazard for a given
mass of spill.
Energy content per unit volume: Gasoline (liquid) has
an energy content of 116 kBtu/gal whereas the LNG value 72
kBtu/gal. That is, a gasoline tanker of the same volume
capacity as a LNG tanker has almost 60 % more energy content
than the LNG tanker.
Density of vapor: The density of vapor of gasoline
emanating from the evaporation of a pool of spilled gasoline is
4.4 kg/m \3\ (or 3.67 times heavier than air). The LNG vapor
given off from a boiling pool of LNG is 1.84 kg/m \3\ (or 1.53
times heavier than air). Therefore, for a given volume of vapor
generated by the evaporation of the pools of gasoline and LNG,
the gasoline vapor gets diluted at a much slower rate, lingers
much longer and spreads to a much greater distance before
becoming non flammable. That is, the dispersion of vapor
generated by a gasoline spill poses a greater dispersion
distance and flammable vapor area danger than from the release
of an equivalent quantity of LNG vapor. Also, LNG vapor can get
heated by the substrate (ground or water) or the sun and become
neutrally buoyant further reducing the area of dispersion to
lower flammability limit. This does not happen with gasoline
vapors, which are essentially at ambient temperature during
dispersion and therefore stay heavy and close to the ground.
Ignition temperature: The ignition temperature of
gasoline vapor in air is between 500 and 745 (440 F and 880
F) depending upon the gasoline blend. This is compared to
methane, which has a higher ignition temperature of 660 K (1088
F). The higher the ignition temperature, the more difficult it
is to ignite a mixture of vapor and air. Therefore, a gasoline
air mixture is more easily ignitable than methane air mixtures
by hot surfaces.
Flame/Fire temperature: The gasoline and methane fires
have about the same temperature (3580 F for gasoline and 3410
F for methane fire). Therefore, it is expected that the
radiant heat output from each would be about the same. For a
given (small) diameter pool fire gasoline fire is sootier than
an LNG fire of the same size. However, as the fire diameter
increases and the shrouding effect of black soot produced in
the fire becomes dominant it can be argued that both gasoline
and LNG fires will show similar radiant heat output
characteristics. Unfortunately, there are no experimental data
for either large gasoline fires or large LNG fires (of sizes in
the hundreds of meters in diameter).
The above facts clearly indicate that an LNG fire is no more
dangerous than an equivalent size gasoline fire. I do wish to point out
to the Committee that large gasoline pool (of tens of meters in
diameter) are dangerous and no one, to the best of my knowledge, has
successfully put out such size fires with any of the conventional
techniques used in Therefore, large LNG pool fires and gasoline pool
fires pose similar dangers; neither is better or worse than the other.
Question 3: In your testimony you mention three missiles striking a
LPG carrier and the resulting fire. Did the cargo explode? Did the ship
survive?
Response 3: To the best of my knowledge the cargo carried by the
Fountain at the time of its attack (October 12, 1984) in the Persian
Gulf carried 18,850 tons of liquefied petroleum gas (LPG). The
information I have is from the article presented in a conference.\16\
According to this paper, the ship was hit by three air-to-ground,
guided and armour-piercing Iranian ``Maverick'' missiles. The ship
suffered extensive damage to the deck plate and to one of the LPG
tanks. There was an extensive fire on the deck and in some of the crew
quarters from the exploding missiles. However, the flammable cargo,
LPG, did not explode. There was however, leak of propane gas through a
gash in the roof of one of the tanks. The fire burned as a torch fire
(similar to a flare normally seen in petrochemical refineries).
---------------------------------------------------------------------------
\16\ Captain J. A. Carter, Salvage of Cargo from the War-Damaged
Gaz Fountain, Paper presented at the 1985 Gastech Conference held at
Nice, France.
---------------------------------------------------------------------------
All of the crew abandoned the ship and were saved. The ship itself
was towed Dubai, to the remainder LPG cargo unloaded safely and
repaired. The ship not only survived the missile attack but also (after
repair) is said to be back in the same service.
Question 4: The GAO report recommend the DOE (1) incorporate into
its current LNG study the key issues identified by the panel of experts
assembled GAO and (2) that DOE examine the potential for cascading
failure of LNG tanks. Will the two principal research recommendations
in the GAO report, if implemented, provide sufficient knowledge you as
an expert scientist need to perform an accurate prediction of the
extent of the hazard?
Response 4: The GAO has identified only two of the principal area
for further research. I am of the opinion that there are a number of
equally important issues that have not been highlighted in this report,
which have considerable influence on the assessment of hazards.
Therefore, my response to your question, Mr. King, is that while better
assessments of the hazard can be performed with better confidence, if
the research recommended by GAO is successfully carried out, it will
not provide all of the answers to performing an ``accurate'' prediction
of the extent of the hazard. I will elaborate my answer below.
Hazard assessment is dynamic process in which many of
the phenomena considered may change as technology and
procedures change. For example, larger LNG ships than the ones
in service now are being and in the near future will join the
world fleet. What issues these ships (which in some cases have
twice the carrying capacity of present day ships) may bring to
the forefront in terms of potential hazards be envisioned at
present.
Focusing one or two phenomena for research to the
abandonment (or reduction in emphasis) of other issues may not
be a very good policy decision.
In addition, what constitutes a significant hazard
cannot be based on polling expert opinion only. It has to be
worked out by a careful assessment of the various phenomena and
their interplay with one another. In effect one needs conduct a
thorough study of the failure modes and effects analysis.
GAO ranks the study of cascading failures as the
second highest priority. The statistical basis on which such a
conclusion was arrived at is not clearly indicated by the GAO.
Ten experts suggested a ``great need'' for conducting research
on ``Comprehensive modeling allowing different physical
processes to interact'' whereas only 5 experts said the same on
``Cascading failure.'' Therefore, it is difficult to reconcile
as to why this particular research need is ranked #2. The top
six scores for the ``research types'' are relatively close and
can be considered to have the same statistical significance.
Votes of ``experts'' can be a guide to policy decision-making
only when the ``experts'' have the relevant expertise in the
technical matter of interest. Not all ``experts'' have
expertise in all aspects of release and behavior of LNG. It is
my recommendation, therefore, that prior to making any policy
decisions experts in the field of metallurgy and ship design
should be consulted and their views on the importance (or not)
of this problem should be taken into consideration.
It also is evident from the GAO report (and this shows
the bias of some of the experts towards the very worst case
scenario consideration) that the frequency of occurrence of
events of different types and magnitudes was not considered in
making the recommendations. As I have argued in response to a
question from the Chairman, without performing a detailed risk
assessment, making policy decisions using only one type of
hazard or consequence size consideration leads to non-economic
application of resources (in this case scientific resources).
There are a number of very important phenomena that GAO has not
even alluded to in its report nor was discussed with the experts. These
include the fate of LNG released into water and its rapid evaporation
and production of very large volume of vapor close to the spill source
and its possible ignition and burning in the form of a large fireball.
The remaining un-vaporized liquid will spread on the water surface as a
pool, and will sustain a pool fire. Because of the possible initial and
substantial evaporation the volume of liquid remaining to spread is
smaller thus posing a smaller pool fire hazard. Similarly, the GAO
report has not identified research into the effects of winds and waves
on the movement and expansion of the liquid pool. There are such
numerous other phenomena, each of which affects to a great extent the
calculation of the hazard.
Therefore, I submit that if the GAO report recommendations are
implemented, and the research results are obtained without leading to
the identification of additional phenomena of concern or complications,
they will provide some but not all of the information for me as an
expert scientist to perform an accurate prediction of the extent of the
hazard from LNG releases from a ship.
Questions from the Honorable Bennie G. Thompson, Chairman, Committee on
Homeland SEcurity
Responses from AJ. Mark Robinson
Question 1.: Does the Federal Regulatory Commission (FERC) have the
personnel and assets needed to oversee the additional LNG facilities?
If not, what will will FERC need?
T2Response: Yes. In 2004, the LNG Engineering Branch was formed to
conduct engineering and safety review of the increasing number of
proposed facilities. In 2006, the LNG Compliance Branch was created to
provide oversight of construction and operation of LNG facilities under
jurisdiction. Later that same year, the Office of Energy Projects hired
six engineers for positions in the LNG Engineering and Compliance
Branches to meet the current and expected workload from LNG import
terminal applications and construction. Engineers in these branches
ensure a thorough safety oversight through the three phases
authorization; pre-construction, and pre-operation) of project review
at the Commission.
Question 2.: It has been over 5 years since 9/11, why is there
still disagreement amongst the experts concerning the security on LNG
tankers?
Response: The GAO study reports substantial agreement among the
expert panel concerning many of the potential public safety
consequences of a terrorist attack on an LNG tanker including thermal
radiation from a pool fire, unconfined vapor cloud explosions, burns,
asphyxiation, and rapid phase transitions. The findings of the GAO
expert panel are also consistent with those in the FERC staffs
assessment of LNG facilities. With respect to the December 2004 Sandia
report, eleven of the fifteen experts judged the distance calculations
as either accurate or overly conservative.
The U.S. Coast Guard (Coast Guard), the lead federal agency
responsible for waterway safety and maritime security, has issued
nation-wide guidance to ensure that a uniform approach is taken in
assessing security issues related to LNG vessel transit. The guidance
issued in Navigation and Inspection Circular 05-05 is used by
applicants, the Coast Guard, and port stakeholders to perform an
objective review of whether a waterway is suitable with respect to
navigation safety and maritime security. The conclusions of this port-
and project-specific review are used by both the Coast Guard and the
FERC in deciding whether to issue federal authorizations for the LNG
vessel transit and the on-shore facility.
Question 3.: According to GAO, more research is needed. Why hasn't
this research been completed already?
Response: Sandia National Laboratories has two research initiatives
currently underway: one on threat, breach and hazard modeling and
assessment for larger LNG ships; and the other on safety hazard testing
and modeling of large LNG spills on water. These efforts are planned to
continue through 2007 and 2008 with interim results at intermediate
dates. Sandia has conducted periodic briefings for our staff and other
federal agencies on the progress of each project. We fully support the
research by Sandia and anticipate that the results will validate the
conservatisms in our hazard modeling.
Question 4.: Please provide us with information about the measures
FERC undertakes to ensure the security on the LNG facilities.
Response: As referenced in my March 21,2007 testimony, the
Commission shares security responsibilities for these facilities with
the Coast Guard, which has primary responsibility under the Maritime
Transportation Security Act of 2002. The Commission has a role related
to facility security at all phases of project development. During the
pre-construction review, the preliminary plans to secure the facility
intentional acts are evaluated and discussed at the cryogenic design
and technical review conference for the proposal. Prior to starting
commissioning activities, engineering staff confirms that all plant
security systems are in place (personnel, cameras, and other
equipment), and that the Facility Security Plan is current. During
project operation, engineering staff reviews the facility security as
part of the annual inspection to ensure sufficient levels of security
provided by surveillance cameras; intrusion detection systems; security
fencing; and on-site access control plans.
Question 5.: While there have been no major LNG incidents, there
have been groundings. How does FERC use the lessons learned to improve
the safety and security of all the facilities?
Response: Our environmental impact statements (EIS) disclose the
more significant LNG ship incidents including several groundings in
international waters that resulted in bottom damage but no cargo tank
damage. We are aware of LNG vessel groundings in U.S. waters but they
did not result in any damage.
Our EISs also disclose the accidents that occurred at Cove Point,
Maryland in 1979 and at Skikda, Algeria in 2004. The lessons learned
from these incidents have resulted in revising equipment design and
adding hazard detection to improve the safety of all LNG facilities,
both under review and in operation under FERC jurisdiction.
Question 6.: Five FERC approved LNG facilities are currently under
construction--Louisiana; Freeport, Texas; Sabine, (two); and Cove Point
Maryland. Please provide us with an update at their construction. When
will the construction be completed?
Response: The LNG import terminals and expansions currently under
construction have targeted in-service dates of: March 2008 for LNG
(Phase I) in Freeport, Texas; April 2008 for Cheniere's Sabine Pass LNG
(Phase I) in Sabine, Louisiana; October 2008 for Cameron LNG (Phase I)
in Hackberry, Louisiana; November 2008 for the Cove Point Expansion in
Cove Point, Maryland; and April 2009 for Golden Pass LNG in Port
Arthur, Texas.
Questions from the Honorable Peter T. King, Ranking Member, Committee
on Homeland Security
Question 7.: Has FERC ever denied a LNG licensing request? If sO,
when? how often do companies withdraw from the FERC process?
Response: In an Order issued on July 5,2005, the Commission denied
a proposal by KeySpan to convert its existing LNG peak shaving facility
in Providence, Rhode Island to an LNG import terminal.
In accordance with the Energy Policy Act of 2005, all LNG project
applicants must participate in the mandatory prefiling process
specified under 18 CFR 157.2 1. The prefiling process, as well as the
subsequent formal filing of an application, requires a substantial
commitment of resources by the project sponsor, thereby discouraging
frivolous applications. We are aware of sponsors that have considered a
project, but have never filed a proposal before the Commission. To
date, project sponsors that have either filed applications or have
entered the pre-filing process have not withdrawn their proposals.
Question 8.: How does the LNG industry compare with the oil
industry in terms of safety records? Your testimony indicates that a
LNG ship has never had a major spill. What constitutes a major spill of
LNG?
Response: My testimony identified the commendable safety record of
LNG shipping since its beginning in 1959, and explained the current
process for coordinating reviews with the Coast Guard to ensure the
safety and security of the LNG vessel transit to a proposed import
facility. While our impact statements have not included a comparison
with the oil industry, we are certainly aware of large cargo releases,
fires and explosions involving petroleum tankers, both in U.S. and
international waters, but note that these have not occurred with LNG
vessels.
None of the LNG vessel incidents that are disclosed in our
environmental impact statements resulted in a breach or failure of a
cargo tank. In those incidents where an LNG release occurred, they were
relatively small volumes that occurred during the cargo transfer. A
major spill would require a large breaching of a cargo tank.
Question 9.: Has there ever been an explosion at a LNG facility?
What is the relative risk of an explosion LNG when compared with
gasoline?
Response: The Reliability and Safety Section of each EIS for an LNG
import project describes an incident that occurred in 1979 at the Cove
Point import terminal in a building in which one operator was killed
and another injured. Nevertheless, we do not believe vapors an LNG
spill would explode.
With the exception of the higher surface emissive power and larger
flame heights estimated for LNG fires, the public hazards associated
with LNG vapors are not markedly different than from other fuels such
as gasoline. For example, while gasoline may ignite at a lower
concentration, LNG vapors have a wider flammability range.
Question 10: Can you explain the Commission's role in enforcing the
cost-sharingplans required by the Energy Policy Act of 2005?
Response: Both the Energy Policy Act of 2005 and Commission Orders
authorizing LNG terminals require that we approve an Emergency Response
Plan prior to authorizing any construction. Further, the Emergency
Response Plan must include a cost-sharing plan. The plan must identify
the mechanisms for funding all project-specific security costs and
management costs that would be imposed on state and local agencies. The
cost-sharing plan must what the LNG terminal operator will provide to
cover the cost of the state and local resources required to manage the
security of the LNG terminal and LNG vessel. Commission staff carefully
reviews the plan to ensure that the state and local resources required
for security and emergency management have been adequately addressed
and that no resource gaps remain. The potential costs that are
considered fall into three categories: (1) per-transit costs (for
example, overtime for police or fire department personnel); (2) capital
costs for equipment and personnel base (for example, patrol boats, fire
fighting equipment); and (3) annual costs for specialized training and
for conducting exercises.
Questions from the Honorable Bennie G. Thompson, Chairman, Committee on
Homeland Security
Responses from Rear Admiral Salerno
Question 1: From what countries do we receive LNG? Are all of these
countries compliant with the International Ship and Port Facility
Security Code?
Response: Our primary suppliers of LNG are Trinidad, Algeria, Egypt
and Nigeria. Over the last ten years we've received cargoes from
Malaysia, Oman, Qatar, UAE and even Australia.
The Coast Guard's International Port Security (IPS) Program has
visited Trinidad, Algeria, Nigeria, Malaysia, Oman, Qatar, and
Australia. With the exception of Nigeria, each of these countries was
found to be substantially implementing the International Ship and Port
Facility Security (ISPS) Code. When visiting Nigeria, the Coast Guard
was only able to visit facilities in the port of Lagos. Thus, Nigeria
was found to be provisionally implementing the ISPS Code. We have not
completed an assessment of Nigeria because of political unrest and
potential danger to Coast Guard personnel. When security conditions
improve, another visit to Nigeria will be scheduled. Visits to Egypt
and UAE are anticipated to be completed by March 2008. All the
countries listed have reported their compliance with the ISPS Code to
the International Maritime Organization in accordance with Safety of
Life at Sea security regulations and the ISPS Code.
Question 2: Please outline for the Committee the additional
safeguards placed upon U.S. mariners with the Transportation Worker
Identification Card (TWIC).
Is it true that the additional security requirement of a TWIC is
only to be applied to U.S. mariners? Why are foreign mariners not
vetted in the same manner?
Response: The Maritime Transportation Security Act of 2002, 46 USC
Sec. 70105, requires a biometric transportation security card for U.S.
mariners issued a license, certificate of registry, or merchant mariner
document. The TWIC does provide additional safeguards for U.S. mariners
by providing a biometric credential which is common to the maritime
industry. Whereas the current mariner documents (MMD, license,
Certificate of Registry) are only used by the population of individuals
who work on certain vessels, the TWIC will be used by a larger
population and will be more widely recognized. Having a common
credential increases the chances that a security guard will be able to
identify signs of tampering or forgery of the credential as well as
easing access for the mariner. Inclusion of a biometric on the
credential provides the ability to ensure that the person who presents
the TWIC for access is the person to whom the card was issued by
matching their fingerprint to the biometric template on the card. This
is not a feature currently available on mariner documents. The TWIC
also has limited personal information printed on the face of the card
than the MMD currently has; therefore, if the TWIC was stolen, the
thief would be unable to retrieve as much information on the holder
than if the MMD was stolen. Thus, presenting the TWIC as the preferred
identification document protects mariners' personal information from
theft.
Yes, it is true that the TWIC is only required for U.S. mariners.
The TWIC is not required for foreign mariners.
Foreign mariners are already vetted prior to entering the United
States. Foreign mariners must possess a visa issued by the Department
of State in order to be eligible to enter the United States. The visa
application process includes a face-to-face interview and vetting
performed by the Department of State. Additionally, ninety-six hours
prior to arrival to a U.S. port, a notice of arrival, including a list
of all persons onboard a vessel, must be sent to the Coast Guard. The
persons are then vetted through various databases. Finally, upon the
vessel's arrival at a port facility, Customs and Border Protection
conducts face-to-face interviews with those foreign mariners who
request shore leave. Even with a visa, however, a foreign mariner will
be required to be escorted through secure areas of MTSA regulated
vessels or facilities, because he/she will not hold a TWIC.
It is also not clear that requiring foreign mariners to obtain a
TWIC would provide any security benefit since it is unlikely that a
foreign seafarer will have a criminal record in the United States. The
additional background checks are done during the U.S. Department of
State visa application and Customs and Border Protection screening
processes, as outlined above. In addition to the uncertain security
benefit, foreign mariners would not likely have the means to get to
enrollment centers or to return to claim and activate their
credentials, nor would any be able to present the appropriate identity
documents, or meet the requirement for lawful presence under the TWIC
program. Requiring foreign seafarers to obtain a TWIC would mean that
before being allowed off of a foreign vessel, each foreign seafarer
would need to come to the United States to enroll in the TWIC program,
and then again to pick up their TWIC. Finally, placing such
requirements on foreign seafarers could effect reciprocal requirements
for U.S. mariners in other countries.
Question: To what extent can we improve communication between shore
side first responders and a LNG ship's crew and officers if they are
speaking in the same first language and have similar cultural
backgrounds?
Similarly, would it not be beneficial for the safety of the vessel
and its cargo if both officers and crew communicated in their native
language?
Response: Current international standards satisfy the safety
concern raised in this question. In accordance with Safety of Life at
Sea (SOLAS) Regulation V/14.3, every foreign vessel, even those with
multi-national, multi-cultural crews, is required to have a common
working language that permits effective crew performance. Furthermore,
every Master and Deck officer on vessels subject to SOLAS Chapter I
that engage in ship to ship or ship to shore safety communications must
speak English, unless both parties speak another common language.
Question: Are you concerned about the frequency and the nationality
of stowaways that have been confirmed on international vessels,
particularly from international ports that have been vetted by the U.S
Coast Guard?
Response: The answer to this question is not releasable to the
public and therefore must be provided via a secure venue. The Coast
Guard is available to provide this information at your earliest
convenience.
Question: We have heard today, that energy companies have submitted
32 applications to build additional LNG facilities. Does the Coast
Guard have the assets to protect the additional LNG tankers and
facilities? If not, what will the Coast Guard need to successfully
fulfill this new mission?
Response: The Coast Guard continues to utilize a waterway
suitability assessment and report process to identify safety and
security measures required to mitigate the port-wide risk posed by new
Liquefied Natural Gas (LNG) facilities. Based on the results of these
assessments, resources may be identified from the Coast Guard, state
and local agencies, or the private sector to mitigate that risk. The
President's budget represents the Coast Guard's highest priority
resource needs, including the continual evaluation of the assets
required to mitigate the impact of Certain Dangerous Cargoes (such as
LNG).
Question: Is it true that the additional security requirement of a
Transportation Worker Identification Card is only to be applied to U.S.
mariners? Why are foreign mariners not vetted in the same manner?
Response: The Maritime Transportation Security Act of 2002, 46 USC
Sec. 70105, requires a biometric transportation security card for U.S.
mariners issued a license, certificate of registry, or merchant mariner
document. The TWIC does provide additional safeguards for U.S. mariners
by providing a biometric credential which is common to the maritime
industry. Whereas the current mariner documents (MMD, license,
Certificate of Registry) are only used by the population of individuals
who work on certain vessels, the TWIC will be used by a larger
population and will be more widely recognized. Having a common
credential increases the chances that a security guard will be able to
identify signs of tampering or forgery of the credential as well as
easing access for the mariner. Inclusion of a biometric on the
credential provides the ability to ensure that the person who presents
the TWIC for access is the person to whom the card was issued by
matching their fingerprint to the biometric template on the card. This
is not a feature currently available on mariner documents. The TWIC
also has more limited personal information printed on the face of the
card than the MMD currently has, therefore, if the TWIC was stolen, the
thief would be unable to retrieve as much information on the holder
than if the MMD was stolen. Thus, presenting the TWIC as the preferred
identification document protects mariners? personal information from
theft.
Yes, it is true that the TWIC is only required for U.S. mariners.
The TWIC is not required for foreign mariners.
Yes, it is true that the TWIC is only required for U.S. mariners.
The TWIC is not required for foreign mariners.
Foreign mariners are already vetted prior to entering the United
States. Foreign mariners must possess a visa issued by the Department
of State in order to be eligible to enter the United States. The visa
application process includes a face-to-face interview and vetting
performed by the Department of State. Additionally, ninety-six hours
prior to arrival to a U.S. port, a notice of arrival, including a list
of all persons onboard a vessel, must be sent to the Coast Guard. The
persons are then vetted through various databases. Finally, upon the
vessel's arrival at a port facility, Customs and Border Protection
conducts face-to-face interviews with those foreign mariners who
request shore leave. Even with a visa, however, a foreign mariner will
be required to be escorted through secure areas of MTSA regulated
vessels or facilities, because he/she will not hold a TWIC.
It is also not clear that requiring foreign mariners to obtain a
TWIC would provide any security benefit since it is unlikely that a
foreign seafarer will have a criminal record in the United States. The
additional background checks are done during the U.S. Department of
State visa application and Customs and Border Protection screening
processes, as outlined above. In addition to the uncertain security
benefit, foreign mariners would not likely have the means to get to
enrollment centers or to return to claim and activate their
credentials, nor would any be able to present the appropriate identity
documents, or meet the requirement for lawful presence under the TWIC
program. Requiring foreign seafarers to obtain a TWIC would mean that
before being allowed off of a foreign vessel, each foreign seafarer
would need to come to the United States to enroll in the TWIC program,
and then again to pick up their TWIC. Finally, placing such
requirements on foreign seafarers could effect reciprocal requirements
for U.S. mariners receive in other countries.
Question:: More specifically, will the Coast Guard have the assets
to continue the following security measures for all of the new
facilities including--Inspection of security and tanker loading at the
port of origin.
Occasional on-board escort by Coast Guard ``sea marshals.''
96-hour advanced notice of arrival of an LNG tanker.
Advance notification of local police, fire, and emergency agencies,
as well as the Federal Aviation Administration and the U.S. Navy.
Enforcement of security zones.
Suspension of overflights.
Inspection of adjacent piers for bombs by police divers.
Posting of sharpshooters on nearby rooftops.
Response: All of the activities listed above may not be necessary
or appropriate for each new facility. The appropriate risk mitigation
strategies necessary to ensure the safety and security of new shoreside
LNG facilities, and the resources to carry out such activities, are
determined on a case by case basis during the waterway suitability
assessment and analysis process for each project. Unfortunately, due to
the large number of potential projects, along with the expectation that
only a fraction will actually be constructed, the Coast Guard is unable
to estimate the overall needs associated with future LNG terminals
until construction of each individual terminal is actually approved by
FERC. Once an applicant has received their construction permit from the
Federal Energy Regulatory Commission (FERC), the Coast Guard is then
able to look at the unique needs that will accompany that new facility,
and whether the Coast Guard has the resources in place, balanced
against our other legislatively mandated mission-programs, to meet
those needs. If additional resources are necessary in that geographic
area, the Coast Guard will determine whether those resources are
available elsewhere in the Coast Guard or if a new resource request is
necessary.
Question: How does the LNG industry compare with the oil industry
in terms of safety records?
Response: Transportation of LNG by marine carriers has a long
record of safe operation. Since 1959, when the commercial
transportation of liquefied natural gas began, there has never been a
shipboard death or significant incident involving liquefied natural
gas. As of March 1, 2007, the world fleet of LNG tank ships consisted
of 224 carriers which have safely delivered over 40,000 shiploads while
covering more than 100 million miles. The outstanding LNG shipping
safety record is attributable to continuous improvement of technology,
safety equipment, comprehensive safety procedures, training, equipment
maintenance by responsible ship owners/operators and effective
government regulation and oversight.
Over the history of LNG shipping, there have been no collisions,
fires, explosions or hull failures resulting in a loss of containment
for LNG ships in ports or at sea. According to a Sandia National
Laboratories 2004 report to DOE, over the 45-plus year life of the
industry only eight marine incidents worldwide have resulted in
accidental spillage of LNG and none of the spills have been as a result
of a failure or breach of a containment system. In the cases of
accidental spillage, no fires occurred and only minor structural damage
was noted. Seven additional marine-related incidents have occurred with
none resulting in release of cargo. No explosions or fatalities from a
cargo spill have ever occurred aboard an LNG carrier.
By comparison, the number of marine carriers in the world fleet
which carry oil is significantly larger, but marine carriers have been
transporting oil for a much longer period of time. In 2006, the oil
carrier industry was 120 years old. Since the first oil carrier set
sail in 1886, the oil carrier fleet has grown dramatically in both size
and volume of oil transported worldwide. According to a July 2006
report from the U.S. Maritime Administration (MARAD), there were
approximately 4,454 oil and chemical carriers in the world fleet. The
exact number of those which are oil carriers in operation is unclear,
but the International Maritime Organization (IMO) places the number at
over 3,500. Statistical data and information on the complete safety
record of oil carriers since their entry into the world trade market is
unknown. A recent paper submitted to IMO in December 2006 included an
assessment which looked at casualties on the world fleet of oil
carriers covering a period of 15 years (1990 to 2005). The paper
reported that in the time frame studied, worldwide, there were a total
of 564 lives lost on oil tankers due to various causes and 484 due to
accidents caused by fire and explosion.
Using these comparison standards, the safety record associated with
LNG marine carriers is much better than the safety record associated
with marine carriers of oil.
Question: I understand that the Coast Guard requires crew manifests
be submitted 96-hours prior to the arrival of a ship into port. Are
U.S. mariners on these ships vetted against the same lists?
Response: Yes, U.S. Mariners are vetted against the same federal
terrorism, immigration, and law enforcement databases as foreign
mariners.
Question: The Coast Guard is frequently commended for their risk-
based resource allocations. In the Coast Guard's opinion, would a ship
crewed by U.S. mariners provide less a risk than a ship crewed by
foreign citizens?
Response: The Coast Guard believes the existing screening process
and security checks conducted for all crews on arriving foreign-flag
vessels, combined with the employer vetting process, significantly
reduce the likelihood that an unauthorized crewmember could
surreptitiously join the crew of an LNG vessel.
While a U.S. crew on a U.S. flag LNG vessel could reduce the risk
from internal sabotage, this measure would not mitigate the greatest
risks to the vessel (i.e. a vessel-borne explosive device or an attack
from a stand-off weapon).
Question: There has been some discussion as of late to require U.S.
mariners to crew foreign-flagged LNG carriers offloading in the United
States. Would the Coast Guard provide a ship crewed entirely by U.S.
citizens less of a security envelope compared to a ship with some
foreign citizens?
Response: While a U.S. crew on a U.S. flag LNG vessel could reduce
the risk from internal sabotage, this measure would not mitigate the
greatest risks to the vessel (i.e. a vessel-borne explosive device or
an attack from a stand-off weapon).
Question: What actions or investments has the Coast Guard taken to
prevent a USS Cole or T/V Limberg incident from occurring to a LNG
vessel? Is the Coast Guard's Research and Development Center involved?
Response: The President's Fiscal Year 2008 Budget includes several
items which contribute to improving the overall multi-mission
capability of the Coast Guard. Specifically, the President's Fiscal
Year 2008 budget request supports the following initiatives to increase
specialized forces and intelligence capability to meet the small boat
Improvised Explosive Device (IED) threats.
Nationwide Automatic Identification System
Maritime Security Response Team Shoothouse
Response Boat-Medium
Rescue 21
Deployable Operations Group
Coast Guard Counterintelligence Service
Addressing the threat of small vessel attacks in the U.S. requires
continual review of security gaps and coordination with small vessel
stakeholders, including commercial and recreational vessel operators in
U.S. waters. To further such dialogue with these stakeholders, the
Department of Homeland Security has scheduled a National Small Vessel
Security Summit for June to begin a robust conversation to fully
understand the gaps in maritime border security and collaboratively
develop measures of closing those gaps. Additionally, the Coast Guard
is vigorously exploring a number of ways to close existing gaps
including: unambiguous warning capability to determine intent of small
craft approaching high value assets; technologies appropriate for use
within crowded ports to deter or stop small vessel attacks, including
non-lethal options; regulations expanding current requirements for
tracking of small vessels; and improved sensors (radars, offshore
buoys, etc.).
The Coast Guard's Research and Development (R&D) Center is starting
a new project to addresses challenges faced by Coast Guard boat forces
units conducting waterside security operations. These include Level I
Port, Waterway, and Coastal Security (PWCS) units such as Sectors,
Maritime Safety and Security Teams (MSSTs), Port Security Units (PSUs),
and Maritime Force Protection Units (MFPUs). This project directly
supports the Coast Guard's Small Vessel Response Task Force Final
Report recommendation to vigorously pursue technology to deter or stop
small vessels threats within the port environment.
The R & D Center's Project Objective is to provide Coast Guard
program managers with recommendations for the best short, mid & long
term solutions to close capability gaps in domestic ports. The desired
end-state is to ensure Coast Guard program managers have actionable
information to select and implement changes to policy and procedures,
and new use of force tools. This array of improvements to domestic port
security capabilities will serve to mitigate and reduce risk in the
maritime environment.