Residents of the Lusby, Md., community near Dominion Resources Inc.'s Cove Point liquefied natural gas terminal are pressuring state and federal regulators to complete new risk assessments and consider worst-case accident scenarios, pointing to a recent explosion at an LNG facility in Plymouth, Wash., as evidence of unrecognized project hazards.
Calvert Citizens for a Healthy Community has filed paperwork with the Federal Energy Regulatory Commission and the Maryland Public Service Commission over the past two weeks calling on each to perform a comprehensive risk assessment of Dominion's proposal to convert its Cove Point LNG terminal from an import-only facility to a bidirectional hub to be used primarily for exports.
The residents say that siting an LNG export terminal in the midst of a residential neighborhood is unprecedented and would expose them to potentially "intolerable" risks.
FERC is nearing the release of a draft environmental assessment for the Dominion facility, scheduled for May 15. That document will address human health and safety risks as well as other environmental impacts of the project and is being prepared in place of a more exhaustive environmental impact statement (EIS) that regulators opted against -- although the environmental assessment could conclude that the deeper analysis is needed.
Environmentalists have long been calling on FERC to perform a full EIS in light of the increased natural gas drilling that would go with a new LNG export terminal sited near the Marcellus Shale formation, but so far, FERC has resisted efforts to lump the environmental consequences of drilling with those of exporting natural gas (EnergyWire, Feb. 21).
The push from homeowners near the Cove Point site follows a more established line of reasoning for a closer look at the project: that it poses unacceptable risks to the safety of surrounding communities.
"Dominion's plan for Cove Point poses unique safety risks and vulnerabilities that could make the consequences of a similar explosion far more severe" than the March 31 blast in Plymouth that injured one worker and triggered a local evacuation, the citizens' group said in a notice of its FERC filing.
The Cove Point citizens' group cited media reports that the explosion and fire at the Williams Northwest Pipeline Facility in Washington state were the results of a chain of events not anticipated in the type of risk analysis typically performed by FERC for projects like Dominion's.
Sue Allison, a founder of the citizens' group whose home lies about 1,500 feet from some of the key equipment that would be added to the site under the proposed expansion, said, "I think the Plymouth incident highlights the fact that even when safety precautions are taken, accidents can happen and one mishap can lead to another, and another. In Plymouth, there was an explosion, which led to shrapnel flying through air, which led to a ruptured LNG storage tank, which led to an LNG leak, which led to a flammable vapor cloud, which led to a 2-mile evacuation. In a word, there was a serious 'escalation' event in Plymouth."
Allison says the risk from such unforeseen chains of events is even greater at the Cove Point site, thanks to its being in a more populous area.
Flash fire 'consequence zone'
The FERC safety analysis process rests in large part on showing that in the event of an accident, hazard risks would not reach past the edge of a plant's property line, so the public would not be exposed to danger.
In a previous safety review carried out by the agency in 2005 for the construction of two new LNG storage tanks on the Cove Point site, Dominion's facility met that standard. But the neighbors point to a risk analysis completed around the same time by the Maryland Department of Natural Resources that focused primarily on risk exposure to the surrounding neighborhood and to the Calvert Cliffs Nuclear Power Plant, located 3.6 miles up the shoreline from Cove Point.
Overall, that assessment concluded that "the quantified risks to populations and facilities, including Calvert Cliffs Nuclear Power Plant, fall within a range considered acceptable relative to available industry criteria, including the U.S. Nuclear Regulatory Commission regulatory standards."
But the regulators noted a shortage of publicly available and agreed risk criteria for large industrial facilities like an LNG export plant, when it comes to off-site impacts. Guidance on the issue gleaned from standards in other countries reflected a wide range of tolerances, they said, and ultimately left a large margin in which safety improvements would be called for only to bring risk "as low as reasonably practicable."
Sue Allison and her husband, Dale -- a retired aerospace engineer who spent decades doing safety analysis for the Navy, and who has spent the last few years learning the jargon and specifications of LNG plant engineering in an effort to understand Cove Point's safety profile -- point to the state risk analysis as showing that the "consequence zone" for a flash fire stemming from a storage tank mishap would extend 4,265 feet around the tanks, well beyond Dominion's property line.
Inside that radius, they point out, lie about 360 homes as well as a public park and other public recreation facilities. Another neighborhood of homes that hugs the Chesapeake Bay shoreline falls outside of that radius but relies on a single evacuation road that runs past the Cove Point plant, which they say makes the community vulnerable if the densely wooded area surrounding the facility were to experience such a flash fire.
"The unfortunate mishap which just occurred at the Plymouth LNG facility once again highlights the absolute requirement that LNG terminals only be sited in remote locations. Cove Point is not that site," Dale Allison said in a statement by the citizens' group.
He said that given the close proximity of so many homes to the Cove Point site, FERC should, at a minimum, carry out a risk assessment to look at not just individual accident scenarios but "all possible mishap escalations" that could occur.
"A full [quantitative risk assessment] is the only way that all residents living close to the Cove Point plant can possibly know the full cumulative risk they face -- their probability of loss of life -- based on their separation distance from the plant," Allison said.
Ruptures, sinkholes and crowding
Feeding into the concerns of the Lusby residents are a series of more targeted concerns about the existing Cove Point plants and Dominion's stated expansion plans.
The site currently has seven LNG storage tanks on it that rely on a "single wall" containment system to contain the natural gas, which is chilled to minus 162 degrees Celsius (minus 260 degrees Fahrenheit) for storage as a liquid.
Allison and other neighbors of the facility argue that the tanks -- four of which were placed into operation in 1978, when the terminal first started up, and the rest of which were commissioned in 2004 and 2008, according to Dominion -- are less safe than tanks built with a double-walled technology that uses a second barrier layer to prevent the escape of LNG in case of a rupture.
They also question whether the oldest tanks are suited for continued use.
Jim Norvelle, a Dominion spokesman, defended the equipment's security. "The tanks are inspected regularly to check their integrity and maintained to store LNG safely, just as any component would be. Their life cycle is based on thermal cycling, and age is not an issue. They are safe for the use of storing LNG," he said.
"That said, if there was a leak, the LNG would be contained [by the dikes], would vaporize and dissipate into the atmosphere," he added.
Other concerns expressed by residents include the air emissions from the power plant that Dominion would build to run the gas refrigeration equipment. The proposed 130-megawatt power plant would add new emissions to an area that is already in nonattainment status for air quality with Dominion buying offsets elsewhere in Maryland to cover the new pollution.
One local resident pointed to a risk of soil liquefaction and sinkholes that can form when certain soil types are subjected to heavy vibrations and continued loud noises, pointing to a sinkhole she said appeared in 2001 at the Calvert Cliffs Nuclear Power Plant.
Others worry about the compressed equipment footprint proposed by Dominion for the export plant.
When drawing up plans to build on LNG export capacity, the company initially looked at expanding beyond the existing import plant's boundaries onto undeveloped land nearby.
But the company was bound by a covenant signed in 1972 by the previous owners of the Cove Point plant, the Sierra Club and a state conservation group, which limited the plant to its current boundaries (EnergyWire, April 27, 2012).
The Sierra Club and Dominion went to court over the question of whether the old agreement prevented the addition of export capacity, but the environmentalists lost that fight last year when an appeals court ruled that Dominion had the right to add facilities within the plant's existing footprint.
The result, though, is an unusually space-constrained export proposal that crowds buildings and equipment together at a density that Dominion officials admit will bring added operational challenges.
The local neighbors' group says the configuration does more than that, bringing additional risk of the sorts of accident "escalation" seen in Washington state when closely packed machinery malfunctions and interrupts the safe functioning of other equipment nearby.
'A vast, big explosion'
James Fay is a professor emeritus at the Massachusetts Institute of Technology who specialized in part in LNG safety issues and who has advised the Allisons on aspects of the Cove Point plan.
By phone, Fay expressed concern over the scope of the safety analysis that might come from FERC's environmental assessment and the agency's decision to rely, at least initially, on that shorter process instead of a longer EIS.
"The question is for Cove Point, when you add the liquefaction plant and reverse the [import] process, is that equivalent to a new facility that FERC has to look at in its entirety, or is it just a new piece of equipment costing a billion dollars that they're adding to their existing facility?" Fay asked.
Natural gas liquefaction is an entirely different process from gasification, he said, requiring large power inputs and the use of liquefied propane gas as a refrigerant to chill the fuel and keep it cold.
"The liquefaction component that they would add is no little thing," he said. "I think that's the major issue for the people living around the facility."
Fay pointed to an explosion at an LNG export facility in Algeria in 2004 that killed 26 people, injured about 75 more and flattened several buildings.
The accident was eventually traced to the liquefied propane gas used as a refrigerant there. "What happened is the propane leaked out, and it's heavier than air, and it leaked on the ground and floated into the intake of a boiler that's used to generate electricity, and that started the explosion," Fay said. "But it was a vast, big explosion" with major consequences.
Fay said FERC has not so far had to deal with questions about liquefied propane gas at LNG sites, because gasification for import doesn't require it. "It's not a question that FERC has had to face up to, because there's less potential for an explosion with natural gas than propane," he said.
FERC has so far permitted just one LNG export facility in recent years, and that terminal, Cheniere Energy's Sabine Pass LNG terminal in Louisiana, is currently under construction (a small, 40-year-old export plant located in Alaska was built before today's safety regulations were put in place).
Sabine Pass got through FERC with just an environmental assessment, though at the time, the whole question of LNG exports was subject to far less scrutiny than it is today because the idea of exporting, rather than importing, the fuel was novel.
Fay believes that ultimately FERC will need to complete an EIS for LNG plants that considers all the safety ramifications of the more complicated liquefaction process.
"The issue here is whether FERC has the responsibility to do a complete safety analysis of the facility and its new function, and it isn't clear to me that they're pushing the applicant on this," Fay said.
If that's the case, he said an "intervenor" that has inserted itself as a formal party into the FERC review process could well provide the push to complete such a review, through legal measures.
"It's really a different facility when you turn it around, go the other way. And they're kind of pretending it isn't -- that we just have to do the liquefaction and it's just a small addition," he said.
Fay traced some of that apparent willingness to gloss over problems to pressure on the agency to move quickly. LNG exports have attracted broad support on Capitol Hill, where the industry has support from representatives of many gas-producing areas as well as from industries like equipment manufacturers that stand to benefit from rapid growth in natural gas production, and the president has said he supports getting U.S. natural gas into foreign markets.
"There's a lot of pressure now to get into the export of LNG ... so there's some pressure on FERC to move along on this," Fay said. "That's very troubling because it's very clear, I think, that FERC can't ignore the matters of safety that arise when you have an export terminal that are quite different from an import terminal."
Some facilities, such as those proposed for and under construction along the Gulf Coast, could raise less alarm because they are generally planned for industrial areas with minimal residential presence, Fay suggested.
But he noted that Cove Point could prove a particularly challenging location for FERC to consider. "I don't know yet of any other export facilities around the world where the facility is close to where people live," he said.
Correction: This story was corrected to reflect that the court case between Dominion Resources and the Sierra Club was not initiated by a Sierra Club lawsuit. In fact, Dominion sought out a declaratory judgment on the issue.